LPL Financial LLC

LPL FINANCIAL FIRM BROCHURE BANK WEALTH PROGRAM (BWP) LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This brochure provides information about the qualifications and business practices of LPL Financial. If you have any questions about the contents of this brochure, please contact LPL Financial 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 Financial also is available on the SEC’s website at https://adviserinfo.sec.gov/. ITEM 1 COVER PAGE ITEM 2 MATERIAL CHANGES No material changes were made to this Brochure from the time of the most recent annual update of March 31, 2025. ITEM 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ................................................................................................................................................................... 1 ITEM 2 MATERIAL CHANGES ....................................................................................................................................................... 1 ITEM 3 TABLE OF CONTENTS ..................................................................................................................................................... 1 ITEM 4 ADVISORY BUSINESS ....................................................................................................................................................... 1 ITEM 5 FEES AND COMPENSATION............................................................................................................................................ 4 ITEM 6 PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................................. 4 ITEM 7 TYPES OF CLIENTS ........................................................................................................................................................... 4 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ..................................................................... 4 ITEM 9 DISCIPLINARY INFORMATION ......................................................................................................................................... 9 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................................................................. 11 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING.............. 12 ITEM 12 BROKERAGE PRACTICES ............................................................................................................................................. 13 ITEM 13 REVIEW OF ACCOUNTS ............................................................................................................................................... 13 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................................... 13 ITEM 15 CUSTODY ..................................................................................................................................................................... 14 ITEM 16 INVESTMENT DISCRETION .......................................................................................................................................... 14 ITEM 17 VOTING CLIENT SECURITIES........................................................................................................................................ 14 ITEM 18 FINANCIAL INFORMATION.......................................................................................................................................... 14 ITEM 4 ADVISORY BUSINESS Introduction LPL Financial LLC (“LPL”) is an investment adviser registered with the Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”). LPL has provided advisory services as a registered investment adviser since 1975. Note that registration as an investment adviser with the SEC does not imply a certain level of skill or training. As of December 31, 2025, LPL managed approximately $818,320,000,000 of client assets on a discretionary basis and approximately B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) $797,900,000 of client assets on a non-discretionary basis. LPL is owned 100% by LPL Holdings, Inc., which is owned 100% by LPL Financial Holdings Inc., a publicly held company. Types of Advisory 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 Bank Wealth Program (“BWP”). For more information about LPL’s advisory services and programs other than BWP, please contact LPL for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov/. BWP is a program offered by LPL to clients that are banks, corporate trustees, thrifts, trust companies, broker-dealers, investment advisors, and other financial institutions (“Financial Institution”) and offers various levels of investment advisory, technology, research and back office services to those clients. LPL acts as a service provider to Financial Institutions who then choose how to use the LPL services and how to shape the advice and services they are providing to each end client (“Client”) of the Financial Institution. LPL is also a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”); however, all services provided under BWP are in an advisory capacity. BWP is an open architecture program allowing flexibility to the Financial Institution to use the available LPL services to design the best service for their Client. Financial Institutions choose which components they wish to use within BWP. There are four basic components of BWP: 1. Technology: BWP Technology includes access to a user portal to create and deliver Client proposals, investor questionnaires and reporting. 2. Research: BWP Research is made available through the LPL Research Department. LPL’s Research Department makes available investment research materials, which include recommendations on separate account strategies, and mutual funds. When LPL provides investment research, LPL makes no analysis of and does not consider Clients’ individual circumstances or objectives, and does not tailor any model asset allocation to any specific client’s needs, circumstances or objectives. The BWP Research offering consists of: • Manager due diligence on a selected list of available managers including managers available within BWP and separately managed account managers accessed through BWP technology. It is important to note that LPL does not perform, and has no obligation to perform, due diligence or other research with respect to investment managers or funds that are not on LPL’s current Recommended Manager Line-Up Sheet (“Non-Covered Managers”), even if Performance Reports prepared by LPL include data provided by such Non-Covered Managers. • Asset allocation recommendations made available by LPL Research. • A set list of deliverables created by LPL Research for Financial Institution use. • Access to economic commentary and capital markets research. • Access to LPL’s “Portfolio Designer” system for client investment planning. • Access to the LPL Financial Portal, a web based tool to access research investment information, client performance results, client portfolio accounting and other consulting information. B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) 3. Trade Implementation and Portfolio Management • SMA Program: LPL will provide access to a platform through which the Financial Institution may engage third-party managers (“Portfolio Managers”) who will direct and manage the client accounts. Financial Institutions may choose to implement investment decisions by designating the client accounts as SMA accounts and completing the required paperwork to process those accounts with SMA managers. LPL will facilitate the delivery of the required paperwork to the SMA managers for the designated SMA accounts. • UMA Program: Alternatively, Financial Institution can choose to implement investment decisions through the LPL platform using centralized portfolio management in the UMA program. o The BWP UMA program is a unified management account program that combines managed accounts comprised of individual securities, mutual funds, and ETFs in one diversified portfolio. LPL acts as the Sponsor, otherwise known as the Investment Manager, of the UMA program. LPL may also act in other capacities within the program as detailed below. Additionally, third parties may also participate in the programs as Research Providers or Overlay Managers as detailed below. o A Financial Institution whose Client participates in the UMA establishes a discretionary account that is invested in a manner consistent with one of several multi-manager, multi-asset allocation strategies created by the Financial Institution. o Specifically, responsibilities for management of accounts participating in the UMA are divided as follows:    The Financial Institution is responsible for the creation of a series of multi-manager, multi-asset allocation strategies (“Models”) with varying asset allocations and risk profiles. The Financial Institution is also responsible for recommending which Model(s) a Client may invest in. LPL conducts initial and ongoing due diligence on investment advisers known as Research Providers that provide managed account solutions, typically comprised of individual securities. LPL will also conduct due diligence on and recommend mutual funds which may be selected by the Financial Institutional for use in a model. It is the Financial Institution who makes the final recommendation to the client with regard to which Model(s) they should invest in. LPL may also act as a Research Provider in the BWP UMA program. In cases where LPL acts as a Research Provider its services as such are provided in addition to the other services provided by LPL, and LPL shall be entitled to collect fees from Financial Institutions for such services. LPL also acts as the overlay manager in the BWP UMA program to implement investment decisions made by Financial Institutions. As the Overlay Manager, LPL is responsible for making discretionary trading decisions to implement the models in the BWP UMA program. Upon instruction by the Financial Institution, the Overlay Manager may execute transactions according to its tax efficient management strategy, which may cause it to delay or defer causing the account to mirror its applicable model. The Overlay Manager is responsible for providing periodic rebalancing services so the allocation of these accounts remains consistent with the selected model(s). Unless otherwise directed by a Financial Institution and/or Client, Overlay Manager is responsible for seeking best execution on transactions for BWP UMA accounts. The Overlay Manager may take actions for certain accounts that it does not take for other accounts (e.g., for example, in the case of investment restrictions imposed on an account), even when such accounts are intended to be managed according to the same model portfolio. It is important to note that third party Research Providers for the BWP UMA program provide models to LPL, and it is LPL that has discretion for trade implementation and execution in its BWP accounts. Therefore, models submitted to LPL by third party Research Providers may represent activity that has already been implemented on behalf of other clients of such Research Providers. Because of this fact and because LPL (and not the third-party Research Provider) has discretionary authority to implement trades, performance of an BWP account will differ from the performance of such Research Provider’s discretionary accounts. 4. Back Office Services: To the extent agreed upon by LPL and Financial Institution, LPL may perform back office functions on behalf of the Financial Institution including, but not limited to, Client fee calculation and processing. B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) ITEM 5 FEES AND COMPENSATION Financial Institutions pay a fee set forth in the agreement between the Financial Institution and LPL. The base fee is typically a percentage of the assets held in each SMA or UMA account, as applicable. The fee varies depending on which investment model the Financial Institution chooses, for example, its own model, an LPL, or a third-party manager model. If the base fee falls below a minimum amount, which is set forth in the agreement and varies by Financial Institution, the Financial Institution is still responsible for paying the minimum amount. Additional fees are charged for additional services, such as tax management services or strategist services. BWP also may provide reporting services on brokerage accounts, and a flat annual fee is charged for such services. ITEM 6 PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT This Item is not applicable. LPL does not accept performance-based fees. ITEM 7 TYPES OF CLIENTS LPL’s BWP program offers services to Financial Institution clients only. At this time, BWP is only for use by Financial Institutions. Except as detailed in the agreement between LPL and the Financial Institution, LPL does not require a minimum asset amount for Financial Institutions to participate in BWP. ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS The Financial Institution has access to various research reports and model portfolios to which they may refer in determining investment advice provided to Clients. The Financial Institution chooses the research methods, investment style and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL’s Research Department makes recommendations regarding mutual funds, and money managers. Financial Institutions may or may not follow these recommendations in providing investment advice. LPL Research also constructs asset allocation model portfolios and provides recommendations on the funds and research providers to populate those models. In constructing these models, LPL Research may work with Financial Institutions to customize models and allocations per their specific guidelines. Types of Investments and Risks Depending on the type of service being provided, LPL can recommend different types of securities whose underlying investments may include mutual funds, unit investment trusts (“UITs”), closed end funds, ETFs, collective investment trusts, equities, fixed income securities, options, interval funds, hedge funds, managed futures, and structured products. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments, or underlying investments of recommended investment, that LPL may recommend depending on the service provided. • 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. Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) • • Issuer‐Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. Investment Company Risk. To the extent an investor invests in ETFs or other investment companies, 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 an inventor invests in other investment companies, the investor 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. • Concentration Risk. To the extent an investor concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the investor of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if the investor did not concentrate its investments to such an extent. • Sector Risk. To the extent an investor invests more heavily in particular sectors, industries, or sub‐sectors of the market, performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub‐sectors. An individual sector, industry, or sub‐sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political, or regulatory events. Performance could be affected if the sectors, industries, or sub‐sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. • Alternative Strategy Mutual Funds. Certain mutual funds invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency, and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re- setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts, and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Options. Option trading is permitted in the Program. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and a Program account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), futures-linked ETPs (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Structured Products. Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • Hedge Funds and Managed Futures. Hedge and managed futures funds may be purchased by clients meeting certain qualification standards. Investing in these funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices and the lack of liquidity and performance volatility. In addition, these funds are not required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Client should be aware that these funds are not liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the fund, there B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the fund during the repurchase offer. • Business Development Companies (BDCs). BDCs are typically closed-end investment companies. Some BDCs primarily invest in the corporate debt and equity of private companies and may offer attractive yields generated through high credit risk exposures amplified through leverage. As with other high-yield investments, such as floating-rate/leveraged loan funds, private real estate investment trusts (“REITs”) and limited partnerships, investors are exposed to significant market, credit, and liquidity risks. In addition, fueled by the availability of low-cost financing, BDCs run the risk of over-leveraging their relatively illiquid portfolios. Due to the illiquid nature of non-traded BDCs, investors’ exit opportunities may be limited only to periodic share repurchases by the BDC at high discounts. • Variable Annuities. If client purchases a variable annuity that is part of the program, client will receive a prospectus and should rely solely on the disclosure contained in the prospectus with respect to the terms and conditions of the variable annuity. Client should also be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. • Company Stock. If company stock is available as an investment option to client in a retirement plan, and if client chooses to invest in company stock, client should understand the risks associated with holding company stock in a retirement plan. These risks may include, but are not necessarily limited to, lack of liquidity, over-dependency on client’s employer, and less flexibility to change the allocation of plan assets. Client should pay careful consideration to the benefits of a diversified portfolio. Although diversification is not a guarantee against loss, it can be an effective strategy to help manage investment risk. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • 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 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 B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) 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. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • 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. ITEM 9 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 B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) 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 fine of $750,000 (2016). 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). 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). B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) • • • 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). For more information about those state events and other disciplinary and legal events involving LPL and its investment adviser representatives (“IARs”), client should refer to Investment Adviser Public Disclosure at https://adviserinfo.sec.gov/ or FINRA BrokerCheck at https://brokercheck.finra.org/. ITEM 10 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 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 may be registered representatives of LPL. 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. Please ask your IAR about the investments, models, programs, and services he or she is licensed or qualified to sell. 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 adviser representatives dispersed throughout the United States. If required for their positions with a registered B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) 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 client 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 an advisory 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- BWP 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. 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. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING 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 B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) securities account in the same security on or about the same time as trading by a client can disadvantage the client. LPL addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. 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 LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPL does not permit its IARs to recommend or purchase LPL Financial Holdings Inc. stock. However, LPL or an IAR may recommend or purchase for clients a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. Client should understand that LPL and IAR perform advisory and/or brokerage services for various other clients, and that LPL and IAR may give advice or take actions for those other clients that differ from the advice given to the client. The timing or nature of any action taken for the account may also be different. ITEM 12 BROKERAGE PRACTICES LPL does not receive research or other products or services other than execution from a broker-dealer or third party in connection with client securities transactions (“soft dollar benefits”). LPL does not consider, in selecting or recommending broker-dealers, whether LPL or a related person of LPL receives client referrals from a broker-dealer or third party. Within BWP, LPL also does not integrate LPL’s brokerage services, and Financial Institutions, in most cases, direct trades to third party broker-dealers. If LPL serves as broker-dealer, 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. For securities transactions, this delay may cause a difference between the execution price and the displayed quote at the time the order was entered. This delay may also result in a limit order becoming ineligible for 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. ITEM 13 REVIEW OF ACCOUNTS The Financial Institution is responsible for meeting with Clients and performing reviews of the investment allocation for Client accounts. The Financial Institution receives Clients’ performance reports on a quarterly basis. The performance reports may then be forwarded by the Financial Institution to their respective Clients. ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION Client Referrals There are no client referral programs in place within BWP. Other Compensation LPL and LPL employees receive additional compensation, business entertainment and gifts from product sponsors. However, such compensation may not be tied to the sales of any products. Compensation may include 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 also pay for, or reimburse LPL for the costs associated with, education or training events that are 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. B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. ITEM 15 CUSTODY Within BWP, LPL does not currently custody the assets for any Financial Institution or their Clients. Assets are maintained at a custodian other than LPL. ITEM 16 INVESTMENT DISCRETION LPL takes investment discretion to the extent necessary to implement the trading instructions of the Financial Institutions that implement through the UMA program. ITEM 17 VOTING CLIENT SECURITIES Except as Financial Institution has otherwise instructed LPL, to the extent Financial Institution receives centralized portfolio management services provided by LPL, LPL will vote proxies on the Financial Institution’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of its clients, including Financial Institution. LPL has contracted with a third-party vendor to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of the third-party vendor. Any exceptions to this general policy are referred to LPL’s Research Department, which makes the determination as to how to vote the proxy in accordance with the best interest of the client. A copy of LPL’s proxy voting policies is available upon request. Financial Institution may obtain information about how LPL voted with respect to securities held in an Account contacting LPL. In the case of voluntary corporate actions, LPL intends to follow the instructions provided by the Research Providers unless, in the determination of LPL, such instructions are overtly contrary to a client’s best interest or instructions. Prior to making such determination, however, LPL will first determine if it has a conflict of interest with any of the companies involved in the corporate action. If LPL does have a conflict of interest, LPL will follow the instructions provided by the Research Provider without reviewing individual Financial Institution interests. If a Financial Institution elects to retain the right and obligation to vote proxies, LPL is reimbursed by the mutual fund for the delivery costs to send mutual fund shareholder reports and proxies to the Financial Institution. 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 mutual fund on LPL’s behalf and in certain cases remits a portion of the reimbursement to LPL. LPL and the Research Providers are not obligated to render any advice or take any action on behalf of Financial Institution with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the account, or the issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the account. ITEM 18 FINANCIAL INFORMATION LPL is a qualified custodian as defined in Rule 206(4)-2, and is therefore not required to include a balance sheet for its most recent financial fiscal year. B W P – A D V – 0 3 2 6 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 IP C  LPL FINANCIAL FIRM BROCHURE - BANK WEALTH PROGRAM (BWP) 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 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 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. B W P – A D V – 0 3 2 6 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 IP C 

Guided Wealth Portfolios (GWP) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 your LPL 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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 .............................................................................................................. 8 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 9 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 14 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 14 Item 9: Additional Information ............................................................................................................................................... 14 1 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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, an advisor-enhanced digital advice program, advisory programs offered by third party investment advisor firms, financial planning services, and retirement plan consulting services. This Brochure provides a description of the advisory services offered under LPL’s Guided Wealth Portfolios (GWP) program (Program). LPL’s advisory services are made available to clients primarily through individuals associated with LPL as investment adviser representatives (“IARs”). For more information about the IAR providing advisory services, client should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time client engages the IAR. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lplfinancial.com. 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 or Advisor whether any limitations apply. For more information about LPL’s advisory services and programs other than GWP, please contact your IAR or Advisor 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. GWP also permits clients to select a third-party investment advisor firm (“Advisor”), in lieu of an IAR, to provide the advisory and consulting services described in this Brochure. For more information about the third-party investment advisor firm providing advisory services, please contact Advisor for a copy of a similar brochure. LPL is also a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”), and an IAR or individuals of Advisor, as applicable, also may be registered with LPL as a broker-dealer registered representative. Therefore, an IAR or individuals of Advisor may be able to offer a client both investment advisory and brokerage services. Before engaging with an IAR or Advisor, 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 or Advisor to understand the different types of services available through LPL. Not all LPL IARs have access to all products and services. In addition, as described below, the Program is made available through a web-based portal, and communications concerning the Program are intended to occur primarily through electronic means (including but not limited to, through email communications or through such portal), although an IAR or Advisor, as applicable, will be available to discuss investment strategies, objectives, or the account in general in person or via telephone. Therefore, the Program differs from more traditional advisory relationships in which an IAR or Advisor has more frequent personal interactions with a client. Potential clients should consider whether GWP will provide the type of advisory relationship they desire. The Program offers clients the ability to participate in a centrally managed investment program, which is made available to users and clients through LPL’s Account View, a web-based, interactive account management portal (Account View) and through IAR. Clients are required to maintain an active profile in Account View to participate in the Program. The Program generates investment recommendations based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). 2 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure A preview of the Program (the “Prospect Tool”) is provided to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL by opening a GWP Account). The Prospect Tool and the features of a GWP Account are described in more detail below. Users of the Prospect Tool are not considered to be advisory clients of LPL or the IAR or Advisor (as applicable), do not enter into an advisory agreement with LPL or the IAR or Advisor (as applicable), do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. 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. Features of the Prospect Tool Prospective clients that use the Prospect Tool (each, a “user”) agree to a terms of use (Terms of Use) and complete an investor profile. Users must select from one of the following goals for each account: retirement (Retirement Goal), major purchase (Major Purchase Goal), or general investing (Build Wealth Goal). Based on the investor profile completed, the Prospect l Tool generates sample asset allocation recommendations (Sample Recommendations). The Prospect Tool provides Sample Recommendations that may assist users in determining whether to open a GWP account. The Prospect Tool is intended to be used for educational and informational purposes only. The Prospect Tool does not provide comprehensive financial planning and is not intended to constitute legal, financial or tax advice. To use the Prospect Tool, users are responsible for providing information about, among other things, their goals, age, risk tolerance, and investment horizon. The Prospect Tool is only one of many tools that users may use as part of a comprehensive investment analysis process. Users should not rely on the Prospect Tool as the sole basis for investment decisions. Alternatively, the IAR or Advisor (as applicable) can directly open a GWP account for a client without requiring a client to first use the Prospect tool. Although LPL is an investment adviser and broker-dealer registered with the SEC and a member of the Financial Industry Regulatory Authority, the Prospect Tool does not establish an investment advisory contract or relationship between you and LPL or IAR. The scope of any investment advisory relationship with LPL begins when users complete an Account Application, enter into an account agreement (Account Agreement) with LPL and IAR or Advisor, as applicable. The output that users receive by using the Prospect Tool, including the Sample Recommendations, may differ materially from the advice users would receive as an advisory client of LPL. LPL does not provide ongoing investment management or trading services for assets of users of the Prospect Tool, does not make any determination as to whether the website through which the GWP account is accessed or the Prospect Tool is appropriate for any user, cannot access any assets in any accounts of users, does not place any trades on behalf of users of the Prospect Tool, and does not provide ongoing supervision of assets of users of the Prospect Tool. Features of a GWP Account Investors that open a GWP account (“clients” and each, a “client”) complete an Account Application and enter into the Account Agreement with LPL and IAR or Advisor (as applicable). As part of the account opening process, clients are responsible for providing complete and accurate information regarding, among other things, their goal for the account, age, risk tolerance, and investment horizon (collectively, “Client Profile”). LPL and IAR or Advisor (as applicable) rely on the information in the Client Profile in order to provide services under the Program, including but not limited to, determination of suitability of the Program for clients. Based on the Client Profile, LPL selects an appropriate investment allocation track (Investment Allocation Track) and model portfolio (Model Portfolio) for a client. The IAR or Advisor (as applicable) is required to review and accept the account, including the Investment Allocation Track and Model Portfolio, prior to account opening. The Model Portfolios have been designed and are 3 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure maintained by LPL Research (the “Portfolio Strategist”) and include a list of exchange-traded funds (ETFs) holdings and may in the future include open-end mutual funds (Mutual Funds) holdings (collectively, “Program Securities”), and include relative weightings and a list of potential replacement securities for tax harvesting purposes. LPL Research currently serves as the sole Portfolio Strategist and does not charge a fee for its services. Only one Model Portfolio is permitted per account. As a client approaches the Retirement Age or the specified date of the major purchase, LPL will automatically adjust the client’s asset allocation annually based upon the client’s associated investment allocation track (described below under “LPL as Portfolio Strategist”). For the Major Purchase Goal, after reaching the specified date of the major purchase, LPL will automatically allocate up to 70% of the account to cash and cash equivalents, unless the client extends the timing for the major purchase. For the General Investing Goal, the client’s asset allocation generally remains static, subject to rebalancing and tax loss harvesting as described below. The Investment Allocation Track selected for the account seeks to achieve an overall investment objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time and may be inconsistent with other asset allocations suggested to client by LPL or IAR or Advisor (as applicable) prior to client entering into the Account Agreement. The Investment Allocation Tracks are designed as long-term goals for the account, and asset withdrawals may impair the achievement of client’s investment objectives. A Client Profile that includes a conservative Investment Allocation Track over a long-term investment horizon may result in the selection of riskier investments than would be selected based on the same conservative Investment Allocation Track but over a shorter-term investment horizon. Clients should contact the IAR or Advisor, as applicable, if they believe the Investment Allocation Track does not appropriately reflect the Client Profile. By executing the Account Agreement, clients authorize LPL to have discretion to buy and sell Program Securities in accordance with the Model Portfolio and to liquidate previously purchased non-model securities that are transferred into the account. Mutual Funds and ETFs that are not Program Securities or that are not included within the Model Portfolio selected for the client’s account will not be purchased for the account. LPL has full discretion to invest according to the Model Portfolio. LPL expects to closely track the Model Portfolios, applying discretion only to address particular account issues, including tax loss harvesting, short-term gain avoidance, cash inflows and outflows, and investment restrictions placed on the account. LPL may also deviate from the Model Portfolios in smaller accounts, in which it is not possible or impractical to be invested in all of a Model Portfolio’s holdings. In addition, uninvested cash may be invested in money market funds, the Multi-Bank Insured Cash Account (“ICA”) or the Deposit Cash Account (“DCA”), as applicable, as described in the Account Agreement. Dividends paid by the Program Securities in the account will be contributed to the cash allocation and ultimately reinvested into the account based on the Model Portfolio once the tolerance within cash allocation is surpassed. Pursuant to the Account Agreement, client authorizes LPL to perform tax harvesting based on the guidelines LPL establishes for the Program, on a systematic and periodic basis. LPL will perform tax loss harvesting only when total account unrealized losses and individual positions available losses each exceed thresholds set by LPL for the Program. LPL will seek to re-invest proceeds from tax loss harvesting into a substitute Program Security for the 30-day period from the initial sale of the harvested security, but will hold such proceeds in cash if proceeds cannot be reinvested into a substitute Program Security. In implementing the Investment Allocation Track or processing client requests, including withdrawal requests, LPL may determine the securities for liquidation based in-part on avoiding short-term gain realization. During the term of the Account Agreement, LPL will perform a daily review of the account to determine if rebalancing is appropriate based on tolerance thresholds established by LPL. The account will be rebalanced following a rebalancing review if the Account has available cash for investment and at least one of the account positions, including cash, is outside LPL’s set tolerance thresholds, subject to a minimum transaction amount established by LPL. LPL will also perform an annual rebalancing of the Account if Account positions are outside of LPL’s set tolerance thresholds. In addition, LPL may review the account for rebalancing in the event that a Model Portfolio is changed. LPL may delay placing rebalancing transactions for non-qualified accounts by a number of days, to be determined by LPL, in an attempt to limit the tax treatment of realized short-term gains for any position being sold. In addition, trading in the 4 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure account at any given time is also subject to certain conditions, including but not limited to, conditions related to trade size, compliance tests, the target cash allocation and allocation tolerances. LPL, the IAR or Advisor (as applicable), and clients cannot alter the rebalancing frequency. IAR or Advisor (as applicable) is responsible on an ongoing basis as investment advisor and fiduciary for the client relationship, including for recommending the Program to the client; providing ongoing monitoring of the Program, the performance of client accounts, and the services of LPL; determining initial and ongoing suitability of the Program for clients; reviewing clients’ suggested portfolio allocations; reviewing any change in Investment Allocation Track due to changes clients make to their Client Profile; answering questions regarding the Program, assisting with paperwork and administrative and operational details for accounts; and being available to clients to discuss investment strategies, changes in financial circumstances, objectives or accounts generally in person or via telephone. IAR or Advisor (as applicable) may also recommend other suitable investment programs. Clients may make cash additions to an account and may withdraw account assets at any time, subject to meeting the required account minimum balance of $5,000 and certain other conditions described in the Account Agreement. Liquidation requests in connection with withdrawals, and changes to the Model Portfolio or Investment Allocation Track selected may take up to 5 business days to process, and, in certain circumstances, may take longer to allocate assets. Clients may also fund an account with previously purchased, non-model securities. Clients authorize LPL in the Account Agreement to liquidate previously purchased, non-model securities as soon as reasonably practicable. In some circumstances, LPL will take into consideration the tax implications of realized gain and loss exposure of liquidating previously purchased, non-model securities when effecting liquidations. The Program is designed as a long-term investment vehicle and asset withdrawals may impair the achievement of client’s investment objectives. LPL is appointed by each client as custodian of account assets and broker-dealer with respect to processing securities transactions for a GWP account. LPL also provides administrative services, such as performance reporting, to clients. LPL may aggregate transactions with other clients to improve the quality of execution. Fee Schedule Users of the Prospect Tool do not pay any fees or expenses. Clients that open a GWP account pay LPL an annualized account fee (“Account Fee”). The Account Fee is made up of an Advisor Fee and an LPL Program Fee. LPL reserves the right to increase the upper limits of the Advisor Fee and/or LPL Program Fee range(s) upon 30 days’ prior notice to clients. No performance-based fees are charged to accounts in the Program. Advisor Fee. The Advisor Fee is charged for the investment advisory services of IAR or Advisor. The Advisor Fee is shared with the IAR or Advisor. The Advisor Fee is negotiable between the client and the IAR or Advisor and is based on the value of assets in the account, including cash holdings. The maximum Advisor Fee is 1.00%. LPL shares up to 100% (typically between 90% and 100%) of the Advisor Fee with the IAR or Advisor based on the agreement between LPL and the IAR or Advisor, as applicable. A portion of the Advisor Fee to an 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 Advisor Fee for supervision because the fee affects his or her ability to provide objective supervision of the IAR. LPL Program Fee. Clients will pay a fee of 0.35% for the investment advisory, administrative, trading, custodial, and clearing services of LPL. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a GWP account from the account. LPL calculates and deducts the Account Fee in the method described in the Account Agreement. Alternative payment methods that may be offered in other advisory platforms are not available in GWP. 5 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure Payment in Advance and Refund of Pre-Paid Fees LPL deducts the Account Fee quarterly in advance. For purposes of calculating the quarterly Account Fee and providing performance information, the account quarter will begin on the first day of the month in which the account is accepted by LPL. The initial Account Fee is deducted at the end of the first quarter in which the account is accepted and will include the prorated amount for the initial quarter. Subsequent Account Fees will be assessed at the beginning of each quarter thereafter and will be based on the value of the account assets under management as of the close of business on the last business day of the preceding quarter (as valued by an independent pricing service, where available, or otherwise in good faith as reflected in Client’s account statement) and based on the fee rate in effect at the time of assessment. At the time of a subsequent Account Fee assessment, the Account Fee will be adjusted for deposits and withdrawals during the prior quarter pro rata based on the asset value of the transaction and based on the fee rate in effect at the time of the assessment. If there is a change in the Account Fee rate negotiated between IAR and Client during the quarter, the effective date of any increase or decrease will be at the beginning of the next quarterly cycle. If the Account Agreement is terminated before the end of the quarterly period, LPL will pay the client a pro-rated 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, and re- registration of positions). Other Types of Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to a GWP 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 miscellaneous 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. These fees are subject to change at the discretion of LPL. Clients are notified of these charges and any changes through information provided with their periodic statements. These fees and charges shall continue until thirty (30) days after LPL has notified client in writing of any change in the amount of the fees or charges applicable to the account, at which time the new fees or charges will become effective unless client notifies LPL in writing that the account is to be closed. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in GWP accounts. Some of these fees and charges are described below. In GWP, assets are invested in Model Portfolios that currently are comprised of ETFs and may include mutual funds in the future, and, therefore, there are two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Clients will pay an advisory fee to the fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Clients will also pay LPL and IAR or Advisor, as applicable, the Account Fee with respect to assets invested in ETFs and mutual funds. The ETFs and mutual funds available in the Program can be purchased directly outside of the Program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL and IAR or Advisor and by making their own decisions regarding the investment. If client transfers into a GWP 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, recordkeeping fees and revenue sharing from the previously purchased mutual fund until the position is liquidated and subsequently invested according to the GWP model. If a mutual fund 6 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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 an ETF or mutual fund in the fund’s prospectus, which is available upon request from the IAR or Advisor, as applicable, or directly from the fund. When transferring securities into a GWP account, client should be aware that certain securities are not 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 previously purchased, non-model securities transferred into an account may have been subject to a commission or sales load when the security was originally purchased. If client has paid a commission on the purchase of a security in an LPL brokerage account within up to two years of the transfer of the security into the account, client may be entitled to a credit for a portion of the Account Fee. After transfer into a GWP account, client should understand that an advisory fee will be charged based on the total assets in the account, including the transferred securities. 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. In the future, for Model Portfolios consisting of mutual funds, LPL intends to select only no-load and load-waived mutual funds. In some cases, a mutual fund in GWP will charge shareholders an asset based sales charge or service fee (e.g., 12b-1 fee) that is paid to LPL. Any 12b-1 fees paid to LPL by mutual funds (other than the cash sweep money market funds (Sweep Funds) described in the section of Item 9 labeled “Participation or Interest in Client Transactions” are credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on a GWP Account • The Account Fee is a wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. Clients do not pay a commission or transaction charge to LPL for the execution of transactions in the account. 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: – type and size of the account – type of securities in the Model Portfolio (currently ETFs and possibly mutual funds in the future) – 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. 7 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure • The Account Fee may be higher than the fees charged by other investment advisors for similar services. Clients could generally pay a lower advisory fee for investment advisory services through other investment advisers, including algorithm-driven, automated (robo) providers. However, clients using other robo services will forgo opportunities to utilize LPL-constructed model portfolios or to work directly with a financial advisor. In addition, the Account Fee may be higher than fees charged by other advisors, particularly if the Advisor Fee component of the Account Fee is at or near the maximum fee set out above. The IAR or Advisor, as applicable, is responsible for determining the Advisor Fee to charge each client based on factors such as total amount of assets involved in the relationship and the 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 Advisor Fee with IAR or Advisor. • The investment products available to be purchased in the Program can be purchased by clients outside of a GWP account, through broker-dealers or other investment firms not affiliated with 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 The Program is available for individuals (individually or jointly with another person) and their traditional individual retirement accounts (IRAs), Roth IRAs, and owner-only Simplified Employer Pension IRAs where the only eligible participants of the SEP IRA are the business owners and their spouses. Employee benefit plans subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA) (ERISA Plans) (including SEP IRAs for employees other than business owners and their spouses) are not eligible to participate in the Program. Participation in the Program is subject to LPL’s discretion, and LPL may prohibit any person from participating for any reason or no reason at all. Use of the Prospect Tool is governed by the Terms of Use. For the avoidance of doubt, clients that open a GWP account will be provided under and governed by the Account Agreement entered into at the time of enrollment. A GWP account is governed by the Account Agreement, which may be terminated by any party effective upon written notice to the other parties or by client calling the operational support desk, as set forth in the Account Agreement and as described below in the event certain minimums are not maintained. In the event that a client’s country of residence or citizenship status changes, such notification to LPL as required under the Account Agreement may result in termination of his or her account by LPL if LPL does not service accounts in the new jurisdiction. In addition, if a client revokes his or her consent to electronic delivery of communications, such revocation will be deemed to be a notice from the client to terminate his or her account. Promptly upon termination, accounts will be deactivated. In a deactivated account, no advisory fees are charged, and LPL and IAR or Advisor (as applicable) have no responsibility to provide ongoing investment advice. In order to open a GWP account, LPL requires a minimum value for a Program account to begin being managed. In certain instances, LPL will permit a lower minimum account value. Note that an account will not be invested according to a Model Portfolio until the applicable minimum for the Model Portfolio and allocation has been reached. If LPL has not received all paperwork in good order within the timeframe required by LPL from the day a client submits its Account Application, LPL will discard the Account Application and terminate the account immediately. In addition, if the account has not reached the required minimum value within the timeframe required by LPL, LPL will terminate the account immediately. In the event client withdrawals cause the account asset value to fall below required minimum for a period of 30 days, client understands that the account will be deactivated. In a deactivated account, no advisory fees are charged, and LPL and IAR or Advisor, as applicable, have no responsibility to provide ongoing investment advice. Withdrawals from the account may be made to the extent that the account value does not fall below the required minimum. Withdrawal requests for accounts with a value at the required minimum or less will result in account deactivation. 8 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure Item 6: Portfolio Manager Selection and Evaluation In GWP, the client selects the IAR or Advisor. 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 along with this Brochure at the time client opened the account. For more information about the third-party investment advisor firm providing advisory services, clients should refer to the Advisor’s Form ADV brochure or contact the Advisor for more information. LPL makes available Model Portfolios designed by LPL in GWP. LPL has discretionary authority to implement trades in GWP. LPL as a Portfolio Strategist In GWP, clients invest in Model Portfolios designed by LPL Research. LPL Research provides various types of advisory services. LPL Research provides research recommendations on asset allocation and ETFs and mutual funds. LPL Research provides investment advice on ETF and mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios, Personal Wealth Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap program, Manager Select. Based upon a client’s risk tolerance as indicated in the Client Profile, the client is assigned an investment allocation track (currently conservative, moderate, or aggressive) for a Retirement Goal or a Major Purchase Goal, the purpose of which is to slowly rotate the client’s equity exposure allocation to fixed income exposure and cash over time. LPL Research created these tracks using academic research on optimal retirement allocations, the industry averages as calculated by Morningstar for the target date fund universe, and input from other third parties. Within the applicable allocation track and based upon either a client’s chosen Retirement Age in the Client Profile or the desired date of a major purchase, as applicable, the client will be assigned a Model Portfolio and one of five of LPL’s standard investment objectives: • Income with capital preservation. Designed as a longer term accumulation account, this investment objective is considered generally the most conservative. Emphasis is placed on generation of current income with minimal risk of capital loss. Lowering the risk generally means lowering the potential income and overall return. • Income with moderate growth. This investment objective emphasizes generation of current income with a secondary focus on moderate capital growth. • Growth with income. This investment objective emphasizes modest capital growth with some focus on generation of current income. • Growth. This investment objective emphasizes achieving high long-term growth and capital appreciation. There is little focus on generation of current income. • Aggressive growth. This investment objective emphasizes aggressive growth and maximum capital appreciation, with no focus on generation of current income. This objective has a high level of risk and is for investors with a longer timer horizon. For the General Investing Goal, the client is assigned one of the Investment Allocation Tracks (currently, conservative, moderate conservative, moderate, moderate aggressive or aggressive) and a Model Portfolio based upon the client’s risk tolerance as indicated in the Client Profile. In the General Investing Goal, the client’s asset allocations generally remain static, subject to rebalancing and tax loss harvesting as described below. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research does not charge a fee for its Model Portfolios. IAR or Advisor (as applicable), and clients cannot change or customize the Model Portfolios. 9 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure Types of Investments and Risks The Model Portfolios include ETFs and may include mutual funds in the future. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that are available in the Program. Although LPL, the IAR or Advisor (as applicable) will not make any investment decisions for, or engage in any trading activity on behalf of, users of the Prospect Tool, the investment risks described below are generally applicable to the information provided to users of the Prospect Tool. • 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 fixed income 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). • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer ‐ Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sector of the market may be more sectors, industries, or sub volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political, or regulatory events. A client’s account performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open- end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over 10 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Tax-Loss Harvesting. The tax-loss harvesting feature of GWP account involves a variety or risks. You should confer with your personal tax advisor regarding the tax consequences of investing with the Program and engaging in the tax-loss harvesting strategy, based on your particular circumstances. You and your personal tax advisors are responsible for how the transactions in your account are reported to the IRS or any other taxing authority. Neither LPL nor the IAR or Advisor (as applicable) assumes any responsibility to you for the tax consequences of any transaction. The Program’s tax-loss harvesting strategy is not intended as tax advice, and neither LPL nor the IAR or Advisor (as applicable) represents in any manner that the tax consequences described will be obtained or that the Program’s investment strategy will result in any particular tax consequence. The tax consequences of this strategy are complex and may be subject to challenge by the IRS. This strategy was not developed to be used by, and it cannot be used by, any investor to avoid penalties or interest. You should be aware that if you and/or your spouse have other taxable or non-taxable accounts, and you hold in those accounts any of the securities (including options contracts) held in your GWP account, you cannot trade any of those securities 30 days before or after the Program account trades those same securities as part of the tax-loss harvesting strategy to avoid possible wash sales and, as a result, a nullification of any tax benefits of the strategy. For more information on the wash sale rule, please read IRS Publication 550. In addition, when LPL replaces investments with “similar” investments as part of the tax-loss harvesting strategy, it is a reference to investments that are expected, but are not guaranteed, to perform similarly and that might lower an investor’s tax bill while maintaining a similar expected risk and return on investor’s portfolio. Expected returns and risk characteristics are no guarantee of actual performance. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-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. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, 11 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure Interest.” For additional disclosures and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship with LPL and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL and its IARs for the pledged assets. For a list of the third-party 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 regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” In addition to the risks described above, the Program involves certain additional risks due to its reliance technology systems. • Reliance on Electronic Communications and Delivery. Both the Prospect Tool and a GWP account are primarily online services, and communications concerning the Program are intended to occur primarily through electronic means (including but not limited to, email communications and Account View, although the IAR or Advisor, as applicable, will be available to discuss investment strategies, objectives or the account in general in person or via telephone. Additionally, clients are required to create and maintain an active Account View profile to use the Prospect Tool or maintain an open GWP account. Therefore, the Program differs from more traditional advisory relationships in which an IAR or Advisor has more frequent personal interactions with a client. Persons looking for more personal communications should consider whether the Prospect Tool or opening a GWP account, as applicable, will meet their communication preferences. As set forth in the Terms of Use or the Account Agreement, as applicable, users and clients consent to the electronic delivery of all current and future Form ADVs, brochure supplements, privacy notices, prospectuses and offering documents, tax forms and other legal and regulatory notices, disclosures, reports and other communications, including delivery through Account View, to your e-mail address of record or to such other password-protected website as LPL may designate. • Investment Horizon. The Retirement Goal and the Major Purchase Goal are only appropriate for investors with medium- to long-term investment horizons, before such investors plan to access assets that are invested pursuant to the Program. If investors need access to the assets in their accounts at any point prior to the end of the investment horizon, the prices at which these assets are liquidated may cause them to experience a material loss and will negatively compromise the ability of LPL to help them meet their investing goals. • Reliance on Information Provided by User or Client; Protecting Your Account. LPL and the IAR or Advisor (as applicable provide advice and recommendations based on the information you provide to us regarding your investment objectives, financial condition, income, other investments, and all other information requested of you when using the Prospect Tool or opening a GWP account. If a user or client were to provide LPL and the IAR or Advisor with incomplete or inaccurate information, such omissions or inaccuracies could materially impact the quality and applicability of recommendations of LPL or the IAR or Advisor. In addition, users and clients are responsible for monitoring and updating information provided in the event of changes (e.g., contact information or life event changes, such as a change to Retirement Age), that could impact the recommendations made by the Program. You are solely responsible for additions to and withdrawals from your account and for maintaining the confidentiality of any password you select for your account. You are required to notify LPL and the IAR or 12 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure Advisor in the event you become aware of unauthorized use of your account or any other security breach related to your use of the Prospect Tool or opening a GWP account. • Limitations of a GWP Account. With respect to a GWP account, the recommendations provided by LPL and the IAR or Advisor (as applicable) are not intended to comprise the client’s complete investment program to the extent that a client has investible and invested assets held in ERISA Plans, or other accounts that the client has not transferred into the account. In addition, recommendations of LPL and the IAR or Advisor (as applicable) are generally limited in scope to the information that users and clients provide. There may be additional information or other financial circumstances not considered by LPL and the IAR or Advisor (as applicable) based on the questions asked at the time a user or client establishes their Investment Allocation Track that would inform the investment advice and recommendations provided by LPL and the IAR or Advisor. Clients should contact their IAR or Advisor, as applicable, to discuss any such additional information or other financial circumstances that they believe may be relevant to the advice provided through the Program. • Reliance on Technology; Back-up Measures; Cyber Security Breaches and Identity Theft. The Program’s investment activities and investment strategies are dependent upon various computer and telecommunications technologies, many of which are provided by or are dependent upon third parties, data feed, data center, telecommunications, or utility providers. The successful deployment, implementation, and/or operation of such activities and strategies, and various other critical activities provided by LPL and the IAR or Advisor (as applicable), could be severely compromised, damaged or interrupted by system, network or component failure, computer and telecommunications failure, power loss, a software-related “system crash,” unauthorized system access or use (such as “hacking”), computer viruses and similar programs, other security breaches, fire or water damage or other catastrophic events, power outages, human errors in using or accessing relevant systems, or various other events or circumstances. 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. Voting Client Securities In GWP, LPL and IAR or Advisor (as applicable) do not accept authority to vote client securities. Clients retain the right to vote all proxies that are solicited for securities held in the account. Clients will receive proxies or other solicitations from LPL. When LPL delivers mutual fund shareholder reports and proxies to clients, LPL is reimbursed by the mutual fund for the delivery costs. 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 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 IAR or 13 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure Advisor, as applicable. In addition, clients retain the right and obligation to take action with respect to legal proceedings relating to securities held in the account. Item 7: Client Information Provided to Portfolio Managers Users of the Prospect Tool complete an investor profile, including risk tolerance and Retirement Age or desired date of a major purchase, if applicable. Clients that open a GWP account complete the investor profile and also complete an Account Application which is a part of the Account Agreement. In quarterly communications with clients that open a GWP account, the IAR or Advisor, as applicable, asks clients to contact him or her if there have been any changes in the client’s financial situation or investment objective. Users and clients should understand that the Investment Allocation Track seeks to achieve an overall objective for the entire account and may be inconsistent with a particular Sample Recommendation or holding and, for clients, the account’s performance at any time. Users and clients also should be aware that Investment Allocation Tracks are designed to achieve long-term goals for the account. Item 8: Client Contact with Portfolio Managers LPL does not place any restrictions on a user’s or client’s ability to contact and consult with IARs or Advisors, as applicable, and users and clients should contact their IARs or Advisor, as applicable, with any questions regarding the Program. 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 14 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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: • 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). 15 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure • 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, 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). • 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). For more information about those state events and other disciplinary and legal events involving LPL and its IARs, users and clients should refer to Investment Adviser Public Disclosure at https://adviserinfo.sec.gov/ or FINRA BrokerCheck at https://brokercheck.finra.org/. 16 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth 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, 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 may be 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. With respect to GWP services provided by an Advisor (rather than one of LPL’s IARs), 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 a 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 Program. 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 adviser 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. PTC also provides personal trustee services to clients for a variety of administrative fiduciary service, 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 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-GWP 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. LPL 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 17 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure fee or other forms of indirect compensation. These may include referrals for investment banking, lending, accounting, tax preparation, financial technology tools, corporate trustee services, 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 (or that are recommended to users). 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 Research 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 Research. In addition, employees in LPL Research 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. With respect to GWP services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to Advisor’s Form ADV brochure for more information about the Advisor’s code of ethics and personal trading policies. Participation or Interest in Client Transactions Purchases of mutual fund shares are typically 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 GWP. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPL Financial Holdings Inc. stock may not be purchased in GWP accounts. However, a model may include an ETF or mutual fund that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 18 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some previously purchased, non-model mutual funds charge shareholders a 12b-1 fee, and, in the future, mutual funds selected in a Model Portfolio may charge shareholders a 12b-1 fee. To the extent a mutual fund charges a 12b- 1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds (other than Sweep Funds) will be credited to the account. information for the fund. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of GWP clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative, and shareholder services is based on the amount of GWP client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by GWP clients in the fund (up to $25 per position). 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 fund for complex exchange-traded products 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. LPL does not share this compensation with its IARs or Advisors. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (sponsors) of ETFs, mutual funds, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL representatives so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds (other than the Sweep Funds) consists of flat and/or asset based fees totaling up to 0.15% annually of LPL clients' Investments in the Investment product or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Model Portfolio. However, LPL has a financial incentive to recommend participating products instead of those whose sponsors do not make such payments to LPL. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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 19 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective financial professionals to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the IAR or Advisor who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the retention of previously purchased mutual funds and, in the future, the selection of funds and share classes for a Model Portfolio. In particular, LPL has a financial incentive: (i) to retain or select a product or a share class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to retain or select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to retain or select a product or a share class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or share class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the products that pay recordkeeping compensation and the mutual fund sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds (other than the Sweep Funds), and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with IARs or Advisors, and therefore, there is no financial incentive for an IAR or Advisor to select a participating fund over another fund because of this fee arrangement. Although LPL does not share recordkeeping fees or revenue sharing payments with IARs or Advisors such fees and payments will increase LPL’s profits and indirectly benefit IARs and Advisors, 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. 20 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth 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, 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-sweep-programs.html for information about our customer fees and customer interest rates for ICA and DCA, or contact your IAR or Advisor, as applicable, 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. • 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 21 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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. • 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. 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. fee paid to LPL equals an average annual rate of up • 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 to 0.50% respective SBICA. The 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). • 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 22 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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. LPL’s money market mutual fund sweep option automatically sweeps otherwise uninvested cash balances held in the account and invests them 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. The compensation that LPL receives related to ICA, DCA (including from overflow mechanisms) and the Sweep Funds is in addition to the Account Fee that LPL and IAR or Advisor (as applicable) 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. In addition, LPL will not take into account this compensation when it makes decisions on a Model Portfolio’s allocation to cash. LPL will not share this compensation with IARs or Advisors. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other, potentially more favorable, financing arrangements. If a client obtains a loan from a non-partner bank, client should notify their IAR or Advisor, as applicable, of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating 23 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure banks. For partner banks, LPL does not share this compensation with its IARs or the Advisors, and therefore, IARs and Advisors do not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with its IARs or the Advisors, and therefore, IARs and Advisors have a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your IAR’s or Advisor’s compensation, as applicable, on the SCA product is reduced if your interest rate is discounted, so your IAR or Advisor, as applicable, has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. LPL, its IARs, and Advisors have an interest in continuing to receive investment advisory fees, which gives LPL, its IARs, and Advisors an incentive to recommend that clients borrow money rather than liquidate some of their assets managed by LPL, an IAR, or an Advisor, as applicable. This incentive creates a conflict of interest for LPL, its IARs, and Advisors 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, its IARs and Advisors are compensated primarily through advisory fees paid on clients’ accounts, LPL, its IARs, and Advisors 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 maintenance call. This may present a conflict of interest with clients because it could incentivize LPL’s IARs or Advisors, as applicable, to invest in more conservative, lower performing investments to maintain the stability of the account, or alternatively, could incentivize the IAR or Advisor, as applicable, to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. 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 the account, LPL and LPL IARs have a financial incentive to encourage client to invest those assets in the 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 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. 24 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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 the 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. Client may access account statements, showing account activity and month or quarter-end positions, and confirmations of the transactions that occurred within the account through Account View. Confirmations of transactions will be consolidated in the case of rebalancing transactions. Detailed performance information is generally available in electronic form through Account View and is available on year end statements. IARs or Advisors, as applicable, have access to review accounts statements and performance information. Users of the Prospect Tool do not receive any reporting. 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 also pay for, or reimburse LPL for the costs associated with, education or training events that are attended by LPL employees, IARs and Advisors and for 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. With respect to GWP services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to the Advisor’s Form ADV brochure for more information about conflicts of interest. LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to LPL IARs and Advisors. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to LPL IARs and Advisors, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. LPL 25 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure IARs and Advisors are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL employees provide sales support resources to IARs and Advisors 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 certain advisory programs to IARs and Advisors over other advisory programs. These employees also earn more compensation when IARs and Advisors transition client assets from brokerage accounts to advisory accounts, and have a financial incentive to encourage IARs and Advisors 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 typically 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 IAR or Advisor. In the event a trade error occurs in an 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 If a Model Portfolio is selected that only consists of ETFs and/or mutual funds within the same fund family or within affiliated fund families, the Portfolio Strategist will select only those funds within the affiliated fund families. Conflicts Related to LPL Compensation to its IARs This section applies if an LPL IAR provides advisory and consulting services through the Program. An LPL 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 a portion of the Account 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 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 and benefits, 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: • payments based on production • 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 26 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure • 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 • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • advances of advisory fees • payments in the form of repayable and forgivable loans • 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 GWP than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in GWP 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 GWP 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. 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. Conflicts Related to LPL Compensation to Advisor This section applies if clients select a third-party investment advisor firm (Advisor), in lieu of an LPL IAR, to provide advisory and consulting services through the Program. 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. 27 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth 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. In particular, LPL pays additional compensation to Advisor or its IARs by providing, for example: • payments based on production • 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 • payments in connection with the transition of Advisor’s business from another firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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. for offering GWP at a lower overall fee rate than the fee rate 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 GWP than other programs or services. In such cases, Advisor has a financial incentive to recommend advisory services in GWP 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 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 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 28 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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 IARs with LPL 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. Transition Assistance LPL also provides various benefits and/or payments to IARs or Advisors with broker-dealer registered representatives that are newly associated with LPL to assist the IAR or Advisor 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 or Advisor’s business, satisfying any outstanding debt owed to the IAR’s or Advisor’s prior firm, offsetting account transfer fees (ACATs) as a result of the IAR’s or Advisor’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 or Advisor at his or her prior firm. Such payments are generally based on the size of the IAR’s or Advisor’s business established at his or her prior firm, for example, a percentage of the revenue earned or eligible assets serviced by the IAR or Advisor, as applicable, at the prior firm, and, in certain cases, on the amount of the IAR’s or Advisor’s, as applicable, 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 or new Advisor 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 or Advisor 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 or Advisor has a financial incentive to recommend that a client open and maintain an account with the IAR or Advisor 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 29 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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. With respect to GWP services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to the Advisor’s Form ADV brochure for more information about conflicts of interest. 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. 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: • Referral Networks. Some third parties operate referral networks. Referral networks may present potential clients with a list of possible investing firms and investment adviser 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; • 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; • 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; • 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 • 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’s participation in these referral arrangements does not diminish its fiduciary obligations to its clients. Unaffiliated Financial Institutions LPL and its IARs or Advisors, as applicable, 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. 30 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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 benefits including but not limited to the use of the financial institution’s facilities and for client referrals. Instead of paying the IAR or Advisor, as applicable, the portion of the Account Fee as described above, LPL shares the Account Fee with the financial institution, and the financial institution pays part of that amount to the IAR or Advisor, as applicable, based on a compensation plan between the IAR or Advisor and the financial institution. The financial institutions, along with LPL, determine the compensation plan for the IAR or Advisor, as applicable. The financial institution establishes the compensation plan for IAR, which is subject to approval by LPL. The compensation plan determines how the IAR’s compensation is structured. An 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. LPL also has agreements to provide similar services at financial institutions in which compensation is not shared with the financial institution whereby a portion of the Account Fee is paid directly to the IAR or Advisor. 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 Advisor 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. 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 affiliated products and the IAR may only recommend an investment product that he or she believes is appropriate, suitable and in the best interests of the 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 financial institution. For example LPL pays a financial institution based on production, in the form of repayable or forgivable notes, 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 31 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure association from another broker-dealer or investment advisor firm to LPL, advances of advisory fees, or attendance at LPL’s national conference or top producer forums and events. LPL pays 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 financial 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 or Advisor, as applicable have a financial incentive for the IAR or Advisor to recommend a GWP account and services that will result in the greatest compensation to the financial institution and IAR or Advisor. 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 of the financial institution to IARs working in the financial institution. Those employees frequently receive a nominal referral fee from the financial institution (typically up to $25) as compensation for each referral and such referral programs are governed by Regulation R of the Gramm-Leach-Bliley Act. Employees of trust departments at certain financial institutions are authorized under the terms of applicable trust arrangements to delegate investment advisory 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 GWP 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. LPL will not have custody of any funds and securities of users of the Prospect Tool. Brokerage Practices For a GWP account, LPL is appointed by each client as custodian of account assets and broker-dealer with respect to processing securities transactions for the accounts. When securities transactions are effected through LPL, there are no brokerage commissions charged to the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. The fact that LPL is both the investment adviser and 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission or transaction charge for executing transactions in GWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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 what parameters to set for rebalancing transactions that occur in an account. LPL will aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. LPL also will aggregate rebalancing transactions for an account with other Program accounts. Due to the large number 32 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC  Guided Wealth Portfolios Program Brochure 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 which may result in price differences. 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. Dividends paid by securities in a client’s account may be automatically reinvested or may be paid to the client in cash. In general, mutual fund dividends will be reinvested in the specific mutual fund paying the dividend, while dividends for ETFs will generally be paid in cash. 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. 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. 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, 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. With respect to GWP services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to the Advisor’s Form ADV brochure or contact the Advisor for more information. 33 GWP – ADV – 0326 LPL Financial, member FINRA/SIPC 

LPL ACCESS PORTFOLIOS PROGRAM PROGRAM BROCHURE LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. Item 7 was updated to expand the availability of this program to charitable organizations, corporations, other business entities, and pension and profit sharing plans, including plans subject to ERISA. ITEM 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ...................................................................................................................................................... 1 ITEM 2 MATERIAL CHANGES ......................................................................................................................................... 1 ITEM 3 TABLE OF CONTENTS ........................................................................................................................................ 1 ITEM 4 ADVISORY BUSINESS .......................................................................................................................................... 1 ITEM 5 FEES AND COMPENSATION .............................................................................................................................. 3 ITEM 6 PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................... 5 ITEM 7 TYPES OF CLIENTS ............................................................................................................................................. 5 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................................................... 6 ITEM 9 ADDITIONAL INFORMATION ............................................................................................................................. 9 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ...................................................................... 11 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING .. 13 ITEM 12 BROKERAGE PRACTICES .................................................................................................................................. 15 ITEM 13 REVIEW OF ACCOUNTS ................................................................................................................................... 15 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION ........................................................................................ 15 ITEM 15 CUSTODY.......................................................................................................................................................... 20 ITEM 16 INVESTMENT DISCRETION ............................................................................................................................... 21 ITEM 17 VOTING CLIENT SECURITIES ............................................................................................................................ 21 ITEM 18 FINANCIAL INFORMATION .............................................................................................................................. 21 ITEM 4 ADVISORY BUSINESS Services LPL Financial LLC (“LPL”) is an investment adviser registered with the SEC pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”). LPL has provided advisory services as a registered investment adviser since 1975. Note that registration as an investment adviser with the SEC does not imply a certain level of skill or training. As of December 31, 2025, LPL managed A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE approximately $818,320,000,000 of client assets on a discretionary basis and approximately $797,900,000 of client assets on a non-discretionary basis. LPL is owned 100% by LPL Holdings, Inc., which is owned 100% by LPL Financial Holdings Inc., a publicly held company. LPL’s advisory services are made available to clients primarily through individuals associated with LPL as investment adviser representatives (“IARs”). For more information about the IAR providing advisory services, client should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time client engages the IAR. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lpl.com. 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 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. Types of Advisory Services LPL offers various types of advisory services and programs, including wrap fee programs, mutual fund asset allocation programs, an advisor-enhanced digital advice program, advisory programs offered by third party investment advisor firms, financial planning services, and retirement plan consulting services. This Brochure provides a description of the advisory services offered under the LPL Access Portfolios program (the “Program”). For more information about LPL’s advisory services and programs other than LPL Access Portfolios, please contact your LPL 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 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. In the Program, LPL, through its IARs, provides ongoing discretionary investment advice and management on assets in the client’s account. IARs provide advice on the purchase and sale of various types of investments, such as no-load and load-waived mutual funds, unit investment trusts (“UITs”), closed-end funds, exchange-traded funds (“ETFs”), equities, fixed income securities and certificates of deposit. IARs provide advice that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients may impose restrictions on investing in certain securities or groups of securities by contacting their IAR and providing the necessary written instructions. Under a client’s agreement with one or more custodians (each, a “Custodian”), a client instructs Custodian to maintain custody of Program client funds and securities in a separate brokerage account for clients under such client’s name, trade in securities, and execute other transactions upon our instruction. The IAR obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective for the account. The IAR obtains this information by having the client complete a Client Profile which is a part of the Advisory 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 be aware that the investment objective selected for the Program is an overall objective for the entire account in respect of the Program and may be inconsistent with a particular A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE holding and the account’s performance at any time. Clients should further be aware that achievement of the stated investment objective is a long-term goal for the account in connection with the Program. 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. ITEM 5 FEES AND COMPENSATION Fee Schedule Clients in the Program pay LPL an annualized advisory fee (“Advisory Fee”) for the advisory services of LPL and IAR, as well as the administrative services of LPL. The Advisory Fee is negotiable between the client and the IAR and is typically a straight percentage based on the value of all assets in the account, including cash holdings, and payable quarterly in advance. The maximum Advisory Fee is 2.50%. Upon request, the Advisory Fee may be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds in the account. LPL reserves the right to increase the upper limit of the Advisory Fee upon 30 days’ prior notice to clients. LPL and IARs do not charge performance-based fees to accounts in the Program. LPL retains up to 0.05% of the Advisory Fee, which is not shared with your IAR, for its administrative services. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Advisory Fee with the IAR based on the agreement between LPL and the IAR. A portion of the Advisory Fee to the IAR may also be paid by the IAR to his or her LPL branch manager, another LPL representative for supervision or administrative support. There is a conflict of interest when a branch manager receives a portion of the Advisory Fee for supervision because the fee affects his or ability to provide objective supervision of the IAR. LPL may waive any fee it charges to client or IAR in its sole discretion in whole or in part. In the Program, clients will also pay Custodian fees for its custodian, brokerage, trading and execution services. The Advisory Fee, other related fees and charges associated with the Program account, and fees for brokerage and execution services will appear on account statements prepared by Custodian. How the Advisory Fee is Charged Under a client’s agreement with Custodian, a client authorizes LPL and instructs Custodian to permit LPL to charge the Advisory Fee and other related fees and charges associated with the Program account from the account or another account registered to the client’s name. Payment in Advance and Refund of Pre-Paid Fees LPL deducts the Advisory Fee quarterly in advance. If the Advisory Agreement is terminated before the end of the quarterly period, LPL will pay the client a prorated refund of any pre-paid quarterly Advisory Fee based on the number of days remaining in the quarter after the termination date. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in Program accounts. Some of these fees and charges are described below. If a client’s assets are invested in mutual funds, ETFs or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Client will pay an advisory fee to the fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay LPL and IAR the Advisory Fee with respect to assets A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE invested in mutual funds, ETFs and other pooled products. The mutual funds, ETFs and other pooled funds available in the Program can be purchased directly outside of the Program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL and IAR and by making their own decisions regarding the investment. 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. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share classes are selected by LPL in certain cases for consistency with other LPL’s custodied advisory programs. The Program Share Class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund in those other advisory programs. Other financial services firms may offer the same mutual fund at a lower overall cost to the investor than is available through the Program. 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 under a fund’s frequent trading policy, client will be charged a redemption fee. 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). If client holds a UIT in an account, UIT sponsors charge creation and development fees or similar fees. Further information regarding fees assessed by a mutual fund or UIT is available in the appropriate prospectus or offering document, which is available upon request from the IAR or from the product sponsor directly. Important Information When Funding an Account Ineligible Securities. When transferring securities into the Program account, client should be aware that certain securities may 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. Surrender Charges or CDSCs. If client transfers a previously purchased investment into the Program account , or liquidates the previously purchased investment and transfers the proceeds into an account, client may be charged a fee (sometimes called a “surrender charge,” “contingent deferred sales charge” or “CDSC”) upon the sale or redemption in accordance with the investment product’s prospectus. In many cases, the CDSC is only charged if a client does not hold the security for a minimum period of time. In particular, if a client transfers a previously purchased mutual fund (such as a Class C share) into an account that is subject to a CDSC, then the client will pay that charge when the mutual fund is sold. Previously Paid Commissions. Clients 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. Client should understand that, after the transfer into an account, an advisory fee will be charged based on the total assets in the account, including the transferred security. In other words, if you paid IAR or another financial professional recently an upfront commission on the previously purchased security, you will be paying a new ongoing advisory fee going forward to IAR for advice on that same security. Loss of Benefits. If client will be funding the account with the proceeds of a sale or liquidation of an annuity, client should understand that client may be giving up guaranteed living or death benefits that were provided through the annuity, and will not be provided through the Program account. When transferring securities into an account, client should consider and speak to IAR about whether: a CDSC will apply, and the length of time before the CDSC expires; there will be a loss of a guaranteed benefit, in the case of an annuity; a commission was previously paid on the security; • • • A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE 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. • • Understanding Share Classes and Transaction Charges LPL makes available for purchase only one share class per mutual fund in the Program, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Program Shares”). Program Shares are no-load or load-waived share classes and therefore not subject to any upfront sales charge. A client may transfer other share classes into an account (“Non-Program Share Classes”). Client understands that if a Non-Program Share Class is held in the Account, that share class may be more expensive than the Program Shares. Clients should understand that the Program Share class offered for a particular mutual fund through the Program in many cases will not be the least expensive share class that the mutual fund makes available. Program Share Classes are selected by LPL in certain cases for consistency with other LPL’s custodied advisory programs. The Program Share Class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund in those other advisory programs. Other financial services firms may offer the same mutual fund at a lower overall cost to the investor than is available through the Program. Clients should also understand that Custodian charges clients a transaction charge for purchases and sales of securities. The applicable transaction charge varies based on the type of transaction (e.g., mutual fund, equity, ETF or fixed income security). As with any fee, transaction charges reduce the overall amount of your investment portfolio. Important Things to Consider About Fees • The Advisory Fee is an ongoing fee for investment advisory services. Factors that bear upon the cost of the account in type and size of the account 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 Advisory Fee may be higher than the fees charged by other investment advisors for similar services. This is the case in particular if the Advisory Fee is at or near the maximum Advisory Fee set out above. The IAR is responsible for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, and the number and range of supplementary advisory and client-related services to be provided to the account. The IAR may charge a client more or less than another client. Clients should consider the level and complexity of the advisory services to be provided when negotiating the Advisory Fee with IAR. • The investment products available to be purchased in the Program can be purchased by clients outside of the Program 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 6 PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT This Item is not applicable. LPL and its IARs do not accept performance-based fees. ITEM 7 TYPES OF CLIENTS The Program is available for individuals (individually or jointly with another person), trusts, traditional individual retirement accounts (“IRAs”), Roth IRAs, charitable organizations, corporations, other business entities, and pension and profit sharing plans, including plans subject to the Employee Retirement Income Security Act of 1974, as amended (‘ERISA”). A minimum account value of $10,000 is generally required for the Program. In certain instances, LPL will permit a lower minimum account size. A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Each IAR managing the Program account chooses his/her own research methods, investment strategy and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. The IAR has access to various research reports, including those provided by LPL’s Research Department, to which he/she may refer in determining which securities to purchase or sell. LPL’s Research Department makes available recommendations regarding asset allocation, mutual funds, and model portfolios. IARs may or may not follow these recommendations in managing Program accounts. LPL Research also constructs asset allocation model portfolios and provides recommendations on the funds to populate the model portfolios. In constructing these models, LPL Research uses the following investment strategies: Diversified and Alternative Strategy. Although these descriptions are written in terms of individual equities and/or bonds, they include mutual funds or ETFs whose portfolios consist of the type of equities or bonds referenced. • Diversified. The Diversified investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. The strategy is subject to minimal constraints, which allows for a relatively pure implementation of LPL Research’s recommendations. In general, Diversified portfolios should be considered by investors seeking investments in primarily stocks and bonds, along with the occasional non-traditional asset class to take advantage of potential market opportunities. Diversified portfolios will hold primarily traditional asset classes. Secondarily, if a non-traditional asset class represents the investment that provides the best means of taking advantage of a market opportunity, it will be included in the recommendation. The non-traditional investments included in Diversified portfolios are more standard, such as conservative balanced strategies. Diversified portfolios tend to be steady in their number of positions. These portfolios tend to remain consistently diversified. • Alternative Strategy. The Alternative Strategy investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. Unlike the Diversified investment strategy which may have an allocation to alternative strategy or non-traditional assets classes, this portfolio typically has an allocation to non-traditional asset classes. This strategy extends the diversification beyond the core style box asset classes into strategies with lower correlation to stocks and bonds in order to lower risk, as defined by standard deviation and maximum drawdown (peak to trough loss), while attempting to maintain long-term performance similar to other portfolios in the same investment objective. For each of the above investment strategies, LPL Research recommends a strategic or tactical version. • Strategic. Strategic portfolios typically have a three- to five-year time horizon. The allocations within these portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout that time frame. Although LPL Research recommends investments through a three- to five-year lens, LPL Research may recommend that these portfolios be traded for fine tuning throughout the year. For clients who take a longer term view or are more tax sensitive, a strategic implementation may be more appropriate. • Tactical. Tactical portfolios are more flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present. LPL Research recommends that these portfolios invest in opportunities for as short as one week and as long as five years. Due to the tactical nature, the trading is notably more frequent than strategic portfolios. Tactically managed portfolios should be considered by clients who wish to take advantage of shorter-term market opportunities that may arise and are not opposed to the prospect of more frequent trading. It is important to note that although LPL Research makes available its recommendations and investment strategies, an IAR will not necessarily take into consideration these recommendations and strategies. Clients should contact the IAR managing his/her accounts for additional information on the IAR’s particular investment strategy. It is also important to note that an IAR may use a combination of investment strategies. Types of Investments and Risks In the Program, IARs can recommend many different types of securities, including mutual funds, unit investment trusts (“UITs”), closed end funds, ETFs, equities, fixed income securities and certificates of deposit. LPL determines the types of investments that A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE are eligible to be purchased in Program accounts. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that are available in the Program. • 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. Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile • ‐ • • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Issuer than the market as a whole and can perform differently from the value of the market as a whole. 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ ‐ ‐ ‐ sectors of the market, sectors. its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub An individual sector, industry, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Alternative Strategy Mutual Funds. Certain mutual funds available in the Program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End Funds. Clients should be aware that closed-end funds available within the Program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so. In some cases, there may be an additional cost to investors who redeem before holding shares for a specified amount of time. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Funds (“ETFs”). ETFs are typically investment companies that are legally classified as open-end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • 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 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 A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and its IARs generally will earn more compensation for selling one investment product than another. As a result, LPL and its IARs have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. 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 A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE 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: • • • • • • • • 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’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). A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE • • 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, 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). 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). 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/. ITEM 10 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 A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE located on the premises of certain financial institutions and are employees of LPL Employee Services, LLC, an LPL-affiliated company. IARs may be broker-dealer 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 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 also provides personal trustee services to clients for a variety of administrative fiduciary services. 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- 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 registered 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. Our affiliate, LPL Enterprise, LLC (“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 adviser representatives dispersed throughout the United States. In addition, LPLE is qualified to sell insurance products in all 50 states. 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. A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE Some IARs work with UIT sponsors to create customized UITs. For customized UITs, IARs provide the UIT sponsor with input regarding the portfolio composition of the UIT, and in exchange may be paid a consulting fee. The UIT sponsor retains sole responsibility for creating and implementing the investment portfolio of the UIT. An IAR is permitted to invest Program account assets in customized UITs for which the IAR provided consulting services. LPL has policies and procedures in place for customized UITs that are designed to prevent conflicts of interest and to ensure that IARs act in clients’ best interest. Among other things, these policies prevent IARs from receiving consulting fees for assets that any LPL client invests in customized UITs. Depending on the securities held by the UIT, a customized UIT’s sales charges and sponsor fees could be more expensive than separately purchasing the basket of securities in the UIT’s portfolio. Before investing a customized UIT, ask your IAR questions about compensation received from the UIT and about the UIT’s fees and expenses. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. 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. As described under Brokerage Practices below, IARs may aggregate transactions in equities, options, and fixed income securities for client accounts. Clients should be aware that the IAR’s personal accounts (including related accounts, such as those of family members) can be included in such a block order. Although the same average price would be applied to client accounts and the IAR’s personal accounts, the inclusion of an IAR’s personal account in a block order can present a conflict of interest. It is possible that the inclusion of the personal account could negatively impact the price of the security or result in the client being allocated less of an order. If a partially filled order is allocated on a random basis, the inclusion of the personal account could make it less probable that a client account is randomly selected and the IAR’s personal account could be randomly selected instead of a client account. LPL addresses this conflict by disclosing it to you. Please ask your IAR if you would like more information on the IAR’s practices in this respect. Participation or Interest in Client Transactions Purchases of mutual fund or UIT or shares may be processed through the firm'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 the firm’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 does not permit its IARs to recommend or purchase LPL Financial Holdings Inc. stock in Program accounts. However, IARs may recommend or purchase an ETF or mutual fund that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. Compensation; Revenue Sharing Arrangements, Mutual Fund 12b-1 Fees; and Recordkeeping Services 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 $15,000 per product for complex ETPs. In the case of mutual funds, LPL receives a one-time A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE 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 receives up to $5,000 per trust. LPL does not share this compensation with its IARs. LPL provides investment consulting services to the adviser to the Optimum Funds including, but not limited to: 1) assisting the adviser in determining whether to employ, maintain or terminate sub-advisers for the Optimum Funds, 2) providing quarterly fact sheets describing the performance of the Optimum Funds, 3) providing quarterly analysis consisting of statistical information and analysis regarding the Optimum Funds and sub-adviser performance, 4) meeting with sub-advisers selected by the adviser to the Optimum Funds to discuss their performance and prepare reports regarding their evaluations, and 5) helping the adviser make recommendations on sub-advisers to the Board of Trustees by providing the adviser to the Optimum Funds with potential sub- adviser options. As compensation for these services, LPL receives an investment consulting fee of up to 0.22% of fund assets from the investment advisor to the Optimum Funds. The receipt of this investment consulting compensation by LPL presents a conflict of interest, because LPL has a financial benefit if an Optimum Fund is purchased in an account. This fee is not shared with LPLE or its IARs. In addition, a senior executive officer of LPL serves as a Trustee of the Optimum Funds. The Optimum Funds are available to be purchased and sold in a Program account. From time to time, LPL receives a reallowance of the public offering price per unit on units of certain UITs and structured products sold by LPL during the initial offering period. Non-Sweep Money Market Mutual Fund Investments Clients are able to invest cash balances in a limited number of money market mutual funds (such funds, “Money Market Funds”). Depending on interest rates and other market factors, investment returns of money market mutual funds have been, and may be in the future , lower than the aggregate fees and expenses charged by LPL for a client’s participation in the Program. This may result in a client experiencing a negative overall investment return with respect to cash reserves invested in the Money Market Funds. As described above, under “Fees Charged by Third Parties,” clients should understand that in many cases the Program Share Class offered for a particular Money Market Fund charges higher fees and expenses than other share classes that are offered by the same Money Market Fund but are not available through the Program. Unlike other types of mutual funds available in the Program, LPL makes available Money Market Funds from only a limited number of mutual fund sponsors. Because of the limited number of Money Market Funds available in the Program and the fees paid by those funds, other money market mutual funds not available through the Program are likely to have higher returns than the Money Market Funds. 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 cardholders. Rollovers If a client is a participant in an employer-sponsored 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 recommend that the client invest those assets in the 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 employer-sponsored plans, and there can be maintenance and other miscellaneous fees. As securities held in an employer-sponsored plan are generally not transferrable to 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 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 A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE 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 a 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 IAR 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. Other Clients Clients should understand that LPL and IAR perform advisory and/or brokerage services for various other clients, and that LPL and IAR may give advice or take actions for those other clients that differ from the advice given to the client. The timing or nature of any action taken for the account may also be different. ITEM 12 BROKERAGE PRACTICES In LPL Access Portfolios, LPL requires that clients direct Custodian as the broker-dealer to execute transactions in the account. The IAR is not paid a commission, but Custodian is paid transaction charges by the client for processing trades depending on the type of security. Clients should understand that not all advisors require their clients to direct brokerage. By directing brokerage to Custodian, clients may be unable to achieve the most favorable execution of client transactions. Therefore, directed brokerage may cost clients more money. ITEM 13 REVIEW OF ACCOUNTS LPL reviews program accounts using a risk based exception reporting system that flags accounts for criteria such as trading activity and concentration on a quarterly or monthly basis, depending upon the nature of the exception. The Chief Compliance Officer of LPL oversees the process for reviewing flagged 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. Custodian sends monthly or quarterly account statements showing the amount of funds and each security in the account at the end of the period and setting forth all transactions in the account during that period. Clients should carefully review those account statements. LPL is not responsible for verifying the accuracy of the information in such statements or any losses or errors by Custodian, including but not limited to errors in performance reports and/or fees charged to the account, if caused by, or in any way related to, its reliance on such information and/or the acts or omissions of Custodian with respect to the account. Client will also receive performance information annually from LPL describing account performance, positions and activity. Additional performance information is available upon request. Client understands that it is important to review promptly confirmations, account statements, disclosures, and other documents and communications that LPL or IAR provides. Client agrees to notify LPL or IAR promptly if anything in the account documents appears inaccurate or suspicious. ITEM 14 CLIENT REFERRALS AND 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 A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE $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 also pay for, or reimburse LPL for the costs associated with, education or training events that may be attended by LPL employees and IARs and for 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 servicing customers. LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 certain advisory programs 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. In the event a trade error occurs in a Program 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. 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 Advisory Fee. LPL and its IARs have generally entered into the following types of referral arrangements: • Referral Networks. Some third parties operate referral networks. Referral networks may present potential clients with a list of possible investing firms and investment adviser 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 Advisory Fee; • 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; • 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; A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE • 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 • 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’s participation in these referral arrangements does not diminish its fiduciary obligations to its clients. 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. Such compensation includes other types of compensation, such as bonuses, awards or other things of value offered by LPL to the IAR. 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 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. In particular, LPL pays its IARs in different ways, for example: • payments based on production • 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 attendance at LPL conferences and events. • • • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • • payments in the form of repayable or forgivable loans • 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. A 1 6 – 0 3 2 6 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE 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 the Program than other programs or 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 the Program at a lower overall fee rate than the fee rate for a program offering a third-party manager. In such cases, the IAR has a financial incentive to recommend advisory services in the Program over other programs and services. 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 has systems in place to review IAR-managed accounts in the Program for suitability over the course of the advisory relationship. 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 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 A 1 6 – 0 3 2 6 P a g e 1 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE 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. 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 Advisory 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 Advisory Fee as described above, LPL shares the Advisory Fee with the financial institution, and the financial institution pays part of that amount to the 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 Advisory Fee, after LPL retains its portion of the Advisory 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 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 Advisory 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 Advisory Fees you pay to LPL. 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. If your IAR is an employee of and/or provides services on the premises of one of these financial institutions, the financial institution has a financial incentive for its IAR to select the financial institution’s affiliated investment products or certificates of deposit over non-affiliated products. When an affiliated investment product is selected for an account, A 1 6 – 0 3 2 6 P a g e 1 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE the financial institution receives a portion of the Advisory Fee pursuant to the agreement between LPL and the financial institution and its affiliate receives fees or other benefits from the affiliated investment product. Because affiliates of the financial institution earn fees and other benefits from the affiliated products, the financial institution has an incentive to select its affiliated product 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 a credit in an amount equal to the mutual fund advisory and administrative services fees 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 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 can 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. ITEM 15 CUSTODY LPL utilizes a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act to maintain custody of Program client funds and securities in a separate account for each client under the client’s name. Custodian sends monthly or quarterly account statements showing the amount of funds and each security in the account at the end of the period and setting forth all transactions in the account during that period. Clients should carefully review those account statements. LPL is not responsible for verifying the accuracy of the information in such statements or any losses or errors by Custodian, including but not limited to A 1 6 – 0 3 2 6 P a g e 2 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 IP C  LPL ACCESS PORTFOLIOS - PROGRAM BROCHURE errors in performance reports and/or fees charged to the account, if caused by, or in any way related to, its reliance on such information and/or the acts or omissions of Custodian with respect to the account. ITEM 16 INVESTMENT DISCRETION In the Program, the IAR provides advisory services on a discretionary basis for the purchase and sale of Program securities. The client authorizes the IAR to have discretion by executing the Advisory Agreement and Client Profile. ITEM 17 VOTING CLIENT SECURITIES In the Program, LPL and IARs do not accept authority to vote client securities. Clients retain the right to vote all proxies that are solicited for securities held in the account. Clients will receive proxies or other solicitations from LPL. If clients have questions regarding the solicitation, they should contact the contact person that the issuer identifies in the proxy materials or their 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 18 FINANCIAL INFORMATION LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and is therefore not required to include a balance sheet for its most recent financial fiscal year. LPL is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has it been the subject of a bankruptcy petition at any time during the past ten years. A 1 6 – 0 3 2 6 P a g e 2 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 IP C  LPL ACCESS 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 clients from time to time, they are not the IARs responsible for the ongoing individualized investment advice for your account. For more information about the IAR(s) managing your account, please should refer to the Brochure Supplement(s) for your IAR(s), which should have been provided along with this Brochure at the time you opened the account. If you did not receive a Brochure Supplement for your IAR(s), please contact your IAR or LPL at lplfinancial.adv@lplfinancial.com. A 1 6 – 0 3 2 6 P a g e 2 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 IP C 

Manager Select Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This wrap fee 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 31, 2025. Item 9 was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 7 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 7 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 16 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 16 Item 9: Additional Information ............................................................................................................................................... 16 MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 1  Manager Select 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 client directly and also through third party investment advisor firms (“Advisor”). This Brochure provides a description of LPL’s Manager Select program when offered through an Advisor. For more information about LPL’s advisory services and programs other than Manager Select, please contact your Advisor for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov/. In the Manager Select program, Advisor, through its investment adviser representatives (“IARs”), makes available to clients the investment advisory services and/or model portfolios of third-party portfolio management firms. Within the Manager Select program, LPL offers two alternatives – the Separately Managed Account Platform (the “SMA Platform”) and the Model Portfolio Platform (the “MP Platform” and collectively, the “Platforms”). In connection with the Platforms, LPL acts as an investment advisor, serves as the custodian of the assets, provides brokerage and execution services as a broker-dealer on transactions, and performs administrative services, such as reporting to clients. Advisor through its IAR assists the client to determine the client’s investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and, in the case of the SMA Platform, to select an investment strategy and SMA Portfolio Manager, or in the case of the MP Platform, to select a model portfolio (Model Portfolio) provided by LPL Research or third-party investment advisors (Model Advisors). Your Advisor and IAR cannot change the SMA Portfolio Manager or Model Advisor you select for your Account without your approval. SMA Platform In the SMA Platform, Advisor through its IAR assists the client to determine the client’s investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and to select an investment strategy and SMA Portfolio Manager. Advisor through its IAR provides the client with ongoing advice and monitoring relating to the SMA Portfolio Manager’s services and serves as the point of contact between the client and the SMA Portfolio Manager with regards to changes in the client’s investment objective, financial situation, and investment restrictions. The SMA Portfolio Manager selected by the client provides ongoing discretionary investment advice regarding the investment and reinvestment of account assets in accordance with the investment objective, restrictions and guidelines set forth in the Application or in other agreed-upon written instructions. The SMA Portfolio Manager independently determines whether to accept the client account based on the content of the Account Application, suitability, and whatever other factors the SMA Portfolio Manager deems appropriate. The SMA Portfolio Manager has the sole authority to determine the securities to be purchased, sold, or exchanged and which portion, if any, of the assets shall be held uninvested. The SMA Portfolio Manager has discretion to invest among a broad variety of security types, including equities, fixed-income securities, options, mutual funds, and exchange-traded funds (“ETFs”). LPL and Advisor do not play a role in the selection of particular securities to be purchased or sold. A SMA Portfolio Manager may hire one or more sub-advisors to manage all or a portion of a client’s account. MP Platform In the MP Platform, the Advisor through its IAR assists the client in setting an appropriate investment objective and selecting a model portfolio (“Model Portfolio”) provided by LPL Research or third-party investment advisors (“Model Advisors”). Advisor through its IAR provides the client with ongoing advice and monitoring relating to the Model Portfolio, is available on an ongoing basis to receive deposit and withdrawal instructions, and to convey to LPL any changes in Client’s financial circumstances, investment objectives or investment restrictions. Under the MP Platform, LPL provides ongoing discretionary investment advice regarding the investment, reinvestment, and the rebalancing of account assets in accordance with the Model Portfolio selected by the client. LPL is expected to closely track the Model Portfolio, making modifications only to address particular account issues, including tax loss harvesting, rebalancing, short-term gain avoidance, cash inflows and outflows, and tracking error from the Model Portfolio, and MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 2  Manager Select Program Brochure to ensure that investment restrictions are being followed. 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. Fee Schedule In the Platforms, clients pay LPL an annualized fee (“Account Fee”). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the client changes the model selected for the Account, or if the model investment value changes, the overall Account Fee may increase or decrease. 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, IARs, SMA Portfolio Managers and Model Advisors do not charge performance-based fees to accounts in the Platforms. Advisory Fee. The Advisory Fee is charged for the investment advisory services of Advisor, as well as the investment advisory, administrative, trading, and custodial services of LPL. The Advisory Fee is shared with the Advisor. The Advisory Fee is negotiable between the client and the Advisor and is based on the value of all assets in the account, including cash holdings, and is payable quarterly in advance. The maximum Advisory Fee is 2.35%, although certain legacy accounts may remain higher, so long as the maximum combined Advisory Fee and Manager Fee is no more than 2.95%. Upon request, the Advisory Fee also can be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds in the Account. LPL retains a portion of the Advisory Fee, up to 0.35% of the value of the assets of the account, for its investment advisory, administrative, custody and clearing services. LPL shares up to 100% (typically between 90% to 100%) of the remaining portion of the Advisory Fee with the Advisor based on the agreement between LPL and the Advisor. LPL retains any portion of the Advisory Fee not shared with the Advisor. Manager Fee. The Manager Fee is charged for the services provided by Model Advisor or SMA Portfolio Manager, as applicable. Clients do not pay LPL or Advisor brokerage commissions or transaction charges for execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Clients pay a Manager Fee set by LPL for services provided by the SMA Portfolio Manager in the case of the SMA Platform and for use of the model portfolio of the Model Advisor in the case of the MP Platform. The Manager Fee is based on the value of all assets in the Account, including cash holdings, and payable quarterly in advance. This fee ranges from 0% to 0.60%. The amount of the Manager Fee will differ depending on the SMA Portfolio Manager or Model Advisor selected for Account, and also may vary depending on which investment strategy or Model Portfolio is selected. For Model Portfolios in the MP Platform, LPL charges a fee of up to 0.05% of account assets per year for the costs and services associated with effecting trades to implement a model, such as order formation, execution, settlement and sleeving of transactions. This LPL fee for its trading services is reflected in the Manager Fee on client statements. Generally, LPL charges 0.05% of account assets per year for models transacting primarily in equities, and LPL charges 0.03% of model assets per year for models transacting primarily in fixed income or other over-the-counter securities. For certain Model Portfolios designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL either charges a Manager Fee as Model Advisor or charges a fee for its trading services, there is a conflict of interest for LPL to recommend such models. LPL charges the fee for trading services to retirement and nonretirement accounts to the extent permissible under applicable law. Advisor does not receive any portion of the Manager Fee, including based on recommending a model for which LPL charges this compensation. Information about the client’s model and fee rates can be requested from IAR. Certain Model Advisors or SMA Portfolio Managers receive a reduced Manager Fee or do not receive a Manager Fee. This is often because the Model Advisor or SMA Portfolio Manager has included proprietary or affiliated mutual funds or exchange-traded funds in the Model or Investment Strategy which charges a management fee. This management fee can be found in the prospectuses of the mutual funds or exchange traded funds included in the Model or Investment Strategy. Because a Model Advisor, SMA Portfolio Manager or their affiliates benefit financially when an affiliated MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 3  Manager Select Program Brochure fund is selected, there is a conflict of interest that affects the Model Advisor or SMA Portfolio Manager’s ability to provide unbiased, objective investment advice concerning the selection of funds for a Model or Investment Strategy. The fees paid to SMA Portfolio Managers in the SMA Platform and to Model Advisors in the MP Platform are generally less than fees those advisors would charge a client seeking to establish a direct relationship with them outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, and marketing expenses that would otherwise be borne by those advisors, including trading expenses for Model Advisors. SMA Portfolio Managers and Model Advisors generally have higher minimum account size requirements and fees for direct accounts because of such additional expenses. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a Manager Select account from the account. LPL pays the applicable portion of the Account Fee to the SMA Portfolio Manager or Model Advisor. 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 or 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 pro-rated 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 there is no investment advisor responsible for providing ongoing investment advice. Other Types of Fees and Expenses of LPL LPL charges fees related to a Manager Select account in addition to the Account Fee, such as miscellaneous administrative or custodial-related fees and charges. LPL notifies clients of these charges at account opening. These miscellaneous 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. As described below under “Additional Information - Participation in Client Transactions,” if LPL as broker-dealer executes a principal transaction in a Manager Select account, LPL may earn a markup or markdown in addition to the Account Fee. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in Manager Select accounts. As described below under “Additional Information – Brokerage Practices,” if a SMA Portfolio Manager chooses to execute a transaction through a broker-dealer other than LPL, the execution price to the client may include a commission, markup/markdown, or other fee imposed by the executing broker-dealer in addition to the Account Fee. If client holds an American Depositary Receipt (“ADR”) in an account, there may be custodial fees or taxes related to the ADR. If a client’s assets are invested in mutual funds, ETFs or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Client will pay an advisory fee to the fund manager and other expenses charged by the fund. Client will also pay LPL, the SMA Portfolio Manager (exclusively in the case of the SMA Platform) and Advisor the Account Fee with respect to assets invested in such mutual funds, ETFs, or other pooled investment products. Clients generally can purchase mutual funds MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 4  Manager Select Program Brochure directly outside of the program. Therefore, clients could avoid the second layer of fees by not using the advisory services of LPL, SMA Portfolio Manager, Advisor and its IARs and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” A SMA Portfolio Manager or Model Advisor available in the program may be affiliated with an Advisor. As a consequence, selection of an affiliated SMA Portfolio Manager or Model Advisor generates additional compensation to Advisor’s affiliates. Advisor may charge fees in addition to the Account Fee. Clients should refer to the Brochure of Advisor for more information regarding fees charged by Advisor. If client transfers into a Manager Select 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 Manager Select model. 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 Advisor or directly from the fund. When transferring securities into a Manager Select 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 a Manager Select 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 Advisor 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. For those Manager Select accounts investing in mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in Manager Select charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 5  Manager Select Program Brochure 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds will be credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on a Manager Select Account • The Account Fee is an ongoing wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. The Account Fee may cost the client more than purchasing the program services separately, for example, paying fees for the advisory services LPL, Advisor, and the SMA Portfolio Manager or Model Advisor, as applicable, plus commissions 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: – type and size of the account – 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. • It is important to note that a client may or may not be able to purchase advisory services directly from the SMA Portfolio Managers or Model Advisors, as they often do not offer such services for client accounts of the size typically associated with wrap programs. If they do offer such services to accounts the size of a program account, they often charge a higher fee as they do not enjoy the economies of scale related to providing services to clients of a wrap program. • Certain of the SMA Portfolio Managers or Model Advisors available in the program may be affiliated with an Advisor. As a consequence, selection of an affiliated SMA Portfolio Manager or Model Advisor generates additional compensation to Advisor or its affiliates. • 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 Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, the fees associated with the SMA Portfolio Manager or Model Advisor, and the 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 Advisory 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 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 Manager Select 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, MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 6  Manager Select Program Brochure and other client services. Therefore, the Advisor and its IARs can have a financial incentive to recommend a program account over other programs and services. • 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 A minimum account value of $25,000 generally is required for the program. In certain instances, the minimum account size may be lower or higher. Note that an account will not be invested until the applicable minimum for the investment strategy or Model Portfolio has been reached. Clients should consult with Advisor through its IAR to obtain more information about the applicable investment minimum based on the strategy or Model Portfolio selected. The program is available for individuals, 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 Manager Select, Advisor through its IARs is responsible for the investment advisory services related to the selection and retention of the SMA Portfolio Manager, in the case of the SMA Platform, and Model Portfolio, in the case of the MP Platform. The client selects Advisor and its IAR who services the account. Advisor is responsible for determining the standards required for its IARs to provide investment advice to program accounts. For more information about Advisor and the IAR servicing the account, client should refer to Advisor’s Firm Brochure and the Brochure Supplement for the IAR, which client should have received from Advisor at the time client opened the account. LPL makes available the advisory services of SMA Portfolio Managers. LPL does not act as a portfolio manager for the SMA Platform. LPL does, however, act as portfolio manager for the MP Platform. Criteria for Participating and Recommended SMA Portfolio Managers and Model Advisors LPL selects and reviews SMA Portfolio Managers and Model Advisors for the program based on quantitative, qualitative and infrastructure criteria, which may include the criteria listed below. Quantitative Criteria LPL evaluates quantitative criteria, including but not limited to: • Rate of return • Number of employees and accounts Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Years in the business • Assets under management • Investment philosophy • Risk controls • Legal and compliance issues MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 7  Manager Select Program Brochure Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a SMA Portfolio Manager or Model Advisor can handle operational requirements, including but not limited to: • Composite calculation methodology • Trade rotation policy • Back office review • Client servicing resources • Firm-wide program commitment Additional Criteria for Recommended Managers and Model Advisors SMA Portfolio Managers and Model Advisors that are “Recommended” by LPL Research are subject to a more rigorous selection and review process than the criteria set out above that applies to all SMA Portfolio Managers and Model Advisors available in the program. In addition to the criteria noted above, additional evaluation criteria for Recommended SMA Portfolio Managers or Model Advisors include: • Sound investment philosophy and process that drives performance • Consistency of returns and risk • Qualitative assessment of the investment manager and team Clients should speak to the IAR regarding whether the SMA Portfolio Manager or Model Advisor being considered for selection or that has been selected by the client is Recommended or Participating. LPL as a Model Advisor Clients may invest in Model Portfolios designed by LPL Research. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Model Portfolios to meet different investor needs. LPL Research Model Portfolios are built by seeking certain quantitative characteristics for each portfolio. LPL Research’s Model Portfolios are each designed to hold constituents of a specific underlying index. LPL Research looks for specific characteristics or investment factors of the constituents within the index and designs a Model Portfolio to capture the investment results of that characteristic or factor. For example, one such Model Portfolio seeks to have index-like representation to reasonably track large cap index returns such as the Russell 1000 Index, while another focuses on dividends by seeking a yield premium over the index. The LPL Research Model Portfolios are managed tactically, which means they are flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of trading as frequently as monthly. The participation of LPL Research as a Model Advisor under the MP Platform gives rise to conflicts of interests. For certain LPL Research model portfolios, LPL charges clients a Manager Fee. In addition, LPL has a financial incentive to promote its internal team and further grow its assets under management, in part because as assets under management at LPL increase, LPL is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. However, LPL does not share the Manager Fee with Advisor. Removal of a SMA Portfolio Manager or Model Advisor LPL may elect to remove or replace a SMA Portfolio Manager or Model Advisor should it determine that the firm has failed to meet one or more of the above selection criteria or if the SMA Portfolio Manager or Model Advisor has failed to maintain sufficient assets under management at LPL to maintain profitability on the Platform. In making a decision to remove or replace a SMA Portfolio Manager or Model Advisor, LPL takes into consideration all criteria; no one MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 8  Manager Select Program Brochure criteria, other than the maintenance of assets under management at LPL, is necessarily determinant in the decision. Short-term developments are monitored but are not necessarily sufficient for a decision to remove or replace a SMA Portfolio Manager or Model Advisor. While LPL would have the authority to remove the LPL Research Department as a Model Advisor, it is unlikely to do so. Portfolio Manager Performance LPL Research uses information provided by the SMA Portfolio Manager or Model Advisor and may also use independent, third-party databases when evaluating a SMA Portfolio Manager or Model Advisor. In order for a SMA Portfolio Manager or Model Advisor to be selected for the Platforms, LPL generally requires a third-party verification letter related to compliance of the firm’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. This requirement may be waived by LPL for various reasons including alternative methods of verifying the experience and/or performance of the SMA Portfolio Manager or Model Advisor. SMA Portfolio Manager and Model Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate the performance record of the SMA Portfolio Manager or Model Advisor. However, LPL provides clients with individual performance information. Performance information distributed by LPL is compiled using third party portfolio accounting and reporting software. Client performance is reported on a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that third-party Model Advisors provide Model Portfolios to LPL, and it is LPL that has discretion for trade implementation and execution in MP Platform accounts. Therefore, Model Portfolios submitted to LPL by third-party Model Advisors represent activity that has already been implemented on behalf of other clients of such Model Advisors. Because of this fact and because LPL (and not the third-party Model Advisor) has discretionary authority to implement trades, performance of an MP Platform account will differ from and may be worse than the performance of such Model Advisor’s discretionary accounts. Investment Strategies SMA Portfolio Managers and Model Advisors may provide advisory services or models based on the following types of investment strategies. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Small Cap Blend Small Cap Growth Small Cap Value Tax Free Fixed Income Taxable Fixed Income All Cap Core All Cap Growth All Cap Value Balanced Convertibles Global Balanced Global Equity Growth Equity Income Preferred Large Cap Core Large Cap Foreign Large Cap Growth Large Cap Value Mid Cap Core Mid Cap Growth Mid Cap Value REIT Sector Types of Investments and Risks In Manager Select, LPL (in the case of the MP Platform) or SMA Portfolio Managers (in the case of the SMA Platform) may invest in many different types of securities, including equities, fixed income securities, options, mutual funds, closed-end funds, interval funds and ETFs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and particular risks associated with some types of investments available in the program. • 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. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 9  Manager Select Program Brochure • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Alternative Strategy Mutual Funds. Certain mutual funds available in the programs invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an “interval fund”). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 10  Manager Select Program Brochure repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • 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. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 11  Manager Select Program Brochure issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 12  Manager Select Program Brochure default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • Options. Option trading is permitted in the program. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and a program account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), futures-linked ETPs (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 13  Manager Select Program Brochure • 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 in accordance with the terms of the lending arrangement, 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.” • Blockchain Technology. Blockchain is a novel technology for which its uses, opportunities, applications, and abilities are unknown and unproven. There can be no assurances that companies investing in this technology will be able to benefit from it. The amount and type of investment restrictions are subject to change and manager’s acceptance. Companies investing in blockchain tend to be concentrated in the technology and financial sectors. As a result, the portfolio will be subject to the concentration risk described above and the portfolio’s performance may vary materially from that of its MSCI World Index benchmark. This portfolio invests in American depositary receipts (ADRs), negotiable certificates traded on a U.S. exchange which are issued by U.S. banks and which represent a specified number of shares (or one share) in a foreign stock. As a result, the portfolio will be subject to the Non-U.S. securities risk described below. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • 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. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 14  Manager Select Program Brochure 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and Advisor generally will earn more compensation for selling one investment product than another. As a result, LPL and Advisor have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. Voting Client Securities In the case of the SMA Platform, the SMA Portfolio Manager, and not LPL, is responsible for voting proxies with respect to issuers held in an account, unless a client directs otherwise in writing. The SMA Portfolio Manager, and not LPL, likewise determines how to respond to any voluntary corporate actions. LPL does not assume responsibility for reviewing the SMA Portfolio Manager’s proxy voting decisions or policies, including for compliance with law. In the case of the MP Platform, unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. A copy of LPL’s proxy voting policies is available upon request to Advisor through its IAR. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting the 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of third-party Model Advisors without reviewing individual client interests, unless LPL believes that such instructions are overtly contrary to our clients’ best interests. In such case, LPL will determine whether or how to act consistent with the best interests of our clients. LPL, Advisor, IARs and Model Advisors are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 15  Manager Select Program Brochure Account, or issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the Account. Item 7: Client Information Provided to Portfolio Managers When a client opens a Manager Select account, Advisor through its IARs obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective for the account. The Advisor through its IARs obtains this information by having the client complete an Account Application which is a part of the Account Agreement. In the case of SMA Platform accounts, LPL forwards this information to the selected SMA Portfolio Manager. In the case of MP Platform accounts, the IAR uses this information to assist the client in selecting an investment strategy and Model Portfolio for the account. LPL typically will not provide client information to third- party Model Advisors. After the account opening, LPL asks clients quarterly to contact the Advisor if there have been any changes in the client’s financial situation or investment objectives or if the client wishes to impose any reasonable restrictions on the management of the account or modify existing restrictions. If client communicates to the Advisor or its IARs regarding material changes in the client’s financial circumstances, investment objective or investment restrictions, such information is forwarded to the SMA Portfolio Manager. Clients may communicate such information to the Advisor or its IARs, or otherwise communicate directly with the SMA Portfolio Manager, although clients are encouraged to direct communication through the Advisor and its IARs. Client should be aware 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 should further be aware that achievement of the stated investment objective is a long-term goal for the account. Item 8: Client Contact with Portfolio Managers In the case of SMA Platform accounts, SMA Portfolio Managers are reasonably available to consult with IARs and clients regarding accounts. Clients may consult directly with the SMA Portfolio Manager, although clients are encouraged to direct contact with SMA Portfolio Manager through Advisor and its IAR. In the case of MP Platform accounts, because the Model Advisor’s role is solely to provide Model Portfolios to LPL, and not to provide individualized discretionary advisory services to MP Platform clients, third party Model Advisors generally are not available to be contacted or consulted by MP Platform clients. 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). MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 16  Manager Select 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: • 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). MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 17  Manager Select Program Brochure • 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, 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). • 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). MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 18  Manager Select Program Brochure • 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 IAR’s VA sales, and an undertaking to review such representative’s brokerage and advisory activities and LPL’s related policies and procedures (MA, 2017). 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/. 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. IARs may be 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, 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 service, 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-Manager Select 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. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 19  Manager Select Program Brochure 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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 In the case of the SMA Platform, LPL, as principal, buys securities from and sells securities to clients in SMA Platform accounts. This practice could put LPL in a position where its own interests are in conflict with clients. However, LPL is not a market maker in securities and does not carry an inventory. In addition, it is the SMA Portfolio Manager (and not LPL) who as investment advisor determines the securities to be traded in the account. It is also the SMA Portfolio Manager who has a duty of best execution in negotiating transactions for clients. When LPL executes trades for an SMA Portfolio Manager in a principal capacity on the SMA Platform, it receives a markup or markdown on the transaction. This means, for example, if LPL sells a security at a price higher than what LPL paid, LPL will earn a markup. Conversely, if LPL buys a security at a price lower than what LPL sells it for, LPL will receive a markdown. The maximum markup or markdown that LPL receives when acting in a principal capacity in a SMA Platform account is $2.00 per bond. In many cases, this maximum does not apply, and the actual markup or markdown is lower, typically $1.00 per bond. Details about a markup or markdown for a particular transaction will be furnished upon request. In the case of the MP Platform, LPL as investment advisor determines the securities to be traded in the account; however, LPL is expected to closely track the Model Portfolio, applying discretion only to address particular account issues, including tax loss harvesting, rebalancing, short-term gain avoidance, cash inflows and outflows, and tracking error from the Model Portfolio, and to ensure that investment restrictions are being followed. 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. Though LPL also processes securities transactions, as broker-dealer, for MP Platform accounts, LPL does not charge commissions. Purchases of mutual fund shares are typically 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 the firm’s use of a proprietary account for the mutual fund purchase. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when: a client is also trading whole shares of the security; in connection with a dividend reinvestment plan; or to sell remaining fractional shares to close a position. Trades in whole and fractional shares typically happen on the same day and will be executed at the same price as a trade in whole shares, or otherwise at market closing price. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. SMA Portfolio Managers are not prevented from purchasing LPL Financial Holdings Inc. stock in Manager Select accounts. In addition, a Manager Select account may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 20  Manager Select Program Brochure investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in Manager Select charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b- 1 fees paid to LPL by mutual funds will be credited to the account. LPL performs recordkeeping, administrative services, and shareholder on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by program clients in the fund (up to $25 per position). 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. SMA Portfolio Managers and Model Providers pay LPL initial diligence and setup fees of up to $5,000 per strategy or Model Portfolio and up to a $5,000 per strategy fee for onboarding and annual due diligence reviews to make their services available in the Program. In the case of ETPs, 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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with Advisors or IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of mutual funds, ETFs, annuities, alternative investment products, and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL representatives so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to 0.15% annually, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for an Account. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 21  Manager Select Program Brochure 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective financial professionals to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with Advisor or the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Model Portfolio in the case of Model Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds , and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with third party SMA Portfolio Managers or Model Advisors, and, therefore, there is no financial incentive for an a SMA Portfolio Manager or Model Advisor to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 22  Manager Select Program Brochure to LPL. LPL also does not share these payments with Advisor. Although LPL does not share recordkeeping fees or revenue sharing payments with Advisor or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisor and IARs, for example by being used by LPL to support marketing or training costs. 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 or the LPL Deposit Cash Account (“DCA”) Program, 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. 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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 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 MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 23  Manager Select Program Brochure 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. • 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 . 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. • 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. This compensation that LPL and Advisor receive related to ICA and DCA (including from any ICA and DCA overflow mechanisms) is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to ICA and DCA 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 or DCA. LPL shares a portion of this compensation with Advisor. However, this compensation LPL receives on ICA and DCA is not shared with SMA Portfolio Managers or Model Advisors. Therefore, this compensation does not cause a SMA Portfolio Manager or Model Advisor to have a financial incentive to recommend that cash be held in the account instead of holding securities. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 24  Manager Select 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, 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. Other Clients Client should understand that SMA Portfolio Managers, Model Advisors, LPL, Advisor and IAR perform advisory and/or brokerage services for various other clients, and that they may give advice or take actions for those other clients that differ from the advice given to the client. The timing or 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. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 25  Manager Select Program Brochure Other Compensation LPL and LPL employees also receive additional compensation from product sponsors, including SMA Portfolio Managers and Model Advisors. Such compensation may not be tied to the sales of any products or services. Compensation may include 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. SMA Portfolio Managers, Model Advisors and other 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, 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 from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 certain advisory programs 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. 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 the Advisers Act and maintains custody of Manager Select 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. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 26  Manager Select Program Brochure Brokerage Practices In the case of the MP Platform, all transactions will be executed through LPL, and Client directs that securities transactions for the Account be initiated through LPL. In the case of the SMA Platform, Client directs SMA Portfolio Managers to execute transactions through LPL, subject to the SMA Portfolio Manager’s duty as an investment advisor to seek to achieve best execution. Clients should understand that an SMA Portfolio Manager may choose to place some or all trades for accounts with broker-dealer firms other than LPL (“trade away” or “step outs”). Some SMA Portfolio Managers have historically placed nearly all client trades with broker-dealer firms other than LPL for execution, in particular, if the SMA Portfolio Manager follows a fixed-income, foreign or small cap investment strategy. In addition, SMA Portfolio Managers may choose to trade away from LPL in order to aggregate all client transactions into one or more larger “block trades” that are executed through one broker-dealer. This practice may enable an SMA Portfolio Manager to obtain more favorable execution, including a more advantageous net price, than would otherwise be available if orders were not aggregated into a single “block trade.” It may also assist the SMA Portfolio Manager in potentially avoiding an adverse effect on the price of a security which could result from simultaneously placing a number of separate, successive or competing client orders. When securities transactions are effected through LPL, there are no brokerage commissions charged to the account. If an SMA Portfolio Manager chooses to execute a transaction through a broker-dealer other than LPL, the execution price will usually include a commission or fee imposed by the executing broker-dealer. Clients should understand that the client will bear any such additional trading cost, in addition to the account fee paid to LPL. The additional expenses charged by the broker-dealer executing the transaction may include commissions, mark-ups, mark-downs or “spreads” paid to executing broker dealer firm. Additionally, if a foreign currency transaction is required, there may be foreign exchange or similar fees, including but not limited to fees for foreign ordinary conversion and creation of American Depositary Receipts (“ADRs”) charged by third parties as well as foreign tax charges. In many cases, the commission, mark-up, mark-down or other additional expenses charged by the executing broker-dealer or third party will be embedded in the purchase or sale price of such transactions, and not separately indicated on trade confirmations and custodial account statements provided by LPL. In evaluating whether to execute a trade through a broker-dealer other than LPL, an SMA Portfolio Manager will consider the fact that an account will not be charged an additional expenses (such as a commission) if effected directly through LPL. 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. Clients should understand that LPL is not able to fully evaluate whether an SMA Portfolio Manager is meeting its best execution obligations to clients for specific transactions when trading away, as it is not a party to such transactions and is not in a position to negotiate the price or transaction related charges with the executing broker. The responsibility to determine whether to trade away lies with the SMA Portfolio Manager and arises out of an SMA Portfolio Manager’s individual fiduciary duty to clients. Additional information regarding equity trading away practices of SMA Portfolio Managers is available on lpl.com/disclosures.html (see “Third-Party Portfolio Manager Trading Practices” under “Market & Trading Disclosures”). Clients should consider whether or not the appointment of LPL as the broker-dealer may or may not result in certain costs or disadvantages as a result of possibly less favorable executions. Clients should understand that not all wrap program sponsors require brokerage to be directed to the sponsor. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution of client transactions. In particular, a client’s Manager Select account may not be able to participate in block trades affected by a SMA Portfolio Manager for its other accounts, which may result in a difference between prices charged to a Manager Select account and SMA Portfolio Manager’s other accounts. For these reasons, directed brokerage may cost clients more money. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 27  Manager Select Program Brochure SMA Portfolio Managers (in the case of SMA Platform Accounts) or LPL may aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. Clients should read and understand the disclosure in Form ADV Part 2 of the applicable SMA Portfolio Manager in the case of SMA Platform accounts. 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 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 contact the Advisor. For more information about the portfolio manager managing the account (i.e., the SMA Manager for an SMA Platform account or LPL for an MP Platform account), client should review the Brochure of the portfolio manager. MS302 – EQH – 0326 LPL Financial, member FINRA/SIPC 28 

Model Wealth Portfolios Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. Item 9 was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 8 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 9 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 17 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 17 Item 9: Additional Information ............................................................................................................................................... 17 A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 1  Model Wealth 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, including Equitable Advisors, LLC (Advisor) (“Equitable Financial Advisors” in MI and TN) and its associated persons. This Brochure provides a description of LPL’s Model Wealth Portfolios (MWP) program when offered through an Advisor. For more information about LPL’s advisory services and programs other than MWP, please contact LPL or your Advisor for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov/. The MWP program is a unified managed account program in which LPL and Advisor provide ongoing investment advice. The Advisor, through its designated investment adviser representative (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 Advisor, or the client with the assistance of the Advisor, selects one or more model portfolios of securities (each, a “Portfolio”) designed by LPL Research, a third party investment strategist or Advisor, through its IAR (each, a “Portfolio Strategist”) consistent with the client’s stated investment objective. These Portfolios may contain mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), closed-end funds, equities or fixed-income securities. The Advisor provides ongoing advice on the selection or replacement of a Portfolio based on the client’s individual needs. The Advisor, or the client with the assistance of the Advisor, may choose more than one Portfolio to be managed within a single MWP account. A Portfolio may be comprised of one or more underlying models. 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 Portfolio Strategist is responsible for selecting the securities within a Portfolio and for making changes to the securities selected. LPL has discretion to buy and sell securities in the account according to the Portfolio selected and liquidate previously purchased securities that are transferred into the account. The client authorizes LPL to have discretion by executing the Account Agreement and Account Application. Except for LPL, the Portfolio Strategists are independent investment advisor firms. Portfolio Strategists provide LPL on an ongoing basis with a Portfolio that includes recommended asset allocations and securities. LPL enters into an agreement with the Portfolio Strategist for these Portfolio services. Except for LPL and Advisor, the Portfolio Strategist does not have discretion from the client to implement the Portfolio and does not provide individualized investment advice to specific program clients. Some third-party investment strategists have entered into subadvisory agreements with LPL to manage, on a discretionary basis, accounts or portions of accounts in the Program allocated to their fixed-income Portfolios (Subadvisers). If Advisor, or a client, chooses to allocate all or a portion of an account to a Portfolio provided by a Subadviser, LPL will delegate some of its responsibilities to the Subadviser, subject at all times to oversight by LPL. Subadvisers will have discretion to make decisions about how to implement their Portfolios, including decisions on purchasing and selling fixed-income securities, executing trades through brokerage firms selected by the Subadviser and rebalancing the assets in the Account allocated to their models, which may occur on a different frequency than as determined by the Overlay Portfolio Manager. Subadvisers have discretion whether to consider state preferences (if client provides to IAR) when selecting from the inventory of bonds, if applicable. Not all states will carry inventory to suffice for a selection. Please note that there is no guaranty that state preference will be considered. The discretion to consider state preferences is not intended as tax advice, and neither LPL nor any Subadviser represents in any manner that implementation of state preferences will achieve tax-advantaged returns. Notwithstanding LPL’s delegation of some of its responsibilities to the Subadviser, LPL will remain responsible for all advisory services provided in the Program. LPL conducts initial and ongoing due diligence of Subadvisers and has the ultimate authority to hire and fire Subadvisers to accounts in the Program, and may terminate a Subadviser’s authority to manage client assets at its discretion. A client who wishes not to engage a Subadviser would be required to select A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 2  Model Wealth Portfolios Program Brochure a different Portfolio. If your Advisor or you choose to invest in a Portfolio provided by a Subadviser, please carefully review the Subadviser’s Form ADV Part 2 Brochure for information on the Subadviser’s investment strategies, risks, brokerage practices and conflicts of interest. LPL acts as the overlay portfolio manager (OPM) in coordinating the trades in the account and performing tax harvesting services. LPL expects to closely track the Portfolios, applying discretion only to address particular account issues, including tax loss harvesting, rebalancing, short-term gain avoidance, cash inflows and outflows, and tracking error from the Portfolio, customized requests, and investment restrictions placed on the account. 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. LPL as the OPM is responsible for rebalancing accounts in accordance with the allocations in the Portfolio. LPL will review an account to determine if rebalancing is appropriate based on the frequency selected by the client at account opening or as altered by the client through Advisor from time to time. The choices for frequency of rebalancing review are quarterly (four times per year), semiannually (two times per year) or annually (once per year). An additional rebalance may be requested outside of the scheduled frequency once every 12 months. At each rebalancing review date, LPL will rebalance the account only if the account has available cash for investment and at least one security position, including cash, is outside a pre-determined range, subject to a minimum transaction amount established by LPL in its discretion. In addition, LPL will review an account for rebalancing in the event that the Portfolio Strategist changes the allocation targets. LPL accommodates reasonable requests to restrict holdings of specific securities, specific industries, specific sectors, and certain pre-defined categories (e.g., “sin” stocks). In the event that client restrictions prevent the investment in certain securities otherwise recommended by a Portfolio Strategist, assets will be invested pro-rata across the remaining securities in the model. Such restrictions do not apply to any mutual funds, ETFs or fixed-income securities that are held in the account. Restrictions placed on an account can affect the performance of the account. The OPM may choose not to accept an account with restrictions that are inconsistent with the investments chosen by the OPM or as recommended by the Portfolio Strategist. LPL, at the request of the Advisor, performs tax harvesting, which may include using the proceeds of tax-related transactions to purchase appropriate securities (such as ETFs or mutual funds) for an account. Client may also request Advisor to initiate tax harvesting with LPL. In such case, proceeds of tax-related transactions may be held in cash or securities until appropriate wash sale periods have expired. Once the wash sale period has expired, the related proceeds will be invested according to the current targeted allocation for the Portfolio. Similarly, LPL may delay a tax harvesting request to sell securities acquired in the previous 30 days until the wash sale period has expired. Under certain conditions, LPL also will accommodate requests for all or a portion of an account to remain allocated to cash for a period of time. In addition to general tax harvesting requests described above, clients may authorize LPL to provide more comprehensive tax overlay services (LPL Tax Overlay Services). If directed by client, LPL will provide LPL Tax Overlay Services to the client’s account. The end objective of LPL Tax Overlay Services is to improve the after-tax return for the client while staying consistent with the investment strategies of the Portfolios. LPL Tax Overlay Services is available only to clients subject to U.S. capital gains tax. LPL does not provide tax planning advice or services. LPL does not represent in any manner that the desired tax objectives will be obtained or that MWP’s investment strategy will result in any particular tax outcome. Clients should discuss any questions with or request further information from their IAR or their tax consultant in using the LPL Tax Overlay Services. LPL charges 0.08% of the value of the account to provide LPL Tax Overlay Services, which it retains from the Advisory Fee, as described under the section titled “Fee Schedule” below. This charge will not be separately indicated on account statements or otherwise. When Advisor recommends discontinuing LPL Tax Overlay Services, Advisor has a conflict of interest since discontinuing this service will increase the portion of the Advisory Fee paid to the Advisor. Clients will be notified when services are discontinued, including a reminder to discuss whether a reduction of the Advisory Fee is appropriate. Please ask your IAR for additional information. In some cases, clients may experience significant performance differences from the selected investment strategy for one or more Portfolios and/or the overall account, due to participation in LPL Tax Overlay Services. If a client chooses A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 3  Model Wealth Portfolios Program Brochure to participate in this service, LPL makes no assurances that the client’s account performance will be within any range of the selected investment strategy or the strategy’s benchmark. A client’s returns will likely differ from, and could be lower than, the Portfolio Strategist’s model when enrolled in Tax Overlay Services. In addition, LPL may manage the client’s account using tools and processes which may result in the client’s trades being executed at a different time or in a different manner than other LPL trades, including the potential to not participate in LPL’s standard trade rotation processes (if such trades would have been otherwise eligible to participate). In connection with the program, LPL also acts as custodian to accounts, provides research information to Advisor, provides brokerage and execution services as the broker-dealer on transactions, and performs administrative services, such as performance reporting to clients. Fee Schedule Clients in the MWP Program pay an annualized fee (Account Fee). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the Advisor or IAR changes the model selected for an account, or if the model investment value changes, the overall Account Fee may increase or decrease. 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, IARs, and Portfolio Strategists do not charge performance-based fees to accounts in the Program. Advisory Fee. The Advisory Fee is charged for the investment advisory services of Advisor, as well as the investment advisory, administrative, trading, custodial and clearing services of LPL. The Advisory Fee is shared with the Advisor. The Advisory Fee is negotiable between the client and Advisor and is based on the value of assets in the account, including cash holdings. The maximum Advisory Fee is 2.35%. Upon request, the Advisory Fee may be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds. LPL retains a portion of the Advisory Fee, up to 0.35% of the value of the account, for its investment advisory, administrative, trading, custodial and clearing services. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Advisory Fee with the Advisor based on the agreement between LPL and Advisor. LPL retains any portion of the Advisory Fee not shared with the Advisor. Manager Fee. Depending upon the model(s) selected for the account, clients pay a Manager Fee set by LPL for the use of each model portfolio. The Manager Fee is based on the value of the assets in the account, including cash holdings, and payable quarterly in advance. This fee ranges from 0% to 0.60%. For Portfolios designed by Portfolio Strategists other than Advisor, LPL pays all or a portion of the Manager Fee to the Portfolio Strategist. For certain models, LPL charges up to 0.05% of model assets per year for the costs and services associated with effecting trades to implement the models, such as order formation, execution, settlement and sleeving of transactions. This LPL fee for trading services is reflected in the Manager Fee on client statements. Generally, LPL charges 0.05% of model assets per year for models transacting primarily in equities, and LPL charges 0.03% of model assets per year for models transacting primarily in fixed income or other over-the-counter securities. For certain models designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL either charges a Manager Fee as Portfolio Strategist or charges a fee for trading services, there is a conflict of interest for LPL to recommend such models. LPL charges the fee for trading services to retirement and nonretirement accounts to the extent permissible under applicable law. Advisor does not receive any portion of the Manager Fee, including based on recommending a model for which LPL charges this compensation. A list of the client’s current model(s) and associated fee rates will be reflected on client account statements or can be requested from Advisor. Please note that if an account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. Clients do not pay LPL or Advisor brokerage commissions or transaction charges for the execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Certain Portfolio Strategists charge a reduced Manager Fee or do not charge a Manager Fee for their models. This is often because the Portfolio Strategist earns a management fee from proprietary or affiliated mutual funds or exchange-traded funds included in the model. This management fee can be found in the prospectuses of the mutual A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 4  Model Wealth Portfolios Program Brochure funds or exchange traded funds included in the model. Because a Portfolio Strategist or their affiliates benefit financially when an affiliated fund is selected, there is a conflict of interest that affects the Portfolio Strategist’s ability to provide unbiased, objective investment advice concerning the selection of funds for a model. If a Portfolio is selected that consists of mutual funds and/or ETFs primarily or only within the same fund family or within affiliated fund families (typically as indicated by the title of the model portfolio), the Portfolio Strategist will select at least a majority of funds within that fund family or affiliated fund families. In such case, because mutual funds or ETFs in a Portfolio are affiliated with a third-party Portfolio Strategist that designs the Portfolio, an investment in the affiliated fund generates compensation to that third-party Portfolio Strategist or its affiliates, including, among other types of compensation, fund-level management fees, in addition to any portion of the Account Fee it receives. The fees paid to Portfolio Strategists are generally less than fees those strategists would charge a client seeking to establish a direct relationship with them outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, marketing and trading expenses that would otherwise be borne by those strategists. Portfolio Strategists generally have higher minimum account size requirements and fees for direct accounts because of such additional expenses. Portfolio Strategist Fee Rate LPL Financial Research 0.00%-0.60% (depending on model) Advisor 0.00% AB* 0.00% Equitable Investment Management* 0.00% PST Advisors** 0.25% * AB and Equitable Investment Management are affiliates of Advisor. “Equitable Investment Management” is the brand name for Equitable Investment Management Group, LLC, which among other things serves as investment advisor to the 1290 Funds. ** PST Advisors is not affiliated with Advisor but certain of its IARs are principals of PST and may be compensated both as a strategist and as a financial professional on the Account. Please note that if the Account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. 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. If the client changes the model selected for the Account, or if the model investment value changes, the overall Account Fee may increase or decrease. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with an MWP account from the account. LPL pays the applicable portion of the Account Fee to the Portfolio Strategists. 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. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 5  Model Wealth Portfolios Program Brochure 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 pro-rated 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 Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative and custodial- related fees and charges that apply to an MWP 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 miscellaneous 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. These fees may be changed by LPL. Other LPL advisory programs and/or other financial services firms separately offer certain models available through the Program, in some cases at a lower overall costs to investors. When the same model is offered in different LPL advisory programs, the difference in cost to clients for use of that model is typically up to five basis points. Advisory programs differ significantly in the overall features and functionalities offered, and an IAR may only recommend a program or service that he or she believes is suitable and in the best interest of a client in accordance with the applicable standards under the Advisers Act. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in MWP accounts. Some of these fees and charges are described below. In MWP, assets are often invested in mutual funds or ETFs 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 fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay the Account Fee with respect to assets invested in mutual funds and ETFs. The mutual funds and ETFs available in the program can be purchased directly outside of the Program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL, Advisor and Portfolio Strategists and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 6  Model Wealth Portfolios Program Brochure If client transfers into an MWP 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 MWP model. 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 Advisor or directly from the fund. When transferring securities into the account, client should be aware that certain securities may 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 MWP 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 Advisor 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. For those Portfolios consisting of mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in MWP charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds will be credited to the client’s account. Certain of the mutual funds available for investment in the program may be affiliated with Advisor. Therefore, investment in an affiliated mutual fund generates additional compensation to the Advisor’s affiliates, including, among other types of compensation, fund-level management fees. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on a MWP Account • The Account Fee is a wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. Clients do not pay a commission or transaction charge to LPL for the execution of transactions in the account. 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: – type and size of the account A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 7  Model Wealth Portfolios Program Brochure – type of securities in the Portfolio (whether mutual funds, ETFs, equities, or fixed income) – 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 fee set out above. The Advisor is responsible for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, the number, complexity and mix of the portfolio, and the 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 Advisory Fee with Advisor. • Because Advisor and a Portfolio Strategist may be affiliated as described in Item 6 below, Advisor can have a financial incentive to recommend model portfolios designed by its affiliate because it will result in additional compensation to Advisor’s affiliate. • 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 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 MWP 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 can 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 MWP account, through broker-dealers or other investment firms not affiliated with 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 requires a minimum asset value for a program account to be managed. The minimums vary depending on the Portfolio(s) selected and the account’s allocation amongst Portfolios. The lowest minimum for a Portfolio is $10,000. In certain instances, LPL will permit a lower minimum for a Portfolio. Note that an account will not be invested according to a Portfolio or Portfolios until the applicable minimum for the Portfolio(s) and allocation has been reached. Clients should consult with Advisor and IAR to obtain more information about the applicable investment minimum based on the Portfolio(s) selected and the allocation amongst Portfolios. The program is available for individuals, individual retirement account (“IRAs”), banks and thrift institutions, credit unions, pension and profit-sharing plans, including plans subject to ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 8  Model Wealth Portfolios Program Brochure Item 6: Portfolio Manager Selection and Evaluation In MWP, LPL and Advisor are responsible for the overall investment advice and management services offered to clients, and the client selects the Advisor. 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. LPL makes available Portfolios designed by LPL, third party Portfolio Strategists and Advisor, through its IAR, for a particular account. Except as set forth below for AB, Equitable Investment Management and PST Advisors, LPL reviews on a periodic basis Advisor, acting through its IAR, as Portfolio Strategist on MWP. In addition, LPL selects and reviews on a periodic basis the third-party Portfolio Strategists available on MWP. LPL uses information provided by the third-party Portfolio Strategist and also may use independent, third-party data sources when evaluating such Portfolio Strategist. Third party Portfolio Strategist performance information is not calculated on a uniform and consistent basis. LPL does not review performance information to determine or verify its accuracy and does not calculate third party Portfolio Strategist performance. However, LPL provides Advisor and clients with individual performance information. Performance information distributed by LPL is compiled using third party portfolio accounting and reporting software. Client performance information is calculated on a uniform and consistent basis using a time weighted basis. Performance information is intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to investment indices. When MWP is offered through Advisor, there are Portfolios available that are designed by AB (f/k/a Alliance Bernstein), Equitable Investment Management and PST Advisors, in addition to those designed by LPL and Portfolio Strategists that are selected and reviewed by LPL. AB and Equitable Investment Management are investment advisor firms affiliated with Advisor. “Equitable Investment Management” is the brand name for Equitable Investment Management Group, LLC, which among other things serves as investment advisor to the 1290 Funds. PST Advisors is not affiliated with Advisor; however, associated persons of PST Advisors are also investment adviser representatives and/or registered representatives of Advisor. AB, Equitable Investment Management and PST Advisors are referred to herein as “Equitable Strategists.” In the case of the Equitable Investment Management and PST Advisors Portfolios, clients should understand that such Portfolios are made available at the request of Advisor, that Advisor is responsible for the inclusion of these Equitable Strategists, and that LPL has not applied its standard selection criteria to Equitable Investment Management or PST Advisors and their Portfolios, as it does for other third party Portfolio Strategists. Because Advisor is affiliated with Equitable Investment Management and AB, Advisor has a financial incentive to recommend Equitable Investment Management and AB Portfolios because it will result in additional compensation to Advisor’s affiliate. Because associated persons of PST Advisors are also associated with Advisor, Advisor’s associated persons similarly have a financial incentive to recommend a PST Advisors Portfolio. LPL is not recommending any particular Equitable Strategist or Portfolio, and client’s selection of any Equitable Strategist or Portfolio should be the client’s independent decision arrived at in consultation with Advisor. It is important to note that third party Portfolio Strategists provide the Portfolios to LPL, and it is LPL that has discretion for trade implementation and execution in MWP accounts. Therefore, Portfolios submitted to LPL by third party Portfolio Strategists may represent activity that has already been implemented on behalf of other clients of such Portfolio Strategists. Because of this fact and because LPL (and not the third-party Portfolio Strategist) has discretionary authority to implement trades, performance of an MWP account will differ from the performance of such Portfolio Strategist’s discretionary accounts. LPL as a Portfolio Strategist In MWP, clients may invest in Portfolios designed by LPL Research. LPL’s LPL Research designs many types of mutual fund, ETF, fixed-income and equity Portfolios to meet the varying needs of clients. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 9  Model Wealth Portfolios Program Brochure LPL Research designs different types of Portfolios for different timeframes, needs or themes that have meaning to investors. LPL Research generally designates Portfolios as either strategic or tactical model styles. The allocations in strategic Portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout a 3 to 5 year timeframe and are intended for investors who take a longer term view or who are more tax sensitive. Tactical Portfolios are more flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of more frequent trading. Within the strategic and tactical model styles, LPL Research focuses each model on an investment theme or objective. For example, LPL Research designs alpha-focused Portfolios that are structured for more aggressive investors. There are also downside risk aware Portfolios that are intended to be structured more conservatively to help provide more protection in the event of a down market. LPL Research designs portfolios that are largely allocated to alternative strategies to provide diversified exposure to those more esoteric asset classes. LPL Research also designs Portfolios intended for investors who place a priority on income generation and Portfolios for investors seeking to minimize tax impacts. Such income generation Portfolios are also available in investment objectives that are not typically focused on income. Additionally, LPL Research designs portfolios intended for investors who want to invest primarily with certain mutual fund or ETF families. There are also Portfolios that emphasize socially responsible investing and sustainability. LPL Research also designs portfolios that follow a “direct indexing” strategy, or a strategy that seeks to replicate a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the market index. In a direct indexing strategy, LPL Research partners with an index provider to license an index and pays a portion of the Manager Fee to the index provider. For a complete list of the current models provided by LPL Research, please discuss with your Advisor or IAR. The participation of LPL Research as a Portfolio Strategist gives rise to conflicts of interests. For certain LPL Research model portfolios, LPL charges clients a Manager Fee. In addition, LPL has a financial incentive to select its internal team and further grow its assets under management, in part because as assets under management at LPL increase, LPL is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. However, LPL does not share the Manager Fee with Advisor. Advisor, through its IAR, as Portfolio Strategist In addition to portfolios designed by LPL Research and third party Portfolio Strategists, clients can invest in portfolios managed by Advisor, through its IAR for their account. Advisor, through its IAR, is responsible for selecting the mutual funds, ETFs, ETNs, closed-end funds, equities or fixed-income securities within a Portfolio, the asset allocation for the Portfolio, and for making changes to the funds selected and asset allocation over time. Advisor, through its IAR, will typically manage Portfolios tailored to an investment theme or particular style that is core to the IAR’s beliefs and expertise. Advisor, through its IAR, chooses research methods, investment strategy and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Advisor has access to various research reports, including those provided by LPL Research, to which IAR may refer in determining which securities to purchase or sell. As OPM, LPL has discretion to buy and sell securities in the Account (according to the Portfolio selected) and to liquidate previously purchased securities that are transferred into the Account. LPL expects to closely track the Portfolios, applying discretion only to address particular account issues, including tax rebalancing, loss harvesting, tracking error from the Portfolio, customized requests, and investment restrictions placed on the account. 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. Types of Investments and Risks The Portfolios may include different types of securities, such as mutual funds, ETFs, ETNs, closed-end funds, equities and fixed-income securities. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that are available in the program. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 10  Model Wealth Portfolios Program Brochure • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • 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. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 11  Model Wealth Portfolios Program Brochure • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 12  Model Wealth Portfolios Program Brochure the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and Advisor generally will earn more compensation for selling one investment product than another. As a result, LPL and Advisor have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. • Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End Funds. Client should be aware that closed-end funds available within the program may not be readily marketable. In an effort to provide investor liquidity, the funds may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, clients may be unable to liquidate all or a portion of their shares in these types of funds. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 13  Model Wealth Portfolios Program Brochure • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (Single Inverse ETPs), futures-linked ETPs (Futures Linked ETPs) and cryptocurrency-related ETPs (Cryptocurrency ETPs). A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 14  Model Wealth Portfolios Program Brochure Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • 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 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 in accordance with the terms of the lending arrangement, 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, A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 15  Model Wealth Portfolios Program Brochure Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” • Tax-Loss Harvesting. The tax-loss harvesting feature of MWP involves a variety of risks. You should confer with your personal tax advisor regarding the tax consequences of investing and engaging in the tax-loss harvesting strategy, based on your particular circumstances. You and your personal tax advisors are responsible for how the transactions in your account are reported to the IRS or any other taxing authority. Neither LPL nor Advisor assumes any responsibility to you for the tax consequences of any transaction. MWP’s tax-loss harvesting strategy is not intended as tax advice, and neither LPL nor Advisor represents in any manner that the tax consequences described will be obtained or that MWP’s investment strategy will result in any particular tax consequence. The tax consequences of this strategy are complex and may be subject to challenge by the IRS. This strategy was not developed to be used by, and it cannot be used by, any investor to avoid penalties or interest. You should be aware that if you and/or your spouse have other taxable or non-taxable accounts, and you hold in those accounts any of the securities (including options contracts) held in your MWP account, you cannot trade any of those securities 30 days before or after the MWP account trades those same securities as part of the tax-loss harvesting strategy to avoid possible wash sales and, as a result, a nullification of any tax benefits of the strategy. For more information on the wash sale rule, please read IRS Publication 550. In addition, when LPL replaces investments with “similar” investments as part of the tax-loss harvesting strategy, it is a reference to investments that are expected, but are not guaranteed, to perform similarly and that might lower an investor’s tax bill while maintaining a similar expected risk and return on investor’s portfolio. Expected returns and risk characteristics are no guarantee of actual performance. Voting Client Securities Unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of the Portfolio Strategist without reviewing individual client interests, unless LPL determines that such instructions are overtly contrary to our clients’ best interest. In such case, LPL will determine whether or how to act consist with the best interest of our clients. LPL and Advisor are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the account, or the issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the account. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 16  Model Wealth 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 objective or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Because the third party Portfolio Strategist’s role is limited to providing Portfolios to LPL, and does not provide individualized discretionary advisory services to MWP clients, LPL generally does not communicate specific client information to third party Portfolio Strategists. 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 model in the account, 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 client’s ability to contact and consult with Advisor or LPL. Because a third party Portfolio Strategist’s role is solely to provide Portfolios to LPL, and not to provide individualized discretionary advisory services to MWP clients, third party Portfolio Strategists generally are not available to be contacted or consulted by MWP clients. 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 A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 17  Model Wealth Portfolios Program Brochure 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: • 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). A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 18  Model Wealth Portfolios Program Brochure • 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, 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). • 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). For more information about those state events and other disciplinary and legal events involving LPL and its IARs, client should refer to Investment Advisor Public Disclosure at https://adviserinfo.sec.gov/ or FINRA BrokerCheck at https://brokercheck.finra.org. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 19  Model Wealth 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. IARs may be broker-dealer 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. PTC also provides personal trustee services to clients for a variety of administrative fiduciary service, 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 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-MWP 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 advisor 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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 the firm’s proprietary account resulting in such purchases being characterized as principal transactions for certain reporting purposes. In every case, the shares will be purchase A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 20  Model Wealth Portfolios Program Brochure at the funds’ net asset value, and no additional charges will be applied to such transactions as a result of the firm’s use of a proprietary account. LPL does not otherwise engage in principal transactions with its clients in MWP. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. Third-party Portfolio Strategists are not prevented from purchasing LPL Financial Holdings Inc. stock in MWP accounts. In addition, a model may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in MWP charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds will be credited to the account. LPL performs recordkeeping, administrative services and shareholder on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of MWP clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of MWP client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by MWP clients in the fund (up to $25 per position). 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. Portfolio Strategists pay LPL initial diligence and setup fees of up to $5,000 per strategy or model portfolio and up to a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance to make their services available in the Program. 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 exchange-traded products 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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with Advisor or IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (sponsors) of mutual funds and ETFs that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 21  Model Wealth Portfolios Program Brochure a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL representatives so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to 0.15% annually of LPL clients’ investments in the investment product, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective financial professionals to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with Advisor or the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 22  Model Wealth Portfolios Program Brochure products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds, and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with Advisor or third party Portfolio Strategists, and, therefore, there is no financial incentive for Advisor or a third party Portfolio Strategist to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments with Advisor or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisor and IARs, for example by being used by LPL to support marketing or training costs. 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 or the LPL Deposit Cash Account (“DCA”) Program, 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 IC or, DCA disclosure booklet. 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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 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. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 23  Model Wealth Portfolios Program Brochure • 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. • 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. 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. • 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 A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 24  Model Wealth Portfolios Program Brochure 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. The compensation that LPL and Advisor receive related to the ICA and DCA (including from overflow mechanisms) is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to the ICA and DCA 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 or DCA. However, Portfolio Strategists do not share in this compensation and therefore an unaffiliated Portfolio Strategist does not have a financial incentive to allocate a Portfolio to cash instead of other holdings. In addition, LPL and Advisor do not take into account this compensation when it makes decisions about 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, as well as 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 IAR 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 and 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, they 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. 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. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 25  Model Wealth Portfolios Program Brochure 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 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 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 as an unaffiliated Portfolio Strategist. Such compensation may not be tied to the sales of any products or services. Compensation may include 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, 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 from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 sales employees have an incentive to promote MWP to IARs of Advisor over other advisory programs. These employees also earn more compensation with 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. In the event a trade error occurs in an 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. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 26  Model Wealth Portfolios Program Brochure LPL and BlackRock Advisors, LLC (“BlackRock”) entered into an agreement pursuant to which BlackRock agreed to pay LPL an annual fixed amount for analytical data pertaining to BlackRock proprietary ETFs on LPL’s platform during the term of the agreement. BlackRock Investment Management, LLC, an affiliate of BlackRock, is one of the Portfolio Strategists available on the program. BlackRock is also affiliated with mutual funds and ETFs that may be included in the Portfolios it designs and those model portfolios designed by LPL or the other Portfolio Strategists. Because LPL benefits from these payments, the amount of which is significant, LPL’s financial interests conflict with its ability to use strictly objective factors in making the selection and retention of a BlackRock affiliate as a Portfolio Strategist and its selection of ETFs in its Portfolios. However, LPL did not agree to guarantee that BlackRock’s affiliated Portfolios will be used for any MWP client account. In addition, neither LPL nor the other Portfolio Strategists are required to include BlackRock-affiliated funds or ETFs in their Portfolios. The BlackRock affiliate is required to satisfy the same review as all other third party Portfolio Strategists. LPL has sole discretion to select Portfolio Strategists that are made available on MWP. Financial Information and Custody LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody of MWP 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 MWP, 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. The fact that LPL is both the investment advisor and 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission or transaction charge for executing transactions in MWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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 to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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. Subadvisers who have discretion to trade fixed income Portfolios for clients may choose to place some or all trades for accounts with broker-dealer firms other than LPL (“trade away” or “step out”). This practice may enable a Subadviser to obtain more favorable execution, including a more advantageous net price, than would otherwise be available. If a Subadviser chooses to execute a transaction through a broker-dealer other than LPL, the execution price will usually include fees or expenses imposed by the executing broker-dealer, which the client will bear, in addition to the account fee paid to LPL. The additional expenses charged by the broker-dealer executing the transaction include mark-ups, mark-downs or “spreads” paid to the executing broker dealer firm, which are typically embedded in the purchase or sale price of such transactions, and not separately indicated on trade confirmations and custodial account statements provided by LPL. In evaluating whether to execute a trade through a broker-dealer other A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 27  Model Wealth Portfolios Program Brochure than LPL, a Subadviser will consider the fact that an account will not be charged additional trading expenses if effected directly through LPL. Clients should understand that LPL is not able to fully evaluate whether a Subadviser is meeting its best execution obligations to clients for specific transactions when trading away, as it is not a party to trading away transactions and is not in a position to negotiate the price or transaction related charges with the executing broker. The responsibility to determine whether to trade away lies with the Subadviser and is subject to the Subadviser’s fiduciary duty to clients. 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, 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 or contact the Advisor. A11 – EQH – 0326 LPL Financial, member FINRA/SIPC 28 

Optimum Market Portfolios (OMP) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. 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. Item 9 was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 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 ..................................................................................................................... 9 Item 9: Additional Information ................................................................................................................................................. 9 A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 1  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 Research 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 Account Fee and/or Manager Fee range(s) upon A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 2  Optimum Market Portfolios Program Brochure 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). 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 A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 3  Optimum Market Portfolios Program Brochure 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. 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 • 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: – type and size of the account A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 4  Optimum Market Portfolios Program Brochure – 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 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. A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 5  Optimum Market Portfolios Program Brochure In OMP, clients invest in Portfolios designed by LPL Research. 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 Research 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 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 A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 6  Optimum Market Portfolios Program Brochure 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 in accordance with the terms of the lending arrangement, 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.” • 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 A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 7  Optimum Market Portfolios Program Brochure 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. 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. 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. A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 8  Optimum Market Portfolios Program Brochure 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: • 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). A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 9  Optimum Market Portfolios Program Brochure • 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, 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). • 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 A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 10  Optimum Market Portfolios Program Brochure 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). 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/. 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. A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 11  Optimum Market Portfolios Program Brochure 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 Research 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 Research. In addition, employees in LPL Research 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 A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 12  Optimum Market Portfolios Program Brochure 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. 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 or the LPL Deposit Cash Account (DCA) Program 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 IARs 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. 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA have been both lower and higher than the aggregate fees and charges received by LPL. A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 13  Optimum Market Portfolios Program Brochure 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 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. 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. A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 14  Optimum Market Portfolios Program Brochure • 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. The compensation that LPL and Advisor receive related to the ICA and the DCA (including from any overflow mechanisms) is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to the ICA and the DCA 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 or the DCA. 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. A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 15  Optimum Market Portfolios Program Brochure 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. 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 receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 16  Optimum Market Portfolios Program Brochure 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. 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. A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 17  Optimum Market Portfolios Program Brochure 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. A12 – EQH – 0326 LPL Financial, member FINRA/SIPC 18 

Personal Wealth Portfolios (PWP) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This wrap 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 31, 2025. Item 9 was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 6 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 6 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 14 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 15 Item 9: Additional Information ............................................................................................................................................... 15 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 1  Personal Wealth 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 Personal Wealth Portfolios (PWP) program when offered through an Advisor. For more information about LPL’s advisory services and programs other than PWP, 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 PWP program is a unified managed account program in which LPL and Advisor provide ongoing investment advice and management. In PWP, clients invest in asset allocation portfolios (Portfolios) designed by LPL’s Research Department (LPL Research), which include a combination of mutual funds, exchange-traded funds (ETFs) and investment models (Models) provided to LPL by third party money managers (PWP Advisors). The Models typically consist of equity and fixed income securities, but may include investment company securities. LPL Research selects the mutual funds, ETFs and Models to be made available in a Portfolio. 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, or client with the assistance of the Advisor, selects a Portfolio based on client’s investment objective and then selects among the mutual funds, ETFs and/or Models available in the Portfolio. If client authorizes Advisor to take discretion to make such selections on client’s behalf, the discretionary authority will be set out in the Account Agreement and Application signed by the client. LPL has discretionary authority to purchase and sell securities in the account. The client authorizes LPL to take discretion by executing the Account Agreement and Application. LPL acts as the overlay portfolio manager (OPM) in coordinating the trades among the various securities and sleeves of a PWP account. After a PWP account is opened, and upon deposit of funds by the client, LPL will invest the client’s funds based on the Portfolio selected. It generally will take up to 5 business days from the date the account is fully funded for all assets to be fully allocated across the Portfolio. In certain cases, it may take longer to allocate assets to fixed income securities because of market conditions or the illiquid nature of certain issues. In the case of municipal security Models (Muni Models), it typically can take between 30 to 90 days for the Model to be fully invested. Subsequent deposits accumulate and will not be invested in the Portfolio until certain conditions are met, including conditions related to trade size and position deviation from the target allocation. During the normal course of business, LPL reviews accounts on a daily basis and executes trades as needed. In addition, each year on the anniversary date of the initial account asset allocation, LPL will examine if any particular asset class in an account has drifted beyond a tolerance limit and determine if the account should be rebalanced to be within acceptable asset allocation tolerances. Except as described below for Muni Models, the role of the PWP Advisors is limited to submitting Models to LPL, who has discretion as OPM for trade execution. However, if a Portfolio is selected that includes a Muni Model, the PWP Advisor for that Model will have discretionary trading authority with respect to the purchase and sale of fixed income securities for the portion of the account invested according to the Muni Model (Muni Sleeve). Although the PWP Advisor has discretion over the Muni Sleeve, LPL has ultimate discretion over the entire account and may exercise discretion over securities in the Muni Sleeve (e.g., to rebalance the Account or to liquidate securities for withdrawal requests). LPL may appoint from time to time other PWP Advisors to take discretion over a portion of the account managed according to that PWP Advisor’s Model. 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 quarterly performance reporting to clients. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 2  Personal Wealth Portfolios Program Brochure Fee Schedule Clients in the PWP program pay LPL an annualized fee (the “Account Fee”). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the Advisor changes the PWP Advisor, investment strategy, or model portfolio selected for an account, or if the investment value of the account changes, the overall Account Fee may increase or decrease. 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, IARs and PWP Advisors do not charge performance-based fees to accounts in the PWP program. Advisory Fee. The Advisory Fee is charged for the investment advisory services of Advisor, as well as the investment advisory, administrative, trading, custodial and clearing services of LPL. The Advisory Fee is shared with Advisor. The Advisory Fee is negotiable between the client and the Advisor and is based on the value of assets in the account, including cash holdings, and is payable quarterly in advance. The maximum Advisory Fee is 2.35%. LPL retains a portion of the Advisory Fee, up to 0.675% of the value of the account for its administrative, custody and clearing services, and the portfolio design services of LPL Research. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Advisory Fee with the Advisor based on the agreement between LPL and the Advisor. LPL retains any portion of the Advisory Fee not shared with the Advisor. Manager Fee. Depending on the PWP Advisor selected, clients pay a Manager Fee for a PWP Advisor that is set by the PWP Advisor. The Manager Fee will differ depending on the PWP Advisor selected for the Account and may also differ depending on which investment strategy or model portfolio is selected. Clients do not pay LPL or Advisor brokerage commissions or transaction charges for the execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” The Manager Fee is based on the value of the assets in the Portfolio advised by the PWP Advisor, including cash holdings, and payable quarterly in advance. The Manager Fee currently ranges from 0.15% to 0.60%. For certain models designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL retains portions of the Manager Fee for trading services, there is a conflict of interest for us to recommend such models. The Advisor does not receive any portion of the Manager Fee, including based on recommending a model for which LPL retains this compensation. Please note that if the Account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. The fees paid by LPL to PWP Advisors in the program out of the Manager Fee are generally less than a PWP Advisor would charge a client seeking to establish a direct relationship outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, trading and marketing expenses that would otherwise be borne by the PWP Advisor and the role of the PWP Advisor is generally limited to providing models to LPL. PWP Advisors generally have higher minimum account size requirements when managing direct accounts and higher fees when the PWP Advisor bears those expenses. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a PWP account from the account. LPL pays the applicable portion of the Account Fee to the PWP Advisors whose models are selected for 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 pro-rated 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 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 3  Personal Wealth Portfolios Program Brochure 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 Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that may apply to a PWP account. LPL notifies clients of these charges at account opening and makes available a current list of these charges at lpl.com/disclosures.html. These miscellaneous 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 will be lowered or waived for certain clients. Clients do not pay LPL brokerage commissions, markups or transaction charges for execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in PWP accounts. Some of these fees and charges are described below. In PWP, assets may be invested in mutual funds or ETFs 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 fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that may vary depending on the performance of the fund. Client also will pay the Account Fee with respect to assets invested in ETFs and mutual funds. The mutual funds and ETFs available in the program 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, the PWP Advisors and Advisor, and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” If client transfers into a PWP 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 PWP model. 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. When transferring securities into a PWP account, client should be aware that certain securities may not be eligible for the account. In such case, the securities may be rejected, sold after the transfer, or moved to a brokerage account. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 4  Personal Wealth Portfolios Program Brochure 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 a PWP 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 Advisor or 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. For those Portfolios consisting of mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in PWP charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds will be credited to the client’s account. Certain of the mutual funds available for investment in the program may be affiliated with Advisor. Therefore, investment in an affiliated mutual fund generates additional compensation to the Advisor’s affiliates, including, among other types of compensation, fund-level management fees. A PWP Advisor available in the program may be affiliated with an Advisor. As a consequence, selection of an affiliated PWP Advisor generates additional compensation to Advisor’s affiliates. As described below under “Additional Information – Brokerage Practices,” if a PWP Advisor for a Muni Model chooses to execute a transaction through a broker-dealer other than LPL, the execution price to the client may include a commission, markup/markdown, or other fee imposed by the executing broker-dealer in addition to the Account Fee. If client holds an American Depositary Receipt (ADR) in an account, there may be custodial fees or taxes related to the ADR. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Wrap Fees on a PWP Account: • The Account Fee is an ongoing fee for investment advisory services, the execution of transactions and other administrative and custodial services. The Account Fee may cost the client more than purchasing the program services separately, for example, paying a separate advisory fee for each of the services of LPL, Advisor and the PWP Advisor, 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: – type and size of the account – type and number of securities in the Portfolio (whether equities, fixed income securities, mutual funds or ETFs) – 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 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 5  Personal Wealth Portfolios Program Brochure for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, and the 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 Advisory 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 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 PWP 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. • Some of the investment products available to be purchased in the program can be purchased by clients outside of a PWP account, through broker-dealers or other investment firms not affiliated with 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 $250,000. In certain instances, LPL will permit a lower minimum account size. An account will not be invested according to the Portfolio until the minimum account size and the targeted funding value of the account 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 ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. Item 6: Portfolio Manager Selection and Evaluation In PWP, LPL and Advisor are responsible for the overall investment advice and management services 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. LPL makes available Models designed by PWP Advisors. LPL selects and reviews on an ongoing basis the PWP Advisors available on PWP based on quantitative, qualitative and infrastructure criteria, which may include: Quantitative Criteria LPL evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style group, including but not limited to: A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 6  Personal Wealth Portfolios Program Brochure • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Quantitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP Advisor can handle operational requirements including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable • Back office review • Client servicing resources • Firm-wide program commitment LPL reviews PWP Advisors currently participating in the program and reviews new PWP Advisors prior to the addition of their Models to the program. LPL may elect to remove a PWP Advisor should it determine that the PWP Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in management staff). In making a decision to remove a PWP Advisor, LPL Research takes into consideration all criteria; no one criteria is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove a PWP Advisor. PWP Advisor Performance LPL Research uses information provided by the PWP Advisor and also may use independent, third-party databases when evaluating a PWP Advisor. In order for a PWP Advisor to be selected for the program, LPL generally requires a third-party verification letter related to compliance of the PWP Advisor’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performance. However, LPL provides Advisor and clients with individual performance information. Performance information distributed by LPL is compiled using third party accounting and reporting software. Client performance information is calculated by LPL on a uniform and consistent basis using a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that PWP Advisors provide Models to LPL, and, except in the case of Muni Models, LPL is the party with discretion for trade implementation and execution in PWP accounts. Therefore, Models submitted to LPL by PWP Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisor. Because of this fact and because LPL (and not the PWP Advisor) has discretionary authority to implement trades, performance of a PWP account will differ from the performance of PWP Advisor’s discretionary accounts. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 7  Personal Wealth Portfolios Program Brochure LPL Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL Research. LPL Research provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap programs, Manager Select and Manager Access Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The Advisor, or the client with the assistance of Advisor, selects the Portfolio and provides advice based on the client’s individual needs. LPL Research uses various investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL Research determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the Advisor of the change in status and provide alternatives for the account from which the Advisor, or the client with the assistance of the Advisor, will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. Types of Investments and Risks The Portfolios may include different types of securities, such as mutual funds, closed end funds, ETFs, ETNs, and equity and fixed income securities. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • 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. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 8  Personal Wealth Portfolios Program Brochure • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or unit investment trusts. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 9  Personal Wealth Portfolios Program Brochure varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Closed-End Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax-managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 10  Personal Wealth Portfolios Program Brochure allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products ("ETPs”). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), futures-linked ETPs (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the- counter markets and may not be afforded all of the investor protections of other ETPs. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • 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 in accordance with the terms of the lending arrangement, 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 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 11  Personal Wealth Portfolios Program Brochure 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.” • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • 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. inaccuracies or errors could have adverse • 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 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. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • 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 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 12  Personal Wealth Portfolios Program Brochure 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and Advisor generally will earn more compensation for selling one investment product than another. As a result, LPL and Advisor have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. LPL’s Overlay Portfolio Management Services As OPM, LPL provides advisory services tailored to the individual needs of the clients. LPL reviews accounts on a daily basis for rebalancing. LPL accommodates reasonable requests to restrict holdings of specific securities, specific industries, specific sectors, and certain pre-defined categories (e.g., “sin” stocks). In the event that client restrictions prevent the investment in certain securities otherwise recommended by a PWP Advisor, assets will be invested pro- rata across the remaining securities in the Model. Such restrictions do not apply to any mutual funds, ETFs or fixed- income securities that may be held in the account. Restrictions placed on an account may affect the performance of the account. The OPM may choose not to accept an account with restrictions that are inconsistent with the investments chosen by the OPM or as recommended by the PWP Advisor. LPL accommodates requests to perform tax harvesting, which may include using the proceeds of tax-related transactions to purchase appropriate securities (such as ETFs) for an account. In such case, proceeds of tax-related transactions may be held in cash or securities until appropriate wash sale periods have expired. Once the wash sale period has expired, the related proceeds will be invested according to the Portfolio selected. Similarly, LPL may delay a tax harvesting request to sell securities acquired in the previous 30 days until the wash sale period has expired. In certain circumstances, LPL also accommodates requests for all or a portion of the account to remain allocated to cash for a period of time. After the expiration of that time period, LPL will reinvest the Account according to the model portfolio selected. Such customized requests and changes to and withdrawals from the Portfolios selected may take up to 5 days to process, and, in certain circumstances, may take longer. As LPL generally has discretion to implement a Model, an account’s holdings may differ from the Model submitted. For example, LPL may limit small trades (defined by minimum dollar amounts, share amounts, percentage of account, or percentage of individual asset class). In addition, due to market conditions or the illiquid nature of certain issues, there may be times when LPL will not be able to invest in specific taxable fixed income securities that appear in a Model. In those circumstances LPL will attempt to invest in fixed income securities with similar characteristics as those in the Models. For clients in California and New York, if tax-free fixed income securities are selected for a Muni Model, the PWP A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 13  Personal Wealth Portfolios Program Brochure Advisor will attempt to limit the fixed income securities purchased to state-specific, tax free fixed income securities; however, the PWP Advisor may also include non-state-specific securities. Voting Client Securities Unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures to in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. A copy of LPL’s proxy voting policies is available upon request to LPL through Advisor. A client may obtain information about how LPL voted with respect to securities held in the client’s account by contacting LPL through 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of the PWP Advisors without reviewing individual client interests, unless LPL determines that such instructions are overtly contrary to our client’s best interest. In such case, LPL will determine whether or how to act consistent with the best interests of our clients. LPL, Advisor and the PWP Advisors are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the account, or the issuers thereof. The client retains the right and obligation 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 an appropriate investment objective 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. Because the PWP Advisor’s role generally is limited to providing Models to LPL, and the PWP Advisor does not provide individualized discretionary advisory services to PWP clients, LPL generally does not communicate specific client information to PWP Advisors. However, in the case of PWP Advisors for the Muni Models, the PWP Advisor does provide individualized discretionary advisory services with respect to the Muni Sleeve. If a Muni Model is selected, LPL forwards client information from the Account Application to the PWP Advisor. If client communicates to the Advisor regarding material changes in the client’s financial circumstances, investment objectives or investment restrictions, such information is forwarded to the PWP Advisor for the Muni Model. Clients may communicate such information to the Advisor or otherwise communicate directly with the PWP Advisor, although clients are encouraged to direct communication through their Advisor. 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 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 14  Personal Wealth Portfolios Program Brochure 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. Because the PWP Advisor’s role generally is limited to providing Models to LPL, and the PWP Advisor does not provide individualized discretionary advisory services to PWP clients, PWP Advisors generally are not available to be contacted or consulted by PWP clients. However, in the case of PWP Advisors for the Muni Models, the PWP Advisor does provide individualized discretionary advisory services with respect to the Muni Sleeve. If a Muni Model is selected, clients may consult directly with the PWP Advisor, although clients are encouraged to direct contact with the PWP Advisor through OPM or their Advisor. 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). A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 15  Personal Wealth Portfolios Program Brochure LPL, as a broker-dealer, is a member of FINRA and was 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, 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). A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 16  Personal Wealth 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). 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/. 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 investment adviser representatives 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. 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 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 17  Personal Wealth Portfolios Program Brochure 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-PWP 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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. PWP Advisors are not prevented from purchasing LPL Financial Holdings Inc. stock in PWP accounts. In addition, a PWP account may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 18  Personal Wealth Portfolios Program Brochure 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in PWP charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by PWP clients in the fund (up to $25 per position). 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 ETPs, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per fund and up to $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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with Advisor or IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (sponsors) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL representatives so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to 0.15% annually, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 19  Personal Wealth Portfolios Program Brochure LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the Advisor or IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from LPL’s receipt of 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the fund or Program Share Class offered through the program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds, and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with Advisor or PWP Advisors, and, therefore, there is no financial incentive for Advisor or a PWP Advisor to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments with Advisor or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisor and IARs, for example by being used by LPL to support marketing or training costs. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 20  Personal Wealth 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 , 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 IARs 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. 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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 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. 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 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 21  Personal Wealth Portfolios Program Brochure 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. • 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. The compensation that LPL and Advisor receive related to the ICA and DCA (including from any overflow mechanisms) is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to the ICA and DCA 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 or DCA . 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. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 22  Personal Wealth Portfolios Program Brochure 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. 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 performance information available upon request. In addition, LPL sends 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 PWP Advisors reimburse LPL for costs associated with the use of technology necessary for a PWP Advisor to perform its services under the program. LPL and LPL employees also receive additional compensation from product sponsors, including a PWP Advisor or its affiliate. Such compensation may not be tied to the sales of any products or services. Compensation may include 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 A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 23  Personal Wealth Portfolios Program Brochure 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 from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 sales employees have an incentive to promote PWP 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 balance. In such cases, LPL receives compensation in the form of earnings on cash. 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 the Advisers Act and maintains custody of PWP 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 PWP, LPL requires that clients direct LPL as broker-dealer to execute transactions in the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. The fact that LPL is both the investment advisor and 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission for executing transactions in PWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 24  Personal Wealth Portfolios Program Brochure 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 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. If a Portfolio is selected that includes a Muni Model, the PWP Advisor will have discretion to purchase and sell securities in the Muni Sleeve of the account. In connection with its duty to seek to achieve best execution, the PWP Adviser may choose to execute transactions through a broker-dealer other than LPL. In such case, the execution price may include a commission, markup or markdown, or other charges in addition to the Account Fee. Clients should read and understand the brokerage practices and other disclosures in the Firm Brochure of the PWP Advisor for the Muni Model. LPL will aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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 affect 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. 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 Advisers Act. 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 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 contact the Advisor. A9 – EQH – 0326 LPL Financial, member FINRA/SIPC 25 

Strategic Asset Management (SAM) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. Item 11 was updated was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts. Item 12 was updated to include additional information about LPL’s Dividend Reinvestment Program (DRP). A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 1  Strategic Asset Management (SAM) Program Brochure Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................................... 1 Item 2: Material Changes .......................................................................................................................................................... 1 Item 3: Table of Contents.......................................................................................................................................................... 2 Item 4: Advisory Business ......................................................................................................................................................... 2 Item 5: Fees and Compensation ............................................................................................................................................... 3 Item 6: Performance Based Fees and Side-by-Side Management ..................................................................................... 12 Item 7: Types of Clients ........................................................................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................... 12 Item 9: Disciplinary Information ............................................................................................................................................. 21 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................... 23 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................... 24 Item 12: Brokerage Practices .................................................................................................................................................. 27 Item 13: Review of Accounts................................................................................................................................................... 28 Item 14: Client Referrals and Other Compensation .............................................................................................................. 29 Item 15: Custody ...................................................................................................................................................................... 29 Item 16: Investment Discretion ............................................................................................................................................... 30 Item 17: Voting Client Securities ............................................................................................................................................ 30 Item 18: Financial Information ............................................................................................................................................... 30 Item 4: Advisory Business Introduction LPL Financial LLC (“LPL”) is an investment adviser registered with the SEC pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”). LPL has provided advisory services as a registered investment adviser since 1975. Note that registration as an investment adviser with the SEC does not imply a certain level of skill or training. As of December 31, 2025, LPL managed approximately $818,320,000,000 of client assets on a discretionary basis and approximately $797,900,000 of client assets on a non-discretionary basis. LPL is owned 100% by LPL Holdings, Inc., which is owned 100% by LPL Financial Holdings Inc., a publicly held company. Types of Advisory 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 client directly and also through third party investment advisor firms (“Advisor”). This Brochure provides a description of LPL’s Strategic Asset Management program (the “Program”) when offered through an Advisor. For more information about LPL’s advisory services and programs other than the Program, please contact your Advisor for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov/. In the Program, Advisor, through its investment adviser representatives (“IARs”), provides ongoing investment advice and management on assets in the client’s account. Advisor, through its IARs, provides advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 2  Strategic Asset Management (SAM) Program Brochure (“ETNs”), interval funds, variable annuity subaccounts, business development companies (“BDCs”), private equity, real estate investment trusts (“REITs”), equities, and fixed income securities. Advisor provides advice that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients may impose restrictions on investing in certain securities or groups of securities by contacting Advisor and providing the necessary written instructions. Advisor obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective for the account. Advisor obtains this information by having the client complete an Account Application which is a part of the Account Agreement. In quarterly communications, clients should contact 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 be aware 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. Clients should further be aware that achievement of the stated investment objective is a long-term goal for the account. LPL acts as custodian to accounts, provides research information to Advisor and its IARs, provides brokerage and execution services as the broker-dealer on transactions, and performs administrative services, such as providing performance information to clients. Item 5: Fees and Compensation Fee Schedule Clients in the SAM Program pay LPL and Advisor an annualized account fee (“Account Fee”) for the investment advisory services of LPL and Advisor, as well as the investment advisory, administrative, custody and clearing services of LPL. The Account Fee is shared with the Advisor. The Account Fee is negotiable between the client and the Advisor and is typically a straight percentage based on the value of all assets in the account, including cash holdings but excluding certain assets that are not billed upon in certain instances, and payable quarterly in advance. The maximum Account Fee is 2.50%. Upon request, the Account Fee may be structured on a tiered basis and/or grouped basis, with a reduced percentage rate based on reaching certain thresholds in the Account or in a group of eligible advisory accounts. LPL reserves the right to increase the upper limit of the Account Fee upon 30 days’ prior notice to clients. LPL, Advisor and IARs do not charge performance-based fees to accounts in the SAM program. LPL retains a portion of the Account Fee, up to 0.20%, which is not shared with the Advisor or IAR, for its administrative, custody and clearing services. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Account Fee with the Advisor based on the agreement between LPL and Advisor. Advisor is responsible for sharing its portion of the Account Fee with its IARs. The Account Fee may be higher than the fee charged by other investment advisors for similar services. 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, type of securities to be held in the program (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, and the number and range of supplementary advisory and client related services to be provided to the account. Advisor may charge a client more or less than another client. Clients should consider the level and complexity of the advisory services to be provided when negotiating the Account Fee with Advisor. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a Program 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 Advisor or IAR. The Account Fee for certain alternative investments (such as non-exchange traded REITs, BDCs or hedge funds, each a “Non-Traded Alternative Investment”) is calculated based on unaudited net asset values provided as estimates by the sponsor of the Non-Traded Alternative A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 3  Strategic Asset Management (SAM) Program Brochure Investment (such unaudited net asset values, a “Fair Value”). Fair Values are provided by Non-Traded Alternative Investment sponsors on a reporting period basis, such as monthly or quarterly. LPL does not audit or confirm the accuracy of the Fair Values provided by the sponsors of Non-Traded Alternative Investments. Sponsors of Non-Traded Alternative Investments do not adjust previously determined Fair Values. The portion of the Account Fee calculated on a Non-Traded Alternative Investment reflects the Fair Value of the prior reporting period and will not reflect the current net asset value of the Non-Traded Alternative Investment as of the date of the Account Fee’s calculation. 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, LPL and Advisor do not provide advisory services to the account, and Advisor and its IARs have no responsibility to provide ongoing investment advice. Other Types of Fees and Expenses of LPL LPL charges fees related to a Program account in addition to the Account Fee. • In the Program, clients do not pay Advisor or IAR brokerage commissions for transactions in the account; however, the client pays LPL a transaction charge for the purchase and sale of certain securities in the account. The transaction charges are set out in SAM Account Agreement and the Miscellaneous Account and Service Fee Schedule-Advisory. The transaction charges are paid to LPL to defray costs associated with trade execution; however, they are not directly related to transaction-related expenses of LPL and are a source of revenue to LPL. Transaction charges present conflicts of interest. For example, transaction charges vary depending on the type of security being purchased or sold (e.g., $7 for equities, $50 for fixed income), and therefore LPL earns more from transactions that result in an investment with a higher charge. In addition, where transaction charges apply, the more transactions a client enters into, the more compensation LPL receives. Transaction charges will not reduce the Account Fee you pay. Transaction charges are not shared with Advisor or its IARs. In the case of mutual funds and ETFs, the transaction charges vary depending on the type of security being purchased or sold. For more information, see the section of this Item 4 titled “Understanding Share Classes and Transaction Charges in SAM Accounts”. • In the Program, Advisor may also separately agree with the clients to bear the transaction charges for purchases and sales of certain securities in the account. If Advisor pays the transaction charges in an account, there is a different conflict of interest than if the client pays the transaction charges. Clients should understand that the cost to Advisor of transaction charges will in certain instances be a factor that Advisor considers when deciding which securities to select and how frequently to place transactions in an account. For more information, see the section of this Item 5 titled “Understanding Share Classes and Transaction Charges in SAM Accounts” and the section of Item 12 titled “Brokerage Practices.” • LPL charges accounts with assets valued at less than $100,000 an additional $10 quarterly fee at the end of the quarter. • Clients that hold hedge funds, managed futures, BDCs and certain REITs pay an annual alternative investment administrative fee per position, subject to a maximum per account per year. • If an account is approved for trading on margin and the client has entered into a margin agreement with LPL, the client will be charged margin interest on any credit extended to or maintained by the client. LPL will retain a portion of any interest charged and may share with Advisor. This interest charge is in addition to A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 4  Strategic Asset Management (SAM) Program Brochure the Account Fee. The Account Fee is not charged on any margin debit balance, rather only on the net equity of the account. • Clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to a SAM 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 cash sweep fees, retirement account fees and termination fees, including, as applicable, an annual Individual Retirement Account (“IRA”) maintenance fee, an annual qualified retirement plan maintenance fee, 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 miscellaneous fees are not directly based on the costs of the transaction or service by LPL, will include a profit to LPL in certain instances, and certain of the fees will be lowered or waived for certain customers. • LPL may waive any fee it charges Client or Advisor in its sole discretion in whole or in part. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in Program accounts. Some of these fees and charges are described below. If a client’s assets are invested in mutual funds, ETFs or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Client will pay an advisory fee to the fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay LPL and Advisor the Account Fee with respect to assets invested in mutual funds, ETFs and other pooled products. The mutual funds, ETFs and other pooled funds available in the program can be purchased directly outside of the Program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL, Advisor and its IARs and by making their own decisions regarding the investment. 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 Programs, and such other mutual funds and share classes may be equally or more appropriate for a client’s account. As discussed below, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. Other financial services firms may offer the same mutual funds that are offered through the Programs but at lower overall costs to investors than the costs that clients incur by investing through the Programs. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Programs (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” Certain of the mutual funds available for investment in the Program may be affiliated with Advisor. Therefore, investment in an affiliated mutual fund generates additional compensation to Advisor or its affiliates, including, among other types of compensation, fund-level management fees. 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 under a fund’s frequent trading policy, client will be charged a redemption fee. 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). If client holds a variable annuity as part of an account, there are mortality, expense and administrative charges, subaccount management fees, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. If a client holds a REIT or BDC as part of an account, there are dealer management fees and other organizational, offering and pricing expenses imposed by the REIT or BDC, as A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 5  Strategic Asset Management (SAM) Program Brochure applicable. If client holds a UIT in an account, UIT sponsors charge creation and development fees or similar fees. Further information regarding fees assessed by a mutual fund, variable annuity, alternative investment (such as a REIT, BDC or hedge fund) or UIT is available in the appropriate prospectus or offering document, which is available upon request from the IAR or from the product sponsor directly. Important Information When Funding an Account Ineligible Securities. When transferring securities into a Program account, client should be aware that certain securities may 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 Program account. Surrender Charges or CDSCs. If client transfers a previously purchased investment into a Program account, such as a mutual fund, annuity or alternative investment, or liquidates the previously purchased investment and transfers the proceeds into an account, client may be charged a fee (sometimes called a “surrender charge,” “contingent deferred sales charge” or “CDSC”) upon the sale or redemption in accordance with the investment product’s prospectus. In many cases, the CDSC is only charged if a client does not hold the security for a minimum period of time. In particular, if a client transfers a previously purchased mutual fund (such as a Class C share) into an account that is subject to a CDSC, then the client will pay that charge when the mutual fund is sold. Previously Paid Commissions. Clients 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. Client should understand that, after the transfer into an account, an advisory fee will be charged based on the total assets in the account, including the transferred security. Depending on the share class and fee structure of the previously purchased mutual fund, LPL can receive fees such as 12b-1 fees, recordkeeping fees and revenue sharing from the previously purchased mutual fund until the position is liquidated and subsequently invested. In other words, if you paid IAR or another financial professional recently an upfront commission on the previously purchased security, you will be paying a new ongoing advisory fee going forward to IAR for advice on that same security. Loss of Benefits. If client will be funding the account with the proceeds of a sale or liquidation of an annuity, client should understand that client may be giving up guaranteed living or death benefits that were provided through the annuity, and will not be provided through a Program account. When transferring securities into an account, client should consider and speak to IAR about whether: there will be a loss of a guaranteed benefit, in the case of an annuity; • a CDSC will apply, and the length of time before the CDSC expires; • • 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. Advisor may charge fees in addition to the Account Fee. Clients should refer to the Brochure of Advisor for more information regarding fees charged by Advisor. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 6  Strategic Asset Management (SAM) Program Brochure Understanding Share Classes in SAM Accounts LPL makes available for purchase only one share class per mutual fund in the Program, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Program Shares”). Program Shares are no-load or load-waived share classes and therefore not subject to any upfront sales charge. Share classes previously available in the Program prior to November 21, 2016, such as Class A Shares that are subject to 12b-1 fees, can still be held but not purchased in the Programs (“Non-Surviving Share Classes”). A client also may transfer Non-Surviving Share Classes into client’s account. Any 12b-1 fees received by LPL from mutual funds in the Program will be credited to the client account. Because the Non-Surviving Share Class could have a higher overall expense ratio than the Program Shares, the Non-Surviving Share class could cost the client more than Program Shares, even after the 12b-1 fees is credited to the account. Client should understand that the Program Share class offered for a particular mutual fund through the Program in many cases will not be the least expensive share class that the mutual fund makes available. Program Share classes are selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Other financial services firms may offer the same mutual fund at a lower overall cost to the investor than is available through the Program. Understanding Transaction Charges in SAM Accounts Clients, when participating in the Program, should also understand that LPL charges clients a transaction charge of $0, $4.50 or $26.50 for mutual fund purchases and redemptions. The applicable transaction charge varies depending on the amount of recordkeeping fees that LPL receives from the mutual fund and/or whether the sponsor of the mutual fund participates in LPL’s Mutual Fund No Transaction Fee Network (“MF NTF Network”) described below. When a mutual fund participating in the MF NTF Network is purchased in an account, the mutual fund’s sponsor directs a payment to LPL on behalf and for the benefit of the client that is used exclusively as a credit to defray the bona fide transaction charge obligations of the client’s account. When a participating mutual fund is sold in an account, LPL waives the transaction charge. Clients also should be aware that mutual funds participating in the MF NTF Network typically have higher ongoing internal expenses that can be used to offset payments made by sponsors for transaction charge waivers, and this can reduce the investment returns over time relative to other share classes of the same fund. The Program also offers an ETF No Transaction Fee Network (“ETF NTF Network”). LPL typically charges a transaction charge of $9 for transactions in ETFs, however, for certain ETFs in the ETF NTF Network, the ETF sponsors direct a payment to LPL on behalf and for the benefit of Client that is used as a credit to defray all or a portion of the bona fide transaction charge obligations of the Account. To the extent the sponsor does not pay the entire transaction charge amount, LPL waives the remaining portion to bring the cost to Client to $0. For purchases of other ETFs in the ETF NTF Network in the Program, the sponsor pays LPL a flat annual amount and/or a fee based on the non-retirement client account assets invested in ETF NTF Network funds, and LPL waives the transaction charge. In the case of certain of these fee arrangements, the sponsor pays LPL a combination of a flat fee and asset-based fee for ETFs. The asset-based fee paid to LPL for certain ETFs will be higher based on the ETF’s expense ratio. These arrangements present a conflict of interest because LPL has an incentive to select more expensive ETFs. In addition, as described in more detail below in Item 8, LPL’s Research Department (“LPL Research”) provides asset allocation model portfolios for Advisor or IAR to use with clients. Certain of these model portfolios include ETFs participating in the ETF NTF Network that are more expensive and pay more fees to LPL. However, these conflicts are mitigated insofar as the sponsor fees are not shared with Advisor or IAR who selects the ETFs for the client. For further details and an updated list of ETF sponsors for the ETF NTF Network, please refer to the Disclosures page on lpl.com/disclosures.html. The ETF NTF Network creates a conflict of interest because Advisor has a financial incentive to select ETFs participating in the ETF NTF Network to avoid paying the transaction charges. Clients should consider such conflict when monitoring the purchase of ETFs in recognition of the overall fee and other arrangements with LPL and Advisor A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 7  Strategic Asset Management (SAM) Program Brochure for management of the account. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of the account. In particular, clients should be aware that participating ETFs typically have higher ongoing internal expenses than other ETFs that can be used to offset payments made by sponsors for transaction charge waivers. To the extent that LPL receives from a sponsor of an ETF participating in the ETF NTF Network a flat fee or an asset-based fee that exceeds bona fide transaction charge obligations of the participating client accounts, the payment creates a conflict of interest as further described below as revenue sharing. When Advisor agrees to bear transaction charges on behalf of a client and a participating mutual fund or ETF is purchased in the account, the mutual fund or ETF sponsor defrays all or a portion of the transaction charge otherwise borne by Advisor, and LPL waives the remaining amount of the transaction charge. For all ERISA Accounts for which Advisor agrees to bear transaction costs on behalf of a client, LPL waives the transaction charge to Advisor when a participating mutual fund or ETF is purchased or sold. Transaction Charge Considerations When the client pays the transaction charges, Advisor may recommend greater volume of trading activity than when it has a financial incentive to limit such transactions. Moreover, clients should understand that engaging in frequent trading will result in paying more transaction charges and will increase the overall costs associated with the Account. These costs impact the performance of the Account. LPL has a conflict of interest insofar as it has a financial incentive to engage in trading for the Account to generate transaction charges. Clients should also note that the Account Fee being charged in the Program may take the payment of transaction charges into consideration. That is, the Account Fee charged to SAM accounts may be lower than the Account Fee charged to other types of accounts to the extent that the transaction charges are factored into the overall Account Fee charged to such accounts. If Advisor has agreed to pay transaction costs on behalf of the client, the cost to Advisor of transaction charges may be a factor that Advisor, through its IARs, considers when deciding which securities, mutual funds or ETFs to select and whether or not to place transactions in the account. Similar to clients, the transaction charges borne by Advisor vary based on the type of transaction (e.g., mutual fund, ETF, equity or fixed income security). Advisor has a financial incentive to recommend transactions in certain securities that carry lower fees (e.g., transactions involving equity securities may be recommended over fixed income securities because of the lower transaction charge) or to limit the overall number of transactions it recommends to clients. In particular, Advisor has a financial incentive to select NTF Funds or ETFs that participate in the ETF NTF Network to avoid paying or to lower the transaction charges over others that may be more suitable for the client. Clients should consider such conflict when monitoring the purchase of NTF Funds or ETFs that participate in the ETF NTF Network in recognition of the overall fee and other arrangements with LPL and Advisor for management of the account. All such conflicts may have an impact on the investment performance of the client’s account. Mutual Fund 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements; Other Product Related Compensation Some mutual funds and Program Share Classes in the Programs charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b- 1 fees paid to LPL by mutual funds that are held in Program accounts will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of Program clients. These services include establishing and maintaining accounts with 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 the Program account. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of Program A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 8  Strategic Asset Management (SAM) Program Brochure client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by Program clients in the fund (up to $25 per position). If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. 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 ("ETPs"), $15,000 as a sponsor level due diligence fee, up to LPL receives up to $7,500 per fund and up to $15,000 per product for complex exchange-traded products 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. In the case of annuities, LPL typically receives a one-time onboarding/networking setup fee of up to $100,000 from the annuity product sponsor to reimburse LPL for associated technology-related costs. In the case of alternative investments, LPL receives up to $35,000 for initial products, and up to $15,000 for follow-on product offerings or additional share classes. LPL also receives a one-time payment of up to $25,000 from certain alternative investment sponsors for training and education and other benefits such as prominent placement of sponsor logos, website links or content on materials disseminated to IARs and priority access to education programs and events and conference speaking opportunities. LPL does not share this compensation with Advisor or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee (typically quarterly) based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL IARs so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to 0.15% annually of LPL clients’ investments in the investment product, or up to $1,000,000 . For alternative investments, the maximum revenue sharing fee received by LPL under these arrangements is up to 0.35% on assets or 1.50% on new sales. Certain sponsors of alternative investments are not required to pay such fees. For annuities, the maximum revenue sharing fee received by LPL under these arrangements is up to 0.25% of assets or up to 0.50% of new sales. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. LPL accepts revenue sharing fees for assets held in retirement accounts to the extent permitted by applicable law, including ERISA. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 9  Strategic Asset Management (SAM) Program Brochure receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with Advisor or the IAR who selects or recommends the investment products for client accounts. LPL has network fee arrangements with sponsors of fee-based variable annuities, pursuant to which LPL receives compensation based on the number of LPL customer positions held with the variable annuity sponsor (up to $6.00 per position per year). LPL does not share this compensation with Advisor. From time to time, LPL receives a reallowance of the public offering price per unit on units of certain UITs and structured products sold by LPL during the initial offering period. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of products and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable product or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds , and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees or revenue sharing payments with Advisor or its IARs, and, therefore, there is no financial incentive for Advisor or its IAR to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 10  Strategic Asset Management (SAM) Program Brochure payments with Advisor or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisor and IARs, for example by being used by LPL to support marketing or training costs. LPL provides investment consulting services to the investment advisor of the Optimum Funds mutual fund family. 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 fund 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. The Optimum Funds are available to be purchased and sold in a Program account. The receipt of this investment consulting compensation by LPL presents a conflict of interest, because LPL has a financial benefit if an Optimum Fund is purchased in an account. However, the investment consulting compensation is retained by LPL and is not shared with Advisor and IARs. Therefore, there is no financial incentive for Advisor and IAR to recommend an Optimum Fund for purchase in a Program account. LPL receives a fee from the issuers of structured products for administrative services and related support LPL provides in connection with the structuring and distribution of these products. This fee can be up to 0.75% of the principal amount of a trade and generally varies among products according to the complexity of the structuring. This fee is not shared with Advisor or its IAR who recommends these products to clients. Client should review the product offering documents for additional details. Important Things to Consider About Fees on a SAM Account • The Account Fee is an ongoing fee for investment advisory services and other administrative and custodial services. The Account Fee may cost the client more than purchasing the Program’s services separately. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the: • type and size of the account • 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. • Clients participating in the Program do not pay Advisor commissions on transactions but do pay LPL transaction charges. Transaction charges for the securities purchased and sold in an account may also cost the client more than purchasing the Program’s services separately. As with any fee, transaction charges reduce the overall amount of your investment portfolio. • The Account Fee may cost the client more than if assets were held in a traditional brokerage account. Advisor also may be a broker-dealer and may be able to service clients in a brokerage account. In a brokerage account, a client pays a broker-dealer representative a sales commission for transactions, and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than a Program account. In addition, LPL may only offer certain products in an advisory account, even though there is a version of the product or a similar product that may be lower cost and could be available in a brokerage account, and vice versa. • LPL offers certain alternative products, including certain non-traded alternative investments, in certain accounts offering solely brokerage services and in certain accounts offering solely investment advisory services. This means that clients can only purchase those investments by paying a commission or other brokerage fee in the case of a brokerage account or advisory fee in the case of an advisory account. Depending on the length of time that a client holds such an investment, it may cost more to pay the commission than it would if the investment was available in a SAM program account and the client paid the annual Account Fee on the investment. • 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 A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 11  Strategic Asset Management (SAM) Program Brochure 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 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 Programs. 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 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, 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 a SAM account, through broker-dealers or other investment firms not affiliated with LPL and Advisor. • 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 6: Performance Based Fees and Side-by-Side Management This Item is not applicable. LPL and Advisor do not accept performance-based fees. Item 7: Types of Clients The Program is available for individuals, IRAs, banks, thrift institutions, credit unions, pension and profit sharing plans, including plans subject to ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. A minimum account value of $10,000 is generally required for the Programs. In certain instances, LPL will permit a lower minimum account size. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Advisor, through its IARs, chooses the research methods, investment strategy and management philosophy used in managing a SAM account. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Advisor and its IARs have access to various research reports, including those provided by LPL Research, to which he/she may refer in determining which securities to purchase or sell. LPL Research makes available its recommendations regarding asset allocation, mutual funds, model portfolios, and variable annuity subaccounts. Advisor and IARs may or may not follow these recommendations in managing SAM program accounts. LPL Research also constructs asset allocation model portfolios and provides recommendations on the funds to populate the model portfolios. In constructing these models, LPL Research uses the following investment strategies: Diversified and Alternative Strategy. Although these descriptions are written in terms of individual equities and/or bonds, they include mutual funds or ETFs whose portfolios consist of the type of equities or bonds referenced. • Diversified. The Diversified investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. The strategy is subject to minimal constraints, which allows for a relatively pure implementation of LPL Research’s recommendations. In general, Diversified portfolios should be considered by investors seeking investments in primarily stocks and bonds, along with the occasional non-traditional asset class to take advantage of potential market opportunities. Diversified A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 12  Strategic Asset Management (SAM) Program Brochure portfolios will hold primarily traditional asset classes. Secondarily, if a non-traditional asset class represents the investment that provides the best means of taking advantage of a market opportunity, it will be included in the recommendation. The non-traditional investments included in Diversified portfolios are more standard, such as conservative balanced strategies. Diversified portfolios tend to be steady in their number of positions. These portfolios tend to remain consistently diversified. • Alternative Strategy. The Alternative Strategy investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. Unlike the Diversified investment strategy which may have an allocation to alternative strategy or non-traditional assets classes, this portfolio typically has an allocation to non-traditional asset classes. This strategy extends the diversification beyond the core style box asset classes into strategies with lower correlation to stocks and bonds in order to lower risk, as defined by standard deviation and maximum drawdown (peak to trough loss), while attempting to maintain long-term performance similar to other portfolios in the same investment objective. For each of the above investment strategies, LPL Research recommends a strategic or tactical version. • Strategic. Strategic portfolios typically have a three- to five-year time horizon. The allocations within these portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout that time frame. Although LPL Research recommends investments through a three- to five- year lens, LPL Research may recommend that these portfolios be traded for fine tuning throughout the year. For clients who take a longer term view or are more tax sensitive, a strategic implementation may be more appropriate. • Tactical. Tactical portfolios are more flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present. LPL Research recommends that these portfolios invest in opportunities for as short as one week and as long as five years. Due to the tactical nature, the trading is notably more frequent than strategic portfolios. Tactically managed portfolios should be considered by clients who wish to take advantage of shorter-term market opportunities that may arise and are not opposed to the prospect of more frequent trading. It is important to note that although LPL Research makes available its recommendations and investment strategies, Advisor and its IARs will not necessarily take into consideration these recommendations and strategies. Clients should contact Advisor through its IAR for additional information on the particular investment strategy used for the account. It is also important to note that Advisor and its IARs may use a combination of investment strategies. Types of Investments and Risks In the Program, Advisor through its IARs can recommend many different types of securities, including mutual funds, unit investment trusts (“UITs”), closed end funds, ETFs, ETNs, variable annuity subaccounts, equities, fixed income securities, interval funds, options, hedge funds, managed futures, BDCs, private equity, REITs, and structured products. LPL and Advisor determine the types of investments that are eligible to be purchased in SAM program accounts. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with some types of investments available in the Program. • 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. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 13  Strategic Asset Management (SAM) Program Brochure • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • ‐ Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance sectors do not perform as expected. Alternatively, the lack could be affected if the sectors, industries, or sub of exposure to one or more sectors or industries may adversely affect performance. ‐ • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 14  Strategic Asset Management (SAM) Program Brochure • Alternative Strategy Mutual Funds. Certain mutual funds available in the Program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the Program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. In some cases, there may be an additional cost to investors who redeem before holding shares for a specified amount of time. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 15  Strategic Asset Management (SAM) Program Brochure typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Options. Option trading is permitted in the Program. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and the Program account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 16  Strategic Asset Management (SAM) Program Brochure futures-linked ETPs • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Structured Products. Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 17  Strategic Asset Management (SAM) Program Brochure • Hedge Funds and Non-Traded Managed Futures. Hedge funds and non-traded managed futures funds are available to clients meeting certain qualification standards. Investing in these funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices, currency and interest rate risk, lack of liquidity and performance volatility. In addition, these funds are not required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Clients should be aware that these funds are not liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the fund, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the fund during the repurchase offer. In some cases, there may be an additional cost to investors who redeem before holding shares for a specified amount of time. Issuers typically accept redemption requests only periodically (monthly or quarterly), and often have the discretion to suspend redemptions in times of market stress. Even after a redemption request is accepted, the redemption proceeds may not be available for a significant period of time following the effective date of the redemption. A portion of the redemption proceeds may also be withheld to account for potential future adjustments to the valuation of the security. Funds of hedge funds are pooled investments in several hedge funds. Expenses in funds of hedge funds are typically higher than mutual funds. Because they may invest in a number of private hedge funds, funds of funds also bear a part of the fees and expenses of those underlying hedge funds. • Business Development Companies (BDCs). BDCs are types of closed-end investment companies, which are available to clients meeting certain qualification standards. Generally, BDCs invest primarily in the debt and equity of private and/or small U.S. companies and may offer distribution rates generated through potentially significant credit and liquidity risk exposures amplified through leverage. As with other high-yield investments, such as floating-rate/leveraged loan funds, private REITs and limited partnerships, investors are exposed to significant market, credit, interest rate and liquidity risks. In addition, BDCs run the risk of over- leveraging their relatively illiquid portfolios. Due to the illiquid nature of non-traded BDCs, investors’ exit opportunities may be limited only to periodic share repurchases by the BDC. A tender offer pursuant to a share redemption program may be oversubscribed so that the BDC accepts only a pro rata portion of the shares a client tenders during a redemption program. In such cases, a client may experience significant delays (including, potentially, indefinite delays) to exit from the investment. In addition, share redemption programs may be shut down at any time at the discretion of the issuer’s board. Also, BDCs may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to make investments. In some cases, there may be an additional cost to investors who redeem before holding the shares for a specified number of years. • REITs. REITs invest in real estate, and there are special risks associated with investing in real estate, including, but not limited to, sensitivity to changes in real estate values, the risk of investment loss due to the use of leveraging and other speculative investment practices, interest rate risk, lack of liquidity and performance volatility. Non-Traded REITs, which are available to clients meeting certain qualification standards, are not required to provide annual valuations until two years and 150 days after reaching the minimum capital raise required to begin purchasing properties. This threshold is generally outlined in the product’s prospectus. Non- Traded REITs may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to invest in new assets. Clients should be aware that these securities may not be liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the security, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the security during the repurchase offer. Issuers may repurchase shares at a price below net asset value. The repurchase program may also be suspended under certain circumstances. • Private Equity Funds. Private equity investments are speculative and involve significant risks. It is possible that investors may lose some or all of their investment. The risks associated with private equity include: limited diversification, the use of leverage, and limited liquidity. The investment timeline for private equity A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 18  Strategic Asset Management (SAM) Program Brochure can be a decade or more. Some issuers or general partners may penalize limited partners who redeem before holding units for a specified amount of time, or may disallow redemptions entirely. • Variable Annuities. If client purchases a variable annuity that is part of the Program, client will receive a prospectus and should rely solely on the disclosure contained in the prospectus with respect to the terms and conditions of the variable annuity. Clients should also be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. Some products may charge a recapture or redemption fee for contracts or benefits not held for a specified period of time or that do not follow stated withdrawal terms. • Non-traded Products. Non-traded products do not trade on a securities exchange and are not publicly traded. Consequently, non-traded products can be riskier than products that are publicly traded because the product cannot be sold readily in a market by the investor. The non-traded product may offer to redeem shares from investors, but such share redemptions are typically subject to limitations. Share redemptions may also require that shares be redeemed at a discount and there is no guarantee that client will be able to redeem the security during the repurchase offer. In addition, non-traded products may lack share value transparency because there is no market price readily available. Without share value transparency, investors may not be able to assess the value or performance of the non-traded product. • Margin Accounts. Client should be aware that margin borrowing involves additional risks. Margin borrowing will result in increased gain if the value of the securities in the account go up, but will result in increased losses if the value of the securities in the account goes down. LPL, acting as the client’s creditor, will have the authority to liquidate all or part of the account to repay any portion of the margin loan, even if the timing would be disadvantageous to the client. For performance illustration purposes, the margin interest charge will be treated as a withdrawal and will, therefore, not negatively impact performance reports. • 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 in accordance with the terms of the lending arrangement, 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.” A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 19  Strategic Asset Management (SAM) 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and Advisor generally will earn more compensation for selling one investment product than another. As a result, LPL and Advisor have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 20  Strategic Asset Management (SAM) Program Brochure • Annuity Products. If investor client invests in annuity products in a Program account, client should be aware of the specific risks and limitations of the annuity products. Clients should be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. Some products may charge a recapture or redemption fee for contracts or benefits not held for a specified period of time or that do not follow stated withdrawal terms. Registered Index Linked Annuities (RILAs) are insurance products tied to the performance of a market index, offering the positive returns of the index up to a cap and providing a buffer for a certain level of negative returns. RILAs are subject to risks associated with other investment products, including market risk, and the total loss of principal is possible. If client purchases an annuity product that is part of the Program, client will receive a prospectus with respect to the terms and conditions of the annuity product. Item 9: 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 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 was 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 A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 21  Strategic Asset Management (SAM) Program Brochure 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, 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). • 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). A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 22  Strategic Asset Management (SAM) Program Brochure • 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 IAR’s VA sales, and an undertaking to review such representative’s brokerage and advisory activities and LPL’s related policies and procedures (MA, 2017). 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/. Item 10: 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 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 IARs who 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. 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 A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 23  Strategic Asset Management (SAM) Program Brochure 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 SAM 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-SAM 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. Item 11: Code of Ethics, Participation or Interest in Client Transactions 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 SAM 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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, UIT or alternative investment shares may be processed through the firm's proprietary account resulting in the purchase 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 the firm’s use of a proprietary account. LPL does not otherwise engage in principal transactions with its clients in the Program. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 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 A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 24  Strategic Asset Management (SAM) Program Brochure 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 IARs, 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, they 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, 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.” 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, 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 IARs do not typically recommend specific sweep service options or underlying sweep holdings. For more information, please see your customer agreement and the applicable ICA disclosure booklet. 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. Historically, customer yields in ICA have always been lower 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 A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 25  Strategic Asset Management (SAM) Program Brochure 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 are eligible for FDIC insurance (subject to applicable limits). Eligibility for pass-through deposit insurance coverage for ICA deposits is subject to fulfilling specific conditions. Client Cash Accounts 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. 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. • 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. This compensation that LPL and Advisor receive related to the ICA (including any ICA overflow mechanism) is in addition to the Account Fee that LPL, Advisor and IAR receive with respect to the assets in the sweep investment. This compensation related to the ICA 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 or funds. LPL shares a portion of this compensation with Advisor. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 26  Strategic Asset Management (SAM) Program Brochure Non-Sweep Money Market Mutual Fund Investments (Outside of LPL’s Sweep Service Options) Clients are able to invest cash balances in a limited number of money market mutual funds outside the sweep service options offering (such funds, “Non-Sweep Money Market Funds”). Like any other mutual fund transactions at LPL, transaction and other fees may apply. Moreover, unlike under the sweep services, transactions in Non-Sweep Money Market Funds are customer-directed (or directed by customer’s representative) and do not provide for automatic daily sweep. Depending on current interest rates and other market factors, investment returns of money market mutual funds could be lower or higher than the aggregate fees and expenses charged by LPL in connection with the transaction. Contact your IAR for information about current fees and investment returns on money market funds. As described above, under “Fees Charged by Third Parties,” clients should understand that the share class offered for a particular Non-Sweep Money Market Fund charges higher fees and expenses than other share classes that are offered by the same Non-Sweep Money Market Fund but are not available on LPL’s platform. LPL receives compensation for the LPL customer assets invested in the Non-Sweep Money Market Funds (up to 0.30% on an annual basis) for distribution, recordkeeping, shareholder servicing and administrative services it provides for the funds and in connection with marketing support services LPL provides to the fund sponsors as described in this disclosure. This compensation related to Money Market Funds presents a conflict of interest to LPL because LPL has a financial benefit if cash is invested in the Money Market Funds. However, Advisor, and not LPL, is the investment advisor responsible for cash management. Unlike other types of mutual funds available on LPL’s platform, LPL makes available Non-Sweep Money Market Funds from only a limited number of mutual fund sponsors. By making available a limited number of Non-Sweep Money Market Funds, LPL is able to negotiate greater compensation from the fund companies for services it provides to the funds. Because of the limited number of Non-Sweep Money Market Funds available on the platform and the fees paid by those funds, other money market mutual funds not available through LPL’s brokerage platform are likely to have higher returns than the Non-Sweep Money Market Funds. In addition, LPL has received a waiver from the Money Market Funds to allow a lower investment minimum for the Program Share class of the than that set out in the prospectus; however, LPL imposes its own minimum investment amounts that are higher than minimums that may apply if a client were to invest in the Money Market Funds through another firm outside of the Program. In light of the investment minimums that LPL imposes with respect to the Money Market Funds, an investment in the Money Market Funds outside of the Program or an investment in one of the many other money market mutual funds offered outside of the Program would likely be more economically advantageous than an investment in the Money Market Funds through the Program. LPL does not charge transaction charges on Money Market Funds. 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 Clients should understand that LPL, Advisor and IAR perform advisory and/or brokerage services for various other clients, and that LPL, Advisor and IAR may give advice or take actions for those clients that differ from the advice given to the client. The timing or nature of any action taken for the account also may be different. Item 12: Brokerage Practices LPL does not receive research or other products or services other than execution from a broker-dealer in connection with client securities transactions (“soft dollar benefits”). LPL does not consider, in selecting or recommending broker- dealers, whether LPL or a related person of LPL receives client referrals from a broker-dealer or third party. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 27  Strategic Asset Management (SAM) Program Brochure In the Program, LPL requires that clients direct LPL as the sole and exclusive broker-dealer to execute transactions in the Program account. LPL may be paid transaction charges for processing trades, which presents a conflict of interest. Clients should understand that not all advisors require their clients to direct brokerage. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution of client transactions. Therefore, directed brokerage may cost clients more money. In addition, in the case of mutual funds, execution is made at the net asset value of the fund. If LPL as broker purchases a new issue security on behalf of client accounts, the execution price may include a concession to the dealers participating in the syndicate. Although LPL is not part of the syndicate and does not receive this concession, the concession is included in the price and is in addition to the Account Fee. An IAR of Advisor may aggregate transactions in equity and fixed income securities for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. For partially filled orders, an IAR may allocate trades pro-rata or on a random basis to treat clients fairly and not favor one client over another. Advisor or IAR may determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, the liquidity of the securities and the discretionary or non-discretionary nature of the trades. If Advisor and IARs do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. 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. For securities transactions, this delay may cause a difference between the execution price and the displayed quote at the time the order was entered. This delay may also result in a limit order becoming ineligible for 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. Item 13: Review of Accounts LPL provides Advisor with an exception reporting system that flags accounts for criteria such as performance, trading activity, and concentration on a quarterly or monthly basis, depending upon the nature of the exception. Advisor oversees the process for reviewing flagged 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 performance information available upon request. LPL also provides an additional year- end report for accounts not established on a calendar quarter basis. In addition, LPL sends to clients trade confirmations and account statements showing transactions, positions, and deposits and withdrawals of principal and income. LPL does not send trade confirmations for systematic purchases, systematic redemptions and systematic exchanges. Portfolio values and returns shown in performance information 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. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 28  Strategic Asset Management (SAM) Program Brochure Item 14: Client Referrals and Other Compensation Other Compensation LPL and LPL employees receive additional compensation, business entertainment and gifts from product sponsors. However, such compensation may not be tied to the sales of any products. Compensation may include 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, Advisor, its employees and IARs 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 from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 certain advisory programs 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. In the event a trade error occurs in an account, and such error is determined to be caused by LPL, LPL typically will cancel the trade and remove the resulting monetary loss to 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. Item 15: Custody LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody Program 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. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 29  Strategic Asset Management (SAM) Program Brochure Although most securities available in Program accounts are custodied at LPL, there are certain securities managed as part of the account that are held at third parties, and not at LPL. For example, hedge funds and managed futures are often held directly with the investment sponsor. For those outside positions, client will receive confirmations and statements directly from the investment sponsor. For outside positions not custodied at LPL, LPL may receive information (e.g., number of shares held and market value) from these investment sponsors and display that information on statements and reports prepared by LPL. Such information also may be used to calculate performance in performance reports prepared by LPL. Although LPL believes that the information it receives from the investment sponsors is reliable, LPL recommends that you refer to the statements and reports you receive directly from the investment sponsor and compare them with the information provided in any statements or reports from LPL. The statements and reports you receive from LPL with respect to outside positions should not replace the statements and reports you receive directly from the investment sponsor. Item 16: Investment Discretion In the Program, Advisor typically provides advisory services on a non-discretionary basis, and therefore, it is the client who directs the purchase and sale of securities in the account. In some cases, the client may provide discretionary authorization to the Advisor and its IAR for transactions in its Program account by signing a Discretion Authorization Form, allowing the IAR to place trades without seeking the prior specific consent of the client for each transaction. Provided, however, when exercising discretionary authority, an Advisor IAR is not permitted to purchase shares of funds advised by the Advisor’s affiliates or Equitable-branded variable annuity products without client consent, as discussed in Section 16 of the Advisor’s Form ADV Part 2A. Item 17: Voting Client Securities In the Program, LPL, Advisor and IARs do not accept authority to vote client securities. Clients retain the right to vote all proxies that are solicited for securities held in the account. Clients will receive proxies or other solicitations from LPL. When LPL delivers mutual fund shareholder reports and proxies to clients, LPL is reimbursed by the mutual fund for the delivery costs. 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 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 IAR. In addition, LPL, Advisor and IARs do not accept authority to take action with respect to legal proceedings relating to securities held in the account. Item 18: Financial Information LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and is therefore not required to include a balance sheet for its most recent financial fiscal year. LPL is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has it been the subject of a bankruptcy petition at any time during the past ten years. Brochure Supplements Accompanying this Brochure are Brochure Supplements for individual employees or officers of LPL. Note that although these individuals are responsible for investment research provided by LPL, they are not the individuals responsible for the ongoing individualized investment advice provided to a particular client. For more information about Advisor and an IAR servicing the account, client should contact Advisor or IAR. A7 – EQH – 0326 LPL Financial, Member FINRA/SIPC 30 

LPL Financial Firm Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This brochure provides information about the qualifications and business practices of LPL Financial. If you have any questions about the contents of this brochure, please contact your LPL Financial representative or LPL Financial 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 Financial 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 31, 2025. Items 8 and 11 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................................. 1 Item 2: Material Changes ........................................................................................................................................................ 1 Item 3: Table of Contents........................................................................................................................................................ 1 Item 4: Advisory Business ....................................................................................................................................................... 2 Item 5: Fees and Compensation ............................................................................................................................................. 6 Item 6: Performance Based Fees and Side-By-Side Management ................................................................................... 10 Item 7: Types of Clients ......................................................................................................................................................... 10 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................. 10 Item 9: Disciplinary Information ........................................................................................................................................... 19 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................. 21 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................... 23 Item 12: Brokerage Practices ................................................................................................................................................ 26 Item 13: Review of Accounts................................................................................................................................................. 27 Item 14: Client Referrals and Other Compensation ............................................................................................................ 27 Item 15: Custody .................................................................................................................................................................... 33 Item 16: Investment Discretion ............................................................................................................................................. 34 Item 17: Voting Client Securities .......................................................................................................................................... 34 Item 18: Financial Information ............................................................................................................................................. 34 1 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure Item 4: Advisory Business Introduction LPL Financial LLC (LPL) is an investment adviser registered with the Securities and Exchange Commission (SEC) pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”). LPL has provided advisory services as a registered investment adviser since 1975. Note that registration as an investment adviser with the SEC does not imply a certain level of skill or training. As of December 31, 2025, LPL managed approximately $818,320,000,000 of client assets on a discretionary basis and approximately $797,900,000 of client assets on a non-discretionary basis. LPL is owned 100% by LPL Holdings, Inc., which is owned 100% by LPL Financial Holdings Inc., a publicly held company. LPL’s advisory services are made available to clients primarily through individuals associated with LPL as investment adviser representatives (“IARs”). For more information about the IAR providing advisory services, client should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time client engages the IAR. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lplfinancial.com. 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. Types of Advisory Services LPL offers various types of advisory services and programs, including wrap programs, mutual fund asset allocation programs, advisory programs offered by third party investment advisor firms, financial planning and consulting services, retirement plan consulting services, investment research, analyses and consulting services, an advisor- enhanced digital advice program, and other customized advisory services. This Brochure provides information about LPL and the following types of advisory services that LPL provides: financial planning and consulting services, advisory and consulting services to participants on retirement plan assets, third party asset management program services, customized advisory services, investment research, overlay portfolio management services, 529 savings plan account management and referral services related to advisory programs of third party asset management firms. LPL provides information in separate disclosure brochures for its services offered through the following LPL advisory programs: Strategic Asset Management, Manager Select, Manager Access Select, Personal Wealth Portfolios, Optimum Market Portfolios, Model Wealth Portfolios, Guided Wealth Portfolios, Retirement Plan Consulting and Strategic Market Solution programs. If clients would like more information on such programs, clients should contact the IAR for a copy of the program brochure that describes such 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. LPL is also a broker-dealer registered with the Financial Industry Regulatory Authority (FINRA), and IARs are typically also registered with LPL as a broker-dealer registered representative. Therefore, in such case, IARs are 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. 2 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure As further discussed in this Brochure, certain programs are offered either on a non-discretionary or discretionary basis. “Non-discretionary” services require clients to initiate or pre-approve investment transactions in their accounts before they can occur, whereas “discretionary” services authorize the IAR or other designated third-party investment advisor to buy, sell, or hold investment positions without obtaining pre-approval from clients for each transaction. Following is a summary description of advisory services covered by this Brochure. Please consult the applicable client account agreement and fee schedules for additional information and details regarding these programs. Financial Planning & Consulting Services Under our Financial Planning & Consulting Services Program, LPL, through its IARs, provides personal financial planning and consulting services tailored to the individual needs of the client. The scope and duration of services varies and is determined between the client and IAR, and may range from comprehensive financial planning to consulting on a particular issue, including focus on topics such as retirement planning, education planning, estate planning, risk management planning, personal wealth planning, tax planning, business planning, investment planning, divorce planning, , or such other financial planning or consulting services needs as designated in the Financial Planning & Consulting Services Program Agreement, and may include delivery of a written financial plan or report depending upon the scope of agreed upon services. Client remains solely responsible for determining whether or not to implement program recommendations and taking all necessary steps to do so. LPL and IAR will not exercise investment discretion or implement any investment advice or recommendations provided as part of the services. Rather, the services are offered as point-in-time based consultations that are provided either on a one-time basis or periodically at such frequency as requested by client, and do not include providing ongoing active investment management or monitoring services. Moreover, to the extent that the services include consideration of a client’s group or individual qualified retirement plan assets, this is not intended to result in LPL or IAR acting as a “fiduciary” as such term applies under the Employee Retirement Security Act of 1974 (“ERISA”). Clients may elect to retain LPL and IAR to provide various securities and/or ongoing investment management or monitoring services by enrolling in other programs available through LPL. Individual Participant Advice (IPA) Under the IPA program, LPL, through its IARs, provides discretionary management of a participant’s self-directed retirement plan account maintained at certain unaffiliated third-party custodians, if permitted by the participant’s plan. In certain cases, LPL may also accommodate non-discretionary management arrangements or other account types on an exception basis. IAR will provide advice regarding securities made available as investment options through the plan or a self-directed brokerage account, or as otherwise available for accounts enrolled on an exception basis. These services will be offered through an agreement between LPL, the IAR, and the client in addition to client completing account paperwork with the designated custodian. In connection with such services, IAR will obtain the necessary financial data from the client, assist the client in setting an appropriate investment objective for the account, and provide investment advice with respect to the assets in the account based on the investment objective selected. Clients may impose reasonable restrictions on investing in certain securities or a group of securities. IAR will typically have discretionary authority to trade the participant’s account directly at the custodian; however, non-discretionary services may be accommodated in limited cases. Neither LPL nor the IAR will provide advice or recommendations regarding any retirement plan participant loans or hardships as part of the IPA program, although IAR is available to provide general information and educational assistance to participants regarding these options as applicable. Off-Platform Advice (OPA) Under the OPA program, LPL, through its IARs, provides management of a participant’s self-directed retirement plan account maintained by Fiduciary Trust Company of New Hampshire (FTC), an affiliate of LPL, that must generally be approved by the participant’s plan to provide services. These services will be offered through an agreement between LPL, the IAR, the client and FTC. In its capacity as the legal custodian for the OPA program, FTC delegates certain 3 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure brokerage, recordkeeping and other services to LPL, which in turn outsources certain functions to a third-party service provider. The investment products available under this program are determined by FTC and generally limited to various mutual funds and exchange-traded funds managed by unaffiliated product sponsors. In connection with such services, IAR will obtain the necessary financial data from the client, assist the client in setting an appropriate investment objective for the account, and provide investment advice with respect to the assets in the account based on the investment objective selected. Clients may impose reasonable restrictions on investing in certain securities or a group of securities. IAR will typically have discretionary authority to trade the client’s account directly at the custodian; however, non-discretionary arrangements may be accommodated in limited cases. Neither LPL nor IAR will provide any advice or recommendations regarding any retirement plan participant loans or hardships as part of the OPA program, although IAR is available to provide general information and educational assistance to participants regarding these options as applicable. Other Participant Advice Services LPL, through its IARs, may also provide ongoing management of a participant’s self-directed retirement plan account through a centralized management platform using investment models designed by LPL and third-party investment strategists. Under such engagements, clients may authorize LPL and/or IARs to purchase and sell securities on a discretionary or non-discretionary basis pursuant to an investment objective chosen by the client. In addition, clients also may have access to other services available through LPL for participants, including automated rebalancing features. Discretionary or non-discretionary authority is set out in the advisory agreement between LPL, IAR and the client, as well as any additional access to tools described above. The IAR obtains the necessary financial data from the client, assists the client in determining the suitability of the advisory services and assists the client in setting the appropriate investment objective. LPL and IAR provide ongoing investment advice and management that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients generally may impose reasonable restrictions on investing in certain securities or groups of securities. 529 Savings Plan Account Management LPL, through its IARs, provides management of a client’s 529 savings plan account sponsored by a third-party program manager (Program Manager). IAR will provide advice regarding investment options made available by the 529 plan’s Program Manager through the 529 plan. A 529 savings plan account Program Manager ordinarily makes mutual funds, target-date mutual funds, exchange-traded funds, money market funds, and insured deposit accounts available as investment options in the 529 savings plan, however, other investment options may be available. These services will be offered through an agreement between LPL, the IAR, and the client. In connection with such services, IAR will obtain the necessary financial data from the client, assist the client in setting an appropriate investment objective for the account, and provide investment advice with respect to the assets in the account based on the investment objective selected. IAR will typically have discretionary authority to trade the participant’s account directly at the custodian. IAR’s ability to implement investment recommendations will be limited by the terms of the 529 plan and the client’s account with the Program Manager, including, for example, limits on the frequency with which investments may be changed. Third-Party Asset Management Program (TAMP) TAMP services are generally offered through LPL as co-investment advisory service arrangements but may also be referral-based in nature, as designated within the applicable TAMP sponsor (as defined below) agreement, disclosures or other account paperwork provided to the client when establishing a TAMP account. Co-Investment Advisory Services: LPL, through its IARs, provides access to asset management programs offered by third-party investment advisors (referred to as “TAMP sponsors”) with which LPL has entered an agreement to provide services as a co-investment advisor. These TAMP sponsors are subject to review according to LPL standards for inclusion as an available TAMP and may change from time to time. As of the date of this Brochure, these firms include AssetMark, Beacon, Brinker Capital (including CLS Investments), City National Rochdale Investment Management, 4 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure Dunham & Associates, Flexible Plan, FOCUS Partners (formerly Buckingham Strategic Partners), Freedom Investment Management, Madison Investments, Matson Money, Manning & Napier, Members Trust Company, Orion Portfolio Solutions, SEI, Symmetry Partners, and The Pacific Financial Group. Please consult IAR for information regarding TAMP sponsors. TAMP services generally begin by the IAR assisting the client with setting an appropriate investment objective based on their unique financial circumstances and needs, determining the appropriateness of the program and opening an account with a suitable TAMP sponsor. The IAR also typically assists the client with selecting a suitable model investment portfolio consisting of securities selected and managed by either the TAMP sponsor or a designated portfolio management firm (referred to as a “subadvisor”) available through the TAMP sponsor. The TAMP sponsor or subadvisor is typically granted authority in its client agreement to purchase and sell securities on a discretionary basis pursuant to the investment objective chosen by the client, though trading authority may be limited to non- discretionary under certain circumstances based on the terms of the terms governing the arrangement. LPL, through its IAR, provides ongoing monitoring of the client’s TAMP account and may periodically recommend that the client change model portfolios, or TAMP sponsor or subadvisor, as appropriate based on updates to the client’s investment objective or other relevant factors. In the case of group retirement plans, LPL and the IAR do not act as an “investment manager” as defined under Section 3(38) of ERISA, unless otherwise expressly acknowledged in writing by LPL. The TAMP sponsor and subadvisors typically provide impersonal investment advice by constructing and maintaining various model investment portfolios that are managed according to specific investment strategies associated with the corresponding models, and that are not generally customized for individual clients (subject to the client’s ability to request reasonable investment restrictions). In limited cases, the TAMP sponsor or subadvisor may enable the IAR or client a great degree of influence and/or discretion to customize model portfolio holdings, pursuant to the terms of the TAMP sponsor’s client agreement. In addition to portfolio management services, the TAMP sponsor will also generally arrange for custody of client assets, trade execution, cashiering services, and such other services as outlined in their separate client agreement and disclosure brochure. Since the services provided by each TAMP sponsor or subadvisor are unique, clients should request and carefully review the applicable disclosure brochure, client agreement and other account paperwork for each TAMP sponsor for more detailed information about their services, including without limitation, a description of the TAMP sponsor’s background, investment strategies, fees, custody arrangements, conflicts of interest, and other relevant information. Clients may request a copy of the TAMP sponsor’s disclosure brochure from the IAR or by visiting https://adviserinfo.sec.gov/. Clients may also request the Form ADV 2B Supplemental Brochure for TAMP sponsors and subadvisors from their IAR for detailed information about the management personnel at the TAMP sponsors responsible for managing investment portfolios. Referral-based Services: On a limited basis, LPL offers TAMP referral and related services through its IARs to accommodate certain (i) clients serviced by AssetMark or BNY Mellon Wealth Management, (ii) group retirement plan sponsors or participants and (iii) other legacy or unique client arrangements LPL elects to accommodate and service on a referral basis. In such case, the TAMP sponsor’s client agreement, disclosures or other account paperwork will ordinarily identify LPL and its IARs as either a referral agent, solicitor or promoter, and outline details of the referral arrangement between the TAMP sponsor and LPL. Under these arrangements, the client engages the TAMP sponsor as the investment advisor responsible for providing ongoing investment advice and portfolio management, and LPL is compensated by the TAMP sponsor for providing the referral, enrollment and ongoing account administrative support as a liaison between the client and TAMP sponsor through the IAR. Customized Advisory Services LPL, through its IARs, offers advisory services to clients outside of an LPL advisory program or any TAMP program described above. Under such customized engagements, clients authorize IARs to purchase and sell securities on a discretionary or non-discretionary basis pursuant to an investment objective chosen by the client. This authority is set out in an advisory agreement between LPL, IAR and the client. The IAR obtains the necessary financial data from the client, assists the client in determining the suitability of the advisory services and assists the client in setting the 5 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure appropriate investment objective. The IAR provides ongoing investment advice and management that is tailored to the individual needs of the client based on the investment objective chosen by the client. Depending on the specific engagement, the types of securities that the IAR may purchase and sell include mutual funds, ETFs, equities, fixed income securities, variable annuity, and/or variable universal life insurance subaccounts. Clients generally may impose reasonable restrictions on investing in certain securities or groups of securities. The assets managed as part of a customized engagement typically are held at a custodian other than LPL. Research Services LPL’s Research Department (LPL Research) makes available investment research materials, which include recommendations on asset allocation and mutual funds, variable annuity or variable universal life insurance subaccounts, and ETFs. When LPL provides investment research, LPL makes no analysis of and does not consider clients’ individual circumstances or objectives, and does not tailor any model asset allocation to any specific client’s needs, circumstances or objectives. LPL Research provides investment consulting services to the investment advisor of the Optimum Funds mutual fund family. These services include assisting the investment advisor in determining whether to engage, maintain or terminate subadvisors for the Optimum Funds. LPL Research also provides investment consulting services to third-party investment advisor firms. These services include providing information, illustrations, reports, analyses, educational materials, portfolio guidance (which may include asset allocation), and other similar materials for the investment advisor firm to consider for its portfolio management activities. The materials provided by LPL are for informational purposes only and the investment advisor firm remains the fiduciary that is responsible for deciding whether and how to use such materials for its portfolio management activities. Bank Wealth Program LPL provides several wealth management tools, such as technology, research, and advisory services, through a platform called the Bank Wealth Program (BWP). BWP is available to clients that are banks, corporate trustees, thrifts, trust companies, broker-dealers, investment advisors, and other financial institutions (Institutions). BWP’s tools and services include client acquisition and management tools, data reconciliation services, portfolio monitoring and rebalancing technologies, reporting services, research services, and money manager due diligence. Not all services are provided to every Institution on the BWP platform. For instance, LPL’s research may or may not be offered to each Institution. Furthermore, LPL does not currently custody the assets for BWP, though it may in the future. LPL also does not integrate LPL’s brokerage services, and Institutions, in most cases, direct trades to third party broker-dealers, as directed by the Institution. Institutions may use active discretionary investment management services from independent investment managers researched by LPL. LPL provides due diligence on some independent investment managers offered on BWP. LPL may also offer asset allocation analysis. LPL primarily evaluates money managers and managers of separate accounts, but may also evaluate mutual funds and other security types. Item 5: Fees and Compensation Financial Planning & Consulting Services For these services, the fee is negotiated between the IAR and client and the amount of the fee is as stated in Schedule A to the client agreement. The fee is paid to LPL, and LPL shares up to 100% (typically between 90% and 100%) of the fee with the IAR based on the agreement between LPL and the IAR. Clients generally pay either a flat or hourly fee and will be billed at such frequency (e.g., upfront, monthly, quarterly or annually) as determined between Client and IAR. These fees typically range from $0 to $15,000, or up to $500 per hour, but may exceed this amount depending on 6 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure the frequency and scope of complexity of the financial planning engagement. The IAR may elect to provide these services on a discounted or complimentary basis for no fee. Clients should understand that the fee client negotiates with IAR for these services will be higher than the fees charged by other investment advisors for similar services in certain circumstances and particularly if the fee is at or near the maximum fees set out above. The IAR is responsible for determining the fee to charge each client based on factors such as total amount of assets involved in the relationship, the complexity of the planning services, and the number and range of supplementary advisory and client- related services to be provided. Clients should consider the level and complexity of the planning services to be provided when negotiating the fee with IAR. If IAR engages LPL’s home office team to assist with advance financial planning analysis, the IAR may incur consulting fees for such services which may result in the client being charged a higher fee by the IAR than if LPL’s team was not retained by IAR. Clients may pay the financial planning fee by check made payable to LPL Financial LLC. In the alternative, clients may instruct and authorize LPL to debit the fee on a one-time or reoccurring basis either (i) from a non-retirement account of the client held at LPL or (ii) through an LPL approved third party payment processing service. The client may terminate their services agreement at any time and request a pro-rata refund of unearned fees, if any, based on the time and effort of services completed prior to termination of the agreement. TAMP – Co-Investment Advisory Services For co-investment advisory TAMP arrangements, LPL and the TAMP sponsor each charge an advisory fee to the client for their respective services as indicated in the TAMP sponsor’s account paperwork. The IAR negotiates the fee payable to LPL typically up to a maximum of 2% (but may be higher in certain circumstances) and the TAMP sponsor often discloses a standardized fee schedule with a set minimum or maximum fee, though its fees may also be negotiable. The advisory fee is ordinarily based on the value of assets under management as calculated by the designated custodian, which generally deducts and pays fees to LPL and the TAMP sponsor either quarterly in arrears or in advance, although some arrangements may support monthly fees. The total advisory fee is often paid to the TAMP sponsor which in turn pays the agreed upon portion to LPL. LPL typically shares between 90% and 100% of its advisory fee with the IAR based on the agreement between LPL and the IAR. The program agreements and/or disclosure brochures provided by LPL and the TAMP sponsor will outline how a client may terminate a TAMP arrangement and request a refund of any pre-paid unearned fees. There are other fees and charges imposed by the TAMP sponsor or third parties that apply to investments in TAMP accounts. Some of these fees and charges are described below and should also be outlined in the TAMP sponsors’ respective disclosure brochures as applicable. The client will be charged commissions, markups, markdowns, or transaction charges by the broker-dealer who executes transactions in the TAMP account. There also are custodial related fees imposed by the custodian of assets for the program account. These additional fees and charges will be set out in the TAMP disclosure brochure and the agreements executed by the client at the time the account is opened. LPL does not share in any of the transaction fees or custodial fees associated with TAMP accounts. If assets are invested in mutual funds, ETFs or other pooled funds, there are two layers of advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. Client will also pay the TAMP advisory fee with respect to those assets. The mutual funds and ETFs available in the programs often may be purchased directly. Therefore, clients could avoid the second layer of fees by not using the advisory services of the TAMP and IAR and by making their own decisions regarding the investment. A mutual fund in a TAMP account may pay an asset based sales charge or service fee (e.g., 12b-1 fee) that is paid to the broker-dealer on the account. LPL and IARs generally are not paid these fees for TAMP accounts. If client transfers into a TAMP 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. 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). 7 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure If client holds variable annuity or variable universal life insurance subaccount assets that are managed as part of a TAMP account, there are mortality, expense and administrative charges, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the sponsor. If client holds a UIT in a TAMP account, UIT sponsors charge creation and development fees or similar fees. Further information regarding fees assessed by a mutual fund, variable annuity, variable universal life insurance product, or UIT is available in the appropriate prospectus, which clients may request from IAR. Client understands that a TAMP account will be charged an ongoing fee for investment advisory services and that the ongoing fee may cost more than if the assets were held in a traditional brokerage account. In a brokerage account, a client is charged a commission for each transaction, and there is typically no duty to provide ongoing advice with respect to the account. If client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, client should consider opening a brokerage account rather than a TAMP account. If the TAMP arrangement is a wrap fee program, clients should understand that the wrap fee may cost the client more than purchasing the program services separately, for example, paying fees for the advisory services of the TAMP and IAR, plus commissions 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: • type and size of the account • types of securities in the account • 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 investment products and services available to be purchased in TAMP accounts can be purchased by clients outside of a TAMP account, through LPL or through broker-dealers or other investment firms not affiliated LPL or the TAMP sponsor. In addition, investment models or subadvisors offered by TAMP sponsor may also be available through other LPL advisory programs at a lower overall cost to clients. Where the same model or subadvisor is offered by a TAMP sponsor and in another LPL advisory program, the total cost a client pays to access these through a TAMP sponsor, including amounts charged directly or indirectly for co-advisory or referral fees to paid LPL and the IAR could exceed the total inclusive cost for access to the same model or subadvisor through an alternative LPL advisory program. Advisory programs differ in overall features and functionalities offered, and an IAR may only recommend a program or service that he or she believes is suitable and in the best interest of a client. TAMP sponsors may offer one or more share classes per mutual fund in their investment models or programs. Share classes are different types of mutual fund shares that typically carry different levels of distribution or servicing fees and are available for purchase by different types of investors, and include, for example, “Class I, “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes. For LPL’s other advisory programs, mutual fund share classes are generally no-load or load-waived, however the share classes are, in many cases, not the least expensive share class that the mutual fund makes available. In the TAMP program, the TAMP sponsor or a model advisor or subadvisor determines which mutual fund share classes to use. The share classes chosen by the TAMP sponsor or other third-party adviser may be more or less expensive to clients than those available in LPL’s other advisory programs. Therefore, clients may be able to purchase the same mutual funds outside of the TAMP program for lower fees. Client should be aware that securities transferred into a TAMP account may have been subject to a commission or sales load when the security was originally purchased. After transfer into a TAMP 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. 8 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure Customized Advisory Services, IPA, OPA and Other Participant Advice Services Fees for customized, individual participant, off-platform and other participant advisory services are typically based on the value of assets under management and will vary by engagement. The amount of the fee will be set out in the client agreement executed by the client at the time the relationship is established. The maximum advisory fee is generally 1.5% and is negotiable between the IAR and the client, and is typically payable in arrears but may also be deducted in advance, as described in the client agreement with the custodian. The advisory fee will be paid to LPL, and LPL shares between 70% and 100% of the advisory fee with the IAR based on the agreement between LPL and the IAR. The portion of the advisory fee received by IAR may be more than what the IAR would receive at another investment advisor firm. A custom program account may be terminated according to the client agreement. If the client agreement provides for payment in advance, the agreement will state how the client can obtain a refund of any pre-paid fee if the agreement is terminated before the end of the billing period. LPL may also offer certain of its participant advice platforms to separately registered investment advisers. In such situations, LPL does not serve in an advisory or brokerage capacity to plan sponsors or participants. In certain cases, LPL serves as the broker-dealer on transactions in a customized advisory account. In such cases, LPL charges the client transaction charges in connection with trade execution through LPL. The transaction charges will be clearly stated in the client agreement executed by the client at the time the relationship is established. If the custom advisory services apply to variable annuities or variable universal life insurance products for which the IAR receives trail compensation, such trail fees generally will be used to offset the advisory fee. In most cases, however, a third- party broker dealer will provide trade execution. In such case, the broker-dealer charges clients commissions, markups, markdowns and/or transaction charges. For OPA, LPL receives compensation of up to 0.35% annually of LPL client assets invested in the money market sweep fund designated for investment of any cash balances under the program. This fee is paid to LPL by the fund sponsor for administration and service-related support that LPL provides the fund and is not shared with the IAR. Clients should refer to the general information provided above for TAMP programs regarding other fees and charges imposed by third parties as often similarly apply to a custom advisory, IPA, OPA, participant, or other custom advice services. Clients should also closely review any agreements, disclosures or offering documents provided by the custodians for these custom programs and the product sponsors. 529 Savings Plan Account Management LPL currently does not charge a separate fee for its 529 savings plan account management advisory services. However, clients may obtain separate services from LPL and IAR that involve the payment of fees or commissions for those services. Client will incur fees and charges imposed by third parties other than LPL and IAR, including fees charged by the Plan Manager or Administrator, 12b-1 fees and administrative servicing fees, recordkeeping and other service provider fees. The investment options made available in a 529 savings plan include mutual funds and ETFs, and, therefore, there are two layers of advisory fees and expenses for those assets. As a shareholder of a fund, clients will pay an advisory fee to the fund manager and other expenses charged by the fund. The program utilizes no-load or load-waived share classes that are not subject to any upfront sales charge. Clients should understand that in many cases the mutual funds and mutual fund share classes offered through a 529 savings plan charge higher fees and expenses than those that are not offered through the plan, and such other mutual funds and share classes may be equally or more appropriate for a client’s account. Other financial services firms may offer the same mutual funds that are offered through the 529 savings plan but at lower overall costs to investors than the costs that clients incur by investing through the 529 savings plan. 9 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure Clients should also understand that in many cases the share class offered for a particular mutual fund available through the 529 savings plan charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the 529 savings plan. Research Services There are certain LPL Research services that are part of a bundled service offering to other investment firms for which LPL does not charge a separate fee. LPL Research also offers stand-alone investment research and consulting services for a maximum annual fee of $125,000. The actual fee charged will depend on the size and sophistication of the investment firm. As compensation for the investment consulting services LPL provides to the investment advisor to the Optimum Funds, LPL receives an investment consulting fee of up to 0.22% of assets from such investment advisor. Bank Wealth Program For BWP, Institutions pay an advisory fee set forth in the agreement between Institution and LPL. The base fee is typically a percentage of the assets held in each SMA or UMA account, as applicable. The fee varies depending on which investment model the Institution chooses, for example, its own model or a third-party manager model. If the base fee falls below a minimum amount, which is set forth in the agreement and varies by Institution, the Institution is still responsible for paying the minimum amount. Additional fees may or may not be charged for additional services, such as tax management services or strategist services. BWP also may provide reporting services on brokerage accounts, and a flat annual fee is charged for such services. Item 6: Performance Based Fees and Side-By-Side Management This Item is not applicable. LPL and its IARs do not accept performance-based fees. Item 7: Types of Clients LPL’s advisory services are available for individuals, individual retirement accounts (IRAs), banks, thrift institutions, credit unions, pension and profit sharing plans, including plans subject to ERISA, participants in such plans, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. LPL does not require a minimum asset amount for financial planning and consulting services, participant consulting or research services. For customized advisory services, any required minimum account value will be set out in the client agreement. For TAMPs, the TAMP sponsor typically establishes a minimum account value, which will be set out in the account opening documents and Form ADV Part 2A of the TAMP sponsor. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss The IAR has access to various LPL and third party research reports and model portfolios to which he or she may refer in determining investment advice to clients. The IAR chooses his or her own research methods, investment style and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research makes recommendations regarding asset allocation, mutual funds, variable annuity and variable universal life insurance subaccounts and money managers. IARs may or may not follow these recommendations in providing investment advice. LPL Research also constructs asset allocation model portfolios and provides recommendations on the funds to populate those models. In constructing these models, LPL Research uses the 10 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure following investment strategies: Diversified and Alternative Strategy. Although these descriptions are written in terms of individual equities and/or bonds, they include mutual funds or ETFs whose portfolios consist of the type of equities or bonds referenced. • Diversified. The Diversified investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. The strategy is subject to minimal constraints, which allows for a relatively pure implementation of LPL Research’s investment advice. In general, Diversified portfolios should be considered by investors seeking investments in primarily stocks and bonds, along with the occasional non-traditional asset class to take advantage of potential market opportunities. Diversified portfolios will hold primarily traditional asset classes. Secondarily, if a non-traditional asset class represents the investment that provides the most appropriate means of taking advantage of a market opportunity, it will be included in the recommendation. The non-traditional investments included in Diversified portfolios are more standard, such as conservative balanced strategies. Diversified portfolios tend to be steady in their number of positions. These portfolios tend to remain consistently diversified. • Alternative Strategy. The Alternative Strategy investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. Unlike the Diversified investment strategy, which may have an allocation to alternative strategy or non-traditional assets classes, this portfolio typically has an allocation to non-traditional asset classes. This strategy extends the diversification beyond the core style box asset classes into strategies with lower correlation to stocks and bonds in order to lower risk, as defined by standard deviation and maximum drawdown (peak to trough loss), while attempting to maintain long-term performance similar to other portfolios in the same investment objective. For each of the above investment strategies, LPL Research recommends a strategic or tactical version. • Strategic. Strategic portfolios typically have a three- to five-year time horizon. The allocations within these portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout that time frame. Although LPL Research recommends investments through a three- to five-year lens, LPL Research may recommend that these portfolios be traded for fine tuning throughout the year. For clients who take a longer term view or are more tax sensitive, a strategic implementation may be more appropriate. • Tactical. Tactical portfolios are more flexible and are designed to help take advantage of short-, mid-, and long- term opportunities the markets present. LPL Research recommends that these portfolios invest in opportunities for as short as one week and as long as five years. Due to the tactical nature, the trading is notably more frequent than strategic portfolios. Tactically managed portfolios should be considered by clients who wish to take advantage of shorter-term market opportunities that may arise and are not opposed to the prospect of more frequent trading. Types of Investments and Risks Depending on the type of service being provided, LPL and IARs can recommend different types of securities, including mutual funds, unit investment trusts (UITs), closed end funds, interval funds, ETFs, collective investment trusts, variable annuity or variable universal life insurance subaccounts, equities, fixed income securities, options, hedge funds, managed futures, and structured products. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that an IAR can recommend depending on the service provided. • 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. 11 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped 12 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Alternative Strategy Mutual Funds. Certain mutual funds invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. 13 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts, and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax-managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Options. Option trading is permitted in certain programs. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and the account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (naked). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can 14 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (Single Inverse ETPs), futures-linked ETPs (Futures Linked ETPs) and cryptocurrency-related ETPs (Cryptocurrency ETPs). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the- counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Structured Products. Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. 15 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure • Hedge Funds and Managed Futures. Hedge and managed futures funds may be purchased by clients meeting certain qualification standards. Investing in these funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices and the lack of liquidity and performance volatility. In addition, these funds are not required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Client should be aware that these funds are not liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the fund, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the fund during the repurchase offer. • Business Development Companies (BDCs). BDCs are typically closed-end investment companies. Some BDCs primarily invest in the corporate debt and equity of private companies and may offer attractive yields generated through high credit risk exposures amplified through leverage. As with other high-yield investments, such as floating-rate/leveraged loan funds, private real estate investment trusts (REITs) and limited partnerships, investors are exposed to significant market, credit and liquidity risks. In addition, fueled by the availability of low-cost financing, BDCs run the risk of over-leveraging their relatively illiquid portfolios. Due to the illiquid nature of non-traded BDCs, investors’ exit opportunities may be limited only to periodic share repurchases by the BDC at high discounts. • REITs. REITs invest in real estate, and there are special risks associated with investing in real estate, including, but not limited to, sensitivity to changes in real estate values, the risk of investment loss due to the use of leveraging and other speculative investment practices, interest rate risk, lack of liquidity and performance volatility. Non-Traded REITs are not required to provide annual valuations until two years and 150 days after reaching the minimum capital raise required to begin purchasing properties. This threshold is generally outlined in the product’s prospectus. Non-Traded REITs may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to invest in new assets. Clients should be aware that these securities may not be liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the security, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the security during the repurchase offer. Issuers may repurchase shares at a price below net asset value. The repurchase program may also be suspended under certain circumstances. • Private Equity Funds. Private equity investments are speculative and involve significant risks. It is possible that investors may lose some or all of their investment. The risks associated with private equity include: limited diversification, the use of leverage, and limited liquidity. The investment timeline for private equity can be a decade or more. Some issuers or general partners may penalize limited partners who redeem before holding units for a specified amount of time, or may disallow redemptions entirely. • Variable Annuities and Variable Universal Life Insurance Products. If client purchases a variable annuity or variable universal life insurance product that is part of the program, client will receive a prospectus and should rely solely on the disclosure contained in the prospectus with respect to the terms and conditions of the variable annuity or variable universal life insurance product. Client should also be aware that certain riders purchased with a variable annuity or variable universal life insurance product may limit the investment options and the ability to manage the subaccounts. Additionally, the decision to liquidate an annuity prior to its maturity date may result in surrender charges and a complete loss of certain benefits for which significant fees may have previously paid to the annuity issuer. Death benefit guarantees of variable universal life insurance products are subject to the claims paying ability of the carrier or issuer. • Other Annuity Products. If client invests in other annuity products, client should be aware of the specific risks and limitations of such products. If client purchases an annuity product that is part of the program, client will receive a prospectus with respect to the terms and conditions of the annuity product. Some products may charge a recapture or redemption fee for contracts or benefits not held for a specified period of time or that do not follow stated withdrawal terms. Registered Index Linked Annuities (RILAs) are insurance products tied to the 16 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure performance of a market index, offering the positive returns of the index up to a cap and providing a buffer for a certain level of negative returns. RILAs are subject to risks associated with other investment products, including market risk, and the total loss of principal is possible. • Non-traded Products. Non-traded products do not trade on a securities exchange and are not publicly traded. Consequently, non-traded products can be riskier than products that are publicly traded because the product cannot be sold readily in a market by the investor. The non-traded product may offer to redeem shares from investors, but such share redemptions are typically subject to limitations. Share redemptions may also require that shares be redeemed at a discount and there is no guarantee that client will be able to redeem the security during the repurchase offer. In addition, non-traded products may lack share value transparency because there is no market price readily available. Without share value transparency, investors may not be able to assess the value or performance of the non-traded product. • Collateralized Lending Program. For eligible programs, LPL allows clients to pledge securities in their accounts as collateral for non-purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-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. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship with LPL and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL and its IARs for the pledged assets. For a list of 17 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure in LPL’s collateralized the third-party banks currently participating 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • 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. • Cyber Security Risk. Failures or breaches of the electronic systems of LPL, its services 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. • 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. • Comparable Products. LPL offers various mutual funds, ETFs and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and its IARs generally will earn more compensation for selling one investment product than another. As a result, LPL and its IARs have a conflict of 18 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. • Company Stock. If company stock is available as an investment option to client in a retirement plan, and if client chooses to invest in company stock, client should understand the risks associated with holding company stock in a retirement plan. These risks may include, but are not necessarily limited to, lack of liquidity, over-dependency on client’s employer, and less flexibility to change the allocation of plan assets. Client should pay careful consideration to the benefits of a diversified portfolio. Although diversification is not a guarantee against loss, it can be an effective strategy to help manage investment risk. Item 9: 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 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: • 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 19 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure 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, 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). • 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). 20 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure • 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). 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. Item 10: 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, variable universal life insurance products, 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 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 may be 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, 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. If required 21 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure 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 client 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 an advisory 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 OPA 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. 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 and consulting 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, corporate trustee services, 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. 22 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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 LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPL does not permit its IARs to recommend or solicit orders of LPL Financial Holdings Inc. stock. However, LPL or an IAR may recommend or purchase for clients a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. As part of financial planning and consulting services, an IAR may or may not provide recommendations as to investment products or securities. To the extent that IAR recommends that client invest in products and services that will result in compensation being paid to LPL and the IAR, this presents a conflict of interest. The compensation to IAR and LPL may be more or less depending on the product or service that the IAR recommends. Therefore, the IAR has a financial incentive to recommend that a financial plan or consulting advice be implemented using a certain product or service over another product or service. The client is under no obligation to purchase securities or services through LPL and the IAR. If the client decides to implement the recommendations received pursuant to a financial plan or consulting services through an LPL advisory program or service, the IAR will provide client at the time of engagement with a Brochure, client agreement and other account paperwork that contain specific information about fees and compensation that the IAR and LPL will receive in connection with that program. The Brochures are also available at https://adviserinfo.sec.gov If the client desires instead to purchase securities in a brokerage account through IAR acting as a registered representative of LPL, LPL and IAR will receive brokerage-related compensation for those services, such as commissions and/or trail fees. LPL provides information regarding such brokerage compensation at the time of a brokerage transaction and also on its website at lpl.com/disclosures.html. When considering whether to implement recommendations received pursuant to a financial plan or consulting services through IAR and LPL, clients should discuss with the IAR how LPL and IAR will be compensated for any recommendations in the plan. It is important to note that clients are under no obligation to implement recommendations received pursuant to a financial plan or consulting services through LPL. Clients should understand that the investment products, securities, and services that an IAR recommends as part of financial planning and consulting services are available to be purchased through broker-dealers, investment advisors or other investment firms not affiliated with LPL. A portion of the fee to the IAR is, in certain circumstances, 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 23 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure receives a portion of this fee for supervision because the fee affects his or her ability to provide objective supervision of the IAR. Collateralized Lending Program For eligible programs, LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with its IARs, and therefore, an IAR does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with its IARs, and therefore, an IAR has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your IAR’s compensation on the SCA product is reduced if your interest rate is discounted, so your IAR has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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, or alternatively, could incentivize the IAR to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. 24 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure 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 the 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 either general investment education or a recommendation 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 IAR 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 the 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. OPA Program – Mutual Fund and Recordkeeping Serving Fees LPL charges mutual fund sponsors a one-time setup fee up to $15,000 as a sponsor level due diligence fee and a setup fee of $7,500 per fund. Additionally, Client should be aware that mutual funds offered under OPA typically charge fees such as subtransfer agent fees, networking fees and omnibus processing fees, a portion of which are received by LPL for recordkeeping and other administrative services it provides to the mutual fund sponsors, and which varies among the available mutual funds. The amount of such fees is described in the mutual fund’s prospectus under fund expenses and is also reflected on the fund’s financial statements. The mutual fund sponsors typically compensate LPL for the administrative services it provides based on client assets invested in the sponsor’s mutual funds at an annual rate of up to 0.15% for individual plans (e.g., SEPs, SIMPLEs, etc.) and up to 0.25% for group plans (e.g., 403b, 457, etc.). Client should understand that the share class offered for a particular mutual fund through OPA in many cases will not be the 25 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure least expensive share class that the mutual fund makes available. As a result, LPL will not achieve best execution for purchases of share classes that are more expensive because the recordkeeping and other expenses make it a more expensive share class than Client otherwise would be eligible to purchase had LPL chosen to make that share class available. Client understands that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through OPA. These compensation arrangements with mutual funds sponsors result in a conflict of interest between clients and LPL because they give LPL an incentive to recommend investments that may result in higher compensation for certain mutual funds than others and could cause lower performance for client accounts. However, these conflicts are mitigated insofar as the fees LPL receives from mutual fund sponsors are not shared with the IAR who selects or recommends the investment products for client. TAMP Investment Advisory – Members Trust Pursuant to networking agreements with TruStage Wealth Management Solutions, a marketing name of CUNA Brokerage Services, Inc. (“CBSI) and various credit unions, LPL offers its investment programs through IARs who are also employees of CMFG Life Insurance Company (“CMFG”) or the associated credit unions, and CBSI shares in a portion of the revenue generated at these credit unions. As disclosed above, LPL provides access to Members Trust Company (“MTC”) as a TAMP sponsor in the TAMP Program. CMFG, an affiliate of CBSI, holds a minority ownership interest in MTC, and, at the time of this brochure’s publication, has associated person(s) serving on the MTC Board of Directors. IARs who are employees of CMFG or its affiliates have a conflict of interest in recommending MTC as a TAMP sponsor because of the financial benefit to CBSI. Further, certain credit unions are also partial owners of MTC – including without limitation at the time of this publication, CEFCU, SchoolsFirst Credit Union, Suncoast Credit Union and Teachers Credit Union – and their employee IARs thus also have a conflict of interest due to the ownership interests and discretionary compensation these credit unions indirectly receive from MTC to assist with funding their operations. However, these IARs do not receive any individual incentives to recommend MTC over other TAMPs, and LPL receives no additional benefit. Other Clients Client should understand that LPL and IAR perform advisory and/or brokerage services for various other clients, and that LPL and IAR may give advice or take actions for those other clients that differ from the advice given to the client. The timing or nature of any action taken for the account may also be different. In addition, LPL and IAR may, but are not obligated to, purchase or sell or recommend for purchase or sale any security which LPL or IAR or any of their affiliates may purchase or sell for their own accounts or the account of any other client. Item 12: Brokerage Practices LPL does not receive research or other products or services other than execution from a broker-dealer in connection with client securities transactions (soft dollar benefits). LPL does not consider, in selecting or recommending broker- dealers, whether LPL or a related person of LPL receives client referrals from a broker-dealer or third party. In connection with TAMP programs, the TAMP sponsor may require that clients direct brokerage to a broker-dealer, including the TAMP sponsor or broker-dealer affiliated with the TAMP sponsor. In addition, in connection with customized advisory services, the client may direct that transactions be executed through LPL or specified third party broker-dealer. Clients should understand that not all advisors require their clients to direct brokerage. By directing brokerage to a broker, clients may be unable to achieve the most favorable execution of client transactions and may pay more in transaction charges than other broker-dealer firms. Therefore, directed brokerage may cost clients more money. For more information about the brokerage practices of a TAMP sponsor, clients should refer to the disclosure brochure for the applicable TAMP. For customized advisory services, IARs may aggregate transactions in equity and fixed income securities for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased 26 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure or sold its proportionate share of the securities involved at the average price obtained. For partially filled orders, the IAR generally will allocate trades pro-rata or on a random basis to treat clients fairly and not favor one client over another. IARs may determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, the liquidity of the securities and the discretionary or non-discretionary nature of the trades. If IARs do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. Please ask your IAR if you would like more information on the IAR’s practices in this respect. Item 13: 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. For financial planning and consulting services, clients are encouraged to promptly inform the IAR of any changes to their financial circumstances and investment goals, and to consult and update their financial plans annually. Such consultations and annual reviews are conducted at the election of the client as determined with their IAR and may consist of an updated personal financial plan or recommendations if the client’s circumstances and/or goals have changed. Alternatively, the review may be a comparison of the client’s current assets and goals (in the form of a progress report or update). For TAMP services, 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, quarterly performance information, and other information or data related to the client’s account and investment objective. The TAMP sponsor or custodian of the TAMP account assets send clients regular written reports and statements regarding the account. For customized advisory services, IARs review client accounts on an ongoing basis to provide management services. IARs review monthly or quarterly account statements provided by the custodian. In addition, LPL reviews accounts using risk based criteria such as performance, trading activity, and concentration. The Advisory Chief Compliance Officer of LPL oversees the process for reviewing customized accounts. To the extent LPL acts as broker-dealer and has custody of assets in a customized program account, LPL will transmit to clients required trade confirmations and monthly or quarterly account statements. Such statements show all transactions in cash and securities and all deposits and withdrawals of principal and income during the preceding calendar month or quarter depending upon activity. Item 14: Client Referrals and Other Compensation 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, marketing events or advertising initiatives, including services for identifying prospective clients. Product sponsors also pay for, or reimburse LPL for the costs associated with, education or training events that are attended by LPL employees and IARs and for LPL-sponsored conferences and events. For example, LPL receives marketing and educational support payments of up to $260,000 annually from recordkeepers and retirement plan product sponsors for access to data analytics, and to participate and present at LPL education and training events for IARs. Any such support payments are not tied to the sales of any products or client assets in the products. IARs do not receive any portion of these payments. 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. For a current and complete list of the product sponsors that pay such marketing and educational support payments, please see lpl.com/disclosures.html or ask your IAR. 27 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 sales employees have an incentive to promote certain advisory programs 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 do transition brokerage accounts to advisory. The IAR recommending a TAMP program to the client receives compensation as a result of the client’s participation in the program. This compensation includes a portion of the advisory fee or referral fee and other compensation, such as bonuses, awards or other things of value offered by the TAMP to the IAR. For example, some TAMPs pay additional marketing payments to LPL, its employees and/or IARs to cover fees to attend conferences or reimbursement of expenses for workshops, seminars presented to clients or advertising, marketing, or practice management. The eligibility of an IAR to receive such reimbursements and the amount of such reimbursements are based on the amount of assets referred by the IAR to the TAMP. The amount of this compensation may be more or less than what the IAR would receive if the client participated in LPL advisory programs, programs of other investment advisors or paid separately for investment advice, brokerage, and other client services. Therefore, in such case, the IAR has a financial incentive to recommend a TAMP program account over other programs and services. LPL has entered into solicitor referral agreements with certain TAMP sponsors listed under Item 4 “Third Party Asset management Program” pursuant to which LPL and IARs receive referral fees from the TAMP sponsors in return for referring clients. Referrals to TAMP sponsors are subject to restrictions imposed by LPL. Because LPL is engaged by and paid by the TAMP sponsor for the referral, any recommendation of a TAMP sponsor as part of a referral presents a conflict of interest. LPL addresses this conflict by disclosing the role of LPL and IAR, and the referral fee we receive, when making a referral. For more information regarding these arrangements, see Item 4 above. LPL and its IARs may serve as broker-dealer of record on accounts managed by the independent third-party investment advisor. In such case, LPL and its representatives receives normal and customary compensation (e.g., commissions, 12b-1 fees, trails) from the sale of mutual funds or variable annuities in such accounts. This compensation is in addition to the solicitor fee paid by the third-party investment advisor. In addition, LPL enters into other agreements with TAMP sponsors or third-party investment advisers to whom LPL refers clients, pursuant to which LPL provides (i) marketing services on behalf of the third party investment advisers to LPL representatives; or (ii) data technology services to integrate third party investment adviser account data on LPL’s technology systems. LPL receives fees for these data technology services and such fees may be a flat upfront or annual fee or be based on the amount of assets (up to 10 basis points) recommended or referred by LPL to the TAMP or the third-party investment adviser. Please refer to lpl.com/disclosures.html for current information about any third- party investment adviser that pays this compensation. The IAR does not share in these fees. Any agreements related to referrals are separate from the services provided by LPL or its IARs. In some cases, the third-party investment advisers pay additional marketing payments to LPL, its employees and/or IARs to cover fees to attend conferences or reimbursement of expenses for workshops, seminars presented to IARs clients or advertising, marketing or practice management. 28 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure 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: • Referral Networks. Some third parties operate referral networks. Referral networks may present potential clients with a list of possible investing firms and investment adviser 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 advisory fee; • 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; • 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; • 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 • 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’s participation in these referral arrangements does not diminish its fiduciary obligations to its clients. 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 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 29 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure 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 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: • payments based on production • 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 • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • payments in the form of repayable or forgivable loans • advances of advisory fees • 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 one program than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in that program 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 one program at a lower overall fee rate than the fee rate for a program offering a third-party manager. However, IAR may only recommend a program or service that he or she believes is suitable and in the best interest 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 30 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure 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 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, and in cases of businesses not supported by LPL, to further recommend that a client’s current holdings be reinvested in a program offering LPL does support. 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. Unaffiliated Financial Institutions LPL and its IARs offer advisory services on the premises of unaffiliated businesses, including insurance companies, employee benefit companies, and financial institutions, such as 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 financial institutions pursuant to which LPL typically shares compensation, including a portion of the advisory fee, with the financial institution for benefits including but not limited to the use of the financial institution’s facilities and for client referrals. Instead of paying the IAR the portion of the advisory fee as described above, LPL shares the advisory fee with the financial institution, and the financial institution pays part of 31 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure that amount to the IAR based on a compensation plan between the IAR and the financial institution. 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. The compensation plan determines the amount of compensation the IAR receives. IARs 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. LPL also has agreements to provide similar services at financial institutions in which compensation is not shared with the financial institution whereby a portion of the account fee is paid directly to the IAR. 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. Some of these financial institutions may be 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 paid by the client 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 affiliated products and the IAR may only recommend an investment product that he or she believes is appropriate, suitable and in the best interest of the clients. LPL reviews and selects investment products for its programs 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 a 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 financial 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 pays 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 to assist with offsetting time and 32 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure 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 financial 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 recommends 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 of the financial institution 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 and such referral programs are governed by Regulation R of the Gramm-Leach-Bliley Act. Employees of trust departments at certain financial institutions are authorized under the terms of applicable trust arrangements to delegate investment advisory 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. 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. Item 15: Custody For TAMP programs, 529 Savings Plan Account Management services and generally for customized advisory services, client assets are maintained at a custodian other than LPL. In such case, the client will complete account paperwork with the outside custodian that will provide the name and address of the custodian. The client will receive statements and reports directly from the custodian, rather than from LPL. Clients should refer to the statements and reports that they receive from the custodian or TAMP sponsor. Clients should review these statements and reports carefully. For BWP, IPA, OPA and other custom advice services, client’s assets are typically maintained at a custodian other than LPL. For example, IARs may provide management services under the IPA program for participant self-directed retirement plan accounts custodied at Charles Schwab or TIAA-CREF. The retirement plan sponsor (e.g., the client’s employer) or the client is responsible for selecting the custodian for retirement plan assets to the extent permitted by the plan. For certain services described in this brochure (e.g., hourly consulting services), LPL may receive prepayment of fees for 6 or more months in advance. For LPL’s Strategic Asset Management, Manager Select, Manager Access Select, Personal Wealth Portfolios, Optimum Market Portfolios, Model Wealth Portfolios, and Guided Wealth Portfolios programs, which are described in separate disclosure brochures, LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody of client funds and securities in a separate account for each client under the client’s name. LPL as a qualified custodian for those program accounts 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. If clients 33 A58 – 0326 LPL Financial, Member FINRA/SIPC  LPL Financial Firm Brochure would like more information on such programs, clients should contact the IAR for a copy of the program brochure that describes such program or go to https://adviserinfo.sec.gov. Item 16: Investment Discretion With respect to financial planning and consulting services, LPL and the IAR do not have any discretionary investment authority, and do not implement or monitor any recommendations provided to clients. For services under the IPA or OPA program, the IAR typically is granted investment discretion in the advisory agreement. For customized advisory services, the IAR may provide management services on a discretionary or non-discretionary basis as stated in the client agreement. For its overlay portfolio management services, LPL has discretion to trade accounts based on investment models, and to manage accounts according to investment restrictions and tax efficient strategies. For LPL’s Manager Select, Manager Access Select, Personal Wealth Portfolios, Optimum Market Portfolios, Model Wealth Portfolios and Guided Wealth Portfolios programs, which are described in separate disclosure brochures, LPL has discretionary investment authority. For the Strategic Asset Management program, discretion is typically limited to certain security types, but the client can agree to expand or limit the discretionary authority granted to LPL and IAR. For TAMPs, the client typically authorizes the third-party investment advisor to purchase and sell securities on a discretionary basis pursuant to the investment objective chosen by the client. This authorization will be set out in the TAMP client agreement. LPL and the IAR generally do not have discretion on TAMP program accounts subject to limited exceptions on an accommodation basis. For 529 Savings Plan Account Management advisory services, the client typically grants IAR and LPL complete and unlimited discretionary trading authority with respect to the purchase and sale of the available investment options within the client’s account. Item 17: Voting Client Securities LPL does not accept authority to vote client securities in connection with any of the services described in this Brochure. LPL does accept authority to vote client securities in connection with certain of its advisory programs. Please see the brochure for each program for more information. Item 18: Financial Information LPL is a qualified custodian as defined in Rule 206(4)-2, and is therefore not required to include a balance sheet for its most recent financial fiscal year. 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 the IARs responsible for the individualized investment advice provided to a particular client. For more information about the IAR servicing the client, 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. 34 A58 – 0326 LPL Financial, Member FINRA/SIPC 

Manager Select Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This wrap fee 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 your LPL 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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 ............................................................................................................. 7 Item 6 Portfolio Manager Selection And Evaluation............................................................................................................. 7 Item 7 Client Information Provided To Portfolio Managers ............................................................................................... 16 Item 8 Client Contact With Portfolio Managers .................................................................................................................. 17 Item 9 Additional Information .............................................................................................................................................. 17 MS302 – 0326 LPL Financial, member FINRA/SIPC 1  Manager Select Program Brochure 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 Manager Select program. For more information about LPL’s advisory services and programs other than Manager Select, 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 IARs are typically also registered with LPL as a broker-dealer registered representative. Therefore, in such cases, an IAR is 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. In the Manager Select program, LPL, through its IARs, makes available to clients the investment advisory services and/or model portfolios of third-party portfolio management firms. Within the Manager Select program, LPL offers two alternatives – the Separately Managed Account Platform (the SMA Platform) and the Model Portfolio Platform (the “MP Platform” and collectively, the “Platforms”). In connection with the Platforms, LPL acts as an investment advisor, serves as the custodian of the assets, provides brokerage and execution services as a broker-dealer on transactions, and performs administrative services, such as reporting to clients. The IAR assists the client to determine the client’s investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and, in the case of the SMA Platform, to select an investment strategy and SMA Portfolio Manager, or in the case of the MP Platform, to select a model portfolio (Model Portfolio) provided by LPL Research or third-party investment advisors (Model Advisors). The Manager Select program also permits clients to select a third- party investment advisor firm typically associated with an LPL registered representative, in lieu of an LPL investment adviser representative (IAR) to provide the advisory services of the IAR described in this brochure. The IAR cannot change the SMA Portfolio Manager or Model Advisor selected for the client’s account without client’s approval. 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. MS302 – 0326 LPL Financial, member FINRA/SIPC 2  Manager Select Program Brochure SMA Platform In the SMA Platform, the IAR assists the client to determine the client’s investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and to select an investment strategy and SMA Portfolio Manager. The IAR provides the client with ongoing advice and monitoring relating to the SMA Portfolio Manager’s services and serves as the point of contact between the client and the SMA Portfolio Manager with regards to changes in the client’s investment objective, financial situation, and investment restrictions. The SMA Portfolio Manager selected by the client provides ongoing discretionary investment advice regarding the investment and reinvestment of account assets in accordance with the investment objective, restrictions and guidelines set forth in the Application or in other agreed-upon written instructions. The SMA Portfolio Manager independently determines whether to accept the client account based on the content of the Account Application, suitability and whatever other factors the SMA Portfolio Manager deems appropriate. The SMA Portfolio Manager has the sole authority to determine the securities to be purchased, sold, or exchanged and which portion, if any, of the assets shall be held uninvested. The SMA Portfolio Manager has discretion to invest among a broad variety of security types, including equities, fixed-income securities, options, mutual funds, and exchange-traded funds (ETFs). LPL and IAR do not play a role in the selection of particular securities to be purchased or sold. A SMA Portfolio Manager may hire one or more sub-advisors to manage all or a portion of a client’s account. MP Platform In the MP Platform, the IAR assists the client in setting an appropriate investment objective and selecting a model portfolio (Model Portfolio) provided by LPL Research or third-party investment advisors (Model Advisors). The IAR provides the client with ongoing advice and monitoring relating to the Model Portfolio, is available on an ongoing basis to receive deposit and withdrawal instructions, and to convey to LPL any changes in Client’s financial circumstances, investment objectives or investment restrictions. Under the MP Platform, LPL provides ongoing discretionary investment advice regarding the investment, reinvestment, and the rebalancing of account assets in accordance with the Model Portfolio selected by the client. LPL is expected to closely track the Model Portfolio, making modifications only to address particular account issues, including tax loss harvesting, rebalancing, short-term gain avoidance, cash inflows and outflows, and tracking error from the Model Portfolio, and to ensure that investment restrictions are being followed. 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. Fee Schedule In the Platforms, clients pay LPL an annualized fee (Account Fee). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the client changes the model selected for the Account, or if the model investment value changes, the overall Account Fee may increase or decrease. 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, IARs, SMA Portfolio Managers and Model Advisors do not charge performance-based fees to accounts in the Platforms. Advisory Fee. The Advisory Fee is charged for the investment advisory services of IAR, as well as the investment advisory, administrative, trading and custodial services of LPL. The Advisory Fee is shared with the IAR. The Advisory Fee is negotiable between the client and the IAR and is based on the value of all assets in the account, including cash holdings, and is payable quarterly in advance. The maximum Advisory Fee is 2.35%, although certain legacy accounts may remain higher, so long as the maximum combined Advisory Fee and Manager Fee is no more than 2.95%. Upon request, the Advisory Fee also can be structured on a tiered basis and/or grouped basis, with a reduced percentage rate based on reaching certain thresholds in the Account or in a group of eligible advisory accounts. LPL retains a portion of the Advisory Fee, up to 0.35% of the value of the assets of the account, for its investment advisory, administrative, custody and clearing services. LPL shares up to 100% (typically between 90% to 100%) of the remaining portion of the Advisory Fee with the IAR based on the agreement between LPL and the IAR. LPL retains any portion of the Advisory Fee not shared with 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 3  Manager Select Program Brochure 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. Manager Fee. The Manager Fee is charged for the services provided by Model Advisor or SMA Portfolio Manager, as applicable. Clients do not pay LPL or IARs brokerage commissions or transaction charges for execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Clients pay a Manager Fee set by LPL for services provided by the SMA Portfolio Manager in the case of the SMA Platform and for use of the model portfolio of the Model Advisor in the case of the MP Platform. The Manager Fee is based on the value of all assets in the Account, including cash holdings, and payable quarterly in advance. This fee ranges from 0% to 0.60%. The amount of the Manager Fee will differ depending on the SMA Portfolio Manager or Model Advisor selected for Account, and also may vary depending on which investment strategy or Model Portfolio is selected. For Model Portfolios in the MP Platform, LPL charges up to 0.05% of account assets per year for the costs and services associated with effecting trades to implement the models, such as order formation, execution, settlement and sleeving of transactions. This LPL fee trading services is reflected in the Manager Fee on client statements. Generally, LPL charges 0.05% of account assets per year for models transacting primarily in equities, and LPL charges 0.03% of model assets per year for models transacting primarily in fixed income or other over-the-counter securities. For certain Model Portfolios designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL either charges a Manager Fee as Model Advisor or charges a fee for trading services, there is a conflict of interest for LPL to recommend such models. When acting as Model Advisor, LPL does not charge the Manager Fee to retirement accounts; however, LPL charges the fee for trading services to retirement and nonretirement accounts to the extent permissible under applicable law. The IAR does not receive any portion of the Manager Fee, including based on recommending a model for which LPL retains this compensation. Information about your model and fee rates can be requested from IAR. Certain Model Advisors or SMA Portfolio Managers receive a reduced Manager Fee or do not receive a Manager Fee. This is often because the Model Advisor or SMA Portfolio Manager has included proprietary or affiliated mutual funds or exchange-traded funds in the Model or Investment Strategy which charges a management fee. This management fee can be found in the prospectuses of the mutual funds or exchange traded funds included in the Model or Investment Strategy. Because a Model Advisor, SMA Portfolio Manager or their affiliates benefit financially when an affiliated fund is selected, there is a conflict of interest that affects the Model Advisor or SMA Portfolio Manager’s ability to provide unbiased, objective investment advice concerning the selection of funds for a Model or Investment Strategy. The fees paid to SMA Portfolio Managers in the SMA Platform and to Model Advisors in the MP Platform are generally less than fees those advisors would charge a client seeking to establish a direct relationship with them outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, and marketing expenses that would otherwise be borne by those advisors, including trading expenses for Model Advisors. SMA Portfolio Managers and Model Advisors generally have higher minimum account size requirements and fees for direct accounts because of such additional expenses. From time to time, LPL may make available Model Portfolios provided by third-party Model Advisors with associated persons who are also associated persons of LPL; however, if a client selects one of these associated persons to act as IAR for their account, such Model Advisor will not receive a separate Manager Fee for its services as a model provider. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a Manager Select account from the account. LPL pays the applicable portion of the Account Fee to the SMA Portfolio Manager or Model Advisor. 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. MS302 – 0326 LPL Financial, member FINRA/SIPC 4  Manager Select Program Brochure 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 pro-rated 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). Other Types of Fees and Expenses of LPL LPL charges fees related to a Manager Select account in addition to the Account Fee, such as miscellaneous administrative or custodial-related fees and charges. 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, an annual Individual Retirement Account (IRA) maintenance fee, an annual qualified retirement plan maintenance fee, 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 miscellaneous fees are not directly based on the costs of the transaction or service by LPL, can include a profit to LPL, and certain of the fees may be lowered or waived for certain clients. As described below under “Additional Information - Participation in Client Transactions,” if LPL as broker-dealer executes a principal transaction in a Manager Select account, LPL earns a markup or markdown in addition to the Account Fee. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in SMA Platform and MP Platform accounts. As described below under “Additional Information – Brokerage Practices,” if a SMA Portfolio Manager chooses to execute a transaction through a broker-dealer other than LPL, the execution price to the client may include a commission, markup/markdown, or other fee imposed by the executing broker-dealer in addition to the Account Fee. If client holds an American Depositary Receipt (“ADR”) in an account, there can be custodial fees or taxes related to the ADR. If a client’s assets are invested in mutual funds, ETFs or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Client will pay an advisory fee to the fund manager and other expenses charged by the fund. Client will also pay the Account Fee with respect to assets invested in such mutual funds, ETFs, or other pooled investment products. Clients generally can purchase mutual funds directly outside of the Program. Therefore, clients could avoid the second layer of fees by not using the advisory services of provided in the Platforms and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. Other financial services firm, 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” MS302 – 0326 LPL Financial, member FINRA/SIPC 5  Manager Select Program Brochure The cash sweep money market fund (Sweep Fund) used in the program may be managed by the same SMA Portfolio Manager that client has appointed to manage its account or be invested in a Model Portfolio provided by the same Model Advisor. If that is the case, clients should understand that the SMA Portfolio Manager or Model Advisor and its affiliates earn fees from the Sweep Fund for managing and performing other services for the fund which will be in addition to Account Fee charged to client. If client transfers into a Manager Select 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 Manager Select model. 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 a Manager Select 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 a Manager Select 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. For those Manager Select accounts investing in mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in Manager Select charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds (other than Sweep Funds described in the section of Item 9 labeled “Participation or Interest in Client Transactions”) will be credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on an Account • The Account Fee is an ongoing wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. The Account Fee may cost the client more than purchasing the program services separately, for example, paying fees for the advisory services of LPL, IAR and the SMA Portfolio Manager MS302 – 0326 LPL Financial, member FINRA/SIPC 6  Manager Select Program Brochure or Model Advisor, as applicable, plus commissions 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: – type and size of the account – 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. • It is important to note that a client may or may not be able to purchase advisory services directly from the SMA Portfolio Managers or Model Advisors, as they often do not offer such services for client accounts of the size typically associated with wrap programs. If they do offer such services to accounts the size of a program account, they often charge a higher fee as they do not enjoy the economies of scale related to providing services to clients of a wrap program. • 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 Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, the fees associated with the SMA Portfolio Manager or Model Advisor, and the 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 Advisory Fee with IAR. • 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 A minimum account value of $25,000 generally is required for the program. In certain instances, the minimum account size may be lower or higher. Note that an account will not be invested until the applicable minimum for the investment strategy or Model Portfolio has been reached. Clients should consult with IAR to obtain more information about the applicable investment minimum based on the strategy or Model Portfolio selected. The Platforms are available for individuals, 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 the Platforms, LPL and IAR are responsible for the investment advisory services related to the selection and retention of the SMA Portfolio Manager (in the case of the SMA Platform) and Model Advisor (in the case of the MP Platform). 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 servicing the account, client should refer to the Brochure Supplement for the IAR available from the IAR. LPL makes available the advisory services of SMA Portfolio Managers. LPL does not act as a portfolio manager for the SMA Platform. LPL does, however, act as portfolio manager for the MP Platform. Criteria for Participating and Recommended SMA Portfolio Managers and Model Advisors LPL selects and reviews SMA Portfolio Managers and Model Advisors for the Platforms based on quantitative, qualitative and infrastructure criteria, which include the criteria listed below. MS302 – 0326 LPL Financial, member FINRA/SIPC 7  Manager Select Program Brochure Quantitative Criteria LPL evaluates quantitative criteria, including but not limited to: • Rate of return • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Investment philosophy • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a SMA Portfolio Manager or Model Advisor can handle operational requirements, including but not limited to: • Composite calculation methodology • Trade rotation policy • Back office review • Client servicing resources • Firm-wide program commitment Additional Criteria for Recommended Managers or Model Advisors SMA Portfolio Managers or Model Advisors that are “Recommended” by LPL Research are subject to a more rigorous selection and review process than the criteria set out above that applies to all SMA Portfolio Managers and Model Advisors available in the program. In addition to the criteria noted above, additional evaluation criteria for Recommended SMA Portfolio Managers or Model Advisors include: • Sound investment philosophy and process that drives performance • Consistency of returns and risk • Qualitative assessment of the investment manager and team Clients should speak to the IAR regarding whether the SMA Portfolio Manager or Model Advisor being considered for selection or that has been selected by the client is Recommended or Participating. LPL as a Model Advisor Clients may invest in Model Portfolios designed by LPL Research. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Model Portfolios to meet different investor needs. LPL Research Model Portfolios are built by seeking certain quantitative characteristics for each portfolio using a rules-based, disciplined process for security selection and portfolio construction. LPL Research looks for specific characteristics or investment factors and designs a Model Portfolio to capture the investment results of that characteristic or factor. For example, one such Model Portfolio seeks to have index-like representation to reasonably track large cap index returns such as the Russell 1000 Index, while another focuses on dividends by seeking a yield premium over the index. The LPL Research Model Portfolios are managed tactically, which means they are flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of trading as frequently as monthly. MS302 – 0326 LPL Financial, member FINRA/SIPC 8  Manager Select Program Brochure The participation of LPL Research as a Model Advisor under the MP Platform gives rise to conflicts of interests. For certain model portfolios, LPL charges clients a Manager Fee. However, LPL will not charge this fee to retirement accounts. In addition, LPL has a financial incentive to select its internal team and further grow its assets under management, in part because as assets under management at LPL increase, the firm is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. However, the selection of LPL Research model portfolios has no impact on your IAR’s compensation and/or employment status, and your IAR may only recommend a model portfolio that he or she believes is appropriate for you and in your best interest. Removal of a SMA Portfolio Manager or Model Advisor LPL may elect to remove or replace a SMA Portfolio Manager or Model Advisor should it determine that the firm has failed to meet one or more of the above selection criteria or if the SMA Portfolio Manager or Model Advisor has failed to maintain sufficient assets under management at LPL to maintain profitability on the SMA Platform. In making a decision to remove or replace a SMA Portfolio Manager or Model Advisor, LPL takes into consideration all criteria; no one criteria, other than the maintenance of assets under management at LPL, is necessarily determinant in the decision. Short-term developments are monitored but are not necessarily sufficient for a decision to remove or replace a SMA Portfolio Manager or Model Advisor. While LPL would have the authority to remove the LPL Research Department as a Model Advisor, it is unlikely to do so. Portfolio Manager Performance LPL Research uses information provided by the portfolio manager and may also use independent, third-party databases when evaluating a SMA Portfolio Manager or Model Advisor. In order for a SMA Portfolio Manager or Model Advisor to be selected for the Platforms, LPL generally requires a third-party verification letter related to compliance of the firm’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. This requirement may be waived by LPL for various reasons including alternative methods of verifying the experience and/or performance of the SMA Portfolio Manager or Model Advisor. SMA Portfolio Manager and Model Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate the performance record of the SMA Portfolio Manager or Model Advisor. However, LPL provides clients with individual performance information. Performance information distributed by LPL is compiled using third party portfolio accounting and reporting software. Client performance is reported on a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that third-party Model Advisors provide Model Portfolios to LPL, and it is LPL that has discretion for trade implementation and execution in MP Platform accounts. Therefore, Model Portfolios submitted to LPL by third-party Model Advisors represent activity that has already been implemented on behalf of other clients of such Model Advisors. Because of this fact and because LPL (and not the third-party Model Advisor) has discretionary authority to implement trades, performance of an MP Platform account will differ from and may be worse than the performance of such Model Advisor’s discretionary accounts. Investment Strategies Portfolio managers provide advisory services based on the following types of investment strategies. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Small Cap Blend Small Cap Growth Small Cap Value Tax Free Fixed Income Taxable Fixed Income All Cap Core All Cap Growth All Cap Value Balanced Convertibles Global Balanced Global Equity Growth Equity Income Preferred Large Cap Core Large Cap Foreign Large Cap Growth Large Cap Value Mid Cap Core Mid Cap Growth Mid Cap Value REIT Sector MS302 – 0326 LPL Financial, member FINRA/SIPC 9  Manager Select Program Brochure Types of Investments and Risks In the Platforms, SMA Portfolio Managers (in the case of the SMA Platform) or LPL (in the case of the MP Platform) invest in many different types of securities, including equities, fixed-income securities, options, mutual funds, closed- end funds, interval funds and ETFs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political, or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Alternative Strategy Mutual Funds. Certain mutual funds available in the programs invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as MS302 – 0326 LPL Financial, member FINRA/SIPC 10  Manager Select Program Brochure sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • 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 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. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This MS302 – 0326 LPL Financial, member FINRA/SIPC 11  Manager Select Program Brochure difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts, and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the MS302 – 0326 LPL Financial, member FINRA/SIPC 12  Manager Select Program Brochure ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • Options. Option trading is permitted in the Program. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and a Program account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (naked). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (Single Inverse ETPs) futures-linked ETPs (Futures Linked ETPs) and cryptocurrency-related ETPs (Cryptocurrency ETPs). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the MS302 – 0326 LPL Financial, member FINRA/SIPC 13  Manager Select Program Brochure performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-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. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship with LPL and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review MS302 – 0326 LPL Financial, member FINRA/SIPC 14  Manager Select Program Brochure Interest.” For additional disclosures the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL and its IARs for the pledged assets. For a list of the third-party 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 regarding LPL’s Secured Credit Account, please visit of lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Blockchain Technology. Blockchain is a novel technology for which its uses, opportunities, applications, and abilities are unknown and unproven. There can be no assurances that companies investing in this technology will be able to benefit from it. The amount and type of investment restrictions are subject to change and manager’s acceptance. Companies investing in blockchain tend to be concentrated in the technology and financial sectors. As a result, the portfolio will be subject to the concentration risk described above and the portfolio’s performance may vary materially from that of its MSCI World Index benchmark. This portfolio invests in American depositary receipts (ADRs), negotiable certificates traded on a U.S. exchange which are issued by U.S. banks and which represent a specified number of shares (or one share) in a foreign stock. As a result, the portfolio will be subject to the Non-U.S. securities risk described below. U.S. Securities Risk. Non • Non ‐ ‐ ‐ U.S. securities involve risks in addition to those associated with comparable U.S. securities and can be more volatile and experience more rapid and extreme changes in price than U.S. securities. Additional risks include exposure to less developed or less efficient trading markets; social, political or economic U.S. currencies and in the U.S. dollar exchange rate to those currencies; instability; fluctuations in non nationalization or expropriation of assets; settlement, custodial or other operational risks; less stringent auditing, accounting, financial reporting and legal standards; excessive taxation; and exchange control regulations. Adverse conditions in a particular region could negatively affect securities of countries whose economies appear to be unrelated or not interdependent. In many countries, there is less publicly available and lower quality information about issuers than is available in the reports and ratings published about issuers in the U.S. • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), MS302 – 0326 LPL Financial, member FINRA/SIPC 15  Manager Select Program Brochure and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and its IARs generally will earn more compensation for selling one investment product than another. As a result, LPL and its IARs have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. Voting Client Securities In the case of the SMA Platform, the SMA Portfolio Manager, and not LPL, is responsible for voting proxies with respect to issuers held in an account, unless a client directs otherwise in writing. The SMA Portfolio Manager, and not LPL, likewise determines how to respond to any voluntary corporate actions. LPL does not assume responsibility for reviewing the SMA Portfolio Manager’s proxy voting decisions or policies, including for compliance with law. In the case of the MP Platform, unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. A copy of LPL’s proxy voting policies is available upon request to your IAR. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting the 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of third-party Model Advisors without reviewing individual client interests, unless LPL believes that such instructions are overtly contrary to our clients’ best interests. In such case, LPL will determine whether or how to act consistent with the best interest of our clients. LPL, IARs and Model Advisors are not obligated to render any advice or take any action on behalf of client with respect to any legal proceedings, including bankruptcies, involving securities or other investment held in the Account, or issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the Account. Item 7: Client Information Provided to Portfolio Managers When a client opens an account, the IAR obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective 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 the case of SMA Platform accounts, LPL forwards this information to the selected SMA Portfolio Manager. In the case of MP Platform accounts, the IAR uses this information to assist the client in selecting an investment strategy and Model Portfolio for the account. LPL typically will not provide client information to third-party Model Advisors. MS302 – 0326 LPL Financial, member FINRA/SIPC 16  Manager Select Program Brochure After the account opening, LPL asks clients quarterly to contact the IAR if there have been any changes in the client’s financial situation or investment objectives or if the client wishes to impose any reasonable restrictions on the management of the account or modify existing restrictions. If client communicates to the IAR regarding material changes in the client’s financial circumstances, investment objective or investment restrictions, such information is forwarded to the SMA Portfolio Manager for SMA Platform accounts. Clients may communicate such information to the IAR, or SMA Platform clients may otherwise communicate directly with the SMA Portfolio Manager, although clients are encouraged to direct communication through the IAR. Client should be aware 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 should further be aware that achievement of the stated investment objective is a long-term goal for the account. Item 8: Client Contact with Portfolio Managers In the case of SMA Platform accounts, SMA Portfolio Managers are reasonably available to consult with IARs and clients regarding accounts. Clients may consult directly with the SMA Portfolio Manager, although clients are encouraged to direct contact with SMA Portfolio Manager through the IAR. In the case of MP Platform accounts, LPL does not place any restrictions on a client’s ability to contact and consult with IARs. Because the Model Advisor’s role is solely to provide Model Portfolios to LPL, and not to provide individualized discretionary advisory services to MP Platform clients, third party Model Advisors generally are not available to be contacted or consulted by MP Platform clients. 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 17  Manager Select Program Brochure 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: • 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). MS302 – 0326 LPL Financial, member FINRA/SIPC 18  Manager Select Program Brochure • 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, 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). • 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). 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/. MS302 – 0326 LPL Financial, member FINRA/SIPC 19  Manager Select 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 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 may be 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. In certain cases, associated persons of a SMA Portfolio Manager or Model Advisor may also broker-dealer registered representatives of LPL. If an associated person of a SMA Portfolio Manager or Model Advisor is a broker-dealer registered representative of LPL, that person is providing advisory services to the program account on behalf of SMA Portfolio Manager or Model Advisor, as applicable. That person is not acting in a brokerage capacity or on behalf of LPL with respect to the portfolio management services provided under this program. The SMA Portfolio Manager’s or Model Advisor’s Form ADV, as applicable, should disclose whether or not its associated persons are registered representatives of LPL. 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 service, 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-Manager Select 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. 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. MS302 – 0326 LPL Financial, member FINRA/SIPC 20  Manager Select Program Brochure 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, corporate trustee services, 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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 LPL, as principal, buys securities from and sells securities to clients in Manager Select accounts. This practice could put LPL in a position where its own interests are in conflict with clients. However, LPL is not a market maker in securities and does not carry an inventory. In the case of the SMA Platform, it is the SMA Portfolio Manager (and not LPL) who as investment advisor determines the securities to be traded in the account. It is also the SMA Portfolio Manager who has a duty of best execution in negotiating transactions for clients. In the case of the MP Platform, LPL as investment advisor determines the securities to be traded in the account; however, LPL is expected to closely track the Model Portfolio, applying discretion only to address particular account issues, including tax loss harvesting, rebalancing, short-term gain avoidance, cash inflows and outflows, and tracking error from the Model Portfolio, and to ensure that investment restrictions are being followed. 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. Though LPL also processes securities transactions, as broker-dealer, for MP Platform accounts, LPL does not charge commissions. When LPL executes trades for an SMA Portfolio Manager in a principal capacity on the SMA Platform, it receives a markup or markdown on the transaction. This means, for example, if LPL sells a security at a price higher than what LPL paid, LPL will earn a markup. Conversely, if LPL buys a security at a price lower than what LPL sells it for, LPL will receive a markdown. The maximum markup or markdown that LPL receives when acting in a principal capacity in a Manager Select account is $2.00 per bond. In many cases, this maximum does not apply, and the actual markup or MS302 – 0326 LPL Financial, member FINRA/SIPC 21  Manager Select Program Brochure markdown is lower, typically $1.00 per bond. Details about a markup or markdown for a particular transaction will be furnished upon request. The IAR does not share in this markup or markdown. Purchases of mutual fund shares are typically 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 the firm's use of a proprietary account for the mutual fund purchase. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when: a client is also trading whole shares of the security; in connection with a dividend reinvestment plan; or to sell remaining fractional shares to close a position. Trades in whole and fractional shares typically happen on the same day and will be executed at the same price as a trade in whole shares, or otherwise at market closing price. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. SMA Portfolio Managers are not prevented from purchasing LPL Financial Holdings Inc. stock in Manager Select accounts. In addition, a Manager Select account may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings, Inc. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in Manager Select charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b- 1 fees paid to LPL by mutual funds (other than the Sweep Funds) will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by clients in the fund (up to $25 per position). 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. SMA Portfolio Managers and Model Providers pay LPL initial diligence and setup fees of up to $5,000 per strategy or Model Portfolio and up to a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance to make their services available in the Program. In the case of ETPs, 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 exchange-traded products (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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with IARs. MS302 – 0326 LPL Financial, member FINRA/SIPC 22  Manager Select Program Brochure When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (sponsors) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through a Platform, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL IARs so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds (other than the Sweep Funds) consists of flat and/or asset based fees totaling up to 0.15% annually, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for an Account. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Model Portfolio in the case of Model Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another MS302 – 0326 LPL Financial, member FINRA/SIPC 23  Manager Select Program Brochure comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds (other than the Sweep Funds), and therefore, LPL does not have an incentive to select on fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with SMA Portfolio Managers or Model Advisors, and, therefore, there is no financial incentive for an a SMA Portfolio Manager or Model Advisor to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. LPL also does not share these payments with IARs. Although LPL does not share recordkeeping fees or revenue sharing payments 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. 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 IARs 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 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 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 24  Manager Select Program Brochure 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. • 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. • 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. 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. • 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 25  Manager Select Program Brochure 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). • 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. LPL’s money market mutual fund sweep option automatically sweeps otherwise uninvested cash balances held in the account and invests them 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. The compensation that LPL receives related to ICA, DCA (including from 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 26  Manager Select Program Brochure LPL has a financial benefit if cash balances are maintained in ICA, DCA, or the Sweep Funds. However, this compensation is retained by LPL and is not shared with SMA Portfolio Managers or Model Advisors. Therefore, this compensation does not cause an SMA Portfolio Manager or Model Advisor to have a financial incentive to recommend that cash be held in the account instead of holding securities. LPL does not share this compensation with IARs. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with its IARs, and therefore, an IAR does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with its IARs, and therefore, an IAR has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your IAR’s compensation on the SCA product is reduced if your interest rate is discounted, so your IAR has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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 or alternatively, could incentivize the IAR to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. MS302 – 0326 LPL Financial, member FINRA/SIPC 27  Manager Select Program Brochure 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 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 IAR 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 the 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. 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 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. IARs review monthly or quarterly account statements as well as performance information. MS302 – 0326 LPL Financial, member FINRA/SIPC 28  Manager Select Program Brochure Other Compensation LPL, LPL employees and IARs also receive additional compensation from product sponsors, including SMA Portfolio Managers or firms affiliated with SMA Portfolio Managers and third-party Model Advisors or firms affiliated with third-party Model Advisors. 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 also pay for, or reimburse LPL for the costs associated with, education or training events that are attended by LPL employees and IARs and for 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 receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 certain advisory programs 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 typically 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 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 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 29  Manager Select Program Brochure 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 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: • payments based on production • 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 • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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 the Program than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in the Program 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 MS 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 interest 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 30  Manager Select Program Brochure 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 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 31  Manager Select Program Brochure 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: • Referral Networks. Some third parties operate referral networks. Referral networks may present potential clients with a list of possible investing firms and investment adviser 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; • 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; • 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; • 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 • 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’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 benefits including but not limited to 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 shares the Account Fee with the financial institution, and the financial institution pays part of that amount to IAR based on a compensation plan between the IAR and the financial institution. The financial institutions, along with LPL, determine the compensation plan for the 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. LPL also has agreements to provide similar services at financial MS302 – 0326 LPL Financial, member FINRA/SIPC 32  Manager Select Program Brochure institutions in which compensation is not shared with the financial institution whereby a portion of the Account Fee is paid directly to the IAR. 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 Advisory 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. 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 affiliated products and the IAR may only recommend an investment product that he or she believes is appropriate, suitable, and in the best interests of the 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. Some of these financial institutions are affiliated with investment advisory firms that act as a Model Advisor or an SMA Portfolio Manager. An IAR offering advisory services on the premises of a financial institution has a potential conflict of interest when the IAR recommends that clients utilize an affiliated Model Advisor or SMA Portfolio Manager because the financial institution has the ability to influence the IAR’s compensation and employment status. However, an IAR may only recommend a model portfolio that they believe is in the best interest of clients. Affiliated Model Advisors and SMA Portfolio Managers sometimes receive a reduced Manager Fee or do not receive a Manager Fee at all. This is often because the affiliated Model Advisor or SMA Portfolio Manager has included proprietary or affiliated mutual funds or exchange-traded funds in the model portfolio which charges a separate fee. The absence of a Manager Fee creates a conflict of interest for the IARs insofar as IARs can negotiate a higher LPL Advisory Fee than they could for an account subject to a higher third-party Manager Fee. In addition, model portfolios benefit from having increased assets under management even if they do not charge a Manager Fee. If your financial advisor is an employee of Community Bank, you should note that the selection of Nottingham Advisors, a wholly-owned subsidiary of Community Bank, as an SMA Portfolio Manager or a Model Advisor presents a conflict of interest because it gives an incentive to your financial advisor for the selection of an affiliated advisory firm based on the compensation received by Nottingham Advisors rather than on a client’s needs. However, an IAR may only recommend a program or service that he or she believes is appropriate for you. MS302 – 0326 LPL Financial, member FINRA/SIPC 33  Manager Select Program Brochure If your IAR is an employee of M&T Bank (M&T Financial Professional), you should note that certain investment strategies and Model Portfolios available in the Program are provided by M&T Bank’s affiliate, Wilmington Trust Investment Advisors, Inc. (WTIA). Unlike other third-party investment strategies and Model Portfolios used in accounts advised by M&T Financial Professionals, WTIA does not charge LPL a Manager Fee for WTIA Model Portfolios used in those accounts. You also should be aware that certain of the WTIA Model Portfolios include mutual funds that are advised and/or sub- advised by affiliates of M&T Bank, including WTIA. In some Model Portfolios, these affiliated funds currently can represent up to 65% of the funds in the portfolio. Because WTIA and/or other affiliates of M&T Bank earn fees and other compensation from the affiliated mutual funds, WTIA has an incentive to select its affiliated funds for such Model Portfolios due to the compensation and benefits it and/or its affiliates receive(s). If your account is a retirement account, your account will receive a credit in an amount equal to the mutual fund advisory and administrative services fees that M&T affiliates receive in connection with the affiliated mutual funds held in your account. If your financial advisor is an employee of Commerce Bank (Commerce Financial Professional), you should note that certain Model Portfolios in Manager Select are provided by a division of the Bank, Commerce Trust. As a Model Provider, Commerce Trust in some cases charges LPL clients a fee. However, Commerce Trust will not charge this fee to accounts advised by Commerce Financial Professionals. You also should be aware that the Commerce Trust Model Portfolios include mutual funds that are advised and/or sub-advised by its affiliate, Commerce Investment Advisors, Inc., a subsidiary of Commerce Bank. In some Model Portfolios, these affiliated funds can represent 0 to 100% of the funds in the portfolio. Commerce Trust has an incentive to select affiliated funds for the model portfolios due to the fees and other compensation and benefits its affiliate receives. However, your IAR may only recommend a model that he or she believes is appropriate for you. Your account will receive a credit in an amount equal to the mutual fund advisory and administrative services fees that Commerce Bank affiliates receive in connection with the affiliated mutual funds held in your account. If your IAR is associated with Wintrust Investments, LLC (Wintrust Financial Professional) you should note that certain model portfolios available in the Program were created by Great Lakes Advisors, LLC (GLA), an affiliate of Wintrust Investments. GLA in some cases charges LPL clients a Manager Fee. However, GLA will not charge this fee to accounts advised by Wintrust Financial Professionals. Your IAR has an incentive to select the GLA model portfolios for your account due to their association with Wintrust Investments, which has the ability to influence your Financial Advisor’s compensation and employment status. However, your IAR may only recommend a model portfolio that he or she believes is appropriate for you and in your best interest. LPL reviews and selects SMA Portfolio Managers and Model Portfolios for the Platforms and LPL may elect to remove or replace an SMA Portfolio Manager or a Model Advisor. There is a conflict of interest because the business relationship between LPL and these unaffiliated financial institutions affects LPL’s ability to objectively select and determine whether to continue to maintain their managed strategies on the Platforms. LPL also provides other forms of compensation to financial institutions, such as bonuses, awards or other things of value offered by LPL to the financial institution. For example LPL pays financial institutions based on production, in the form of repayable or forgivable notes, 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 pays 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 financial 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 34  Manager Select Program Brochure account 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 of the financial institution 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 and such referral programs are governed by Regulation R of the Gramm-Leach-Bliley Act. Employees of trust departments at certain financial institutions are authorized under the terms of applicable trust arrangements to delegate investment advisory responsibility to 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 Manager Select 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 the case of the MP Platform, all transactions will be executed through LPL, and Client directs that securities transactions for the Account be initiated through LPL. In the case of the SMA Platform, Client directs SMA Portfolio Managers to execute transactions through LPL, subject to the SMA Portfolio Manager’s duty as an investment advisor to seek to achieve best execution. Clients should understand that an SMA Portfolio Manager may choose to place some or all trades for accounts with broker-dealer firms other than LPL (“trade away” or “step outs”). Some SMA Portfolio Managers have historically placed nearly all client trades with broker-dealer firms other than LPL for execution, in particular, if the SMA Portfolio Manager follows a fixed-income, foreign or small cap investment strategy. In addition, SMA Portfolio Managers may choose to trade away from LPL in order to aggregate all client transactions into one or more larger “block trades” that are executed through one broker-dealer. This practice may enable an SMA Portfolio Manager to obtain more favorable execution, including a more advantageous net price, than would otherwise be available if orders were not aggregated into a single “block trade.” It may also assist the SMA Portfolio Manager in potentially avoiding an adverse effect on the price of a security which could result from simultaneously placing a number of separate, successive, or competing client orders. When securities transactions are effected through LPL, there are no brokerage commissions charged to the account. If an SMA Portfolio Manager chooses to execute a transaction through a broker-dealer other than LPL, the execution price will usually include a commission or fee imposed by the executing broker-dealer. Clients should understand that the client will bear any such additional trading cost, in addition to the account fee paid to LPL. The additional expenses charged by the broker-dealer executing the transaction may include commissions, mark-ups, mark-downs or “spreads” paid to executing broker dealer firm. Additionally, if a foreign currency transaction is required, there may be foreign exchange or similar fees, including but not limited to fees for foreign ordinary conversion and creation of American Depositary Receipts (“ADRs”) charged by third parties as well as foreign tax charges. In many cases, the commission, mark-up, mark-down or other additional expenses charged by the executing broker-dealer or third party will be embedded in the purchase or sale price of such transactions, and not separately indicated on trade confirmations and custodial account statements provided by LPL. In evaluating whether to execute a trade through a broker-dealer other than LPL, an SMA Portfolio Manager will consider the fact that an account will not be charged an additional expenses (such as a commission) if effected directly through LPL. 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 MS302 – 0326 LPL Financial, member FINRA/SIPC 35  Manager Select Program Brochure 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. Clients should understand that LPL is not able to fully evaluate whether an SMA Portfolio Manager is meeting its best execution obligations to clients for specific transactions when trading away, as it is not a party to such transactions and is not in a position to negotiate the price or transaction related charges with the executing broker. The responsibility to determine whether to trade away lies with the SMA Portfolio Manager and arises out of an SMA Portfolio Manager’s individual fiduciary duty to clients. Additional information regarding equity trading away practices of SMA Portfolio Managers is available on lpl.com/disclosures.html under “Market & Trading Disclosures” and “Third-Party Portfolio Manager Trading Practices.” Clients should consider whether or not the appointment of LPL as the broker-dealer may or may not result in certain costs or disadvantages as a result of possibly less favorable executions. Clients should also understand that not all wrap program sponsors require brokerage to be directed to the sponsor. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution of client transactions. In particular, clients should understand that their accounts may not be able to participate in block trades effected by a portfolio manager for its other accounts, which may result in a difference between prices charged to the account and the portfolio manager’s other accounts. For these reasons, directed brokerage may cost clients more money. SMA Portfolio Managers (in the case of SMA Platform Accounts) or LPL may aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. Clients should read and understand the disclosure in Form ADV Part 2 of the applicable SMA Portfolio Manager in the case of SMA Platform accounts. 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 responsible for the ongoing individualized investment advice provided to a particular client. For more information about the portfolio manager managing the account (i.e., the SMA Manager for an SMA Platform account or LPL for an MP Platform account), client should review the Brochure of the portfolio manager. For more information about the LPL IAR servicing 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. MS302 – 0326 LPL Financial, member FINRA/SIPC 36 

Model Wealth Portfolios Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 your LPL 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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 ......................................................................................................................................................... 2 Item 4: Services, Fees And Compensation............................................................................................................................... 2 Item 5: Account Requirements And Types Of Clients ............................................................................................................. 8 Item 6: Portfolio Manager Selection And Evaluation ............................................................................................................. 8 Item 7: Client Information Provided To Portfolio Managers ................................................................................................ 16 Item 8: Client Contact With Portfolio Managers ................................................................................................................... 17 Item 9: Additional Information ............................................................................................................................................... 17 A11 – 0326 LPL Financial, member FINRA/SIPC 1  Model Wealth Portfolios Program Brochure 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, an advisor-enhanced digital advice program, advisory programs offered by third party investment advisor firms, financial planning services, and retirement plan consulting services. This Brochure provides a description of the advisory services offered under LPL’s Model Wealth Portfolios (MWP) program. For more information about LPL’s advisory services and programs other than MWP, please contact your LPL 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 MWP program is a unified managed account 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 one or more model portfolios of securities (each, a “Portfolio”) designed by LPL Research, a third-party investment strategist, a large enterprise with which IAR is associated or a financial institution on the premises of which IAR offers advisory services (each, an “Institutional Strategist”), or IAR (each of the foregoing, a “Portfolio Strategist”) consistent with the client’s stated investment objective. These Portfolios may contain mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), closed-end funds, equities, or fixed-income securities. The IAR provides ongoing advice on the selection or replacement of a Portfolio based on the client’s individual needs. The IAR may choose more than one Portfolio to be managed within a single MWP account. A Portfolio could be comprised of one or more underlying models. The MWP 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. The Portfolio Strategist is responsible for selecting the securities within a Portfolio and for making changes to the securities selected. LPL has discretion to buy and sell securities in the account according to the Portfolio selected and liquidate previously purchased securities that are transferred into the account. The client authorizes LPL and the IAR to have discretion by executing the Account Agreement and Application. Except for LPL, IAR and certain Institutional Strategists, the Portfolio Strategists are independent investment advisor firms either registered as investment advisers with the SEC or state securities authority or relying on an exemption therefrom. Portfolio Strategists provide LPL on an ongoing basis with a Portfolio that includes recommended asset allocations and securities. LPL enters into an agreement with the Portfolio Strategist for these Portfolio services. Except for LPL and IAR, and except for Subadvisers (defined below), a Portfolio Strategist does not have discretion A11 – 0326 LPL Financial, member FINRA/SIPC 2  Model Wealth Portfolios Program Brochure from the client to implement the Portfolio and does not provide individualized investment advice to specific program clients. Some third-party investment strategists have entered into subadvisory agreements with LPL to manage, on a discretionary basis, accounts or portions of accounts in the program allocated to their fixed-income Portfolios (Subadvisers). If IAR, or a client, chooses to allocate all or a portion of an account to a Portfolio provided by a Subadviser, LPL will delegate some of its responsibilities to the Subadviser, subject at all times to oversight by LPL. Subadvisers will have discretion to make decisions about how to implement their Portfolios, including decisions on purchasing and selling fixed-income securities, executing trades through brokerage firms selected by the Subadviser and rebalancing the assets in the Account allocated to their models, which may occur on a different frequency than as determined by the Overlay Portfolio Manager. Subadvisers have discretion whether to consider state preferences (if client provides to IAR) when selecting from the inventory of bonds, if applicable. Not all states will carry inventory to suffice for a selection. Please note that there is no guaranty that state preference will be considered. The discretion to consider state preferences is not intended as tax advice, and neither LPL nor any Subadviser represents in any manner that implementation of state preferences will achieve tax-advantaged returns. Notwithstanding LPL’s delegation of some of its responsibilities to the Subadviser, LPL will remain responsible for all advisory services provided in the program. LPL conducts initial and ongoing due diligence of Subadvisers and has the ultimate authority to hire and fire Subadvisers to accounts in the program, and may terminate a Subadviser’s authority to manage client assets at its discretion. A client who wishes not to engage a Subadviser would be required to select a different Portfolio. If your IAR or you choose to invest in a Portfolio provided by a Subadviser, please carefully review the Subadviser’s Form ADV Part 2 Brochure for information on the Subadviser’s investment strategies, risks, brokerage practices and conflicts of interest. LPL acts as the overlay portfolio manager (OPM) in coordinating the trades in the account and performing tax harvesting services. LPL expects to closely track the Portfolios, applying discretion only to address particular account issues, including tax loss harvesting, rebalancing, short-term gain avoidance, cash inflows and outflows, and tracking error from the Portfolio, customized requests, and investment restrictions placed on the account. 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. LPL as the OPM is responsible for rebalancing accounts in accordance with the allocations in the Portfolio. LPL will review an account to determine if rebalancing is appropriate based on the frequency selected by the client at account opening or as altered by the client or the IAR from time to time. The choices for frequency of rebalancing review are quarterly (four times per year), semiannually (two times per year) or annually (once per year). An additional rebalance may be requested outside of the scheduled frequency once every 12 months. At each rebalancing review date, LPL will rebalance the account if the Account has available cash for investment and at least one security position is outside a pre-determined range, subject to a minimum transaction amount established by LPL in its discretion. In addition, LPL will review an account for rebalancing in the event that the Portfolio Strategist changes the allocation targets. LPL accommodates reasonable requests to restrict holdings of specific securities, specific industries, specific sectors, and certain pre-defined categories (e.g., “sin” stocks). In the event that client restrictions prevent the investment in certain securities otherwise recommended by a Portfolio Strategist, assets will be invested pro-rata across the remaining securities in the model. Such restrictions do not apply to any mutual funds, ETFs or fixed-income securities that are held in the account. Restrictions placed on an account can affect the performance of the account. The OPM may choose not to accept an account with restrictions that are inconsistent with the investments chosen by the OPM or as recommended by the Portfolio Strategist. LPL, at the request of the IAR, performs tax harvesting, which may include using the proceeds of tax-related transactions to purchase appropriate securities (such as ETFs or mutual funds) for an account. Client may also request IAR to initiate tax harvesting with LPL. In such case, proceeds of tax-related transactions may be held in cash or securities until appropriate wash sale periods have expired. Once the wash sale period has expired, the related proceeds will be invested according to the current targeted allocation for the Portfolio. Similarly, LPL may delay a tax harvesting request to sell securities acquired in the previous 30 days until the wash sale period has expired. Under A11 – 0326 LPL Financial, member FINRA/SIPC 3  Model Wealth Portfolios Program Brochure certain conditions, LPL also will accommodate requests for all or a portion of an account to remain allocated to cash for a period of time. In addition to general tax harvesting requests described above, clients may authorize LPL to provide more comprehensive tax overlay services (LPL Tax Overlay Services). If directed by client, LPL will provide LPL Tax Overlay Services to the client’s account. The end objective of LPL Tax Overlay Services is to improve the after-tax return for the client while staying consistent with the investment strategies of the Portfolios. LPL Tax Overlay Services are available only to clients subject to U.S. capital gains taxes. LPL does not provide tax planning advice or services. LPL does not represent in any manner that the desired tax objectives will be obtained or that MWP’s investment strategy will result in any particular tax outcome. Clients should discuss any questions with or request further information from their IAR or their tax consultant in using the LPL Tax Overlay Services. LPL charges 0.08% of the value of the account to provide LPL Tax Overlay Services, which it retains from the Advisory Fee, as described under the section titled “Fee Schedule” below. This charge will not be separately indicated on account statements or otherwise. When IAR recommends discontinuing LPL Tax Overlay Services, IAR has a conflict of interest since discontinuing this service will increase the portion of the Advisory Fee paid to IAR or its financial institution or affiliate thereof. Clients will be notified when services are discontinued, including a reminder to discuss whether a reduction of the Advisory Fee is appropriate. Please ask your IAR for additional information. In some cases, clients may experience significant performance differences from the selected investment strategy for one or more Portfolios and/or the overall account, due to participation in LPL Tax Overlay Services. If a client chooses to participate in this service, LPL makes no assurances that the client’s account performance will be within any range of the selected investment strategy or the strategy’s benchmark. A client’s returns will likely differ from, and could be lower than, the Portfolio Strategist’s model when enrolled in Tax Overlay Services. In addition, LPL may manage the client’s account using tools and processes which may result in the client’s trades being executed at a different time or in a different manner than other LPL trades, including the potential to not participate in LPL’s standard trade rotation processes (if such trades would have been otherwise eligible to participate). In connection with the program, LPL also acts as custodian to accounts, provides brokerage and execution 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 MWP Program pay an annualized fee (“Account Fee”). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the IAR changes the model selected for an account, or if the model investment value changes, the overall Account Fee may increase or decrease. 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, IARs, and Portfolio Strategists do not charge performance-based fees to accounts in the Program. Advisory Fee. The Advisory Fee is charged for the investment advisory services of IAR, as well as the investment advisory, administrative, trading, custodial and clearing services of LPL. The Advisory Fee is shared with the IAR. The Advisory Fee is negotiable between the client and IAR and is based on the value of assets in the account, including cash holdings. The maximum Advisory Fee is 2.35%. Upon request, the Advisory Fee may be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds. A11 – 0326 LPL Financial, member FINRA/SIPC 4  Model Wealth Portfolios Program Brochure LPL retains a portion of the Advisory Fee, up to 0.35% of the value of the account, for its investment advisory, administrative, trading, custodial and clearing services. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Advisory Fee with the IAR based on the agreement between LPL and the IAR. LPL retains any portion of the Advisory Fee not shared with the IAR. A portion of the Advisory 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 Advisory Fee for supervision because the fee affects his or her ability to provide objective supervision of the IAR. Manager Fee. Depending upon the model(s) selected for the account, clients pay a Manager Fee set by LPL for the use of each model portfolio. The Manager Fee is based on the value of the assets in the account, including cash holdings, and payable quarterly in advance. This fee ranges from 0% to 0.60%. LPL pays all or a portion of the Manager Fee to the Portfolio Strategist. For certain models, LPL charges up to 0.05% of model assets per year for the costs and services associated with effecting trades to implement the models, such as order formation, execution, settlement and sleeving of transactions. This LPL fee for trading services is reflected in the Manager Fee on client statements. Generally, LPL charges 0.05% of model assets per year for models transacting primarily in equities, and LPL charges 0.03% of model assets per year for models transacting primarily in fixed income or other over-the-counter securities. For certain models designed by LPL Research, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL either charges a Manager Fee as Portfolio Strategist or charges a fee for trading services, there is a conflict of interest for LPL to recommend such models. When acting as Portfolio Strategist, LPL does not charge the Manager Fee to retirement accounts; however, LPL charges the fee for trading services to retirement and nonretirement accounts to the extent permissible under applicable law. The IAR does not receive any portion of the Manager Fee, including based on recommending a model for which LPL charges this compensation. A list of the client’s current model(s) and associated fee rates will be reflected on client account statements or can be requested from the IAR. Please note that if an account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. Clients do not pay LPL or IARs brokerage commissions or transaction charges for the execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Certain Portfolio Strategists charge a reduced Manager Fee or do not charge a Manager Fee for their models. This is often because the Portfolio Strategist earns a management fee from proprietary or affiliated mutual funds or exchange-traded funds included in the model. This management fee can be found in the prospectus of the mutual fund or exchange traded funds included in the model. Because a Portfolio Strategist or their affiliates benefit financially when an affiliated fund is selected, there is a conflict of interest that affects the Portfolio Strategist’s ability to provide unbiased, objective investment advice concerning the selection of funds for a model. If a Portfolio is selected that consists of mutual funds and/or ETFs primarily or only within the same fund family or within affiliated fund families (typically as indicated by the title of the model portfolio), the Portfolio Strategist will select at least a majority of funds within that fund family or affiliated fund families. In such case, because mutual funds or ETFs in a Portfolio are affiliated with a third-party Portfolio Strategist that designs the Portfolio, an investment in the affiliated fund generates compensation to that third party Portfolio Strategist or its affiliates, including, among other types of compensation, fund-level management fees, in addition to any portion of the Account Fee it receives. The fees paid to Portfolio Strategists are generally less than fees those strategists would charge a client seeking to establish a direct relationship with them outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, marketing and trading expenses that would otherwise be borne by those strategists. Portfolio Strategists generally have higher minimum account size requirements and fees for direct accounts because of such additional expenses. A11 – 0326 LPL Financial, member FINRA/SIPC 5  Model Wealth Portfolios Program Brochure How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with an MWP account from the account. LPL pays the applicable portion of the Account Fee to the Portfolio Strategists. 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 pro-rated 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). Other Types of Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to an MWP 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 miscellaneous 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. Other LPL advisory programs and/or other financial services firms separately offer certain models available through the program, in some cases at a lower overall costs to investors. When the same model is offered in different LPL advisory programs, the difference in the Manager Fee for use of that model is typically up to five basis points. Advisory programs differ significantly in the overall features and functionalities offered, and an IAR may only recommend a program or service that he or she believes is suitable and in the best interest of a client in accordance with the applicable standards under the Advisers Act. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in MWP accounts. Some of these fees and charges are described below. In MWP, assets are often invested in mutual funds or ETFs 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 fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay the Account Fee with respect to assets invested in mutual funds and ETFs. The mutual funds and ETFs available in the program can be purchased directly outside of the program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL, IAR and Portfolio Strategists and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. Other financial services firms, including those LPL makes available through its third-party asset management programs, may offer the same A11 – 0326 LPL Financial, member FINRA/SIPC 6  Model Wealth Portfolios Program Brochure 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” If client transfers into an MWP 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 MWP model. 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 MWP account, client should be aware that certain securities are not 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 MWP 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. For those Portfolios consisting of mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in MWP charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds (other than the cash sweep money market funds (“Sweep Funds”) described in the section of Item 9 labeled “Participation or Interest in Client Transactions”) will be credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. A11 – 0326 LPL Financial, member FINRA/SIPC 7  Model Wealth Portfolios Program Brochure Important Things to Consider About Fees on a MWP Account • The Account Fee is a wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. Clients do not pay a commission or transaction charge to LPL for the execution of transactions in the account. 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: – type and size of the account – type of securities in the Portfolio (whether mutual funds, ETFs, equities, or fixed income) – 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 fee set out above. The IAR is responsible for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, the number, complexity and mix of the Portfolios, and the 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 Advisory Fee with IAR. • The investment products available to be purchased in the program can be purchased by clients outside of an MWP account, through broker-dealers or other investment firms not affiliated with 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 requires a minimum asset value for a program account to be managed. The minimums vary depending on the Portfolio(s) selected and the account’s allocation amongst Portfolios. The lowest minimum for a Portfolio is $10,000. In certain instances, LPL will permit a lower minimum for a Portfolio. Note that an account will not be invested according to a Portfolio or Portfolios until the applicable minimum for the Portfolio(s) and allocation has been reached. Clients should consult with IAR to obtain more information about the applicable investment minimum based on the Portfolio(s) selected and the allocation amongst Portfolios. The program is available for individuals, IRAs, banks and thrift institutions, credit unions, pension and profit sharing plans, including plans subject to ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. Item 6: Portfolio Manager Selection and Evaluation In MWP, LPL and IAR are responsible for the overall investment advice and management services offered to clients, and the client selects the IAR who manages 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 along with this Brochure at the time client opened the account. LPL makes available Portfolios designed by LPL, third party Portfolio Strategists, including Subadvisers, Institutional Strategists and the applicable IAR. LPL reviews on a periodic basis Institutional Strategists and IARs acting as Portfolio Strategists on MWP. A11 – 0326 LPL Financial, member FINRA/SIPC 8  Model Wealth Portfolios Program Brochure In addition, LPL selects and reviews on a periodic basis the third-party Portfolio Strategists available on MWP. A third-party Portfolio Strategist may provide services to LPL and the program as a Subadviser. In addition to deciding on the securities and asset allocation for a Portfolio, Subadvisers are responsible for determining when and how to execute transactions and selecting broker-dealers through which to execute transactions. LPL uses information provided by the third-party Portfolio Strategist and also may use independent, third-party data sources when evaluating such Portfolio Strategist. Third party Portfolio Strategist performance information is not calculated on a uniform and consistent basis. LPL does not review performance information to determine or verify its accuracy and does not calculate third party Portfolio Strategist performance. However, LPL provides clients with individual performance information. Performance information distributed is compiled by LPL using third party portfolio accounting and reporting software. Client performance information is calculated on a uniform and consistent basis using a time weighted basis. Performance information is intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to investment indices. It is important to note that, except for Subadvisers, third party Portfolio Strategists provide the Portfolios to LPL, and it is LPL that has discretion for trade implementation and execution in MWP accounts. Therefore, Portfolios submitted to LPL by third party Portfolio Strategists may represent activity that has already been implemented on behalf of other clients of such Portfolio Strategists. Because of this fact and because LPL (and not the third party Portfolio Strategist) has discretionary authority to implement trades, performance of an MWP account will differ from the performance of such Portfolio Strategist’s discretionary accounts. LPL as a Portfolio Strategist In MWP, clients can invest in Portfolios designed by LPL Research. LPL Research designs many types of mutual fund, ETF, fixed-income and equity Portfolios to meet the varying needs of clients. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Portfolios for different timeframes, needs or themes that have meaning to investors. LPL Research generally designates Portfolios as either strategic or tactical model styles. The allocations in strategic Portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout a 3 to 5 year timeframe and are intended for investors who take a longer term view or who are more tax sensitive. Tactical Portfolios are more flexible and are designed to help take advantage of short, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of more frequent trading. Within the strategic and tactical model styles, LPL Research focuses each model on an investment theme or objective. For example, LPL Research designs alpha-focused Portfolios that are structured for more aggressive investors. There are also downside risk aware Portfolios that are intended to be structured more conservatively to help provide more protection in the event of a down market. LPL Research designs Portfolios that are largely allocated to alternative strategies to provide diversified exposure to those more esoteric asset classes. LPL Research also designs Portfolios intended for investors who place a priority on income generation and Portfolios for investors seeking to minimize tax impacts. Such income generation Portfolios are also available in investment objectives that are not typically focused on income. Additionally, LPL Research designs portfolios intended for investors who want to invest primarily with certain mutual fund or ETF families. There are also Portfolios that emphasize socially responsible investing and sustainability. LPL Research also designs portfolios that follow a “direct indexing” strategy, or a strategy that seeks to replicate a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the market index. In a direct indexing strategy, LPL Research partners with an index provider to license an index and pays a portion of the Manager Fee to the index provider. For a complete list of the current models provided by LPL Research, please discuss with your IAR. The participation of LPL Research as a Portfolio Strategist gives rise to conflicts of interests. For certain LPL Research model portfolios, LPL charges clients a Manager Fee. However, LPL will not charge this fee to retirement accounts. In addition, LPL has a financial incentive to select its internal team and further grow its assets under management, in part because as assets under management at LPL increase, LPL is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. However, the selection of A11 – 0326 LPL Financial, member FINRA/SIPC 9  Model Wealth Portfolios Program Brochure LPL Research model portfolios has no impact on your IAR’s compensation and/or employment status, and your IAR may only recommend a model portfolio that he or she believes is appropriate for you and in your best interest. Institutional Strategist or IAR as Portfolio Strategist In addition to portfolios designed by LPL Research and third party Portfolio Strategists, clients can invest in portfolios managed by their Institutional Strategist or IAR. The Institutional Strategist or IAR is responsible for selecting the mutual funds, ETFs, ETNs, closed-end funds, equities or fixed-income securities within a Portfolio, the asset allocation for the Portfolio, and for making changes to the securities selected and asset allocation over time. The Institutional Strategist or IAR will typically manage Portfolios tailored to an investment theme or particular style that is core to the Institutional Strategist or IAR’s beliefs and expertise. Each Institutional Strategist or IAR chooses his/her own research methods, investment strategy and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. The Institutional Strategist or IAR has access to various research reports, including those provided by LPL Research, to which he/she may refer in determining which securities to purchase or sell. As OPM, LPL has discretion to buy and sell securities in the Account (according to the Portfolio selected) and to liquidate previously purchased securities that are transferred into the Account. LPL expects to closely track the Portfolios, applying discretion only to address particular account issues, including tax rebalancing, loss harvesting, tracking error from the Portfolio, customized requests, and investment restrictions placed on the account. 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. Types of Investments and Risks The Portfolios may include different types of securities, such as mutual funds, ETFs, ETNs, closed-end funds, equities and fixed-income securities. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that are available in the program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. A11 – 0326 LPL Financial, member FINRA/SIPC 10  Model Wealth Portfolios Program Brochure • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • 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 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. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sector of the market may be more sectors, industries, or sub volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could A11 – 0326 LPL Financial, member FINRA/SIPC 11  Model Wealth Portfolios Program Brochure sectors do not perform as expected. Alternatively, the lack of be affected if the sectors, industries, or sub exposure to one or more sectors or industries may adversely affect performance. ‐ • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and its IARs generally will earn more compensation for selling one investment product than another. As a result, LPL and its IARs have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. • Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End Funds. Client should be aware that closed-end funds available within the program may not be readily marketable. In an effort to provide investor liquidity, the funds may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, clients may be unable to liquidate all or a portion of their shares in these types of funds. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This A11 – 0326 LPL Financial, member FINRA/SIPC 12  Model Wealth Portfolios Program Brochure difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a A11 – 0326 LPL Financial, member FINRA/SIPC 13  Model Wealth Portfolios Program Brochure wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), futures-linked ETPs (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. A11 – 0326 LPL Financial, member FINRA/SIPC 14  Model Wealth Portfolios Program Brochure Interest.” For additional disclosures • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-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. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship with LPL and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL and its IARs for the pledged assets. For a list of the third-party 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 regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Tax-Loss Harvesting. The tax-loss harvesting feature of MWP involves a variety of risks. You should confer with your personal tax advisor regarding the tax consequences of investing and engaging in the tax-loss harvesting strategy, based on your particular circumstances. You and your personal tax advisors are responsible for how the transactions in your account are reported to the IRS or any other taxing authority. Neither LPL nor IAR assumes any responsibility to you for the tax consequences of any transaction. MWP’s tax-loss harvesting A11 – 0326 LPL Financial, member FINRA/SIPC 15  Model Wealth Portfolios Program Brochure strategy is not intended as tax advice, and neither LPL nor IAR represents in any manner that the tax consequences described will be obtained or that MWP’s investment strategy will result in any particular tax consequence. The tax consequences of this strategy are complex and may be subject to challenge by the IRS. This strategy was not developed to be used by, and it cannot be used by, any investor to avoid penalties or interest. You should be aware that if you and/or your spouse have other taxable or non-taxable accounts, and you hold in those accounts any of the securities (including options contracts) held in your MWP account, you cannot trade any of those securities 30 days before or after the MWP account trades those same securities as part of the tax-loss harvesting strategy to avoid possible wash sales and, as a result, a nullification of any tax benefits of the strategy. For more information on the wash sale rule, please read IRS Publication 550. In addition, when LPL replaces investments with “similar” investments as part of the tax-loss harvesting strategy, it is a reference to investments that are expected, but are not guaranteed, to perform similarly and that might lower an investor’s tax bill while maintaining a similar expected risk and return on investor’s portfolio. Expected returns and risk characteristics are no guarantee of actual performance. Voting Client Securities Unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. A copy of LPL’s proxy voting policies is available upon request to your IAR. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting the 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of the Portfolio Strategist without reviewing individual client interests, unless LPL determines that such instructions are overtly contrary to our clients’ best interest. In such case, LPL will determine whether or how to act consistent with the best interest of our clients. LPL and IARs are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the account, or the issuers thereof. The client retains the right and obligation 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 objective or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Because third party Portfolio Strategist’s role is limited to providing Portfolios to LPL, and does not provide individualized discretionary advisory services to MWP clients, LPL generally does not communicate specific client information to third party Portfolio Strategists. A11 – 0326 LPL Financial, member FINRA/SIPC 16  Model Wealth Portfolios Program Brochure 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 model in the account, 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 client’s ability to contact and consult with IARs. Because a third party Portfolio Strategist’s role is solely to provide Portfolios to LPL, and not to provide individualized discretionary advisory services to MWP clients, third party Portfolio Strategists, except for Subadvisers, generally are not available to be contacted or consulted by MWP clients. 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). A11 – 0326 LPL Financial, member FINRA/SIPC 17  Model Wealth Portfolios Program Brochure 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, 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). A11 – 0326 LPL Financial, member FINRA/SIPC 18  Model Wealth Portfolios Program Brochure • 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). • 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). 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/. 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 may be 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. A11 – 0326 LPL Financial, member FINRA/SIPC 19  Model Wealth Portfolios Program Brochure 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 individual retirement accounts. PTC also provides personal trustee services to clients for a variety of administrative fiduciary service, 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 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-MWP 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. 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, corporate trustee services, 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. A11 – 0326 LPL Financial, member FINRA/SIPC 20  Model Wealth Portfolios Program Brochure 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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 Purchases of mutual fund shares are typically 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 MWP. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. Third-party Portfolio Strategists are not prevented from purchasing LPL Financial Holdings Inc. stock in MWP accounts. In addition, a model may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in MWP charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds (other than the Sweep Funds) will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of MWP clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of MWP client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by MWP clients in the fund (up to $25 per position). In addition, LPL charges a setup fee to product sponsors when A11 – 0326 LPL Financial, member FINRA/SIPC 21  Model Wealth Portfolios Program Brochure adding new investment products or share classes of an investment product to LPL’s investment platforms. Portfolio Strategists pay LPL initial diligence and setup fees of up to $5,000 per strategy or model portfolio and up to a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance to make their services available in the Program. In the case of ETPs, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per fund and up to $15,000 per fund for complex 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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of mutual funds and ETFs that are available for purchase through the program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL IARs so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds (other than the Sweep Funds) consists of flat and/or asset based fees totaling up to 0.15% annually of LPL clients’ investments in the investment product, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. However, LPL has a financial incentive to recommend participating products instead of those whose sponsors do not make such payments to LPL. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate.. LPL offers product sponsors of mutual funds, closed funds, interval funds, ETFs, and advisory strategies 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL A11 – 0326 LPL Financial, member FINRA/SIPC 22  Model Wealth Portfolios Program Brochure to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds (other than the Sweep Funds), and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with IARs or third party Portfolio Strategists, and, therefore, there is no financial incentive for an IAR or a third party Portfolio Strategist to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments 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. 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 IARs 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. A11 – 0326 LPL Financial, member FINRA/SIPC 23  Model Wealth 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 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. • 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. • 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, A11 – 0326 LPL Financial, member FINRA/SIPC 24  Model Wealth Portfolios Program Brochure 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. 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. • 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). • 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. LPL’s money market mutual fund sweep option automatically sweeps otherwise uninvested cash balances held in the account and invests them daily into shares of a money market mutual fund. Currently, taxable and tax-exempt money market funds offered by J.P. Morgan Asset A11 – 0326 LPL Financial, member FINRA/SIPC 25  Model Wealth Portfolios Program Brochure 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. The compensation that LPL receives related to ICA, DCA (including from 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 ICA, DCA or the Sweep Funds. However, the compensation LPL receives on ICA, DCA and Sweep Funds is retained by LPL and is not shared with Portfolio Strategists or IARs. In addition, LPL does not take into account this compensation when it makes decisions about a Portfolio’s allocation to cash. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with its IARs, and therefore, an IAR does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with its IARs, and therefore, an IAR has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your IAR’s compensation on the SCA product is reduced if your interest rate is discounted, so your IAR has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents a conflict of interest with clients because it could incentivize LPL’s IARs to invest in more conservative, lower performing investments to A11 – 0326 LPL Financial, member FINRA/SIPC 26  Model Wealth Portfolios Program Brochure maintain the stability of the account, or alternatively, could incentivize the IAR to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. 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 the 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 an 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 IAR 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 the 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 A11 – 0326 LPL Financial, member FINRA/SIPC 27  Model Wealth Portfolios Program Brochure 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. 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 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. IARs have access to review monthly or quarterly accounts statements as well as performance information. 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 dividend in the year-end performance report can 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, such as an unaffiliated Portfolio Strategist. 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 also pay for, or reimburse LPL for the costs associated with, education or training events that are attended by LPL employees and IARs and for 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 receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 sales employees have an incentive to promote MWP 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 typically 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 IAR. A11 – 0326 LPL Financial, member FINRA/SIPC 28  Model Wealth Portfolios Program Brochure In the event a trade error occurs in an 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. LPL and BlackRock Advisors, LLC (“BlackRock”) entered into an agreement pursuant to which BlackRock agreed to pay LPL an annual fixed amount for analytical data pertaining to BlackRock proprietary ETFs on LPL’s platform during the term of the agreement. BlackRock Investment Management, LLC, an affiliate of BlackRock, is one of the Portfolio Strategists available on the program. BlackRock is also affiliated with mutual funds and ETFs that could be included in the Portfolios it designs and those model portfolios designed by LPL or the other Portfolio Strategists. Because LPL benefits from these payments, the amount of which is significant, LPL’s financial interests conflict with its ability to use strictly objective factors in making the selection and retention of a BlackRock affiliate as a Portfolio Strategist and its selection of ETFs in its Portfolios. However, LPL did not agree to guarantee that BlackRock’s affiliated Portfolios will be used for any MWP client account. In addition, neither LPL nor the other Portfolio Strategists are required to include BlackRock-affiliated funds or ETFs in their Portfolios. The BlackRock affiliate is required to satisfy the same review as all other third party Portfolio Strategists. LPL has sole discretion to select Portfolio Strategists that are made available on MWP. 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 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 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: • payments based on production • 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 A11 – 0326 LPL Financial, member FINRA/SIPC 29  Model Wealth Portfolios Program Brochure • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • advances of advisory fees • payments in the form of repayable and forgivable loans • 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 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 what the IAR receives 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 MWP than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in MWP 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 MWP 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 interest of a client in accordance with the applicable standards under the Advisers Act or other applicable law. LPL has systems in place to review IAR-managed accounts in MWP for suitability over the course of the advisory relationship. 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 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. A11 – 0326 LPL Financial, member FINRA/SIPC 30  Model Wealth Portfolios Program Brochure 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. 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 benefits including but not limited to 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 shares the Account Fee with the financial institution, and the financial institution pays part of that amount to IAR based on a compensation plan between the IAR and the financial institution. The financial institutions, along with LPL, determine the compensation plan for the 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. LPL also has agreements to provide similar services at financial institutions in which compensation is not shared with the financial institution whereby a portion of the Account Fee is paid directly to the IAR. 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 Advisory 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 A11 – 0326 LPL Financial, member FINRA/SIPC 31  Model Wealth Portfolios Program Brochure 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. 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. If your IAR is an employee of and/or provides services on the premises of one of these financial institutions, the financial institution has a financial incentive for the IAR to select the financial institution’s affiliated investment products and/or certificates of deposit over non-affiliated 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/disclsures.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 IAR does not receive additional compensation from the financial institution for selecting affiliated products and the IAR may only recommend an investment product that he or she believes is appropriate, suitable, and in the best interests of the 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. Some of these financial institutions are affiliated with investment advisory firms that act as a Portfolio Strategist. An IAR offering advisory services on the premises of a financial institution has a potential conflict of interest when the IAR recommends that clients utilize an affiliated Portfolio Strategist because the financial institution has the ability to influence the IAR’s compensation and employment status. However, an IAR may only recommend a model portfolio that they believe is in the best interest of clients. Affiliated Portfolio Strategists sometimes receive a reduced Manager Fee or do not receive a Manager Fee at all. This is often because the Portfolio Strategist has included proprietary or affiliated mutual funds or exchange-traded funds in the model portfolio which charges a separate fee. The absence of a Manager Fee creates a conflict of interest for the IARs insofar as IARs can negotiate a higher LPL Advisory Fee than they could for an account subject to a higher third-party Manager Fee. In addition, model portfolios benefit from having increased assets under management even if they do not charge a Manager Fee. LPL also provides other forms of compensation to financial institutions, such as bonuses, awards or other things of value offered by LPL to the financial institution. For example LPL pays financial institutions based on production, in the form of repayable or forgivable notes, 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 pays 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 financial 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 A11 – 0326 LPL Financial, member FINRA/SIPC 32  Model Wealth Portfolios Program Brochure an 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 of the financial institution 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 and such referral programs are governed by Regulation R of the Gramm-Leach-Bliley Act. Employees of trust departments at certain financial institutions are authorized under the terms of applicable trust arrangements to delegate investment advisory 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. If your IAR is associated with Wintrust Investments, LLC (“Wintrust Financial Professional”) you should note that certain model portfolios available in the Program were created by Great Lakes Advisors, LLC (“GLA”), an affiliate of Wintrust Investments. As a Portfolio Strategist, GLA in some cases charges LPL clients a Manager Fee. However, GLA will not charge this fee to accounts advised by Wintrust Financial Professionals. Your IAR has an incentive to select the GLA model portfolios for your account due to their association with Wintrust Investments, which has the ability to influence your Financial Advisor’s compensation and employment status. However, your IAR may only recommend a model portfolio that he or she believes is appropriate for you and in your best interest. 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: • Referral Networks. Some third parties operate referral networks. Referral networks may present potential clients with a list of possible investing firms and investment adviser 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; • 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; • 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; A11 – 0326 LPL Financial, member FINRA/SIPC 33  Model Wealth Portfolios Program Brochure • 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 • 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’s participation in these referral arrangements does not diminish its fiduciary obligations to its clients. Financial Information and Custody LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody of MWP 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 MWP, LPL requires that clients direct LPL as the broker-dealer to execute transactions in the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. The fact that LPL is both the investment advisor and 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission or transaction charge for executing transactions in MWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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 to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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. Subadvisers who have discretion to trade fixed income Portfolios for clients may choose to place some or all trades for accounts with broker-dealer firms other than LPL (“trade away” or “step out”). This practice may enable a Subadviser to obtain more favorable execution, including a more advantageous net price, than would otherwise be available. If a Subadviser chooses to execute a transaction through a broker-dealer other than LPL, the execution price will usually include fees or expenses imposed by the executing broker-dealer, which the client will bear, in addition to the account fee paid to LPL. The additional expenses charged by the broker-dealer executing the A11 – 0326 LPL Financial, member FINRA/SIPC 34  Model Wealth Portfolios Program Brochure transaction include mark-ups, mark-downs or “spreads” paid to executing broker dealer firm, which are typically embedded in the purchase or sale price of such transactions, and not separately indicated on trade confirmations and custodial account statements provided by LPL. In evaluating whether to execute a trade through a broker-dealer other than LPL, a Subadviser will consider the fact that an account will not be charged an additional expenses if effected directly through LPL. Clients should understand that LPL is not able to fully evaluate whether a Subadviser is meeting its best execution obligations to clients for specific transactions when trading away, as it is not a party to such transactions and is not in a position to negotiate the price or transaction related charges with the executing broker. The responsibility to determine whether to trade away lies with the Subadviser and arises out of a Subadviser’s fiduciary duty to clients. 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 certain investment advice provided by LPL, 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. A11 – 0326 LPL Financial, member FINRA/SIPC 35 

Optimum Market Portfolios (OMP) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 your LPL 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 21, 2025. 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. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non- purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 5 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 A12 – 0326 LPL Financial, member FINRA/SIPC 1  Optimum Market Portfolios Program Brochure 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 Research 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 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 A12 – 0326 LPL Financial, member FINRA/SIPC 2  Optimum Market Portfolios Program Brochure 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 Account 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). A12 – 0326 LPL Financial, member FINRA/SIPC 3  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 A12 – 0326 LPL Financial, member FINRA/SIPC 4  Optimum Market Portfolios Program Brochure 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 • 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: – type and size of the account – 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 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. • 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. A12 – 0326 LPL Financial, member FINRA/SIPC 5  Optimum Market Portfolios Program Brochure 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. In OMP, clients invest in Portfolios designed by LPL Research. 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 Research 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. • 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 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 fixed income 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. A12 – 0326 LPL Financial, member FINRA/SIPC 6  Optimum Market Portfolios Program Brochure • 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. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-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. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non-partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship with LPL and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL and its IARs for the pledged assets. For a list of the third-party 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.” For additional A12 – 0326 LPL Financial, member FINRA/SIPC 7  Optimum Market Portfolios Program Brochure disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • 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 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. • 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 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. A12 – 0326 LPL Financial, member FINRA/SIPC 8  Optimum Market Portfolios Program Brochure 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). 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 A12 – 0326 LPL Financial, member FINRA/SIPC 9  Optimum Market Portfolios Program Brochure 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: • 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). A12 – 0326 LPL Financial, member FINRA/SIPC 10  Optimum Market Portfolios Program Brochure • 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, 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). • 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). A12 – 0326 LPL Financial, member FINRA/SIPC 11  Optimum Market Portfolios Program Brochure 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/. 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. 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, A12 – 0326 LPL Financial, member FINRA/SIPC 12  Optimum Market Portfolios Program Brochure tax preparation, financial technology tools, corporate trustee services, 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 Research 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 Research. In addition, employees in LPL Research 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. 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 A12 – 0326 LPL Financial, member FINRA/SIPC 13  Optimum Market Portfolios Program Brochure 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 IARs 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-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 A12 – 0326 LPL Financial, member FINRA/SIPC 14  Optimum Market Portfolios Program Brochure 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. • 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. • 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. 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. • 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 A12 – 0326 LPL Financial, member FINRA/SIPC 15  Optimum Market Portfolios Program Brochure 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 IARs to offer brokerage and advisory services on their premises. This presents an additional conflict of interest because the IAR 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 IARs), 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). • 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. LPL’s money market mutual fund sweep option automatically sweeps otherwise uninvested cash balances held in the account and invests them 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. The compensation that LPL receives related to ICA, DCA (including from 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, A12 – 0326 LPL Financial, member FINRA/SIPC 16  Optimum Market Portfolios Program Brochure 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 Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 lender whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with its IARs, and therefore, an IAR does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with its IARs, and therefore, an IAR has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your IAR’s compensation on the SCA product is reduced if your interest rate is discounted, so your IAR has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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, or alternatively, could incentivize the IAR to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. A12 – 0326 LPL Financial, member FINRA/SIPC 17  Optimum Market Portfolios Program Brochure 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 IAR 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 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 A12 – 0326 LPL Financial, member FINRA/SIPC 18  Optimum Market Portfolios Program Brochure 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 receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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. A12 – 0326 LPL Financial, member FINRA/SIPC 19  Optimum Market Portfolios Program Brochure 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 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: • payments based on production • 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 • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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. A12 – 0326 LPL Financial, member FINRA/SIPC 20  Optimum Market Portfolios Program Brochure 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 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 A12 – 0326 LPL Financial, member FINRA/SIPC 21  Optimum Market Portfolios Program Brochure 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: • 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; • 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; • 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; • 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 • 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’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 benefits including but not limited to 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 the IAR based on a compensation plan between the IAR and the financial institution. 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 A12 – 0326 LPL Financial, member FINRA/SIPC 22  Optimum Market Portfolios Program Brochure the client in accordance with the applicable standards under the Advisers Act. LPL also has agreements to provide similar services at financial institutions in which compensation is not shared with the financial institution whereby a portion of the Account Fee is paid directly to the IAR. 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. 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, suitable and in the best interests of the 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 financial 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 financial 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 A12 – 0326 LPL Financial, member FINRA/SIPC 23  Optimum Market Portfolios Program Brochure 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 of the financial institution 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 and such referral programs are governed by Regulation R of the Gramm-Leach-Bliley Act. Employees of trust departments at certain financial institutions are authorized under the terms of applicable trust arrangements to delegate investment advisory 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 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. A12 – 0326 LPL Financial, member FINRA/SIPC 24  Optimum Market Portfolios Program Brochure IAR, the client should contact the 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 IAR or LPL at did not receive a Brochure Supplement for the lplfinancial.adv@lplfinancial.com. A12 – 0326 LPL Financial, member FINRA/SIPC 25 

Personal Wealth Portfolios (PWP) Program Form Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This wrap 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 your LPL 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 6 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 7 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 15 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 15 Item 9: Additional Information ............................................................................................................................................... 16 A9 – 0326 LPL Financial, member FINRA/SIPC 1  Personal Wealth Portfolios (PWP) Program Form Brochure 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 Personal Wealth Portfolios (“PWP”) program. For more information about LPL’s advisory services and programs other than PWP, please contact your LPL 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 IARs are typically also registered with LPL as a broker-dealer registered representative. Therefore, in such case, an IAR is 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 PWP program is a unified managed account program in which LPL and its investment adviser representatives or IARs provide ongoing investment advice and management. In PWP, clients invest in asset allocation portfolios (Portfolios) designed by LPL’s Research Department (LPL Research), which include a combination of mutual funds, exchange-traded funds (ETFs) and investment models (Models) provided to LPL by third party money managers (PWP Advisors). The Models typically consist of equity and fixed income securities, but may include investment company securities. LPL Research selects the mutual funds, ETFs and Models to be made available in a Portfolio. 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 Portfolio based on client’s investment objective and then selects among the mutual funds, ETFs and/ or Models available in the Portfolio. The PWP 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 discretionary authority to purchase and sell securities in the account. The client authorizes LPL and IAR to take discretion by executing the Account Agreement and Application. LPL acts as the overlay portfolio manager (“OPM”) in coordinating the trades among the various securities and sleeves of a PWP account. After a PWP account is opened, and upon deposit of funds by the client, LPL will invest the client’s funds based on the Portfolio selected. It generally will take up to 5 business days from the date the account is fully funded for all assets to be fully allocated across the Portfolio. In certain cases, it may take longer to allocate assets to fixed income securities because of market conditions or the illiquid nature of certain issues. In the case of municipal security Models (“Muni Models”), it typically can take between 30 to 90 days for the Model to be fully invested. Subsequent deposits accumulate and will not be invested in the Portfolio until certain conditions are met, including conditions related to trade size and position deviation from the target allocation. A9 – 0326 LPL Financial, member FINRA/SIPC 2  Personal Wealth Portfolios (PWP) Program Form Brochure During the normal course of business, LPL reviews accounts on a daily basis and executes trades as needed. In addition, each year based on the anniversary date of the initial account asset allocation, LPL will examine if any particular asset class in an account has drifted beyond a tolerance limit and determine if the account should be rebalanced to be within acceptable asset allocation tolerances. Except as described below for Muni Models, the role of the PWP Advisors is limited to submitting Models to LPL, who has discretion as OPM for trade execution. However, if a Portfolio is selected that includes a Muni Model, the PWP Advisor for that Model will have discretionary trading authority with respect to the purchase and sale of fixed income securities for the portion of the account invested according to the Muni Model (“Muni Sleeve”). Although the PWP Advisor has discretion over the Muni Sleeve, LPL has ultimate discretion over the entire account and may exercise discretion over securities in the Muni Sleeve (e.g., to rebalance the Account or to liquidate securities for withdrawal requests). LPL may appoint from time to time other PWP Advisors to take discretion over a portion of the account managed according to that PWP Advisor’s Model. 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 PWP program pay LPL an annualized fee (the “Account Fee”). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the IAR changes the PWP Advisor, investment strategy, or model portfolio selected for an account, or if the investment value of the account changes, the overall Account Fee may increase or decrease. 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, IARs and PWP Advisors do not charge performance-based fees to accounts in the PWP program. Advisory Fee. The Advisory Fee is charged for the investment advisory services of IAR, as well as the investment advisory, administrative, trading, custodial and clearing services of LPL. The Advisory Fee is shared with IAR. The Advisory Fee is negotiable between the client and the IAR and is based on the value of assets in the account, including cash holdings, and is payable quarterly in advance. The maximum Advisory Fee is 2.35%. LPL retains a portion of the Advisory Fee, up to 0.675% of the value of the account for its administrative, custody and clearing services, and the portfolio design services of LPL Research. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Advisory Fee with the IAR based on the agreement between LPL and the IAR. LPL retains any portion of the Advisory Fee not shared with the IAR. A portion of the fee payable 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. Manager Fee. Depending on the PWP Advisor selected, clients pay a Manager Fee for a PWP Advisor that is set by the PWP Advisor. The Manager Fee will differ depending on the PWP Advisor selected for the Account and may also differ depending on which investment strategy or model portfolio is selected. Clients do not pay LPL or IARs brokerage commissions or transaction charges for the execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” The Manager Fee is based on the value of the assets in the Portfolio advised by the PWP Advisor, including cash holdings, and payable quarterly in advance. The Manager Fee currently ranges from 0.15% to 0.60%. For certain models A9 – 0326 LPL Financial, member FINRA/SIPC 3  Personal Wealth Portfolios (PWP) Program Form Brochure designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL retains portions of the Manager Fee for trading services, there is a conflict of interest for us to recommend such models. Your IAR does not receive any portion of the Manager Fee, including based on recommending a model for which LPL retains this compensation. Please note that if the Account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. The fees paid by LPL to PWP Advisors in the program out of the Manager Fee are generally less than a PWP Advisor would charge a client seeking to establish a direct relationship outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, trading and marketing expenses that would otherwise be borne by the PWP Advisor and the role of the PWP Advisor is generally limited to providing models to LPL. PWP Advisors generally have higher minimum account size requirements when managing direct accounts and higher fees when the PWP Advisor bears those expenses. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a PWP account from the account. LPL pays the applicable portion of the Account Fee to the PWP Advisors whose models are selected for 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). Other Types of Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to a PWP 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 miscellaneous 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 will be lowered or waived for certain clients. Clients do not pay LPL or IARs brokerage commissions, markups or transaction charges for execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in PWP accounts. Some of these fees and charges are described below. In PWP, assets may be invested in mutual funds or ETFs 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 fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay the Account Fee with respect to assets invested in ETFs and mutual funds. The mutual funds and ETFs available in the program can be purchased directly outside of the A9 – 0326 LPL Financial, member FINRA/SIPC 4  Personal Wealth Portfolios (PWP) Program Form Brochure program. Therefore, clients could generally avoid the second layer of fees by not using the advisory services of LPL, the PWP Advisors and IAR and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” If client transfers into a PWP 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 PWP model. 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. When transferring securities into a PWP account, client should be aware that certain securities are not be eligible for the account. In such case, the securities will 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 a PWP 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. For those Portfolios consisting of mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in PWP charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds (other than the cash sweep money market funds (“Sweep Funds”) described in the section of Item 9 labeled “Participation or Interest in Client Transactions”) will be credited to the account. As described below under “Additional Information – Brokerage Practices,” if a PWP Advisor for a Muni Model chooses to execute a transaction through a broker-dealer other than LPL, the execution price to the client may include a commission, mark-up/mark-down, or other fee imposed by the executing broker-dealer in addition to the Account A9 – 0326 LPL Financial, member FINRA/SIPC 5  Personal Wealth Portfolios (PWP) Program Form Brochure Fee. If client holds an American Depositary Receipt (“ADR”) in an account, there are custodial fees or taxes related to the ADR. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Wrap Fees on a PWP Account • The Account Fee is an ongoing fee for investment advisory services, the execution of transactions and other administrative and custodial services. The Account Fee may cost the client more than purchasing the program services separately, for example, paying a separate advisory fee for each of the services of LPL, IAR and the PWP Advisor, 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: – type and size of the account – type and number of securities in the Portfolio (whether equities, fixed income securities, mutual funds or ETFs) – 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 IAR is responsible for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, and the 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 Advisory Fee with IAR. • Some of the investment products available to be purchased in the program can be purchased by clients outside of a PWP account, through broker-dealers or other investment firms not affiliated with 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 $250,000. In certain instances, LPL will permit a lower minimum account size. An account will not be invested according to the Portfolio until the minimum account size and the targeted funding value of the account 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 ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. A9 – 0326 LPL Financial, member FINRA/SIPC 6  Personal Wealth Portfolios (PWP) Program Form Brochure Item 6: Portfolio Manager Selection and Evaluation In PWP, LPL and IAR are responsible for the overall investment advice and management services offered to clients, and the client selects the IAR who manages 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. LPL makes available Models designed by PWP Advisors. LPL selects and reviews on an ongoing basis the PWP Advisors available on PWP based on quantitative, qualitative and infrastructure criteria, which include: Quantitative Criteria LPL evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style group, including but not limited to: • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP Advisor can handle operational requirements including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable • Back office review • Client servicing resources • Firm-wide program commitment LPL reviews PWP Advisors currently participating in the program and reviews new PWP Advisors prior to the addition of their Models to the program. LPL may elect to remove a PWP Advisor should it determine that the PWP Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in management staff). In making a decision to remove a PWP Advisor, LPL Research takes into consideration all criteria; no one criteria is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove a PWP Advisor. A9 – 0326 LPL Financial, member FINRA/SIPC 7  Personal Wealth Portfolios (PWP) Program Form Brochure PWP Advisor Performance LPL Research uses information provided by the PWP Advisor and also may use independent, third party databases when evaluating a PWP Advisor. In order for a PWP Advisor to be selected for the program, LPL generally requires a third party verification letter related to compliance of the PWP Advisor’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performance. However, LPL provides clients with individual performance information. Performance information distributed by LPL is compiled using third party portfolio accounting and reporting software. Client performance information is calculated by LPL on a uniform and consistent basis using a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that PWP Advisors provide Models to LPL, and, except in the case of Muni Models, LPL is the party with discretion for trade implementation and execution in PWP accounts. Therefore, Models submitted to LPL by PWP Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisor. Because of this fact and because LPL (and not the PWP Advisor) has discretionary authority to implement trades, performance of a PWP account will differ from the performance of PWP Advisor’s discretionary accounts. LPL Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL Research. LPL Research provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap program, Manager Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The IAR selects the Portfolio and provides advice based on the client’s individual needs. LPL Research uses various investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or A9 – 0326 LPL Financial, member FINRA/SIPC 8  Personal Wealth Portfolios (PWP) Program Form Brochure ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL Research determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the IAR of the change in status and provide alternatives for the account from which the IAR will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. Types of Investments and Risks The Portfolios include different types of securities, such as mutual funds, closed end funds, ETFs, ETNs, and equity and fixed income securities. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could A9 – 0326 LPL Financial, member FINRA/SIPC 9  Personal Wealth Portfolios (PWP) Program Form Brochure sectors do not perform as expected. Alternatively, the lack of be affected if the sectors, industries, or sub exposure to one or more sectors or industries may adversely affect performance. ‐ • Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or unit investment trusts. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Closed-End Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an “interval fund”). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. A9 – 0326 LPL Financial, member FINRA/SIPC 10  Personal Wealth Portfolios (PWP) Program Form Brochure • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (“ETPs”). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), futures-linked ETPs (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other ETPs. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. A9 – 0326 LPL Financial, member FINRA/SIPC 11  Personal Wealth Portfolios (PWP) Program Form Brochure Interest.” For additional disclosures • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (“SCA”) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (“partner banks”) and other banks (“non-partner banks”). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-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. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non-partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship with LPL and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL and its IARs for the pledged assets. For a list of the third-party 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 regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. A9 – 0326 LPL Financial, member FINRA/SIPC 12  Personal Wealth Portfolios (PWP) Program Form Brochure • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • 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 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. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • 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. A9 – 0326 LPL Financial, member FINRA/SIPC 13  Personal Wealth Portfolios (PWP) Program Form Brochure • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and its IARs generally will earn more compensation for selling one investment product than another. As a result, LPL and its IARs have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. LPL’s Overlay Portfolio Management Services As OPM, LPL provides advisory services tailored to the individual needs of the clients. LPL reviews accounts on a daily basis for rebalancing. LPL accommodates reasonable requests to restrict holdings of specific securities, specific industries, specific sectors, and certain pre-defined categories (e.g., “sin” stocks). In the event that client restrictions prevent the investment in certain securities otherwise recommended by a PWP Advisor, assets will be invested pro- rata across the remaining securities in the Model. Such restrictions do not apply to any mutual funds, ETFs or fixed- income securities that are held in the account. Restrictions placed on an account can affect the performance of the account. The OPM may choose not to accept an account with restrictions that are inconsistent with the investments chosen by the OPM or as recommended by the PWP Advisor. LPL accommodates requests to perform tax harvesting, which may include using the proceeds of tax-related transactions to purchase appropriate securities (such as ETFs) for an account. In such case, proceeds of tax-related transactions may be held in cash or securities until appropriate wash sale periods have expired. Once the wash sale period has expired, the related proceeds will be invested according to the Portfolio selected. Similarly, LPL may delay a tax harvesting request to sell securities acquired in the previous 30 days until the wash sale period has expired. In certain circumstances, LPL also accommodates requests for all or a portion of the account to remain allocated to cash for a period of time. After the expiration of that time period, LPL will reinvest the Account according to the model portfolio selected. Such customized requests, liquidation requests in connection with withdrawals, and changes to the Portfolios or investment objective selected may take up to 5 business days to process, and, in certain circumstances, may take longer. As LPL generally has discretion to implement a Model, an account’s holdings may differ from the Model submitted. For example, LPL may limit small trades (defined by minimum dollar amounts, share amounts, percentage of account, or percentage of individual asset class). In addition, due to market conditions or the illiquid nature of certain issues, there could be times when LPL will not be able to invest in specific taxable fixed income securities that appear in a Model. In those circumstances LPL will attempt to invest in fixed income securities with similar characteristics as those in the Models. For clients in California and New York, if tax-free fixed income securities are selected for a Muni Model, the PWP Advisor will attempt to limit the fixed income securities purchased to state-specific, tax free fixed income securities; however, the PWP Advisor may also include non-state-specific securities. Voting Client Securities Unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions A9 – 0326 LPL Financial, member FINRA/SIPC 14  Personal Wealth Portfolios (PWP) Program Form Brochure to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. A copy of LPL’s proxy voting policies is available upon request to your IAR. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting the 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of the PWP Advisors without reviewing individual client interests, unless LPL determines that such instructions are overtly contrary to our client’s best interest. In such case, LPL will determine whether or how to act consistent with the best interests of our clients. LPL, IAR and the PWP Advisors are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the account, or the issuers thereof. The client retains the right and obligation 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 an appropriate investment objective 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. Because the PWP Advisor’s role generally is limited to providing Models to LPL, and the PWP Advisor does not provide individualized discretionary advisory services to PWP clients, LPL generally does not communicate specific client information to PWP Advisors. However, in the case of PWP Advisors for the Muni Models, the PWP Advisor does provide individualized discretionary advisory services with respect to the Muni Sleeve. If a Muni Model is selected, LPL forwards client information from the Account Application to the PWP Advisor. If client communicates to the IAR regarding material changes in the client’s financial circumstances, investment objectives or investment restrictions, such information is forwarded to the PWP Advisor for the Muni Model. Clients may communicate such information to the IAR or otherwise communicate directly with the PWP Advisor, although clients are encouraged to direct communication through their IARs. 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. Because the PWP Advisor’s role generally is limited to providing Models to LPL, and the PWP Advisor does not provide individualized discretionary advisory services to PWP clients, PWP Advisors generally are not available to be contacted or consulted by PWP clients. However, in the case of PWP Advisors for the Muni Models, the PWP Advisor does provide individualized discretionary advisory services with respect to the Muni Sleeve. If a Muni Model is selected, clients may consult directly A9 – 0326 LPL Financial, member FINRA/SIPC 15  Personal Wealth Portfolios (PWP) Program Form Brochure with the PWP Advisor, although clients are encouraged to direct contact with the PWP Advisor through OPM or their 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: • 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). A9 – 0326 LPL Financial, member FINRA/SIPC 16  Personal Wealth Portfolios (PWP) Program Form Brochure • 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, 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). • 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 A9 – 0326 LPL Financial, member FINRA/SIPC 17  Personal Wealth Portfolios (PWP) Program Form Brochure 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). 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/. 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 may be broker-dealer 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. A9 – 0326 LPL Financial, member FINRA/SIPC 18  Personal Wealth Portfolios (PWP) Program Form Brochure LPL and The Private Trust Company (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-PWP 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. 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, corporate trustee services, 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research are required to obtain A9 – 0326 LPL Financial, member FINRA/SIPC 19  Personal Wealth Portfolios (PWP) Program Form Brochure 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 Purchases of mutual fund shares typically are 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. PWP Advisors are not prevented from purchasing LPL Financial Holdings Inc. stock in PWP accounts. In addition, a PWP account may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in PWP charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds (other than the Sweep Funds) will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of clients. These services include establishing and maintaining accounts with the funds, facilitating the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by PWP clients in the fund (up to $25 per position). 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 ETPs, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per fund and up to $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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted A9 – 0326 LPL Financial, member FINRA/SIPC 20  Personal Wealth Portfolios (PWP) Program Form Brochure with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (sponsors) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access IARs so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds (other than the Sweep Funds) consists of flat and/or asset based fees totaling up to 0.15% annually, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or A9 – 0326 LPL Financial, member FINRA/SIPC 21  Personal Wealth Portfolios (PWP) Program Form Brochure a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds (other than the Sweep Funds), and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with IARs or PWP Advisors, and therefore, there is no financial incentive for an IAR or a PWP Advisor to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments 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. 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 IARs 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-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 A9 – 0326 LPL Financial, member FINRA/SIPC 22  Personal Wealth Portfolios (PWP) Program Form Brochure 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. • 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. • 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. 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. • 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 A9 – 0326 LPL Financial, member FINRA/SIPC 23  Personal Wealth Portfolios (PWP) Program Form Brochure 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). • 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. LPL’s money market mutual fund sweep option automatically sweeps, otherwise uninvested cash balances held in the account and invests them 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. The compensation that LPL receives related to ICA, DCA (including from 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 A9 – 0326 LPL Financial, member FINRA/SIPC 24  Personal Wealth Portfolios (PWP) Program Form Brochure LPL has a financial benefit if cash balances are maintained in ICA or the Sweep Fund. However, the compensation LPL receives on ICA, DCA and Sweep Funds is retained by LPL and is not shared with IARs. LPL Research does not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with its IARs, and therefore, an IAR does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with its IARs, and therefore, an IAR has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your IAR’s compensation on the SCA product is reduced if your interest rate is discounted, so your IAR has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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, or alternatively, could incentivize the IAR to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. A9 – 0326 LPL Financial, member FINRA/SIPC 25  Personal Wealth Portfolios (PWP) Program Form Brochure 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 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 an 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 IAR 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 the 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. Other Clients Client should understand that LPL and IAR perform advisory and/or brokerage services for various other clients, and that LPL and IAR 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 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. A9 – 0326 LPL Financial, member FINRA/SIPC 26  Personal Wealth Portfolios (PWP) Program Form Brochure LPL provides clients with regular written reports regarding their accounts. LPL provides detailed performance information annually describing account performance and positions, with additional performance information available upon request. In addition, LPL sends 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. IARs review monthly or quarterly account statements as well as performance information. Other Compensation PWP Advisors reimburse LPL for costs associated with the use of technology necessary for a PWP Advisor to perform its services under the program. LPL, LPL employees and IARs also receive additional compensation 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 also pay for, or reimburse LPL for the costs associated with, education or training events that are attended by LPL employees and IARs and for 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 receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 sales employees have an incentive to promote PWP 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 typically remain in free credit balance. In such cases, 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. A9 – 0326 LPL Financial, member FINRA/SIPC 27  Personal Wealth Portfolios (PWP) Program Form Brochure 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 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 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: • payments based on production • 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 • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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 A9 – 0326 LPL Financial, member FINRA/SIPC 28  Personal Wealth Portfolios (PWP) Program Form Brochure 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 PWP than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in PWP 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 PWP 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 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 platform, 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. A9 – 0326 LPL Financial, member FINRA/SIPC 29  Personal Wealth Portfolios (PWP) Program Form Brochure 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: • 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; • 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; • 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; • 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 • 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’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 A9 – 0326 LPL Financial, member FINRA/SIPC 30  Personal Wealth Portfolios (PWP) Program Form Brochure 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 benefits including but not limited to 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 shares the Account Fee with the financial institution, and the financial institution pays part of that amount to IAR based on a compensation plan between the IAR and the financial institution. 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. An 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. LPL also has agreements to provide similar services at financial institutions in which compensation is not shared with the financial institution whereby a portion of the Account Fee is paid directly to the IAR. 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 Advisory 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 your 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. 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 and/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 affiliated products and the IAR may only recommend an investment product that he or she believes is appropriate, suitable and in the best interests of the 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 financial institution. For example LPL pays financial institutions payments based on production, in the form of repayable or forgivable loans, reimbursement of fees that LPL charges for items such as A9 – 0326 LPL Financial, member FINRA/SIPC 31  Personal Wealth Portfolios (PWP) Program Form Brochure 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, or attendance at LPL’s national conference or top producer forums and events. LPL pays 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 financial 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 of the financial institution 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 and such referral programs are governed by Regulation R of the Gramm-Leach-Bliley Act. Employees of trust departments at certain financial institutions are authorized under the terms of applicable trust arrangements to delegate investment advisory 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 PWP 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 PWP, LPL requires that clients direct LPL as broker-dealer to execute transactions in the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. The fact that LPL is both the investment advisor and 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission for executing transactions in PWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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 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 A9 – 0326 LPL Financial, member FINRA/SIPC 32  Personal Wealth Portfolios (PWP) Program Form Brochure disclosures about DRP, including eligibility, fees, how dividends are reinvested, and more can be found at lpl.com/disclosures.html. If a Portfolio is selected that includes a Muni Model, the PWP Advisor will have discretion to purchase and sell securities in the Muni Sleeve of the account. In connection with its duty to seek to achieve best execution, the PWP Advisor may choose to execute transactions through a broker-dealer other than LPL. In such case, the execution price may include a commission, markup or markdown, or other charges in addition to the Account Fee. Clients should read and understand the brokerage practices and other disclosures in the Firm Brochure of the PWP Advisor for the Muni Model. LPL will aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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 affect 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. 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 certain investment advice provided by LPL and may meet with clients from time to time, 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 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. A9 – 0326 LPL Financial, member FINRA/SIPC 33 

RETIREMENT PLAN PROGRAMS BROCHURE LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This brochure provides information about the qualifications and business practices of LPL Financial. If you have any questions about the contents of this brochure, please contact your LPL Financial representative or LPL Financial 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 Financial also is available on the SEC’s website at https://adviserinfo.sec.gov/. ITEM 1 COVER PAGE ITEM 2 MATERIAL CHANGES No material changes have been made to this Brochure from the time of the most recent annual update dated March 31, 2025. ITEM 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ................................................................................................................................................................... 1 ITEM 2 MATERIAL CHANGES ....................................................................................................................................................... 1 ITEM 3 TABLE OF CONTENTS ..................................................................................................................................................... 1 ITEM 4 ADVISORY BUSINESS ....................................................................................................................................................... 1 ITEM 5 FEES AND COMPENSATION............................................................................................................................................ 4 ITEM 6 PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................................. 5 ITEM 7 TYPES OF CLIENTS ........................................................................................................................................................... 5 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ..................................................................... 5 ITEM 9 DISCIPLINARY INFORMATION ......................................................................................................................................... 8 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................................................................. 11 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING.............. 12 ITEM 12 BROKERAGE PRACTICES ............................................................................................................................................. 13 ITEM 13 REVIEW OF ACCOUNTS ............................................................................................................................................... 13 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................................... 13 ITEM 15 CUSTODY ..................................................................................................................................................................... 20 ITEM 16 INVESTMENT DISCRETION .......................................................................................................................................... 20 ITEM 17 VOTING CLIENT SECURITIES........................................................................................................................................ 20 ITEM 18 FINANCIAL INFORMATION.......................................................................................................................................... 20 ITEM 4 ADVISORY BUSINESS Introduction LPL Financial LLC (LPL) is an investment advisor registered with the SEC pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”). LPL has provided advisory services as a registered investment advisor since 1975. Note that registration as an investment advisor with the SEC does not imply a certain level of skill or training. As of December 31, 2025, LPL managed approximately $818,320,000,000 of client assets on a discretionary basis and approximately $797,900,000 of client assets on a non-discretionary basis. LPL is owned 100% by LPL Holdings, Inc., which is owned 100% by LPL Financial Holdings Inc., a publicly held company. A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE Types of Advisory Services LPL offers various types of advisory services and programs, including wrap programs, mutual fund asset allocation programs, advisory programs offered by third party investment advisor firms, financial planning services, retirement plan investment and consulting services, investment research, an advisor-enhanced digital advice program, and other customized advisory services. This Brochure sets out information about the retirement plan advisory and consulting services that LPL and its investment adviser representatives (IARs) provide through the Retirement Plan Consulting Program (RPCP) and the Strategic Market Solution Program (SMS) (each, a “Program” and, together, the “Programs”). LPL’s advisory services are made available to clients primarily through individuals associated with LPL as IARs. For more information about the IAR providing advisory services, client should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time client engages the IAR. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lplfinancial.com. 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. Clients in SMS (and in RPCP under limited circumstances) may select a third-party investment advisor firm (Advisor) associated with an LPL registered representative, in lieu of an IAR, to provide the advisory and consulting services described in this Brochure. For more information about the third-party investment advisor firm providing advisory services, please contact Advisor for a copy of a similar brochure. LPL provides information in separate disclosure brochures for its other advisory services and advisory programs, including the Strategic Asset Management, Manager Select, Manager Access Select, Personal Wealth Portfolios, Optimum Market Portfolios, Model Wealth Portfolios, and Guided Wealth Portfolios programs. If clients would like more information on such services and programs, clients should contact the IAR or Advisor for a copy of the disclosure brochure that describes such service or program or go to https://adviserinfo.sec.gov/. LPL is also a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”) and provides brokerage services to clients. All recommendations by LPL in the Programs will be in an advisory capacity. 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. From time to time LPL and/or IAR will make the Plan or Plan participants aware of and will offer services available from LPL and/or IAR that are separate and apart from the services provided under the Programs. Such other services include services to the Plan, to a client with respect to client's responsibilities to the Plan and/or to one or more Plan participants. In offering any such services, neither LPL nor IAR is providing the services under the Programs. If any such separate services are offered to a client, the client will make an independent assessment of such services without reliance on the advice or judgment of LPL or the IAR. If a retirement plan (a “Plan”) makes available publicly traded employer stock (company stock) as an investment option under the Plan, neither LPL nor IARs provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. Also, neither LPL nor IARs provide advice regarding the offering to participants of individual self-directed brokerage accounts, mutual fund windows, or other similar arrangements and are not responsible for the decision to offer such arrangements. In addition, if participants in the Plan invest the assets in their accounts through such arrangements, or obtain participant loans, LPL and IARs do not provide any individualized advice or recommendations to the participants regarding these decisions. Any investment advice provided under the Programs is provided to the Plan Sponsor. LPL and IARs do not provide individualized investment advice to Plan participants regarding their Plan assets under the Programs. A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE Retirement Plan Consulting Program Under the RPCP program, IARs assist clients that are trustees or other fiduciaries to Plans by providing fee-based consulting and/or advisory services. Such Plans may or may not be subject to Employee Retirement Income Security Act of 1974 (ERISA). IARs perform one or more of the following services summarized below, as selected by the client in the client agreement. Investment Advisory Services • Assist the Plan in the preparation or review of an IPS for the Plan. • Recommend or select specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan to be made, available as investment options under the Plan. • Perform ongoing monitoring of investments options available in the Plan. • Assistance in identifying an investment product or model portfolio in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA. • Develop asset allocation target-date or risk-based model portfolios for the Plan to make available to Plan participants, based on funds from the line-up of investment options chosen by the client, and to periodically review these with the client during Plan reviews at such frequency as is mutually agreed upon. • Prepare reports reviewing the performance of Plan investments options. Plan Consulting Services • Assist the Plan by acting as a liaison between the Plan and service providers, product sponsors and/or vendors. • Provide education, training, and/or guidance for the members of the Plan Committee with regard to plan features, retirement readiness matters, or service on the Committee. • Assist the client in enrolling Plan participants in the Plan, including providing participants with information about the Plan. • Assist with participant education, including preparation of education materials and/or conducting investment education seminars and meetings for Plan participants. Assist with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support. • Provide the client with comparisons of Plan data (e.g., regarding fees and services and participant enrollment and contributions). • Assist client in identifying the fees and other costs borne by the Plan. LPL provides advisory services under RPCP as a registered investment adviser under the Advisers Act, and is a fiduciary under the Advisers Act with respect to such services. If client elects to engage LPL and IAR to perform ongoing investment monitoring and ongoing investment recommendation services to a Plan subject to ERISA in the RPCP agreement, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Depending upon the scope of services offered by the IAR, clients may also have the option of engaging LPL and IAR to provide certain of the above Investment Advisory Services on a discretionary basis as an “investment manager” under Section 3(38) of ERISA. Therefore, LPL and IAR will be deemed a “fiduciary” as such term is defined under ERISA when providing either non-discretionary investment advice or discretionary investment manager services, as designated in the client account agreement. Clients should understand that to the extent LPL and IAR are engaged to perform services other than ongoing investment monitoring and recommendations (for example, investment education and general financial information), those services are not “investment advice” under ERISA and therefore, LPL and IAR will not be a “fiduciary” under ERISA with respect to those other services. Strategic Market Solution Under SMS, LPL’s Research Department (a team of investment professionals within LPL) (LPL Research) creates and maintains an investment menu (Investment Menu) consisting of a mix of different asset classes and investment vehicles (Investment Options) for clients that sponsor and maintain participant-directed defined contribution plans (Plan Sponsors). The Investment Menu is designed around key objectives, with the Investment Options organized into tiers based on broad participant behavior profiles. LPL Research is responsible for the selection and monitoring of the Investment Options made available through the Investment Menu (Fiduciary Selection Services). The Investment Options that are offered through SMS are limited to the specific investments available through the record keeper that the Plan Sponsor selects. A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE If the Plan is subject to ERISA, LPL will be a “fiduciary” and serve as “investment manager” (as that term is defined in Section 3(38) of ERISA) in connection with the Fiduciary Selection Services. None of the services offered under SMS other than the Fiduciary Selection Services will constitute “investment advice” under 3(21)(A)(ii) of ERISA, or otherwise cause LPL or IAR or Advisor, as applicable, to be deemed a fiduciary. In addition to the Fiduciary Selection Services, Plan Sponsor may also select from a number of non-fiduciary consulting services available under SMS that are provided by the IAR or Advisor, as applicable. These consulting services may include, but are not limited to: general education, and support regarding the Plan and the investment options selected by Plan Sponsor; assistance regarding the selection of, and ongoing relationship management for, record keepers and other third-party vendors; Plan participant enrollment support; and participant-level education regarding investment in the Plan. These consulting services do not include any individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets, and LPL and the IAR or Advisor, as applicable, do not act as fiduciaries under ERISA in providing such consulting services. ITEM 5 FEES AND COMPENSATION Under RPCP, clients pay LPL a fee (the “RPCP Fee”) for advisory and/or consulting services. LPL shares up to 100% of the RPCP Fee (typically 95%) with the IAR based on the agreement between LPL and the IAR. A portion of the fee to the IAR is, in certain circumstances, 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 RPCP Fee for supervision because the fee affects his or ability to provide objective supervision of the IAR. The RPCP Fee is based on a percentage of the assets held in the Plan (up to 1.25% annually), on an hourly basis (up to $400 per hour), or on a flat rate basis, as negotiated between the Plan and the IAR. The RPCP Fee will be payable to LPL in advance or in arrears on the frequency (e.g., quarterly, monthly, etc.) agreed upon among the client, the IAR, and LPL. If asset-based fees are negotiated, the RPCP Fee payment generally will be based on the value of the Plan assets as of the close of business on the last business day of the period as valued by the custodian of the assets. However, if the RPCP Fee is paid by the Plan or the client through a third-party service provider, such fee will be calculated as determined by the provider. If the RPCP Fee is paid prior to the services being provided, the Plan will be entitled to a prorated refund of any prepaid fees for services not received upon termination of the client agreement among the client, LPL and the IAR. Under SMS, clients pay LPL a fee (the “SMS Fee”) for the advisory services of LPL Research and the services provided by the IAR or Advisor, as applicable, up to an annual maximum of 0.80%. The SMS Fee paid by the client is inclusive of an LPL “Program Fee” for the investment advisory services provided by LPL Research, and an advisor fee for the services provided by the IAR or Advisor, as applicable. The LPL Program Fee is 0.05%, based on an annualized percentage of assets held in the Plan, subject to a minimum annual Program Fee of $1,000. However, certain clients who engaged LPL prior to October 1, 2025 may remain under ongoing legacy pricing with an LPL Program Fee of 0.10% or a $250 annual minimum fee, whichever is greater, up to an annual maximum of 0.85%. In certain instances, LPL offers Program Fee discounts based upon the amount of assets held in the Plan or other criteria. The advisor fee is negotiable at the discretion of each IAR or Advisor, as applicable, up to a maximum of 0.75%. LPL shares up to 100% of the advisor fee (typically 90%) with the IAR or Advisor, as applicable, based on the agreement between LPL and the IAR or Advisor. The SMS Fee will be payable to LPL in arrears on the frequency agreed upon between Client and IAR or Advisor, as applicable. The Plan or Plan Sponsor incurs fees and charges imposed by third parties other than LPL and IAR or Advisor, as applicable, in connection with RPCP and SMS services. These third-party fees can include fund or annuity subaccount management fees, 12b-1 fees and administrative servicing fees, plan recordkeeping and other service provider fees. Further information regarding charges and fees assessed by a fund or annuity are available in the appropriate prospectus. If a client engages LPL and IAR or Advisor, as applicable, to provide ongoing investment recommendations to the Plan or Plan Sponsor regarding the investment options (e.g., mutual funds, collective investment funds) to be made available to Plan participants, clients should understand that there generally will be two layers of fees with respect to such assets. The Plan will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. The client also will pay LPL and IAR or Advisor, as applicable, the RPCP Fee or SMS Fee, as applicable, for the investment recommendation services. Therefore, A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE clients could generally avoid the second layer of fees by not using the advisory services of LPL and IAR or Advisor, as applicable, and by making their own decisions regarding the investment. If a Plan or Plan Sponsor makes available a variable annuity as an investment option, there are mortality, expense and administrative charges, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. If a Plan or Plan Sponsor makes available a pooled guaranteed investment contract (GIC) fund, there are investment management and administrative fees associated with the pooled GIC fund. As part of the RPCP services, in certain instances the IAR will recommend a mutual fund that pays asset-based sales charges or service fees (e.g., 12b-1 fees) to LPL and the IAR as broker-dealer to the Plan. The receipt of 12b-1 fees presents a conflict of interest because it gives LPL and its IARs an incentive to recommend mutual funds based on the compensation received rather than on a client’s needs. LPL addresses this conflict by using 12b-1 fees paid by product sponsors to LPL and IAR as broker- dealer to the Plan to offset the RPCP Fee. Clients should understand that the RPCP Fee or portion of the SMS Fee, as applicable, that client negotiates with IAR or Advisor, as applicable, will be higher than the fees charged by other investment advisors or consultants for similar services in certain circumstances. This is the case, in particular, if the fee is at or near the maximum fees set out above. The IAR or Advisor, as applicable, is responsible for determining the fee to charge each client based on factors such as total amount of assets involved in the relationship, the complexity of the services, and the number and range of supplementary advisory and client- related services to be provided. Clients should consider the level and complexity of the consulting and/or advisory services to be provided when negotiating the fee with IAR or Advisor, as applicable. Clients pay the RPCP Fee or SMS Fee, as applicable, by check made payable to LPL Financial LLC. In the alternative, clients also may instruct a Plan’s service provider or custodian to calculate and debit the fee from the Plan’s account at the custodian and pay such fee to LPL. ITEM 6 PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT This Item is not applicable. LPL and its IARs do not accept performance-based fees for RPCP or SMS. ITEM 7 TYPES OF CLIENTS RPCP is available to clients that are trustees or other fiduciaries to Plans, including 401(k), 457(b), 403(b) and 401(a) plans. Plans include participant directed defined contribution plans and defined benefit plans. Plans may or may not be subject to ERISA. LPL does not require a minimum asset amount for retirement plan consulting services. SMS is available to clients that sponsor and maintain participant-directed defined contribution plans that are subject to ERISA. LPL does not require a minimum asset amount for SMS investment advisory or consulting services. The investment advisory services provided by LPL and its IARs or Advisor, as applicable, are services that are provided only to the Plan Sponsor or the Plan, and not to any particular Plan participant. ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS LPL or IARs, as applicable under either RPCP or SMS, will conduct analyses of securities using a technical/quantitative and/or fundamental/qualitative approach in certain circumstances. The sources of information that LPL (or an IAR, in the case of RPCP) will use to provide advice to Plans or Plan Sponsors include the following: research conducted by LPL (or the IAR in the case of RPCP), research materials prepared by LPL or third parties, statistical and/or analytical industry databases, financial newspapers and magazines, and vendor or company press releases. When providing investment advisory services in RPCP, IARs will recommend asset allocation strategies in certain circumstances. LPL makes available to IARs providing investment and asset allocation recommendations in RPCP an investment analysis scorecard (the “Scorecard”). The Scorecard system is intended to identify suitable investments using a consistent process and monitor the investments on a periodic basis. The system takes into account historical data and uses a 12 point scoring system A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE based on quantitative factors (e.g., style drift, performance, risk and risk-adjusted returns) and qualitative factors (e.g., operating expenses, manager tenure). It is important to note that although LPL makes available research materials and a scoring system to IARs in connection with services provided under RPCP, an IAR will not necessarily take into consideration these materials. Clients are encouraged to speak to their IAR directly to discuss the IAR’s particular approach and strategy for providing consulting services to the Plan. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Under SMS, LPL Research is responsible for the selection of investment options to be made available to participants in a Plan. The applicable Plan Sponsor adopts an Investment Policy Statement that it believes is consistent with the investment needs of the participants in its Plan, and LPL Research selects investment options consistent with such Investment Policy Statement. As part of its evaluation of investment options for a Plan, LPL Research relies on a defined process to select and monitor the investments, including: external and internal database reviews; quantitative analysis of absolute, relative and risk adjusted returns, style analysis and historical allocations; qualitative analysis of the investment sponsor’s organization, professionals and investment processes and procedures; and internal management and committee review meetings. LPL Research will regularly monitor a Plan’s investment options and investment categories for compliance with its investment objectives and to assess whether a particular investment option continues to be appropriate for the Plan. While frequent change is neither expected nor desirable, the process of monitoring investment performance relative to specified guidelines is an ongoing process. Recognizing that short-term fluctuations may cause variations in performance, when monitoring investments under a Plan, LPL Research will evaluate investment performance from a long-term perspective. Monitoring utilizes the same criteria that were the basis of the investment selection decision. Under RPCP, fiduciaries of a Plan choose to select a number of different types of securities and insurance products to make available to Plan participants, including mutual funds, group annuity contracts, collective investment funds, GICs, ETFs, stable value funds, annuity subaccounts or other securities. Under SMS, the Investment Menu includes mutual funds and stable value funds. Each different type of security or product carries with it risks that are inherent in that specific type of security. Mutual funds, collective investment funds, ETFs and annuity subaccounts may also invest in varying types of securities which carry these risks. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks and features associated with investing in general and with some types of investments that may be purchased by a Plan. • 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 Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile • unwilling to meet its financial obligations. Issuer than the market as a whole and can perform differently from the value of the market as a whole. ‐ • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Group Annuities. If client purchases a group annuity contract for the Plan, clients should read and understand the group annuity contract and all other offering material prepared by the issuing insurance company prior to making an investment decision. In considering whether to purchase a particular group annuity for the Plan, clients should be aware that: • A group annuity is a contract between the plan sponsor or the plan trustee and the issuing insurance company that cover the participants in the plan. • A group variable annuity consists of separate accounts that typically invest in underlying investment portfolios the value of which fluctuates with the market value of the securities in the portfolio. • Although a group annuity is issued by an insurance company, the annuity’s investment returns are not “insured” or guaranteed and risk of loss of principal does exist; however, the product may offer participants an option to purchase an annuity with a guaranteed component instead of a cash payout. Any such guarantee for an individual annuity is subject to the claims-paying ability of the insurance company. • A group annuity held in a tax-qualified retirement plan does not provide any additional tax deferred treatment of earnings for the plan or participants beyond the treatment provided by the plan itself. • A group annuity contract generally is not a registered security and separate account is generally not a registered separate account. Therefore, the contract and separate account are not subject to registration or regulation by the SEC under the Securities Act of 1933, the Securities Exchange Act of 1934 or the Investment Company Act of 1940. • Unlike mutual funds and registered variable annuities, which are SEC-registered products, a group annuity generally is not required to prepare or deliver a prospectus. • A group annuity contract typically includes various fees and expenses, including administrative fees for certain services of the insurance company, such as recordkeeping, customer services and enrollment. These fees and expenses are in addition to the fees and expenses of the underlying investment options, which a participant will indirectly bear by investing in those investment options through the group annuity. • Investment Company Risk. Investments in ETFs or other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. • Stable Value Funds. If you are considering a stable value product to make available as an investment option for a Plan, you should review the contract for the product and understand and consider the following: • A stable value fund is a fixed income investment fund with a “wrap” contract issued by a bank or insurance company. These wrap contracts seek to allow participants to transact at their book value (which, generally speaking, is their invested balance plus any accrued interest). • The objective of stable value funds, in general, is to preserve capital while providing a relatively stable rate of return that seeks to exceed returns provided by money market funds. Although designed as a low-risk investment, participants can lose money by investing in a stable value fund. • Stable value funds can be viewed as an alternative to money market funds; however, there are important differences, and stable value products can be complicated. Unlike money market funds, stable value funds are typically not registered with the SEC. In addition, they are not guaranteed by the U.S. government, LPL, or the Plan. The structure of, or investments within, stable value may vary, and it is important to consider these differences in selecting a stable value fund. • Although a contract may provide for book value (even if fair market value is less) for participant-initiated events, the contract typically will not provide for book value for certain employer-initiated events (e.g., plan terminations, layoffs, sale of a division, employer bankruptcies, or change in recordkeepers). In the case of employer-initiated events, the contract A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE typically will provide for a fair market value adjustment, which will not allow the Plan or participants to immediately receive book value if fair market value is less. It is important that plan sponsors understand these terms of the contract, in particular, as it will be a consideration in a future decision as to whether to terminate the stable value product provider. • As the stable value product wrap provider guarantees the receipt of book value to participants, it is important to consider the financial stability of the provider. It also is important to understand the underlying assets of the stable value product, as the type and quality of the assets will bear on the risk vs. reward characteristics that result in a variance between book value and fair market value. • There are fees and costs associated with stable value products. • 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. ITEM 9 DISCIPLINARY INFORMATION Item 9 requires the disclosure of material legal or disciplinary events relating to LPL’s advisory and brokerage business. However, none of the disclosure items below relate to the services that LPL and its IARs provide in connection with retirement plan advisory and consulting programs. 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 A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE 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: • • • • • 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). A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE • • • • 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, 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). 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). A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE 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. ITEM 10 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 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 may also be licensed registered representatives of LPL and may provide brokerage services on behalf 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. With respect to SMS services provided by an Advisor (rather than one of LPL’s IARs), 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 a Program account on behalf of Advisor. That person is not acting in a broker-dealer capacity or on behalf of LPL with respect to services under a Program. 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 client 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 an advisory 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- Retirement Partners 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 registered 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. LPL 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 A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE 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. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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. With respect to SMS services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to Advisor’s Form ADV brochure for more information about the Advisor’s code of ethics and personal trading policies. Participation or Interest in Client Transactions LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPL does not permit its IARs to recommend or purchase LPL Financial Holdings Inc. stock. With respect to SMS services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to Advisor’s Form ADV brochure for more information about conflicts of interest. IAR may be affiliated with the third-party administrator (TPA) that is also servicing a Plan. Prior to utilizing a TPA affiliated with IAR, clients must obtain an analysis from a fiduciary independent of the IAR concluding that 1) utilizing the named TPA is in the best interest of the Plan, the plan participants and their beneficiaries; 2) the fees paid for the services rendered by the TPA are reasonable; and 3) the TPA’s relationship with the IAR was fully understood and accepted during the selection process of each as service providers to the Plan. As part of the services selected by the client, for example, vendor analysis services, an IAR may provide recommendations as to investment products or services. To the extent that IAR recommends that client invest in products and services that will result in compensation being paid to LPL and the IAR, this presents a conflict of interest. The compensation to IAR and LPL may be more or less depending on the product or service that the IAR recommends. Therefore, the IAR has a financial incentive to A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE recommend that a recommendation be implemented using a certain product or service over another product or service. The client is under no obligation to purchase securities or services through LPL and the IAR. It is important to note that clients are under no obligation to implement a recommendation through LPL. Clients should understand that the investment products, securities, and services that an IAR may recommend as part of RPCP are available to be purchased through broker-dealers, investment advisors or other investment firms not affiliated with LPL. Client should understand that LPL, IAR and Advisor perform advisory and/or brokerage services for various other clients, and that LPL, IAR and Advisor may give advice or take actions for those other clients that differ from the advice given to the client. The timing or nature of any action taken for a client may also be different. ITEM 12 BROKERAGE PRACTICES In connection with the services offered under RPCP and SMS, LPL or an IAR may recommend to a client that a Plan use a certain retirement plan platform or service provider (such as a recordkeeper or administrator). In the case of RPCP, LPL and IAR may serve as broker-dealer in connection with the sale of securities or insurance products to the Plan. As noted above, for Plans that are subject to ERISA or are otherwise subject to Section 4975 of the Code, 12b-1 fees paid by product sponsors to LPL and IAR as broker-dealer of record to the Plan are used to offset the RPCP Fee. ITEM 13 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. To the extent services offered under RPCP or SMS to the Plan or Plan Sponsor include performance monitoring or reporting, LPL or the IAR or Advisor, as applicable, will review performance or provide reports of investment manager(s) or investments selected by the Plan on a frequency as agreed with the Plan or Plan Sponsor. If elected by the Plan, IAR or Advisor, as applicable, will provide reports evaluating the performance of Plan investment manager(s) or investments. ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION Other Compensation IAR, LPL and LPL employees receive additional compensation, business entertainment and gifts from product sponsors. Compensation may include 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 also pay for, or reimburse LPL for the costs associated with, education or training events that are attended by LPL employees, IARs and Advisors and for LPL-sponsored conferences and events, including services for identifying prospective clients. For example, LPL receives marketing and educational support payments of up to $260,000 annually from recordkeepers and retirement plan product sponsors for access to data analytics, and to participate and present at LPL education and training events for IARs. Any such support payments are not tied to the sales of any products or client assets in the products. IARs do not receive any portion of these payments. 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. For a current and list of the product sponsors that pay such marketing and educational support payments, please see complete lpl.com/disclosures.html or ask your IAR. With respect to SMS services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to the Advisor’s Form ADV brochure for more information about conflicts of interest. LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL employees provide sales support resources to IARs and Advisors 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 certain advisory programs to IARs and Advisors over other advisory programs. These employees also earn more compensation when IARs and Advisors transition client assets from brokerage accounts to advisory accounts, and have a financial incentive to encourage IARs and Advisors to transition brokerage accounts to advisory. Conflicts related to LPL Compensation to its IARs This section applies if an LPL IAR provides advisory and consulting services through the Program. An 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 a portion of the RPCP Fee or SMS Fee, as applicable, 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 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 may include 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: • payments based on production • 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 attendance at LPL conferences and events. • • • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • • payments in the form of repayable or forgivable loans • 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. Generally, LPL also charges IARs various fees under its independent contractor agreement, for example, for administrative, custody and clearing services to accounts, technology, and licensing as applicable. In certain cases, LPL pays IARs this A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE 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 Program than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in Program 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 Program 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. 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. Conflicts related to LPL Compensation to Advisor This section applies if clients select a third-party investment advisor firm (Advisor), in lieu of an LPL IAR, to provide advisory and consulting services through the Program. LPL pays compensation to Advisor, which includes a portion of the SMS 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 adviser representatives. 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. In particular, LPL may pay additional compensation to Advisor or its representatives by providing, for example: • • payments based on production • 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 • • payments in connection with the transition of Advisor’s business from another firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE • 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. 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 Program than other programs or services. In such cases, Advisor has a financial incentive to recommend advisory services in Program 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 Program 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. Individuals of Advisor also may be associated with LPL as broker-dealer registered representatives and/or investment advisor representatives. Unaffiliated Financial Institutions LPL and certain of 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 RPCP Fee or SMS Fee, as applicable, with the financial institution for the use of the financial institution’s facilities and for client referrals. Instead of paying the IAR or Advisor, as applicable, the portion of the RPCP Fee or SMS Fee, as applicable, as described above, LPL shares the RPCP or SMS Fee, as applicable, with the financial institution, and the financial institution pays part of that amount to IAR or Advisor, as applicable. 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. An 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 RPCP Fee, or SMS Fee, as applicable, after LPL retains its portion of the RPCP Fee or SMS Fee, as applicable, 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 RPCP Fee or SMS Fee, as applicable, and with the financial institution between 0% to 75%. All compensation paid A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE to IAR or the financial institution will be the sole responsibility of LPL, and will not result in any increase in the RPCP Fee or SMS Fee, as applicable, you pay to LPL. Some of these financial institutions may be 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 paid by the client 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 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 its programs 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 a 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 notes, 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 pays this compensation based on overall business production and/or on the amount of assets serviced in LPL advisory programs. 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 or Advisor, as applicable, have a financial incentive for an IAR or Advisor, as applicable, 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. 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 IARs with LPL and they (and any other staff retained or engaged by LPL) become subject to A 1 5 – 0 3 2 6 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE 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 IARs of third-party RIA Firms. Clients should ask their IAR about the extent to which LPL has a financial interest in their practice. Transition Assistance LPL also provides various benefits and/or payments to IARs or Advisors that are newly associated with LPL to assist the IAR or Advisor 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 or Advisor’s business, satisfying any outstanding debt owed to the IAR’s or Advisor’s prior firm, offsetting account transfer fees (ACATs) as a result of the IAR’s or Advisor’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 IAR or Advisor at his or her prior firm. Such payments are generally based on the size of the IAR’s or Advisor’s business established at his or her prior firm, for example, a percentage of the revenue earned or eligible assets serviced by the IAR or Advisor, as applicable, at the prior firm, and in certain cases, on the amount of the IAR’s or Advisor'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 or new Advisor 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 or Advisor 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. The receipt of Transition Assistance creates a conflict of interest in that an IAR or Advisor has a financial incentive to recommend that a client open and maintain an account with the IAR or Advisor 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 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 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. With respect to SMS services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to the Advisor’s Form ADV brochure for more information about conflicts of interest. 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. To the extent permitted by applicable law, including ERISA, LPL has entered into referral agreements with independent third-party investment advisers, pursuant to which LPL and IARs receive referral fees from the third-party investment advisors in return for referral of clients. Any such referral agreements are separate from the services provided under the Programs. Because LPL is engaged by and paid by the third-party investment advisor for the referral, any recommendation regarding a third-party investment advisor as part of a referral presents a conflict of interest. LPL addresses this conflict by providing the client with a disclosure statement explaining the role of LPL and IAR and the referral fee received by LPL and IAR. A 1 5 – 0 3 2 6 P a g e 1 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE In addition, LPL may enter into other agreements with the third-party investment advisers to whom LPL refers certain clients, pursuant to which LPL may provide (i) marketing services on behalf of the third-party investment advisers to LPL representatives; or (ii) data technology services to integrate third party investment adviser account data on LPL’s technology systems. To the extent permitted by applicable law, including ERISA, LPL receives fees for these services and such fees are typically based on the amount of assets (up to 10 basis points) referred by LPL to the third-party investment adviser. Please refer to lpl.com/disclosures.html for current information about any third-party investment adviser that pays this compensation. Any agreements related to referrals are separate from the services provided under the Programs. The IAR does not share in these fees. In some cases, the third-party investment advisers pay additional marketing payments to LPL, its employees and/or IARs to cover fees to attend conferences or reimbursement of expenses for workshops, seminars presented to IARs clients or advertising, marketing, or practice management. LPL has entered into agreements with certain service providers, pursuant to which LPL and IAR receive compensation related to a Plan participant who receives a distribution from the Plan and rolls the distribution to a retail investment product of the service provider. Client Referrals From time to time, LPL and/or its IARs enter into arrangements with other IARs, 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 Program Fee. LPL and its IARs have generally entered into the following types of referral arrangements: • 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 Program Fee; • 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; • 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; • 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 • Retirement Partnership Program. Some LPL IARs enter a referral fee relationship under which one IAR may refer retirement plan-level clients to another IAR for servicing under RPCP. • 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 or between IARs, 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 A 1 5 – 0 3 2 6 P a g e 1 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 IP C  RETIREMENT PLAN PROGRAMS BROCHURE 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’s participation in these referral arrangements does not diminish its fiduciary obligations to its clients. ITEM 15 CUSTODY LPL, IAR and Advisor will not serve as a custodian for Plan assets in connection with the advisory or consulting services offered through the Programs. The client is responsible for selecting the custodian and investment sponsor for Plan assets. In order to service the Plan or Plan Sponsor through the Programs, the IAR, Advisor, or LPL may be listed as the contact for the Plan account held at an investment sponsor. The trustees or other fiduciaries for the Plan will complete account paperwork with the outside custodian that will provide the name and address of the custodian. The custodian for Plan assets is responsible for providing the Plan with periodic confirmations and statements. LPL recommends that Plan sponsors review the statements and reports received directly from the custodian or investment sponsor. ITEM 16 INVESTMENT DISCRETION Under RPCP, LPL and the IAR typically provide investment advisory and consulting services primarily on a non-discretionary basis, so that the client makes the decisions regarding the purchase and sale of securities and the investment options to be made available in the Plan. If investment advisory services are to be provided on a discretionary basis, clients will provide that authorization pursuant to the terms of the account agreement. Under SMS, LPL has investment discretion to select, monitor, and replace the investment options made available through the Investment Menu and each Plan participant determines which available investment options within the Investment Menu to purchase or sell. Client will provide authorization for LPL’s discretionary authority in writing to LPL. LPL, IAR and Advisor do not exercise authority over the administration of the Plan under either Program. RPCP and SMS services do not include advice regarding the interpretation of the Plan documents, the determination of participant eligibility, benefits, or vesting, and the approval of distributions to be made by the Plan. ITEM 17 VOTING CLIENT SECURITIES LPL does not accept authority to vote client securities in connection with its services under the Programs. ITEM 18 FINANCIAL INFORMATION LPL is not required to include a balance sheet for its most recent financial fiscal year, and is not subject to any financial condition under which its ability to meet contractual commitments to clients is or may be impaired. 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 and may meet with clients from time to time, they are not 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. With respect to SMS services provided by an Advisor (rather than one of LPL’s IARs), clients should refer to the Advisor’s Form ADV brochure or contact the Advisor for more information. A 1 5 – 0 3 2 6 P a g e 2 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 IP C 

Strategic Asset Management (SAM) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 your LPL 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 31, 2025. Item 8 was updated to reflect that IARs may delegate discretionary investment and trading authority to LPL Research under certain circumstances. Items 8 and 11 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. Item 12 was also updated to include additional information about LPL’s Dividend Reinvestment Program (DRP). A7 – 0326 LPL Financial, Member FINRA/SIPC 1  Strategic Asset Management Program Brochure Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................................... 1 Item 2: Material Changes .......................................................................................................................................................... 1 Item 3: Table of Contents.......................................................................................................................................................... 2 Item 4: Advisory Business ......................................................................................................................................................... 2 Item 5: Fees and Compensation ............................................................................................................................................... 4 Item 6: Performance Based Fees and Side-by-Side Management ..................................................................................... 13 Item 7: Types of Clients ........................................................................................................................................................... 13 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................... 13 Item 9: Disciplinary Information ............................................................................................................................................. 22 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................... 24 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................... 26 Item 12: Brokerage Practices .................................................................................................................................................. 32 Item 13: Review of Accounts................................................................................................................................................... 33 Item 14: Client Referrals and Other Compensation .............................................................................................................. 33 Item 15: Custody ...................................................................................................................................................................... 38 Item 16: Investment Discretion ............................................................................................................................................... 39 Item 17: Voting Client Securities ............................................................................................................................................ 39 Item 18: Financial Information ............................................................................................................................................... 39 Item 4: Advisory Business Introduction LPL Financial LLC (“LPL”) is an investment adviser registered with the SEC pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”). LPL has provided advisory services as a registered investment adviser since 1975. Note that registration as an investment adviser with the SEC does not imply a certain level of skill or training. As of December 31, 2025, LPL managed approximately $818,320,000,000 of client assets on a discretionary basis and approximately $797,900,000 of client assets on a non-discretionary basis. LPL is owned 100% by LPL Holdings, Inc., which is owned 100% by LPL Financial Holdings Inc., a publicly held company. LPL’s advisory services are made available to clients primarily through individuals associated with LPL as investment adviser representatives (“IARs”). For more information about the IAR providing advisory services, client should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time client engages the IAR. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lpl.com. 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. A7 – 0326 LPL Financial, Member FINRA/SIPC 2  Strategic Asset Management Program Brochure 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. Types of Advisory Services LPL offers various types of advisory services and programs, including wrap fee programs, mutual fund asset allocation programs, an advisor-enhanced digital advice program, advisory programs offered by third party investment advisor firms, financial planning services, and retirement plan consulting services. This Brochure provides a description of the advisory services offered under LPL’s Strategic Asset Management program (the “Program”). For more information about LPL’s advisory services and programs other than the Program, please contact your LPL 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 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. In the Program, LPL, through its IARs, provides ongoing investment advice and management on assets in the client’s account. IARs provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”), interval funds, variable annuity subaccounts, business development companies (“BDCs”), private equity, real estate investment trusts (“REITs”), equities, and fixed income securities. IARs provide advice that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients may impose restrictions on investing in certain securities or groups of securities by contacting their IAR and providing the necessary written instructions. The IAR obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective 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 be aware 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. Clients should further be aware that achievement of the stated investment objective is a long-term goal for the account. In certain circumstances, an IAR may engage LPL’s research department (“LPL Research”) to provide investment management services jointly to clients. In such arrangements, LPL Research will exercise discretionary investment and trading authority over the account in accordance with the client’s investment objectives. LPL also acts as custodian to accounts, provides brokerage and execution 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, A7 – 0326 LPL Financial, Member FINRA/SIPC 3  Strategic Asset Management Program Brochure 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. Item 5: Fees and Compensation Fee Schedule Clients in the SAM Program pay LPL an annualized fee (“Account Fee”) for the investment advisory services of LPL and IAR, as well as the administrative, custody and clearing services of LPL. The Account Fee is shared with the IAR. The Account Fee is negotiable between the client and the IAR and is typically a straight percentage based on the value of all assets in the account, including cash holdings, but excluding certain assets that are not billed upon in certain instances, and payable quarterly in advance. The maximum Account Fee is 2.50%. Upon request, the Account Fee may be structured on a tiered basis and/or grouped basis, with a reduced percentage rate based on reaching certain thresholds in the Account or in a group of eligible advisory accounts. LPL reserves the right to increase the upper limit of the Account Fee upon 30 days’ prior notice to clients. LPL and IARs do not charge performance-based fees to accounts in the SAM program. LPL retains a portion of the Account Fee, up to 0.20%, which is not shared with your IAR, for its administrative, custody and clearing services. A portion of the administrative fee may be shared with additional third parties for services, including the IAR’s employer. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Account Fee with the IAR based on the agreement between LPL and the IAR. In certain circumstances, the IAR portion of the Account Fee may be shared with multiple IARs who jointly provide advisory and other services to you and/or in support of each other. A portion of the fee to the IAR may also be paid by the IAR to his or her LPL branch manager, another LPL representative for supervision or administrative support, or advisory services. 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. There is also a conflict of interest when an IAR’s employer or other LPL IARs receive a portion of the Account Fee for administrative support or advisory services, respectively, because LPL and its IARs have an incentive to recommend programs or strategies in which LPL and its IARs retain a greater portion of the Account Fee. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a Program 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. The Account Fee for certain alternative investments (such as non-exchange traded REITs, BDCs or hedge funds, each a “Non-Traded Alternative Investment”) is calculated based on unaudited net asset values provided as estimates by the sponsor of the Non-Traded Alternative Investment (such unaudited net asset values, a “Fair Value”). Fair Values are provided by Non-Traded Alternative Investment sponsors on a reporting period basis, such as monthly or quarterly. LPL does not audit or confirm the accuracy of the Fair Values provided by the sponsors of Non-Traded Alternative Investments. Sponsors of Non-Traded Alternative Investments do not adjust previously determined Fair Values. The portion of the Account Fee calculated on a Non- Traded Alternative Investment reflects the Fair Value of the prior reporting period and will not reflect the current net asset value of the Non-Traded Alternative Investment as of the date of the Account Fee’s calculation. 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 A7 – 0326 LPL Financial, Member FINRA/SIPC 4  Strategic Asset Management Program Brochure 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 Fees and Expenses of LPL LPL charges fees related to a Program account in addition to the Account Fee. • In the Program, clients do not pay brokerage commissions to IAR for transactions in the account; however, the client pays LPL a transaction charge for the purchase and sale of certain securities in the account. The transaction charges are set out in the Account Agreement and the Miscellaneous Account and Service Fee Schedule-Advisory. The transaction charges are paid to LPL to defray costs associated with trade execution; however, they are not directly related to transaction-related expenses of LPL and are a source of revenue to LPL. Transaction charges present conflicts of interest. For example, transaction charges vary depending on the type of security being purchased or sold (e.g., $7 for equities, $50 for fixed income), and therefore LPL earns more from transactions that result in an investment with a higher charge. In addition, where transaction charges apply, the more transactions a client enters into, the more compensation LPL receives. Transaction charges will not reduce the Account Fee you pay. Transaction charges are not shared with IARs. In the case of mutual funds and ETFs, the transaction charges vary depending on the fund purchased or sold. For more information, see the section of this Item 4 titled “Understanding Share Classes and Transaction Charges in SAM Accounts”. • In the Program, the IAR may also separately agree with clients to bear the transaction charges for purchases and sales of certain securities in the account. If the IAR pays the transaction charges in an account, there is a different conflict of interest than if the client pays the transaction charges. Clients should understand that the cost to IAR of transaction charges will in certain instances be a factor that the IAR considers when deciding which securities to select and how frequently to place transactions in an account. For more information, see the section of this Item 5 titled “Understanding Share Classes and Transaction Charges in SAM Accounts” and the section of Item 12 titled “Brokerage Practices.” • LPL charges accounts with assets valued at less than $100,000 an additional $10 quarterly fee at the end of the quarter. • Clients that hold hedge funds, managed futures, BDCs, and certain REITs pay a processing fee per transaction and an annual alternative investment administrative fee per position, subject to a maximum per account per year. • If an account is approved for trading on margin and the client has entered into a margin agreement with LPL, the client will be charged margin interest on any credit extended to or maintained by the client. LPL will retain a portion of any interest charged. This interest charge is in addition to the Account Fee. The Account Fee is not charged on any margin debit balance, rather only on the net equity of the account. • Clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to a SAM 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 cash sweep fees, retirement account fees and termination fees, including, as applicable, an annual individual retirement account (“IRA”) maintenance fee, an annual qualified retirement plan maintenance fee, 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 miscellaneous fees are not directly based on the costs of the transaction or service by LPL, will include a profit to LPL in certain instances, and certain of the fees will be lowered or waived for certain customers. • LPL may waive any fee it charges to Client or IAR in its sole discretion in whole or in part. A7 – 0326 LPL Financial, Member FINRA/SIPC 5  Strategic Asset Management Program Brochure Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in Program accounts. Some of these fees and charges are described below. If a client’s assets are invested in mutual funds, ETFs or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Client will pay an advisory fee to the fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay LPL and IAR the Account Fee with respect to assets invested in mutual funds, ETFs and other pooled products. The mutual funds, ETFs and other pooled funds available in the program can be purchased directly outside of the Program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL and IAR and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” 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 under a fund’s frequent trading policy, client will be charged a redemption fee. 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). If client holds a variable annuity as part of an account, there are mortality, expense and administrative charges, subaccount management fees, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. If a client holds a REIT or BDC as part of an account, there are dealer management fees and other organizational, offering and pricing expenses imposed by the REIT or BDC, as applicable. If client holds a UIT in an account, UIT sponsors charge creation and development fees or similar fees. Further information regarding fees assessed by a mutual fund, variable annuity, alternative investment (such as a REIT, BDC or hedge fund) or UIT is available in the appropriate prospectus or offering document, which is available upon request from the IAR or from the product sponsor directly. Important Information When Funding an Account Ineligible Securities. When transferring securities into a Program account, client should be aware that certain securities may 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 Program account. Surrender Charges or CDSCs. If client transfers a previously purchased investment into a Program account, such as a mutual fund, annuity or alternative investment, or liquidates the previously purchased investment and transfers the proceeds into an account, client may be charged a fee (sometimes called a “surrender charge,” “contingent deferred sales charge” or “CDSC”) upon the sale or redemption in accordance with the investment product’s prospectus. In many cases, the CDSC is only charged if a client does not hold the security for a minimum period of time. In particular, A7 – 0326 LPL Financial, Member FINRA/SIPC 6  Strategic Asset Management Program Brochure if a client transfers a previously purchased mutual fund (such as a Class C share) into an account that is subject to a CDSC, then the client will pay that charge when the mutual fund is sold. Previously Paid Commissions. Clients 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. Client should understand that, after the transfer into an account, an advisory fee will be charged based on the total assets in the account, including the transferred security. Depending on the share class and fee structure of the previously purchased mutual fund, LPL can receive fees such as 12b-1 fees, recordkeeping fees and revenue sharing from the previously purchased mutual fund until the position is liquidated and subsequently invested. In other words, if you paid IAR or another financial professional recently an upfront commission on the previously purchased security, you will be paying a new ongoing advisory fee going forward to IAR for advice on that same security. Loss of Benefits. If client will be funding the account with the proceeds of a sale or liquidation of an annuity, client should understand that client may be giving up guaranteed living or death benefits that were provided through the annuity, and will not be provided through a Program account. When transferring securities into an account, client should consider and speak to IAR about whether: there will be a loss of a guaranteed benefit, in the case of an annuity; • a CDSC will apply, and the length of time before the CDSC expires; • • 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. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Understanding Share Classes in SAM Accounts Except with respect to Sweep Funds described in the section of Item 11 labeled “Participation or Interest in Client Transactions,” LPL makes available for purchase only one share class per mutual fund in the Program, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Program Shares”). Program Shares are no-load or load-waived share classes and therefore not subject to any upfront sales charge. Share classes previously available in the Program prior to November 21, 2016, such as Class A Shares that are subject to 12b-1 fees, can still be held but not purchased in the Program (“Non-Surviving Share Classes”). A client also may transfer Non-Surviving Share Classes into client’s account. Any 12b-1 fees received by LPL from mutual funds in the Program (other than Sweep Funds) will be credited to the client account. Because the Non-Surviving Share Class could have a higher overall expense ratio than the Program Shares, the Non-Surviving Share class could cost the client more than Program Shares, even after the 12b-1 fees is credited to the account. Clients should understand that the Program Share class offered for a particular mutual fund through the Program in many cases will not be the least expensive share class that the mutual fund makes available. Program Share classes are selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Other financial services firms may offer the same mutual fund at a lower overall cost to the investor than is available through the Program. A7 – 0326 LPL Financial, Member FINRA/SIPC 7  Strategic Asset Management Program Brochure Understanding Transaction Charges in SAM Accounts Clients, when participating in the Program, should understand that LPL charges clients a transaction charge of $0, $4.50 or $26.50 for mutual fund purchases and redemptions. The applicable transaction charge varies depending on the amount of recordkeeping fees that LPL receives from the mutual fund and/or whether the sponsor of the mutual fund participates in LPL’s Mutual Fund No Transaction Fee Network (“MF NTF Network”) described below. When a mutual fund participating in the MF NTF Network is purchased in an account, the mutual fund’s sponsor directs a payment to LPL on behalf and for the benefit of the client that is used exclusively as a credit to defray the bona fide transaction charge obligations of the client’s account. When a participating mutual fund is sold in an account, LPL waives the transaction charge. Clients also should be aware that mutual funds participating in the MF NTF Network typically have higher ongoing internal expenses that can be used to offset payments made by sponsors for transaction charge waivers, and this can reduce the investment returns over time relative to other share classes of the same fund. The Program also offers an ETF No Transaction Fee Network (“ETF NTF Network”). LPL typically charges a transaction charge of $9 for transactions in ETFs, however, for certain ETFs in the ETF NTF Network, the ETF sponsors direct a payment to LPL on behalf and for the benefit of Client that is used as a credit to defray all or a portion of the bona fide transaction charge obligations of the Account. To the extent the sponsor does not pay the entire transaction charge amount, LPL waives the remaining portion to bring the cost to Client to $0. For purchases of other ETFs in the ETF NTF Network in the Program, the sponsor pays LPL a flat annual amount and/or a fee based on the non-retirement client account assets invested in ETF NTF Network funds, and LPL waives the transaction charge. In the case of certain of these fee arrangements, the sponsor pays LPL a combination of a flat fee and asset based fee for ETFs. The asset based fee paid to LPL for certain ETFs will be higher based on the ETF’s expense ratio. These arrangements present a conflict of interest because LPL has an incentive to select more expensive ETFs. In addition, as described in more detail below in Item 8, LPL’s Research Department (LPL Research) provides asset allocation model portfolios for IARs to use with clients. Certain of these model portfolios include ETFs participating in the ETF NTF Network that are more expensive and pay more fees to LPL. However, these conflicts are mitigated insofar as the sponsor fees are not shared with the IAR who selects the ETFs for Client. For further details and an updated list of ETF sponsors for the ETF NTF Network, please refer to the Disclosures page on lpl.com/disclosures.html. The ETF NTF Network creates a conflict of interest because IAR has a financial incentive to select ETFs participating in the ETF NTF Network to avoid paying the transaction charges. Clients should consider such conflict when monitoring the purchase of ETFs in recognition of the overall fee and other arrangements with LPL and IAR for management of the account. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of the account. In particular, clients should be aware that participating ETFs typically have higher ongoing internal expenses than other ETFs that can be used to offset payments made by sponsors for transaction charge waivers. To the extent that LPL receives from a sponsor of a an ETF participating in the ETF NTF Network a flat fee or an asset based fee that exceeds bona fide transaction charge obligations of the participating client accounts, the payment creates a conflict of interest as further described below as revenue sharing. When an IAR agrees to bear transaction charges on behalf of a client and a participating mutual fund or ETF is purchased in the account, the mutual fund or ETF sponsor defrays all or a portion of the transaction charge otherwise borne by the IAR, and LPL waives the remaining amount of the transaction charge. For all ERISA Accounts for which an IAR agrees to bear transaction costs on behalf of a client, LPL waives the transaction charge to the IAR when a participating mutual fund or ETF is purchased or sold. Transaction Charge Considerations When the client pays the transaction charges, an IAR may recommend greater volume of trading activity than when it has a financial incentive to limit such transactions. Moreover, clients should understand that engaging in frequent trading will result in paying more transaction charges and will increase the overall costs associated with the Account. These costs impact the performance of the Account. LPL has a conflict of interest insofar as it has a financial incentive A7 – 0326 LPL Financial, Member FINRA/SIPC 8  Strategic Asset Management Program Brochure to engage in trading for the Account to generate transaction charges. Clients should also note that the Account Fee being charged in the Program may take the payment of transaction charges into consideration. That is, the Account Fee charged to SAM accounts may be lower than the Account Fee charged to other types of accounts to the extent that the transaction charges are factored into the overall Account Fee charged to such accounts. If the IAR has agreed to pay transaction costs on behalf of the client, the cost to the IAR of transaction charges may be a factor that the IAR considers when deciding which securities, mutual funds or ETFs to select and whether or not to place transactions in the account. Similar to clients, the transaction charges borne by the IAR vary based on the type of transaction (e.g., mutual fund, ETF, equity or fixed income security). The IAR has a financial incentive to recommend transactions in certain securities that carry lower fees (e.g., transactions involving equity securities may be recommended over fixed income securities because of the lower transaction charge) or to limit the overall number of transactions it recommends to clients. In particular, the IAR has a financial incentive to select NTF Funds or ETFs that participate in the ETF NTF Network to avoid paying or to lower the transaction charges over others that may be more suitable for the client. Clients should consider such conflict when monitoring the purchase of NTF Funds or ETFs that participate in the ETF NTF Network in recognition of the overall fee and other arrangements with LPL and IAR for management of the account. All such conflicts may have an impact on the investment performance of the client’s account. For certain IARs that have agreed to bear transaction fees on behalf of clients, LPL will agree to charge the IAR an asset-based fee for transactions instead of a per transaction fee. LPL will also waive transaction charges for certain transactions by IARs. Where LPL charges IAR an asset-based fee for transactions or waives transaction fees, conflicts regarding the number and variability of transaction charges are mitigated but Client will not receive any additional financial benefit. Mutual Fund 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements; Other Product Related Compensation Some mutual funds and Program Share Classes in the Program charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b- 1 fees paid to LPL by mutual funds (other than the Sweep Funds) that are held in Program accounts will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of Program clients. These services include establishing and maintaining accounts with the 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 the Program account. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of Program client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by Program clients in the fund (up to $25 per position). If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. 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 $15,000 per product for complex 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. In the case of annuities, LPL typically receives a one-time onboarding/networking setup fee of up to $100,000 from the annuity product sponsor to reimburse LPL for A7 – 0326 LPL Financial, Member FINRA/SIPC 9  Strategic Asset Management Program Brochure associated technology-related costs. In the case of alternative investments, LPL receives up to $35,000 for initial products, and up to $15,000 for follow-on product offerings or additional share classes. LPL also receives a one-time payment of up to $25,000 from certain alternative investment sponsors for training and education and other benefits such as prominent placement of sponsor logos, website links or content on materials disseminated to LPL’s IARs and priority access to education programs and events and conference speaking opportunities. LPL does not share this compensation with its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee (typically quarterly) based on the amount of client sales or assets invested in the sponsor’s products and/or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL IARs so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds (other than the Sweep Funds) consists of flat and asset based fees totaling up to 0.15% annually of LPL clients’ investments in the investment product, or up to $1,000,000. For alternative investments, the maximum revenue sharing fee received by LPL under these arrangements is up to 0.35% on assets or 1.50% on new sales. Certain sponsors of alternative investments are not required to pay such fees. For annuities, the maximum revenue sharing fee received by LPL under these arrangements is up to 0.25% of assets or up to 0.50% of new sales. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. However, LPL has a financial incentive to recommend participating products instead of those whose sponsors do not make such payments to LPL. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. LPL accepts revenue sharing fees for assets held in retirement accounts to the extent permitted by applicable law, including ERISA. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment A7 – 0326 LPL Financial, Member FINRA/SIPC 10  Strategic Asset Management Program Brochure with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the IAR who selects or recommends the investment products for client accounts. LPL has network fee arrangements with sponsors of fee-based variable annuities, pursuant to which LPL receives compensation based on the number of LPL customer positions held with the variable annuity sponsor (up to $6.00 per position per year). LPL does not share this compensation with its IARs. From time to time, LPL receives a reallowance of the public offering price per unit on units of certain UITs and structured products sold by LPL during the initial offering period. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of products and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable fund or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable product or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds (other than the Sweep Funds), and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees or revenue sharing payments with IARs, and, therefore, there is no financial incentive for an IAR to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments 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. LPL provides investment consulting services to the investment advisor of the Optimum Funds mutual fund family. 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 fund assets from the investment advisor to the Optimum Funds. The receipt of this investment consulting compensation by LPL presents a conflict of interest, because LPL has a financial benefit if an Optimum Fund is purchased in an account. This fee is not shared with LPL IARs. In addition, a senior executive officer of LPL serves as a Trustee of the Optimum Funds. The Optimum Funds are available to be purchased and sold in a Program account. A7 – 0326 LPL Financial, Member FINRA/SIPC 11  Strategic Asset Management Program Brochure LPL receives a fee from the issuers of structured products for administrative services and related support LPL provides in connection with the structuring and distribution of these products. This fee can be up to 0.75% of the principal amount of a trade and generally varies among products according to the complexity of the structuring. This fee creates a conflict of interest because LPL has an incentive to recommend structured products over other products that do not pay LPL a similar fee. This conflict is mitigated insofar as the amount LPL receives is consistent for similar types of structured products across different product issuers, and is not shared with its IARs. Client should review the product offering documents for additional details. Important Things to Consider About Fees on a SAM Account • The Account Fee is an ongoing fee for investment advisory services and other administrative and custodial services. The Account Fee may cost the client more than purchasing the Program’s services separately. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the: • type and size of the account • 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. • Clients participating in the Program do not pay IAR commissions on transactions but do pay LPL transaction charges. Transaction charges for the securities purchased and sold in an account may also cost the client more than purchasing the Program’s services separately. As with any fee, transaction charges reduce the overall amount of your investment portfolio. • The Account Fee may cost the client more than if assets were held in a traditional brokerage account. In a brokerage account, a client pays the brokerage representative a commission for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than a Program account. In addition, LPL may only offer certain products in an advisory account, even though there is a version of the product or a similar product that may be lower cost and could be available in a brokerage account, and vice versa. • LPL offers certain alternative products, including certain non-traded alternative investments, in certain accounts offering solely brokerage services and in certain accounts offering solely investment advisory services. This means that clients can only purchase those investments by paying a commission or other brokerage fee in the case of a brokerage account or advisory fee in the case of an advisory account. Depending on the length of time that a client holds such an investment, it may cost more to pay the commission than it would if the investment was available in a SAM program account and the client paid the annual Account Fee on the investment. • 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, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, and the number and range of supplementary advisory and client-related services to be provided to the account. The IAR may charge a client more or less than another client. Clients should consider the level and complexity of the advisory services to be provided when negotiating the Account Fee with IAR. • The investment products available to be purchased in the Program can be purchased by clients outside of a SAM account, through broker-dealers or other investment firms not affiliated with LPL. A7 – 0326 LPL Financial, Member FINRA/SIPC 12  Strategic Asset Management Program Brochure • 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 6: Performance Based Fees and Side-by-Side Management This Item is not applicable. LPL and its IARs do not accept performance-based fees. Item 7: Types of Clients The Program is available for individuals, 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. A minimum account value of $10,000 is generally required for the Programs. In certain instances, LPL will permit a lower minimum account size. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Each IAR managing a SAM account chooses his/her own research methods, investment strategy and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. The IAR has access to various research reports, including those provided by LPL Research (", to which he/she may refer in determining which securities to purchase or sell. LPL Research makes available recommendations regarding asset allocation, mutual funds, model portfolios, and variable annuity subaccounts. IARs may or may not follow these recommendations in managing program accounts. LPL Research also constructs asset allocation model portfolios and provides recommendations on the funds to populate the model portfolios. In constructing these models, LPL Research uses the following investment strategies: Diversified and Alternative Strategy. Although these descriptions are written in terms of individual equities and/or bonds, they include mutual funds or ETFs whose portfolios consist of the type of equities or bonds referenced. • Diversified. The Diversified investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. The strategy is subject to minimal constraints, which allows for a relatively pure implementation of LPL Research’s recommendations. In general, Diversified portfolios should be considered by investors seeking investments in primarily stocks and bonds, along with the occasional non-traditional asset class to take advantage of potential market opportunities. Diversified portfolios will hold primarily traditional asset classes. Secondarily, if a non-traditional asset class represents the investment that provides the best means of taking advantage of a market opportunity, it will be included in the recommendation. The non-traditional investments included in Diversified portfolios are more standard, such as conservative balanced strategies. Diversified portfolios tend to be steady in their number of positions. These portfolios tend to remain consistently diversified. • Alternative Strategy. The Alternative Strategy investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. Unlike the Diversified investment strategy which may have an allocation to alternative strategy or non-traditional assets classes, this portfolio typically has an allocation to non-traditional asset classes. This strategy extends the diversification beyond the core style box asset classes into strategies with lower correlation to stocks and bonds in order to lower risk, as defined by standard deviation and maximum drawdown (peak to trough loss), while attempting to maintain long-term performance similar to other portfolios in the same investment objective. For each of the above investment strategies, LPL Research recommends a strategic or tactical version. A7 – 0326 LPL Financial, Member FINRA/SIPC 13  Strategic Asset Management Program Brochure • Strategic. Strategic portfolios typically have a three- to five-year time horizon. The allocations within these portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout that time frame. Although LPL Research recommends investments through a three- to five- year lens, LPL Research may recommend that these portfolios be traded for fine tuning throughout the year. For clients who take a longer term view or are more tax sensitive, a strategic implementation may be more appropriate. • Tactical. Tactical portfolios are more flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present. LPL Research recommends that these portfolios invest in opportunities for as short as one week and as long as five years. Due to the tactical nature, the trading is notably more frequent than strategic portfolios. Tactically managed portfolios should be considered by clients who wish to take advantage of shorter-term market opportunities that may arise and are not opposed to the prospect of more frequent trading. It is important to note that although LPL Research makes available its recommendations and investment strategies, an IAR will not necessarily take into consideration these recommendations and strategies. Clients should contact the IAR managing his/her accounts for additional information on the IAR’s particular investment strategy. It is also important to note that an IAR may use a combination of investment strategies. Types of Investments and Risks In the Program, IARs can recommend many different types of securities, including mutual funds, unit investment trusts (“UITs”), closed end funds, ETFs, ETNs, variable annuity subaccounts, equities, fixed income securities, interval funds, options, hedge funds, managed futures, BDCs, private equity, REITs, and structured products. LPL determines the types of investments that are eligible to be purchased in program accounts. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that are available in the Program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • ‐ Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • 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 A7 – 0326 LPL Financial, Member FINRA/SIPC 14  Strategic Asset Management Program Brochure company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Alternative Strategy Mutual Funds. Certain mutual funds available in the Program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the Program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering A7 – 0326 LPL Financial, Member FINRA/SIPC 15  Strategic Asset Management Program Brochure to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. In some cases, there may be an additional cost to investors who redeem before holding shares for a specified amount of time. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. A7 – 0326 LPL Financial, Member FINRA/SIPC 16  Strategic Asset Management Program Brochure • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Options. Option trading is permitted in the Program. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and a Program account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. futures-linked ETPs • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of A7 – 0326 LPL Financial, Member FINRA/SIPC 17  Strategic Asset Management Program Brochure the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Structured Products. Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • Hedge Funds and Non-Traded Managed Futures. Hedge funds and non-traded managed futures funds are available to clients meeting certain qualification standards. Investing in these securities involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices, currency and interest rate risk, lack of liquidity and performance volatility. In some cases, there may be an additional cost to investors who redeem before holding shares for a specified amount of time. In addition, these securities may not be required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Clients should be aware that these securities may not be liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the security, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the security during the repurchase offer. Issuers typically accept redemption requests only periodically (monthly or quarterly), and often have the discretion to suspend redemptions in times of market stress. Even after a redemption request is accepted, the redemption proceeds may not be available for a significant period of time following the effective date of the redemption. A portion of the redemption proceeds may also be withheld to account for potential future adjustments to the valuation of the security. Funds of hedge funds are pooled investments in several hedge funds. Expenses in funds of hedge A7 – 0326 LPL Financial, Member FINRA/SIPC 18  Strategic Asset Management Program Brochure funds are typically higher than mutual funds. Because they may invest in a number of private hedge funds, funds of funds also bear a part of the fees and expenses of those underlying hedge funds. • Business Development Companies (BDCs). BDCs are types of closed-end investment companies, which are available to clients meeting certain qualification standards. Generally, BDCs invest primarily in the debt and equity of private and/or small U.S. companies and may offer distribution rates generated through potentially significant credit and liquidity risk exposures amplified through leverage. As with other high-yield investments, such as floating-rate/leveraged loan funds, private REITs and limited partnerships, investors are exposed to significant market, credit, interest rate and liquidity risks. In addition, BDCs run the risk of over- leveraging their relatively illiquid portfolios. Due to the illiquid nature of non-traded BDCs, investors’ exit opportunities may be limited only to periodic share repurchases by the BDC. A tender offer pursuant to a share redemption program may be oversubscribed so that the BDC accepts only a pro rata portion of the shares a client tenders during a redemption program. In such cases, a client may experience significant delays (including, potentially, indefinite delays) to exit from the investment. In addition, share redemption programs may be shut down at any time at the discretion of the issuer’s board. Also, BDCs may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to make investments. In some cases, there may be an additional cost to investors who redeem before holding the shares for a specified number of years. • REITs. REITs invest in real estate, and there are special risks associated with investing in real estate, including, but not limited to, sensitivity to changes in real estate values, the risk of investment loss due to the use of leveraging and other speculative investment practices, interest rate risk, lack of liquidity and performance volatility. Non-Traded REITs are not required to provide annual valuations until two years and 150 days after reaching the minimum capital raise required to begin purchasing properties. This threshold is generally outlined in the product’s prospectus. Non-Traded REITs, which are available to clients meeting certain qualification standards, may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to invest in new assets. Clients should be aware that these securities may not be liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the security, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the security during the repurchase offer. Issuers may repurchase shares at a price below net asset value. The repurchase program may also be suspended under certain circumstances. • Private Equity Funds. Private equity investments are speculative and involve significant risks. It is possible that investors may lose some or all of their investment. The risks associated with private equity include: limited diversification, the use of leverage, and limited liquidity. The investment timeline for private equity can be a decade or more. Some issuers or general partners may penalize limited partners who redeem before holding units for a specified amount of time, or may disallow redemptions entirely. • Variable Annuities. If client purchases a variable annuity that is part of the Program, client will receive a prospectus and should rely solely on the disclosure contained in the prospectus with respect to the terms and conditions of the variable annuity. Clients should also be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. Some products may charge a recapture or redemption fee for contracts or benefits not held for a specified period of time or that do not follow stated withdrawal terms. • Non-traded Products. Non-traded products do not trade on a securities exchange and are not publicly traded. Consequently, non-traded products can be riskier than products that are publicly traded because the product cannot be sold readily in a market by the investor. The non-traded product may offer to redeem shares from investors, but such share redemptions are typically subject to limitations. Share redemptions may also require that shares be redeemed at a discount and there is no guarantee that client will be able to redeem the security during the repurchase offer. In addition, non-traded products may lack share value transparency because A7 – 0326 LPL Financial, Member FINRA/SIPC 19  Strategic Asset Management Program Brochure there is no market price readily available. Without share value transparency, investors may not be able to assess the value or performance of the non-traded product. • Margin Accounts. Clients should be aware that margin borrowing involves additional risks. Margin borrowing will result in increased gain if the value of the securities in the account go up, but will result in increased losses if the value of the securities in the account goes down. LPL, acting as the client’s creditor, will have the authority to liquidate all or part of the account to repay any portion of the margin loan, even if the timing would be disadvantageous to the client. For performance illustration purposes, the margin interest charge will be treated as a withdrawal and will, therefore, not negatively impact performance reports. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (“SCA”) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (“partner banks”) and other banks (“non-partner banks”). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-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. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non-partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship with LPL and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL and its IARs for the pledged assets. For a list of the third-party 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,” A7 – 0326 LPL Financial, Member FINRA/SIPC 20  Strategic Asset Management Program Brochure and then “Third Party Compensation and Related Conflicts of Interest.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • 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 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. • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and its IARs generally will earn more compensation for selling one investment product than another. As a result, LPL A7 – 0326 LPL Financial, Member FINRA/SIPC 21  Strategic Asset Management Program Brochure and its IARs have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. • Annuity Products. If investor client invests in annuity products in a Program account, client should be aware of the specific risks and limitations of the annuity products. Clients should be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. Some products may charge a recapture or redemption fee for contracts or benefits not held for a specified period of time or that do not follow stated withdrawal terms. Registered Index Linked Annuities (RILAs) are insurance products tied to the performance of a market index, offering the positive returns of the index up to a cap and providing a buffer for a certain level of negative returns. RILAs are subject to risks associated with other investment products, including market risk, and the total loss of principal is possible. If client purchases an annuity product that is part of the Program, client will receive a prospectus with respect to the terms and conditions of the annuity product. Item 9: 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 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 was 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: A7 – 0326 LPL Financial, Member FINRA/SIPC 22  Strategic Asset Management Program Brochure • 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, 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). A7 – 0326 LPL Financial, Member FINRA/SIPC 23  Strategic Asset Management 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 Massachusetts (“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). 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/. Item 10: 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 may be broker-dealer 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. A7 – 0326 LPL Financial, Member FINRA/SIPC 24  Strategic Asset Management Program Brochure 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 SAM 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-SAM 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. 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, corporate trustee services, 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. A7 – 0326 LPL Financial, Member FINRA/SIPC 25  Strategic Asset Management Program Brochure Some IARs work with UIT sponsors to create customized UITs. For customized UITs, IARs provide the UIT sponsor with input regarding the portfolio composition of the UIT, and in exchange may be paid a consulting fee. The UIT sponsor retains sole responsibility for creating and implementing the investment portfolio of the UIT. An IAR is permitted to invest SAM account assets in customized UITs for which the IAR provided consulting services. LPL has policies and procedures in place for customized UITs that are designed to prevent conflicts of interest and to ensure that IARs act in clients’ best interest. Among other things, these policies prevent IARs from receiving consulting fees for assets that any LPL client invests in customized UITs. Depending on the securities held by the UIT and on whether a client separately pays transaction charges (for example in a Program account), a customized UIT’s sales charges and sponsor fees could be more expensive than separately purchasing the basket of securities in the UIT’s portfolio. Before investing a customized UIT, you may wish to ask your IAR questions about compensation received from the UIT and about the UIT’s fees and expenses. Item 11: Code of Ethics, Participation or Interest in Client Transactions 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 SAM 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees of LPL Research 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. As described under Brokerage Practices below, IARs may aggregate transactions in equities, options, and fixed income securities for client accounts. Clients should be aware that the IAR’s personal accounts (including related accounts, such as those of family members) can be included in such a block order. Although the same average price would be applied to client accounts and the IAR’s personal accounts, the inclusion of an IAR’s personal account in a block order can present a conflict of interest. It is possible that the inclusion of the personal account could negatively impact the price of the security or result in the client being allocated less of an order. If a partially filled order is allocated on a random basis, the inclusion of the personal account could make it less probable that a client account is randomly selected and the IAR’s personal account could be randomly selected instead of a client account. LPL addresses this conflict by disclosing it to you. Please ask your IAR if you would like more information on the IAR’s practices in this respect. Participation or Interest in Client Transactions Purchases of mutual fund, UIT or alternative investment shares may be processed through the firm'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 the firm’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 does not permit its IARs to recommend or purchase LPL Financial Holdings Inc. stock in SAM accounts unless expressly directed to do so by the client. In addition, IARs may recommend or purchase an ETF or mutual fund that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only A7 – 0326 LPL Financial, Member FINRA/SIPC 26  Strategic Asset Management Program Brochure form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (“SCA”) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with its IARs, and therefore, an IAR does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with its IARs, and therefore, an IAR has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your IAR’s compensation on the SCA product is reduced if your interest rate is discounted, so your IAR has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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, or alternatively, could incentivize the IAR to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “Third Party Compensation and Related Conflicts of Interest.” 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 A7 – 0326 LPL Financial, Member FINRA/SIPC 27  Strategic Asset Management Program Brochure 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 IARs do not typically recommend specific sweep service options or underlying sweep holdings. For more information , 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-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. • 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. A7 – 0326 LPL Financial, Member FINRA/SIPC 28  Strategic Asset Management Program Brochure • 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. 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. • 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). • 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 A7 – 0326 LPL Financial, Member FINRA/SIPC 29  Strategic Asset Management Program Brochure 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. LPL’s money market mutual fund sweep option automatically sweeps otherwise uninvested cash balances held in the account and invests them 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. The compensation that LPL receives related to ICA, DCA (including from 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 the ICA, DCA, or the Sweep Funds. However, this compensation is retained by LPL and is not shared with its IARs. Therefore, this compensation does not cause an IAR to have a financial incentive to recommend that cash be held in the account instead of holding securities. Non-Sweep Money Market Mutual Fund Investments (Outside of LPL’s Sweep Service Options) Clients are able to invest cash balances in a limited number of money market mutual funds outside the sweep options offerings (such funds, “Non-Sweep Money Market Funds”). Like any other mutual fund transactions at LPL, transaction and other fees may apply. Moreover, unlike under the sweep services, transactions in Non-Sweep Money Market Funds are customer-directed (or directed by customer’s representative) and do not provide for automatic daily sweep. Depending on current interest rates and other market factors, investment returns of money market mutual funds could be, lower or higher than the aggregate fees and expenses charged by LPL in connection with the transaction. Contact your IAR for information about current fees and investment returns on money market funds. As described above, under “Fees Charged by Third Parties,” clients should understand that the share class offered for a particular Non- Sweep Money Market Fund charges higher fees and expenses than other share classes that are offered by the same Non-Sweep Money Market Fund but are not available on LPL’s platform. LPL receives compensation for the LPL customer assets invested in the Non-Sweep Money Market Funds (up to 0.30% on an annual basis) for recordkeeping, shareholder servicing and administrative services it provides for the funds and in connection with marketing support services LPL provides to the fund sponsors as described in this disclosure. This compensation related to Money Market Funds presents a conflict of interest to LPL because LPL has a financial benefit if cash is invested in the Money Market Funds. However, this compensation is retained by LPL and is not shared with its IARs. Therefore, this compensation does not cause an IAR to have a financial incentive to recommend that cash be held in the account instead of holding securities. Unlike other types of mutual funds available on LPL’s platform, LPL makes available Non-Sweep Money Market Funds from only a limited number of mutual fund sponsors. By making available a limited number of Non-Sweep Money Market Funds, LPL is able to negotiate greater compensation from the fund companies for services it provides to the funds. Because of the limited number of Non-Sweep Money Market Funds available on LPL’s platform and the fees paid by those funds, other money market mutual funds not available through LPL’s brokerage platform are likely to have higher returns than the Non-Sweep Money Market Funds. A7 – 0326 LPL Financial, Member FINRA/SIPC 30  Strategic Asset Management Program Brochure In addition, LPL has received a waiver from the Money Market Funds to allow a lower investment minimum for the Program Share class of the than that set out in the prospectus; however, LPL imposes its own minimum investment amounts that are higher than minimums that may apply if a client were to invest in the Money Market Funds through another firm outside of the Program. In light of the investment minimums that LPL imposes with respect to the Money Market Funds, an investment in the Money Market Funds outside of the Program or an investment in one of the many other money market mutual funds offered outside of the Program would likely be more economically advantageous than an investment in the Money Market Funds through the Program. LPL does not charge transaction charges on Money Market Funds. 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 cardholders. 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 the 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 IAR 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 the 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 A7 – 0326 LPL Financial, Member FINRA/SIPC 31  Strategic Asset Management Program Brochure 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. Other Clients Clients should understand that LPL and IAR perform advisory and/or brokerage services for various other clients, and that LPL and IAR may give advice or take actions for those other clients that differ from the advice given to the client. The timing or nature of any action taken for the account may also be different. Item 12: Brokerage Practices LPL does not receive research or other products or services other than execution from a broker-dealer in connection with client securities transactions (“soft dollar benefits”). LPL does not consider, in selecting or recommending broker- dealers, whether LPL or a related person of LPL receives client referrals from a broker-dealer or third party. In the Program, LPL requires that clients direct LPL as the sole and exclusive broker-dealer to execute transactions in the account. The IAR is not paid a commission in the Program, but LPL is paid transaction charges by the client for processing trades depending on the type of security. Because LPL is both the investment advisor and broker-dealer on the account in the Program, this presents a conflict of interest. Clients should understand that not all advisors require their clients to direct brokerage. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution of client transactions. Therefore, directed brokerage may cost clients more money. In the case of mutual funds, execution is made at the net asset value of the fund. If LPL as broker purchases a new issue security on behalf of client accounts, the execution price may include a concession to the dealers participating in the syndicate. Although LPL is not part of the syndicate and does not receive this concession, the concession is included in the price and is in addition to the Account Fee. IARs may aggregate transactions in equity, options and fixed income securities for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. For partially filled orders, the IAR will generally allocate trades pro-rata or on a random basis to treat clients fairly and consistent with our fiduciary duty. IARs may determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, the liquidity of the securities and the discretionary or non-discretionary nature of the trades. If IARs do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. 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. For securities transactions, this delay may cause a difference between the execution price and the displayed quote at the time the order was entered. This delay may also result in a limit order becoming ineligible for 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. A7 – 0326 LPL Financial, Member FINRA/SIPC 32  Strategic Asset Management Program Brochure Item 13: Review of Accounts LPL reviews program accounts using a risk based exception reporting system that flags accounts for criteria such as trading activity and concentration on a quarterly or monthly basis, depending upon the nature of the exception. The Chief Compliance Officer of LPL oversees the process for reviewing flagged 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 performance information available upon request. LPL also provides an additional year-end report for accounts not established on a calendar quarter basis. In addition, LPL sends to clients trade confirmations and account statements showing transactions, positions, and deposits and withdrawals of principal and income. LPL does not send trade confirmations for systematic purchases, systematic redemptions and systematic exchanges. 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. Item 14: Client Referrals and Other Compensation 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 also pay for, or reimburse LPL for the costs associated with, education or training events that may be attended by LPL employees and IARs and for 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 servicing customers. LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 certain advisory programs 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 A7 – 0326 LPL Financial, Member FINRA/SIPC 33  Strategic Asset Management Program Brochure 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 IAR. In the event a trade error occurs in a Program 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. 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: • Referral Networks. Some third parties operate referral networks. Referral networks may present potential clients with a list of possible investing firms and investment adviser 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; • 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; • 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; • 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 • 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’s participation in these referral arrangements does not diminish its fiduciary obligations to its clients. A7 – 0326 LPL Financial, Member FINRA/SIPC 34  Strategic Asset Management Program Brochure 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. Where an IAR engages LPL Research to provide investment management services directly to clients, the IAR is responsible for paying for such services which may result in the client being charged a higher Account Fee by the IAR than if LPL Research were not providing services. 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 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: • payments based on production • 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 • payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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 A7 – 0326 LPL Financial, Member FINRA/SIPC 35  Strategic Asset Management Program Brochure 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 SAM than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in SAM over other programs and services. Although the IAR may factor in the fees charged to them by LPL in the overall Account Fee negotiated by the client, IAR can still earn more for offering SAM 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 has systems in place to review IAR-managed accounts in SAM for suitability over the course of the advisory relationship. 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 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 A7 – 0326 LPL Financial, Member FINRA/SIPC 36  Strategic Asset Management Program Brochure 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. 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 benefits including but not limited to the use of the financial institution’s facilities and client referrals. Instead of paying the IAR the portion of the Account Fee as described above, LPL shares the Account Fee with the financial institution, and the financial institution pays part of that amount to the IAR based on a compensation plan between the IAR and the financial institution. 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. LPL also has agreements to provide similar services at financial institutions in which compensation is not shared with the financial institution whereby a portion of the Account Fee is paid directly to the IAR. 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. 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. If your IAR is an employee of and/or provides services on the premises of one of these financial institutions, the financial institution has a financial incentive for the IAR to select the financial institution’s affiliated investment products and/or certificates of deposit over non-affiliated 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 or other benefits from the affiliated investment product. Because affiliates of the financial institution earn fees and other benefits from the affiliated products, the financial institution has an incentive to select its affiliated product based on the compensation A7 – 0326 LPL Financial, Member FINRA/SIPC 37  Strategic Asset Management Program Brochure 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. investment products. We update this Certain financial institutions provide a credit in an amount equal to the mutual fund advisory and administrative services fees for affiliated 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 recommend an investment product that he or she believes is appropriate, suitable and in the best interests of the 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 financial 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 can 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 financial 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 of the financial institution 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 and such referral programs are governed by Regulation R of the Gramm-Leach-Bliley Act. Employees of trust departments at certain financial institutions are authorized under the terms of applicable trust arrangements to delegate investment advisory 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. Item 15: Custody LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody of Program 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. A7 – 0326 LPL Financial, Member FINRA/SIPC 38  Strategic Asset Management Program Brochure Although most securities available in Program accounts are custodied at LPL, there are certain securities managed as part of the account that are held at third parties, and not at LPL. For example, variable annuities, hedge funds and managed futures are often held directly with the investment sponsor. For those outside positions, client will receive confirmations and statements directly from the investment sponsor. For outside positions not custodied at LPL, LPL may receive information (e.g., number of shares held and market value) from the investment sponsor and display that information on statements and reports prepared by LPL. Such information also may be used to calculate performance in performance reports prepared by LPL. Although LPL believes that the information it receives from the investment sponsors is reliable, LPL recommends that you refer to the statements and reports you receive directly from the investment sponsor and compare them with the information provided in any statements or reports from LPL. The statements and reports you receive from LPL with respect to outside positions should not replace the statements and reports you receive directly from the investment sponsor. Item 16: Investment Discretion In the Program, the IAR provides advisory services on a discretionary basis for the purchase and sale of mutual funds, UITs, closed-end funds, ETFs, and variable annuity subaccounts. The IAR provides advisory services on a non- discretionary basis for all other types of securities approved by LPL for investment in the account. In some cases, the client may provide discretionary authorization to the IAR to trade various other securities, including equities and fixed income securities. Alternatively, the client may elect that the IAR manage the account on a non-discretionary basis, so that the client directs the purchase and sale of securities in the account. The client authorizes the IAR to have discretion by executing the Account Agreement and Application. Item 17: Voting Client Securities In the Program, LPL and IARs do not accept authority to vote client securities. Clients retain the right to vote all proxies that are solicited for securities held in the account. Clients will receive proxies or other solicitations from LPL. When LPL delivers mutual fund shareholder reports and proxies to clients, LPL is reimbursed by the mutual fund for the delivery costs. 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 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 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 18: Financial Information LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and is therefore not required to include a balance sheet for its most recent financial fiscal year. LPL is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has it been the subject of a bankruptcy petition at any time during the past ten years. 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 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 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. A7 – 0326 LPL Financial, Member FINRA/SIPC 39 

Manager Select Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This wrap fee 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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 ............................................................................................................................... 1 Item 5: Account Requirements and Types of Clients .............................................................................................................. 6 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 7 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 16 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 16 Item 9: Additional Information ............................................................................................................................................... 17 Item 4: 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 client directly and also through third party investment advisor firms (“Advisor”). Associated persons of Advisor may also be broker-dealer AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 1  Manager Access Select Program Brochure registered representatives of LPL. This Brochure provides a description of LPL’s Manager Access Select program when offered through an Advisor. For more information about LPL’s advisory services and programs other than Manager Access Select, please contact your Advisor for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov/. In the Manager Access Select program, LPL makes available to Advisors and their clients the investment advisory services and/or model portfolios of third-party portfolio management firms. Within the program, LPL offers two alternatives – the Separately Managed Account Platform (the “SMA Platform”) and the Model Portfolio Platform (the “MP Platform” and collectively, the “Platforms”). In connection with the Platforms, LPL acts as an investment advisor, serves as the custodian of the assets, provides brokerage and execution services as a broker-dealer on transactions, and performs administrative services, such as reporting to clients. The Advisor assists the client to determine the client’s investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and, in the case of the SMA Platform, to select an investment strategy and SMA Portfolio Manager, or in the case of the MP Platform, to select a model portfolio (Model Portfolio) provided by LPL Research or third-party investment advisors (Model Advisors). All recommendations by LPL regarding accounts in the Platforms will be in an advisory capacity. Your Advisor cannot change the SMA Portfolio Manager or Model Advisor you select for your Account without your approval. SMA Platform In the SMA Platform, the Advisor assists the client to determine the client’s investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and to select an investment strategy and SMA Portfolio Manager. The Advisor provides the client with ongoing advice and monitoring relating to the SMA Portfolio Manager’s services and serves as the point of contact between the client and the SMA Portfolio Manager with regards to changes in the client’s investment objective, financial situation, and investment restrictions. The SMA Portfolio Manager selected by the client provides ongoing discretionary investment advice regarding the investment and reinvestment of account assets in accordance with the investment objective, restrictions and guidelines set forth in the Application or in other agreed-upon written instructions. The SMA Portfolio Manager independently determines whether to accept the client account based on the content of the Account Application, suitability, and whatever other factors the SMA Portfolio Manager deems appropriate. The SMA Portfolio Manager has the sole authority to determine the securities to be purchased, sold, or exchanged and which portion, if any, of the assets shall be held uninvested. The SMA Portfolio Manager has discretion to invest among a broad variety of security types, including equities, fixed-income securities, options, mutual funds and exchange-traded funds (“ETFs”). LPL and Advisor do not play a role in the selection of particular securities to be purchased or sold. A SMA Portfolio Manager may hire one or more sub-advisors to manage all or a portion of a client’s account. MP Platform In the MP Platform, the Advisor assists the client in setting an appropriate investment objective and selecting a model portfolio (Model Portfolio) provided by LPL Research or third-party investment advisors (Model Advisors). The Advisor provides the client with ongoing advice and monitoring relating to the Model Portfolio, is available on an ongoing basis to receive deposit and withdrawal instructions, and to convey to LPL any changes in Client’s financial circumstances, investment objectives or investment restrictions. Under the MP Platform, LPL provides ongoing discretionary investment advice regarding the investment and reinvestment of account assets in accordance with the Model Portfolio selected by the client. LPL is expected to closely track the Model Portfolio, making modifications only to address particular account issues, including tax loss harvesting, rebalancing, tracking error from the Model Portfolio, and to ensure that investment restrictions are being followed. 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. AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 2  Manager Access Select Program Brochure Fee Schedule In the Platforms, clients pay LPL an annualized fee (“Account Fee”). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the client changes the model selected for the Account, or if the model investment value changes, the overall Account Fee may increase or decrease. 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, IARs, SMA Portfolio Managers and Model Advisors do not charge performance-based fees to accounts in the Platforms. Advisory Fee. The Advisory Fee is charged for the investment advisory services of Advisor, as well as the investment advisory, administrative, trading, and custodial services of LPL. The Advisory Fee is shared with the Advisor. The Advisory Fee is negotiable between the client and the Advisor and is based on the value of all assets in the account, including cash holdings, and is payable quarterly in advance. The maximum Advisory Fee is 2.35%, although certain legacy accounts may remain higher, so long as the maximum combined Advisory Fee and Manager Fee is no more than 2.95%. Upon request, the Advisory Fee also can be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds in the Account. LPL retains a portion of the Advisory Fee, up to 0.35% of the value of the assets of the account, for its investment advisory, administrative, custody and clearing services. LPL shares up to 100% (typically between 90% to 100%) of the remaining portion of the Advisory Fee with the Advisor based on the agreement between LPL and the Advisor. LPL retains any portion of the Advisory Fee not shared with the Advisor. Manager Fee. The Manager Fee is charged for the services provided by Model Advisor or SMA Portfolio Manager, as applicable. Clients do not pay LPL, Advisor or IARs brokerage commissions or transaction charges for execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Clients pay a Manager Fee set by LPL for services provided by the SMA Portfolio Manager in the case of the SMA Platform and for use of the model portfolio of the Model Advisor in the case of the MP Platform. The Manager Fee is based on the value of all assets in the Account, including cash holdings, and payable quarterly in advance. This fee ranges from 0% to 0.60%. The amount of the Manager Fee will differ depending on the SMA Portfolio Manager or Model Advisor selected for Account, and also may vary depending on which investment strategy or Model Portfolio is selected. For Model Portfolios in the MP Platform, LPL charges a fee of up to 0.05% of account assets per year for the costs and services associated with effecting trades to implement the models, such as order formation, execution, settlement and sleeving of transactions. This LPL fee for its trading services is reflected in the Manager Fee on client statements. Generally, LPL charges 0.05% of account assets per year for models transacting primarily in equities, and LPL charges 0.03% of model assets per year for models transacting primarily in fixed income or other over-the-counter securities. In addition, for certain Model Portfolios designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL either charges a Manager Fee as Model Advisor or charges a fee for trading services, there is a conflict of interest for LPL to recommend such models. LPL charges the fee for trading services to retirement and nonretirement accounts to the extent permissible under applicable law. The Advisor does not receive any portion of the Manager Fee, including based on recommending a model for which LPL charges this compensation. Information about the client’s model and fee rates can be requested from Advisor. Certain Model Advisors or SMA Portfolio Managers receive a reduced Manager Fee or do not receive a Manager Fee. This is often because the Model Advisor or SMA Portfolio Manager has included proprietary or affiliated mutual funds or exchange-traded funds in the Model or Investment Strategy which charges a management fee. This management fee can be found in the prospectuses of the mutual funds or exchange traded funds included in the Model or Investment Strategy. Because a Model Advisor, SMA Portfolio Manager or their affiliates benefit financially when an affiliated fund is selected, there is a conflict of interest that affects the Model Advisor or SMA Portfolio Manager’s ability to provide unbiased, objective investment advice concerning the selection of funds for a Model or Investment Strategy. The fees paid to SMA Portfolio Managers in the SMA Platform and to Model Advisors in the MP Platform are generally less than fees those advisors would charge a client seeking to establish a direct relationship with them outside of a AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 3  Manager Access Select Program Brochure wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, and marketing expenses that would otherwise be borne by those advisors, including trading expenses for Model Advisors. SMA Portfolio Managers and Model Advisors generally have higher minimum account size requirements and fees for direct accounts because of such additional expenses. From time to time, LPL may make available Model Portfolios provided by third-party Model Advisors with associated persons who are also associated persons of LPL; however, if a client selects one of these associated persons to act as Advisor for their account, such Model Advisor will not receive a separate fee for its services as a model provider. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a Manager Access Select account from the account. LPL pays the applicable portion of the Account Fee to the SMA Portfolio Manager or Model Advisor. 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 Fees and Expenses of LPL LPL charges fees related to a Manager Access Select account in addition to the Account Fee, such as miscellaneous administrative or custodial-related fees and charges. 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, an annual Individual Retirement Account (“IRA”) maintenance fee, an annual qualified retirement plan maintenance fee, 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 miscellaneous 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. As described below under “Additional Information - Participation in Client Transactions,” if LPL as broker-dealer executes a principal transaction in a Manager Access Select account, LPL may earn a markup or markdown in addition to the Account Fee. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in Manager Access Select accounts. As described below under “Additional Information – Brokerage Practices,” if a SMA Portfolio Manager chooses to execute a transaction through a broker-dealer other than LPL, the execution price to the client may include a commission, markup/markdown, or other fee imposed by the executing broker-dealer in addition to the Account Fee. If client holds an American Depositary Receipt (“ADR”) in an account, there may be custodial fees or taxes related to the ADR. If a client’s assets are invested in mutual funds, ETFs or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Client will pay an advisory fee to the fund manager and other expenses charged by the fund. Client will also pay the Account Fee AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 4  Manager Access Select Program Brochure with respect to assets invested in such mutual funds, ETFs or other pooled investment products. Clients generally can purchase mutual funds directly outside of the program. Therefore, clients could avoid the second layer of fees by not using the advisory services of LPL, SMA Portfolio Manager, Model Advisor, and Advisor and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” The Sweep Fund used in the program may be managed by the same SMA Portfolio Manager that client has appointed to manage its account or be invested in a Model Portfolio provided by the same Model Advisor. If that is the case, clients should understand that the SMA Portfolio Manager or Model Advisor and its affiliates earn fees from the Sweep Fund for managing and performing other services for the fund which will be in addition to Account Fee charged to client. Advisor may charge fees in addition to the Account Fee. Clients should refer to the Brochure of Advisor for more information regarding fees charged by Advisor. If client transfers into a Manager Access Select 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 Manager Access Select model. 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 Advisor or directly from the fund. When transferring securities into a Manager Access Select 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 a Manager Access Select 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 Advisor 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 AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 5  Manager Access Select Program Brochure • client wishes to hold the security in a brokerage account that is not managed and not subject to an advisory fee. For those Manager Access Select accounts investing in mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in Manager Access Select charge shareholders an asset- based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds (other than the cash sweep money market funds (“Sweep Funds”) described in the section of Item 9 labeled “Participation or Interest in Client Transactions”) will be credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on a Manager Access Select Account • The Account Fee is an ongoing wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. The Account Fee may cost the client more than purchasing the program services separately, for example, paying fees for the advisory services of LPL, Advisor, and the SMA Portfolio Manager or Model Advisor, as applicable, plus commissions 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: – type and size of the account – 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. • It is important to note that a client may not be able to purchase advisory services directly from the SMA Portfolio Managers or Model Advisors. SMA Portfolio Managers and Model Advisors often do not offer such services for client accounts of the size typically associated with wrap programs. If they do offer such services to accounts the size of a Manager Access Select account, the SMA Portfolio Managers and Model Advisors often charge a higher fee as they do not enjoy the economies of scale related to providing services to clients of a wrap program. • 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 Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, the fees associated with the SMA Portfolio Manager or Model Advisor, and the 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 Advisory Fee with Advisor. • 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 A minimum account value of $25,000 generally is required for the program. In certain instances, the minimum account size may be lower or higher. Note that an account will not be invested until the applicable minimum for the investment AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 6  Manager Access Select Program Brochure strategy or Model Portfolio has been reached. Clients should consult with Advisor to obtain more information about the applicable investment minimum based on the strategy or Model Portfolio selected. The program is available for individuals, 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 Manager Access Select, Advisor is responsible for the investment advisory services related to the selection and retention of the SMA Portfolio Manager (in the case of the SMA Platform) and selection of the Model Portfolio (in the case of the MP Platform). The client selects Advisor who services the account. For more information about Advisor servicing the account, client should refer to Advisor’s Firm Brochure, which client should have received from Advisor at the time client opened the account. LPL makes available the advisory services of SMA Portfolio Managers. LPL does not act as a portfolio manager for the SMA Platform. LPL does, however, act as portfolio manager for the MP Platform. Criteria for Participating and Recommended SMA Portfolio Managers and Model Advisors LPL selects and reviews SMA Portfolio Managers and Model Advisors for the program based on quantitative, qualitative and infrastructure criteria, which may include the criteria listed below. Quantitative Criteria LPL evaluates quantitative criteria, including but not limited to: • Rate of return • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Investment philosophy • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether an SMA Portfolio Manager or Model Advisor can handle operational requirements, including but not limited to: • Composite calculation methodology • Trade rotation policy • Back office review • Client servicing resources • Firm-wide program commitment Additional Criteria for Recommended SMA Managers or Model Advisors SMA Portfolio Managers and Model Advisors that are “Recommended” by LPL Research are subject to a more rigorous selection and review process than the criteria set out above that applies to all SMA Portfolio Managers and Model AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 7  Manager Access Select Program Brochure Advisors available in the program. In addition to the criteria noted above, additional evaluation criteria for Recommended SMA Portfolio Managers and Model Advisors include: • Sound investment philosophy and process that drives performance • Consistency of returns and risk • Qualitative assessment of the investment manager and team Clients should speak to Advisor regarding whether the SMA Portfolio Manager or Model Advisor being considered for selection or that has been selected by the client is Recommended or Participating. LPL as a Model Advisor Clients may invest in Model Portfolios designed by LPL Research. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Model Portfolios to meet different investor needs. LPL Research Model Portfolios are built by seeking certain quantitative characteristics for each portfolio using a rules-based, disciplined process for security selection and portfolio construction. LPL Research looks for specific characteristics or investment factors and designs a Model Portfolio to capture the investment results of that characteristic or factor. For example, one such Model Portfolio seeks to have index-like representation to reasonably track large cap index returns such as the Russell 1000 Index, while another focuses on dividends by seeking a yield premium over the index. The LPL Research Model Portfolios are managed tactically, which means they are flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of trading as frequently as monthly. The participation of LPL Research as a Model Advisor under the MP Platform gives rise to conflicts of interests. For certain LPL Research model portfolios, LPL charges clients a Manager Fee. In addition, LPL has a financial incentive to promote its internal team and further grow its assets under management, in part because as assets under management at LPL increase, LPL is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. However, LPL does not share the Manager Fee with Advisor. Removal of a SMA Portfolio Manager or Model Advisor LPL may elect to remove or replace a SMA Portfolio Manager or Model Advisor should it determine that the SMA Portfolio Manager or Model Advisor has failed to meet one or more of the above selection criteria or if the SMA Portfolio Manager or Model Advisor has failed to maintain sufficient assets under management at LPL to maintain profitability on the Manager Access Select platform. In making a decision to remove or replace a SMA Portfolio Manager or Model Advisor, LPL takes into consideration all criteria; no one criteria, other than the maintenance of assets under management at LPL, is necessarily determinant in the decision. Short-term developments are monitored but are not necessarily sufficient for a decision to remove or replace a SMA Portfolio Manager or Model Advisor. While LPL would have the authority to remove LPL Research as a Model Advisor, it is unlikely to do so. SMA Portfolio Manager Performance and Model Advisor Performance LPL Research uses information provided by the SMA Portfolio Manager or Model Advisor and may also use independent, third-party databases when evaluating an SMA Portfolio Manager or Model Advisor. In order for a SMA Portfolio Manager or Model Advisor to be selected for the program, LPL generally requires a third-party verification letter related to compliance of the performance information of the SMA Portfolio Manager or Model Advisor with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. This requirement may be waived by LPL for various reasons including alternative methods of verifying the experience and/or performance of the SMA Portfolio Manager or Model Advisor. AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 8  Manager Access Select Program Brochure Performance information used by SMA Portfolio Managers and Model Advisors is not calculated on a uniform and consistent basis. LPL does not calculate the performance record of SMA Portfolio Managers or Model Advisors. However, LPL provides clients, if so directed by Advisor, individual performance information. Performance information is prepared by LPL using portfolio accounting and performance reporting software. Client performance is reported on a time weighted basis. It is important to note that third-party Model Advisors provide Model Portfolios to LPL, and it is LPL that has discretion for trade implementation and execution in MP Platform accounts. Therefore, Model Portfolios submitted to LPL by third-party Model Advisors represent activity that has already been implemented on behalf of other clients of such Model Advisors. Because of this fact and because LPL (and not the third-party Model Advisor) has discretionary authority to implement trades, performance of an MP Platform account will differ from and may be worse than the performance of such Model Advisor’s discretionary accounts. Investment Strategies SMA Portfolio Managers and Model Advisors may provide advisory services based on the following types of investment strategies. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Small Cap Blend Small Cap Growth Small Cap Value Tax Free Fixed Income Taxable Fixed Income All Cap Core All Cap Growth All Cap Value Balanced Convertibles Global Balanced Global Equity Growth Equity Income Preferred Large Cap Core Large Cap Foreign Large Cap Growth Large Cap Value Mid Cap Core Mid Cap Growth Mid Cap Value REIT Sector Types of Investments and Risks In the Platforms, SMA Portfolio Managers (in the case of the SMA Platform) or LPL (in the case of the MP Platform) invest in many different types of securities, including equities, fixed-income securities, options, mutual funds, closed- end funds, interval funds and ETFs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 9  Manager Access Select Program Brochure • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Alternative Strategy Mutual Funds. Certain mutual funds available in the Programs invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an “interval fund”). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • 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, AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 10  Manager Access Select Program Brochure 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. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency, and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 11  Manager Access Select Program Brochure in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Leveraged and Inverse ETFs, ETNs, and Mutual Funds. Leveraged ETFs, ETNs, and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts, and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 12  Manager Access Select Program Brochure • Options. Option trading is permitted in the Program. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and a Program account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (“ETPs”). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), futures-linked ETPs (“Futures Linked ETPs”), and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other ETPs. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 13  Manager Access Select Program Brochure should notify their Advisor of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, Advisor will 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 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. While an 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long-term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Blockchain Technology. Blockchain is a novel technology for which its uses, opportunities, applications, and abilities are unknown and unproven. There can be no assurances that companies investing in this technology will be able to benefit from it. The amount and type of investment restrictions are subject to change and manager’s acceptance. Companies investing in blockchain tend to be concentrated in the technology and financial sectors. As a result, the portfolio will be subject to the concentration risk described above and the portfolio’s performance may vary materially from that of its MSCI World Index benchmark. This portfolio invests in American depositary receipts (ADRs), negotiable certificates traded on a U.S. exchange which are issued by U.S. banks and which represent a specified number of shares (or one share) in a foreign stock. As a result, the portfolio will be subject to the Non-U.S. securities risk described below. U.S. Securities Risk. Non • Non ‐ ‐ U.S. securities involve risks in addition to those associated with comparable U.S. securities and can be more volatile and experience more rapid and extreme changes in price than U.S. securities. Additional risks include exposure to less developed or less efficient trading markets; social, political, or U.S. currencies and in the U.S. dollar exchange rate to those currencies; economic instability; fluctuations in non ‐ AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 14  Manager Access Select Program Brochure nationalization or expropriation of assets; settlement, custodial or other operational risks; less stringent auditing, accounting, financial reporting, and legal standards; excessive taxation; and exchange control regulations. Adverse conditions in a particular region could negatively affect securities of countries whose economies appear to be unrelated or not interdependent. In many countries, there is less publicly available and lower quality information about issuers than is available in the reports and ratings published about issuers in the U.S. • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and Advisor generally will earn more compensation for selling one investment product than another. As a result, LPL and Advisor have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. Voting Client Securities In the case of the SMA Platform, the SMA Portfolio Manager, and not LPL, is responsible for voting proxies with respect to issuers held in an account, unless a client directs otherwise in writing. The SMA Portfolio Manager, and not LPL, likewise determines how to respond to any voluntary corporate actions. LPL does not assume responsibility for reviewing the SMA Portfolio Manager’s proxy voting decisions or policies, including for compliance with law. In the case of the MP Platform, unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. A copy of LPL’s proxy voting policies is available upon request AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 15  Manager Access Select Program Brochure to Advisor. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting the 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 the mutual fund on LPL’s behalf and in certain cases remits a portion of the reimbursement to LPL. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of third-party Model Advisors without reviewing individual client interests, unless LPL believes that such instructions are overtly contrary to our clients’ best interests. In such case, LPL will determine whether or how to act consistent with the best interests of our clients. LPL, Advisor, IARs and Model Advisors are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the Account, or issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the Account. Item 7: Client Information Provided to Portfolio Managers When a client opens an account, the Advisor obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective 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 the case of SMA Platform accounts, LPL forwards this information to the selected SMA Portfolio Manager. In the case of MP Platform accounts, the Advisor uses this information to assist the client in selecting an investment strategy and Model Portfolio for the account. LPL typically will not provide client information to third-party Model Advisors. After the account opening, LPL asks clients quarterly to contact the Advisor if there have been any changes in the client’s financial situation or investment objectives or if the client wishes to impose any reasonable restrictions on the management of the account or modify existing restrictions. If client communicates to the Advisor regarding material changes in the client’s financial circumstances, investment objective or investment restrictions, such information is forwarded to the SMA Portfolio Manager for SMA Platform accounts. Clients may communicate such information to the Advisor, or SMA Platform clients may otherwise communicate directly with the SMA Portfolio Manager, although clients are encouraged to direct communication through the Advisor. Client should be aware 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 should further be aware that achievement of the stated investment objective is a long-term goal for the account. Item 8: Client Contact with Portfolio Managers In the case of SMA Platform accounts, SMA Portfolio Managers are reasonably available to consult with Advisors and clients regarding accounts. Clients may consult directly with the SMA Portfolio Manager, although clients are encouraged to direct contact with SMA Portfolio Manager through the Advisor. In the case of MP Platform accounts, LPL does not place any restrictions on a client’s ability to contact and consult with Advisors. Because the Model Advisor’s role is solely to provide Model Portfolios to LPL, and not to provide individualized discretionary advisory services to MP Platform clients, third party Model Advisors generally are not available to be contacted or consulted by MP Platform clients. AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 16  Manager Access Select Program Brochure 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: • 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). AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 17  Manager Access Select Program Brochure • 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, 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). • 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 AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 18  Manager Access Select Program Brochure 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). 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, 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. 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 brokerage capacity or on behalf of LPL with respect to the services provided under this program. 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. AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 19  Manager Access Select Program Brochure 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 service, 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-Manager Access Select 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 s 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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 In the case of the SMA Platform, LPL, as principal, buys securities from and sells securities to clients in program accounts. This practice could put LPL in a position where its own interests are in conflict with clients. However, LPL is not a market maker in securities and does not carry an inventory. In addition, it is the SMA Portfolio Manager (and not LPL) who as investment advisor determines the securities to be traded in the account. It is also the SMA Portfolio Manager who has a duty of best execution in negotiating transactions for program clients. In the case of the MP Platform, LPL as investment advisor determines the securities to be traded in the account; however, LPL is expected to closely track the Model Portfolio, applying discretion only to address particular account issues, including tax loss harvesting, rebalancing, tracking error from the Model Portfolio, and to ensure that investment restrictions are being followed. 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. Though LPL also processes securities transactions, as broker-dealer, for MP Platform accounts, LPL does not charge commissions. When LPL acts in a principal capacity for an SMA Portfolio Manager, it receives a markup or markdown on the transaction. This means, for example, if LPL sells a security at a price higher than what LPL paid, LPL will earn a markup. Conversely, if LPL buys a security at a price lower than what LPL sells it for, LPL will receive a markdown. The maximum markup or markdown that LPL receives when acting in a principal capacity in a program account is $2.00 per bond. In many cases, this maximum does not apply, and the actual markup or markdown is lower, typically $1.00 per bond. Details about a markup or markdown for a particular transaction will be furnished upon request. AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 20  Manager Access Select Program Brochure Purchase of mutual fund shares are typically 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 the firm’s use of a proprietary account for the mutual fund purchase. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when: a client is also trading whole shares of the security; in connection with a dividend reinvestment plan; or to sell remaining fractional shares to close a position. Trades in whole and fractional shares typically happen on the same day and will be executed at the same price as a trade in whole shares, or otherwise at market closing price. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. SMA Portfolio Managers are not prevented from purchasing LPL Financial Holdings Inc. stock in program accounts. In addition, a Manager Access Select account may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in Manager Access Select charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds (other than the Sweep Funds) will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by clients in the fund (up to $25 per position). 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. SMA Portfolio Managers and Model Providers pay LPL initial diligence and setup fees of up to $5,000 per strategy or Model Portfolio and up to a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance to make their services available in the Program. In the case of ETPs, 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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with Advisor or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 21  Manager Access Select Program Brochure with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL representatives so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds (other than the Sweep Funds) consists of flat and/or asset based fees totaling up to 0.15% annually, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for an Account. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective financial professionals to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the Advisor who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Model Portfolio in the case of Model Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 22  Manager Access Select Program Brochure Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds (other than the Sweep Funds), and therefore, there LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b- 1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with third party SMA Portfolio Managers or Model Advisors, and, therefore, there is no financial incentive for an a third party SMA Portfolio Manager or Model Advisor to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. LPL also does not share these payments with Advisor. Although LPL does not share recordkeeping fees or revenue sharing payments with Advisor or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisor and 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. 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 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 AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 23  Manager Access Select Program Brochure 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 or 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. 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. 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. • 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 AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 24  Manager Access Select Program Brochure 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. LPL’s money market mutual fund sweep option automatically sweeps otherwise uninvested cash balances held in the account and invests them 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. This compensation that LPL receives related to the ICA, DCA (including from 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, 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 Funds. However, this compensation is retained by LPL and is not shared with SMA Portfolio Managers or Model Advisors. Therefore, this compensation does not cause an SMA Portfolio Manager or Model Advisor to have a financial incentive to recommend that cash be held in the account instead of holding securities. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 Advisor of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 25  Manager Access Select Program Brochure has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with Advisor, and therefore, Advisor does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with Advisor, and therefore, an Advisor has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your Advisor’s compensation on the SCA product is reduced if your interest rate is discounted, so your Advisor has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your Advisor receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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, or alternatively, could incentivize the Advisor to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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 SMA Portfolio Managers, Model Advisors, LPL, and Advisor perform advisory and/or brokerage services for various other clients, and they may give advice or take actions for those other clients that differ from the advice given to the client. The timing or 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, performance information annually describing account performance, 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. Other Compensation LPL and LPL employees also receive additional compensation from product sponsors, including SMA Portfolio Managers and Model Advisors. Such compensation may not be tied to the sales of any products or services. Compensation may include 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. SMA Portfolio Managers, Model Advisors and other 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, 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. AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 26  Manager Access Select Program Brochure LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL employees provide sales support resources to Advisors 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 certain advisory programs 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. 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. In the event a trade error occurs in an 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. 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 IARs of third-party RIA Firms. Clients should ask their IAR 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 Manager Access Select 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 AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 27  Manager Access Select Program Brochure 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 the case of the MP Platform, all transactions will be executed through LPL, and Client directs that securities transactions for the Account be initiated through LPL. In the case of the SMA Platform, Client directs SMA Portfolio Managers to execute transactions through LPL, subject to the SMA Portfolio Manager’s duty as an investment advisor to seek to achieve best execution. Clients should understand that an SMA Portfolio Manager may choose to place some or all trades for accounts with broker-dealer firms other than LPL (“trade away” or “step outs”). Some SMA Portfolio Managers have historically placed nearly all client trades with broker-dealer firms other than LPL for execution, in particular, if the SMA Portfolio Manager follows a fixed-income, foreign or small cap investment strategy. In addition, SMA Portfolio Managers may choose to trade away from LPL in order to aggregate all client transactions into one or more larger “block trades” that are executed through one broker-dealer. This practice may enable an SMA Portfolio Manager to obtain more favorable execution, including a more advantageous net price, than would otherwise be available if orders were not aggregated into a single “block trade.” It may also assist the SMA Portfolio Manager in potentially avoiding an adverse effect on the price of a security which could result from simultaneously placing a number of separate, successive or competing client orders. When securities transactions are effected through LPL, there are no brokerage commissions charged to the account. If an SMA Portfolio Manager chooses to execute a transaction through a broker-dealer other than LPL, the execution price will usually include a commission or fee imposed by the executing broker-dealer. Clients should understand that the client will bear any such additional trading cost, in addition to the Account Fee paid to LPL. The additional expenses charged by the broker-dealer executing the transaction may include commissions, mark-ups, mark-downs or “spreads” paid to executing broker dealer firm. Additionally, if a foreign currency transaction is required, there may be foreign exchange or similar fees, including but not limited to fees for foreign ordinary conversion and creation of American Depositary Receipts (“ADRs”) charged by third parties as well as foreign tax charges. In many cases, the commission, mark-up, mark-down or other additional expenses charged by the executing broker-dealer or third party will be embedded in the purchase or sale price of such transactions, and not separately indicated on trade confirmations and custodial account statements provided by LPL. In evaluating whether to execute a trade through a broker-dealer other than LPL, an SMA Portfolio Manager will consider the fact that an account will not be charged any additional expenses (such as a commission) if effected directly through LPL. 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. Clients should understand that LPL is not able to fully evaluate whether an SMA Portfolio Manager is meeting its best execution obligations to clients for specific transactions when trading away, as it is not a party to such transactions and is not in a position to negotiate the price or transaction related charges with the executing broker. The responsibility to determine whether to trade away lies with the SMA Portfolio Manager and arises out of an SMA Portfolio Manager’s individual fiduciary duty to clients. Additional information regarding equity trading away practices of SMA Portfolio Managers is available at lpl.com/disclosures.html under “Market & Trading Disclosures” and “Third-Party Portfolio Manager Trading Practices.” Clients should consider whether or not the appointment of LPL as the broker-dealer may or may not result in certain costs or disadvantages as a result of possibly less favorable executions. Clients should understand that not all wrap program sponsors require brokerage to be directed to the sponsor. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution of client transactions. In particular, a client’s account may not be able to participate in block trades placed by a SMA Portfolio Manager for its other accounts, which may result in a AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 28  Manager Access Select Program Brochure difference between prices charged to a program account and SMA Portfolio Manager’s other accounts. For these reasons, directed brokerage may cost clients more money. SMA Portfolio Managers (in the case of the SMA Platform) and LPL (in the case of the MP Platform) may aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. Clients should read and understand the brokerage practices disclosed in the Firm Brochure of each SMA Portfolio Manager selected by the client (if applicable). 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. 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 IARs by providing, for example: • payments based on production • 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 • payments in connection with the transition of Advisor’s business from another firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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. 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 AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 29  Manager Access Select Program Brochure 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 Manager Access Select than other programs or services. In such cases, Advisor has a financial incentive to recommend advisory services in Manager Access Select 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 Manager Access Select 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 Advisor’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 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. 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 and may meet with clients from time to time, they are not responsible for the ongoing individualized investment advice provided to a particular client. For more information about the SMA Portfolio Manager managing the account or Model Advisor providing a Model Portfolio, client should review the Brochure of the SMA Portfolio Manager or Model Advisor provided to you when you opened your Program account. For more information about the Advisor servicing the account, 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 these documents related to Advisor or its associated persons, the client should contact the Advisor. AP – MAS – R – 0326 LPL Financial, member FINRA/SIPC 30 

Model Wealth Portfolios (MWP) Program Form Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 8 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 8 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 16 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 16 Item 9: Additional Information ............................................................................................................................................... 16 A11 – R – 0326 LPL Financial, member FINRA/SIPC 1  Model Wealth Portfolios (MWP) Program Form 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 and an advisor-enhanced digital advice program. 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 Model Wealth Portfolios (“MW) program when offered through an Advisor. For more information about LPL’s advisory services and programs other than MWP, please contact LPL or your Advisor for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov/. The MWP program is a unified managed account program in which LPL and Advisor provide ongoing investment advice. The Advisor, through its designated investment adviser representative (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 Advisor, or client with the assistance of the Advisor, selects one or more model portfolios of securities (each, a “Portfolio”) designed by LPL’s Research Department, a third-party investment strategist or Advisor (each, a “Portfolio Strategist”) consistent with the client’s stated investment objective. These Portfolios may contain mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), closed-end funds, equities, or fixed-income securities. The Advisor provides ongoing advice on the selection or replacement of a Portfolio based on the client’s individual needs. The Advisor, or the client with the assistance of the Advisor, may choose more than one Portfolio to be managed within a single MWP account. A Portfolio may be comprised of one or more underlying models. 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 Portfolio Strategist is responsible for selecting the securities within a Portfolio and for making changes to the securities selected. LPL has discretion to buy and sell securities in the account according to the Portfolio selected and liquidate previously purchased securities that are transferred into the account. The client authorizes LPL to have discretion by executing the Account Agreement and Account Application. Except for LPL, the Portfolio Strategists are independent investment advisor firms. Portfolio Strategists provide LPL on an ongoing basis with a Portfolio that includes recommended asset allocations and securities. LPL enters into an agreement with the Portfolio Strategist for these Portfolio services. Except for LPL and Advisor, and except for Subadvisers (defined below) a Portfolio Strategist does not have discretion from the client to implement the Portfolio and does not provide individualized investment advice to specific program clients. Some third-party investment strategists have entered into subadvisory agreements with LPL to manage, on a discretionary basis, accounts or portions of accounts in the program allocated to their fixed-income Portfolios (Subadvisers). If Advisor, or a client, chooses to allocate all or a portion of an account to a Portfolio provided by a Subadviser, LPL will delegate some of its responsibilities to the Subadviser, subject at all times to oversight by LPL. Subadvisers will have discretion to make decisions about how to implement their Portfolios, including decisions on purchasing and selling fixed-income securities, executing trades through brokerage firms selected by the Subadviser and rebalancing the assets in the Account allocated to their models, which may occur on a different frequency than as determined by the Overlay Portfolio Manager. Subadvisers have discretion whether to consider state preferences (if client provides to IAR) when selecting from the inventory of bonds, if applicable. Not all states will carry inventory to suffice for a selection. Please note that there is no guaranty that state preference will be considered. The discretion to consider state preferences is not intended as tax advice, and neither LPL nor any Subadviser represents in any manner that implementation of state preferences will achieve tax-advantaged returns. Notwithstanding LPL’s delegation of some of its responsibilities to the Subadviser, LPL will remain responsible for all advisory services provided in the Program. LPL conducts initial and ongoing due diligence of Subadvisers and has the ultimate authority to hire and fire Subadvisers to accounts in the Program, and may terminate a Subadviser’s authority to manage client assets at its discretion. A client who wishes not to engage a Subadviser would be required to select a different Portfolio. If your Advisor or you choose to invest in a Portfolio provided by a Subadviser, please carefully review the A11 – R – 0326 LPL Financial, member FINRA/SIPC 2  Model Wealth Portfolios (MWP) Program Form Brochure Subadviser’s Form ADV Part 2 Brochure for information on the Subadviser’s investment strategies, risks, brokerage practices and conflicts of interest. LPL acts as the overlay portfolio manager (OPM) in coordinating the trades in the account and performing tax harvesting services. LPL expects to closely track the Portfolios, applying discretion only to address particular account issues, including tax rebalancing, tax loss harvesting, short-term gain avoidance, cash inflows and outflows, and tracking error from the Portfolio, customized requests, and investment restrictions placed on the account. 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. LPL as the OPM is responsible for rebalancing accounts in accordance with the allocations in the Portfolio. LPL will review an account to determine if rebalancing is appropriate based on the frequency selected by the client at account opening or as altered by the client or the Advisor from time to time. The choices for frequency of rebalancing review are quarterly (four times per year), semiannually (two times per year) or annually (once per year). At each rebalancing review date, LPL will rebalance the account if the account has available cash for investment and if at least one security position, including cash, is outside a pre- determined range, subject to a minimum transaction amount established by LPL in its discretion. In addition, LPL will review an account for rebalancing in the event that the Portfolio Strategist changes the allocation targets. All recommendations by LPL regarding accounts in the MWP Program will be in an advisory capacity. LPL accommodates reasonable requests to restrict holdings of specific securities, specific industries, specific sectors, and certain pre-defined categories (e.g., “sin” stocks). In the event that client restrictions prevent the investment in certain securities otherwise specified by a Portfolio Strategist, assets will be invested pro-rata across the remaining securities in the model. Such restrictions do not apply to any mutual funds, ETFs or fixed-income securities that are held in the account. Restrictions placed on an account can affect the performance of the account. The OPM may choose not to accept an account with restrictions that are inconsistent with the investments chosen by the OPM or as recommended by the Portfolio Strategist. LPL, at the request of Advisor, performs tax harvesting, which may include using the proceeds of tax-related transactions to purchase appropriate securities (such as ETFs or mutual funds) for an account. Client may also request Advisor to initiate tax harvesting with LPL. In such case, proceeds of tax-related transactions may be held in cash or securities until appropriate wash sale periods have expired. Once the wash sale period has expired, the related proceeds will be invested according to the current targeted allocation for the Portfolio. Similarly, LPL may delay a tax harvesting request to sell securities acquired in the previous 30 days until the wash sale period has expired. Under certain conditions, LPL also will accommodate requests for all or a portion of an account to remain allocated to cash for a period of time. In addition to general tax harvesting requests described above, clients may authorize LPL to provide more comprehensive tax overlay services (“LPL Tax Overlay Services”). If directed by client, LPL will provide LPL Tax Overlay Services to the client’s account. The end objective of LPL Tax Overlay Services is to improve the after-tax return for the client while staying consistent with the investment strategies of the Portfolios. LPL Tax Overlay Services is available only to clients subject to U.S. capital gains tax. LPL does not provide tax planning advice or services. LPL does not represent in any manner that the desired tax objectives will be obtained or that MWP’s investment strategy will result in any particular tax outcome. Clients should discuss any questions with or request further information from their Advisor or their tax consultant in using the LPL Tax Overlay Services. LPL charges 0.08% of the value of the account to provide LPL Tax Overlay Services, which it retains from the Advisory Fee, as described under the section titled “Fee Schedule” below. This charge will not be separately indicated on account statements or otherwise. When Advisor recommends discontinuing LPL Tax Overlay Services, Advisor has a conflict of interest since discontinuing this service will increase the portion of the Advisory Fee paid to the Advisor. Clients will be notified when services are discontinued, including a reminder to discuss whether a reduction of the Advisory Fee is appropriate. Please ask Advisor for additional information. In some cases, clients may experience significant performance differences from the selected investment strategy for one or more Portfolios and/or the overall account, due to participation in LPL Tax Overlay Services. If a client chooses to participate in this service, LPL makes no assurances that the client’s account performance will be within any range A11 – R – 0326 LPL Financial, member FINRA/SIPC 3  Model Wealth Portfolios (MWP) Program Form Brochure of the selected investment strategy or the strategy’s benchmark. A client’s returns will likely differ from, and could be lower than, the Portfolio Strategist’s model when enrolled in Tax Overlay Services. In addition, LPL may manage the client’s account using tools and processes which may result in the client’s trades being executed at a different time or in a different manner than other LPL trades, including the potential to not participate in LPL’s standard trade rotation processes (if such trades would have been otherwise eligible to participate). In connection with the program, LPL also acts as custodian to accounts, provides research information to Advisor, provides brokerage and execution services as the broker-dealer on transactions, and performs administrative services, such as performance reporting. Fee Schedule Clients in the MWP program pay an annualized fee (Account Fee). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the Advisor changes the model selected for an account, or if the model investment value changes, the overall Account Fee may increase or decrease. 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, Advisors, IARs, and Portfolio Strategists do not charge performance-based fees to accounts in the program. Advisory Fee. The Advisory Fee is charged for the investment advisory services of Advisor, as well as the investment advisory, administrative, trading, custodial and clearing services of LPL. The Advisory Fee is shared with the Advisor. The Advisory Fee is negotiable between the client and Advisor and is based on the value of assets in the account, including cash holdings. The maximum Advisory Fee is 2.35%. Upon request, the Advisory Fee may be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds. LPL retains a portion of the Advisory Fee, up to 0.35% of the value of the account, for its investment advisory, administrative, trading, custodial, and clearing services. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Advisory Fee with Advisor based on the agreement between LPL and the Advisor. LPL retains any portion of the Advisory Fee not shared with the Advisor. Manager Fee. Depending upon the model(s) selected for the account, clients pay a Manager Fee set by LPL for the use of each model portfolio. The Manager Fee is based on the value of the assets in the account, including cash holdings, and payable quarterly in advance. This fee ranges from 0% to 0.60%. LPL pays all or a portion of the Manager Fee to the Portfolio Strategist. For certain models, LPL charges up to 0.05% of model assets per year for the costs and services associated with effecting trades to implement the models, such as order formation, execution, settlement and sleeving of transactions. This LPL fee for trading services is reflected in the Manager Fee on client statements. Generally, LPL charges 0.05% of model assets per year for models transacting primarily in equities, and LPL charges 0.03% of model assets per year for models transacting primarily in fixed income or other over-the-counter securities. For certain models designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL either charges a Manager Fee as Portfolio Strategist or charges a fee for trading services, there is a conflict of interest for LPL to recommend such models. LPL charges the fee for trading services to retirement and nonretirement accounts to the extent permissible under applicable law. Advisor does not receive any portion of the Manager Fee, including based on recommending a model for which LPL charges this compensation. A list of the client’s current model(s) and associated fee rates will be reflected on client account statements or can be requested from Advisor. Please note that if an account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. Clients do not pay LPL or Advisor brokerage commissions or transaction charges for the execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Certain Portfolio Strategists charge a reduced Manager Fee or do not charge a Manager Fee for their models. This is often because the Portfolio Strategist earns a management fee from proprietary or affiliated mutual funds or exchange-traded funds included in the model. This management fee can be found in the prospectuses of the mutual funds or exchange traded funds included in the model. Because a Portfolio Strategist or their affiliates benefit A11 – R – 0326 LPL Financial, member FINRA/SIPC 4  Model Wealth Portfolios (MWP) Program Form Brochure financially when an affiliated fund is selected, there is a conflict of interest that affects the Portfolio Strategist’s ability to provide unbiased, objective investment advice concerning the selection of funds for a model. If a Portfolio is selected that consists of mutual funds and/or ETFs primarily or only within the same fund family or within affiliated fund families (typically as indicated by the title of the model portfolio), the Portfolio Strategist will select at least a majority of funds within that fund family or affiliated fund families. In such case, because mutual funds or ETFs in a Portfolio are affiliated with a third-party Portfolio Strategist that designs the Portfolio, an investment in the affiliated fund generates compensation to that third party Portfolio Strategist or its affiliates, including, among other types of compensation, fund-level management fees, in addition to any portion of the Account Fee it receives. The fees paid to Portfolio Strategists are generally less than fees those strategists would charge a client seeking to establish a direct relationship with them outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, marketing and trading expenses that would otherwise be borne by those strategists. Portfolio Strategists generally have higher minimum account size requirements and fees for direct accounts because of such additional expenses. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with an MWP account from the account. LPL pays the applicable portion of the Account Fee to the Portfolio Strategists. 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 pro-rated 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 Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative and custodial- related fees and charges that apply to an MWP 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 miscellaneous 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. Other LPL advisory programs and/or other financial services firms separately offer certain models available through the program, in some cases at a lower overall costs to investors. When the same model is offered in different LPL advisory programs, the difference in the Manager Fee for use of that model is typically up to five basis points. Advisory programs differ significantly in the overall features and functionalities offered, and Advisor may only recommend a program or service that he or she believes is suitable and in the best interest of a client in accordance with the applicable standards under the Advisers Act. A11 – R – 0326 LPL Financial, member FINRA/SIPC 5  Model Wealth Portfolios (MWP) Program Form Brochure Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in MWP accounts. Some of these fees and charges are described below. In MWP, assets are often invested in mutual funds or ETFs 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 fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay the Account Fee with respect to assets invested in mutual funds and ETFs. The mutual funds and ETFs available in the program can be purchased directly outside of the program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL, Advisor and Portfolio Strategist and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” If client transfers into an MWP 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 MWP model. 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 Advisor or directly from the fund. When transferring securities into an MWP account, client should be aware that certain securities may 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 MWP 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 Advisor 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 an account that is not managed and not subject to an advisory fee. For those Portfolios consisting of mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in MWP charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately A11 – R – 0326 LPL Financial, member FINRA/SIPC 6  Model Wealth Portfolios (MWP) Program Form Brochure be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds (other than the cash sweep money market funds (“Sweep Funds”) described in the section of Item 9 labeled “Participation or Interest in Client Transactions”) will be credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on a MWP Account • The Account Fee is a wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. Clients do not pay a commission or transaction charge to LPL for the execution of transactions in the account. 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: – type and size of the account – type of securities in the Portfolio (whether mutual funds, ETFs, equities, or fixed income) – 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 fee set out above. The Advisor is responsible for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, the number, complexity and mix of the portfolio, the selection of the particular Portfolios, and the 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 Advisory Fee with Advisor. • The Advisor recommending the program to the client receives compensation as a result of the client’s participation in the program pursuant to an agreement between LPL and Advisor. This compensation includes a portion of the Account Fee and also can include other compensation, such as bonuses, awards or other things of value offered by LPL to the Advisor. LPL’s arrangements to share the Account Fee and/or to pay additional compensation to Advisor can be based on the Advisor’s overall business production and/or on the amount of assets serviced in all LPL advisory programs, including MWP, or specific to the Advisor’s assets in MWP. Therefore, the amount of compensation from LPL can be more than what Advisor would receive if the client participated in LPL advisory programs other than MWP, programs of other investment advisors or paid separately for investment advice, brokerage and other client services. Therefore, the Advisor can have a financial incentive to recommend an MWP account over other programs and services. • The investment products available to be purchased in the program can be purchased by clients outside of an MWP account, through broker-dealers or other investment firms not affiliated with 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.” A11 – R – 0326 LPL Financial, member FINRA/SIPC 7  Model Wealth Portfolios (MWP) Program Form Brochure Item 5: Account Requirements and Types of Clients LPL requires a minimum asset value for a program account to be managed. The minimums vary depending on the Portfolio(s) selected and the account’s allocation amongst Portfolios. The lowest minimum for a Portfolio is $10,000. In certain instances, LPL will permit a lower minimum for a Portfolio. Note that an account will not be invested according to a Portfolio or Portfolios until the applicable minimum for the Portfolio(s) and allocation has been reached. Clients should consult with Advisor to obtain more information about the applicable investment minimum based on the Portfolio(s) selected and the allocation amongst Portfolios. The program is available for individuals, Individual Retirement Accounts (“IRAs”), banks and thrift institutions, credit unions, pension and profit sharing plans, including plans subject to ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. Item 6: Portfolio Manager Selection and Evaluation In MWP, LPL and Advisor are responsible for the overall investment advice and management services offered to clients, and the client selects the Advisor. 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. LPL makes available Portfolios designed by LPL, third party Portfolio Strategists, including Subadvisers, and Advisor for a particular account. LPL reviews on a periodic basis Advisor acting as Portfolio Strategist on MWP. In addition, LPL selects and reviews on a periodic basis the third party Portfolio Strategists available on MWP. A third party Portfolio Strategist may provide services to LPL and the program as a Subadviser. In addition to deciding on the securities and asset allocation for a Portfolio, Subadvisers are responsible for determining when and how to execute transactions and selecting broker-dealers through which to execute transactions. LPL uses information provided by the third party Portfolio Strategist and also may use independent, third party data sources when evaluating such Portfolio Strategist. Third party Portfolio Strategist performance information is not calculated on a uniform and consistent basis. LPL does not review performance information to determine or verify its accuracy and does not calculate third party Portfolio Strategist performance. However, LPL provides Advisor, and clients, if so directed by Advisor, with individual performance information. Performance information is prepared by LPL using portfolio accounting and performance reporting software. Client performance information is calculated on a uniform and consistent basis using a time weighted basis. It is important to note that, except for Subadvisers, third party Portfolio Strategists provide the Portfolios to LPL, and it is LPL that has discretion for trade implementation and execution in MWP accounts. Therefore, Portfolios submitted to LPL by third party Portfolio Strategists may represent activity that has already been implemented on behalf of other clients of such Portfolio Strategists. Because of this fact and because LPL (and not the third party Portfolio Strategist) has discretionary authority to implement trades, performance of an MWP account will differ from the performance of such Portfolio Strategist’s discretionary accounts. LPL as a Portfolio Strategist In MWP, clients may invest in Portfolios designed by LPL’s Research Department. LPL Research designs many types of mutual fund, ETF, fixed-income and equity Portfolios to meet the varying needs of clients. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Portfolios for different timeframes, needs or themes that have meaning to investors. LPL Research generally designates portfolios as either strategic or tactical model styles. The allocations in strategic Portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout a 3 to 5 year timeframe and are intended for investors who take a longer term view or who are more tax sensitive. Tactical Portfolios are more flexible and are designed to help take advantage of short-, mid-, and A11 – R – 0326 LPL Financial, member FINRA/SIPC 8  Model Wealth Portfolios (MWP) Program Form Brochure long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of more frequent trading. Within the strategic and tactical model styles, LPL Research focuses each model on an investment theme or objective. For example, LPL Research designs alpha-focused Portfolios that are structured for more aggressive investors. There are also downside risk aware Portfolios that are intended to be structured more conservatively to help provide more protection in the event of a down market. LPL Research designs portfolios that are largely allocated to alternative strategies to provide diversified exposure to those more esoteric asset classes. LPL Research also designs Portfolios intended for investors who place a priority on income generation and Portfolios for investors seeking to minimize tax impacts. Such income generation Portfolios are also available in investment objectives that are not typically focused on income. Additionally, LPL Research designs portfolios intended for investors who want to invest primarily with certain mutual fund families. There are also Portfolios that emphasize socially responsible investing and sustainability. LPL Research also designs portfolios that follow a “direct indexing” strategy, or a strategy that seeks to replicate a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the market index. In a direct indexing strategy, LPL Research partners with an index provider to license an index and pays a portion of the Manager Fee to the index provider. For a complete list of the current models provided by LPL Research, please discuss with your Advisor. The participation of LPL’s Research Department as a Portfolio Strategist gives rise to conflicts of interests. For certain LPL Research model portfolios, LPL charges clients a Manager Fee. In addition, LPL has a financial incentive to select its internal team and further grow its assets under management, in part because as assets under management at LPL increase, LPL is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. However, LPL does not share the Manager Fee with Advisor. Advisor as Portfolio Strategist In addition to portfolios designed by LPL Research and third party Portfolio Strategists, clients can invest in portfolios managed by Advisor for their account. Advisor is responsible for selecting the mutual funds, ETFs, ETNs, closed-end funds, equities or fixed-income securities within a Portfolio, the asset allocation for the Portfolio, and for making changes to the securities selected and asset allocation over time. Advisor will typically manage Portfolios tailored to an investment theme or particular style that is core to Advisor’s beliefs and expertise. Advisor chooses research methods, investment strategy and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Advisor has access to various research reports, including those provided by LPL’s Research Department, to which Advisor may refer in determining which securities to purchase or sell. As OPM, LPL has discretion to buy and sell securities in the Account (according to the Portfolio selected) and to liquidate previously purchased securities that are transferred into the Account. LPL expects to closely track the Portfolios, applying discretion only to address particular account issues, including tax rebalancing, loss harvesting, tracking error from the Portfolio, customized requests, and investment restrictions placed on the account. 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. Types of Investments and Risks The Portfolios may include different types of securities, such as mutual funds, ETFs, ETNs, closed-end funds, equities and fixed-income securities. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • 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. A11 – R – 0326 LPL Financial, member FINRA/SIPC 9  Model Wealth Portfolios (MWP) Program Form Brochure • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Cybersecurity Risk. Failures or breaches of the electronic systems LPL, its service providers, of 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. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. A11 – R – 0326 LPL Financial, member FINRA/SIPC 10  Model Wealth Portfolios (MWP) Program Form Brochure • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and Advisor generally will earn more compensation for selling one investment product than another. As a result, LPL and Advisor have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. A11 – R – 0326 LPL Financial, member FINRA/SIPC 11  Model Wealth Portfolios (MWP) Program Form Brochure • Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End Funds. Client should be aware that closed-end funds available within the program may not be readily marketable. In an effort to provide investor liquidity, the funds may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, clients may be unable to liquidate all or a portion of their shares in these types of funds. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund A11 – R – 0326 LPL Financial, member FINRA/SIPC 12  Model Wealth Portfolios (MWP) Program Form Brochure expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (Single Inverse ETPs), futures-linked ETPs (Futures Linked ETPs) and cryptocurrency-related ETPs (Cryptocurrency ETPs). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely A11 – R – 0326 LPL Financial, member FINRA/SIPC 13  Model Wealth Portfolios (MWP) Program Form Brochure monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their Advisor of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, Advisor will 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 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. While an 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long-term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and A11 – R – 0326 LPL Financial, member FINRA/SIPC 14  Model Wealth Portfolios (MWP) Program Form Brochure therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Tax-Loss Harvesting. The tax-loss harvesting feature of MWP involves a variety of risks. You should confer with your personal tax advisor regarding the tax consequences of investing and engaging in the tax-loss harvesting strategy, based on your particular circumstances. You and your personal tax advisors are responsible for how the transactions in your account are reported to the IRS or any other taxing authority. Neither LPL nor Advisor assumes any responsibility to you for the tax consequences of any transaction. MWP’s tax-loss harvesting strategy is not intended as tax advice, and neither LPL nor Advisor represents in any manner that the tax consequences described will be obtained or that MWP’s investment strategy will result in any particular tax consequence. The tax consequences of this strategy are complex and may be subject to challenge by the IRS. This strategy was not developed to be used by, and it cannot be used by, any investor to avoid penalties or interest. You should be aware that if you and/or your spouse have other taxable or non-taxable accounts, and you hold in those accounts any of the securities (including options contracts) held in your MWP account, you cannot trade any of those securities 30 days before or after the MWP account trades those same securities as part of the tax-loss harvesting strategy to avoid possible wash sales and, as a result, a nullification of any tax benefits of the strategy. For more information on the wash sale rule, please read IRS Publication 550. In addition, when LPL replaces investments with “similar” investments as part of the tax-loss harvesting strategy, it is a reference to investments that are expected, but are not guaranteed, to perform similarly and that might lower an investor’s tax bill while maintaining a similar expected risk and return on investor’s portfolio. Expected returns and risk characteristics are no guarantee of actual performance. Voting Client Securities Unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL’s Research Department, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. 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. A11 – R – 0326 LPL Financial, member FINRA/SIPC 15  Model Wealth Portfolios (MWP) Program Form Brochure In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of the Portfolio Strategist without reviewing individual client interests, unless LPL determines that such instructions are overtly contrary to our clients’ best interest. In such case, LPL will determine whether or how to act consistent with the best interest of our clients. LPL and Advisor are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the account, or the issuers thereof. The client retains the right and obligation 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 objective or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Because third party Portfolio Strategist’s role is limited to providing Portfolios to LPL, and does not provide individualized discretionary advisory services to MWP clients, LPL generally does not communicate specific client information to third party Portfolio Strategists. 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 model in the account, 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 client’s ability to contact and consult with Advisor or LPL. Because a third party Portfolio Strategist’s role is solely to provide Portfolios to LPL, and not to provide individualized discretionary advisory services to MWP clients, third party Portfolio Strategists, except for Subadvisers, generally are not available to be contacted or consulted by MWP clients. 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 A11 – R – 0326 LPL Financial, member FINRA/SIPC 16  Model Wealth Portfolios (MWP) Program Form Brochure 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: • 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). A11 – R – 0326 LPL Financial, member FINRA/SIPC 17  Model Wealth Portfolios (MWP) Program Form Brochure • 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, 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). • 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). A11 – R – 0326 LPL Financial, member FINRA/SIPC 18  Model Wealth Portfolios (MWP) Program Form Brochure • 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). 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/. 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 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 program account on behalf of Advisor. That person is not acting in a broker-dealer capacity or on behalf of LPL with respect to services provided under this program. 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 individual retirement accounts. PTC also provides personal trustee services to clients for a variety of administrative fiduciary service, 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 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-MWP 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 IARs. The code of ethics permits LPL employees and IARs to invest for their own personal accounts in the same A11 – R – 0326 LPL Financial, member FINRA/SIPC 19  Model Wealth Portfolios (MWP) Program Form Brochure is available to clients or prospective clients upon request and 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 addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. 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 is available at LPL code of ethics lpl.com/disclosures.html. Participation or Interest in Client Transactions Purchases of mutual fund shares may be processed through the firm’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 the firm’s use of a proprietary account. LPL does not otherwise engage in principal transactions with its clients in MWP. LPL Financial Holdings Inc., is a publicly traded company. Third-party Portfolio Strategists are not prevented from purchasing LPL Financial Holdings Inc. stock in MWP accounts. In addition, a model may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in MWP charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds (other than the Sweep Funds) will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of MWP clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of MWP client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by MWP clients in the fund (up to $25 per position). 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. Portfolio Strategists pay LPL initial diligence and setup fees of up to $5,000 per strategy or model portfolio and up to a yearly A11 – R – 0326 LPL Financial, member FINRA/SIPC 20  Model Wealth Portfolios (MWP) Program Form Brochure $5,000 per strategy fee for annual due diligence reviews and maintenance to make their services available in the Program. 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 $15,000 per fund for complex exchange-traded products 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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with Advisor or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (sponsors) of mutual funds and ETFs that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL representatives so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds (other than the Sweep Funds) consists of flat and/or asset based fees totaling up to 0.15% annually of LPL clients’ investments in the investment product, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective financial professionals to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for A11 – R – 0326 LPL Financial, member FINRA/SIPC 21  Model Wealth Portfolios (MWP) Program Form Brochure which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the Advisor who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds (other than the Sweep Funds), and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with Advisors or third party Portfolio Strategists, and therefore, there is no financial incentive for an Advisor or a third party Portfolio Strategist to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments with Advisor or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisor and 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. 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 A11 – R – 0326 LPL Financial, member FINRA/SIPC 22  Model Wealth Portfolios (MWP) Program Form Brochure rates for ICA and DCA, or contact your 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. • 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. • 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 A11 – R – 0326 LPL Financial, member FINRA/SIPC 23  Model Wealth Portfolios (MWP) Program Form Brochure 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 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 the 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 the 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 the Sweep Funds. However, the compensation LPL receives on ICA, DCA and Sweep Funds is retained by LPL and is not shared with Portfolio Strategists or Advisors. In addition, LPL does not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. A11 – R – 0326 LPL Financial, member FINRA/SIPC 24  Model Wealth Portfolios (MWP) Program Form Brochure Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 Advisor of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL as a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with Advisor, and therefore, Advisor does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with Advisors, and therefore, an Advisor has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your Advisor’s compensation on the SCA product is reduced if your interest rate is discounted, so your Advisor has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your I Advisor receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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, or alternatively, could incentivize Advisor to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. A11 – R – 0326 LPL Financial, member FINRA/SIPC 25  Model Wealth Portfolios (MWP) Program Form Brochure 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. 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. Client Referrals and Other Compensation LPL and LPL employees receive additional compensation, business entertainment and gifts from product sponsors, such as an unaffiliated Portfolio Strategist. Such compensation may not be tied to the sales of any products or services. Compensation may include 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, 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 from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL employees provide sales support resources to Advisor if using LPL advisory programs. The compensation that LPL pays to these employees varies based on the assets in LPL’s different advisory programs. These sales employees have an incentive to promote MWP 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. 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. In the event a trade error occurs in an 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. LPL and BlackRock Advisors, LLC (BlackRock) entered into an agreement pursuant to which BlackRock agreed to pay LPL an annual a fixed amount for analytical data pertaining to BlackRock proprietary ETFs on LPL’s platform during A11 – R – 0326 LPL Financial, member FINRA/SIPC 26  Model Wealth Portfolios (MWP) Program Form Brochure the term of the agreement. BlackRock Investment Management, LLC, an affiliate of BlackRock, is one of the Portfolio Strategists available on the program. BlackRock is also affiliated with mutual funds and ETFs that may be included in the Portfolios it designs and those model portfolios designed by LPL or the other Portfolio Strategists. Because LPL benefits from these payments, the amount of which is significant, LPL’s financial interests conflict with its ability to use strictly objective factors in making the selection and retention of a BlackRock affiliate as a Portfolio Strategist and its selection of ETFs in its Portfolios. However, LPL did not agree to guarantee that BlackRock’s affiliated Portfolios will be used for any MWP client account. In addition, neither LPL nor the other Portfolio Strategists are required to include BlackRock-affiliated funds or ETFs in their Portfolios. The BlackRock affiliate is required to satisfy the same review as all other third party Portfolio Strategists. LPL has sole discretion to select Portfolio Strategists that are made available on MWP. 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 adviser representatives. In particular, LPL pays additional compensation to Advisor or its IARs by providing, for example: • payments based on production • 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 • payments in connection with the transition of Advisor’s business from another firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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. 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 A11 – R – 0326 LPL Financial, member FINRA/SIPC 27  Model Wealth Portfolios (MWP) Program Form Brochure 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 MWP than other programs or services. In such cases, Advisor has a financial incentive to recommend advisory services in MWP 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 MWP 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 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 A11 – R – 0326 LPL Financial, member FINRA/SIPC 28  Model Wealth Portfolios (MWP) Program Form Brochure 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 IARs of third-party RIA Firms. Clients should ask their IAR 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 MWP 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 MWP, LPL requires that clients direct LPL as broker-dealer to execute transactions in the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. The fact that LPL is both the investment advisor and 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission or transaction charge for executing transactions in MWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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 to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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. Subadvisers who have discretion to trade fixed income Portfolios for clients may choose to place some or all trades for accounts with broker-dealer firms other than LPL (“trade away” or “step out”). This practice may enable a Subadviser to obtain more favorable execution, including a more advantageous net price, than would otherwise be available. If a Subadviser chooses to execute a transaction through a broker-dealer other than LPL, the execution price will usually include fees or expenses imposed by the executing broker-dealer, which the client will bear, in addition to the account fee paid to LPL. The additional expenses charged by the broker-dealer executing the transaction include mark-ups, mark-downs or “spreads” paid to the executing broker dealer firm, which are typically embedded in the purchase or sale price of such transactions, and not separately indicated on trade confirmations and custodial account statements provided by LPL. In evaluating whether to execute a trade through a broker-dealer other than LPL, a Subadviser will consider the fact that an account will not be charged additional trading expenses if effected directly through LPL. Clients should understand that LPL is not able to fully evaluate whether a Subadviser is meeting its best execution obligations to clients for specific transactions when trading away, as it is not a party to trading away transactions and is not in a position to negotiate the price or transaction related charges with the executing broker. The A11 – R – 0326 LPL Financial, member FINRA/SIPC 29  Model Wealth Portfolios (MWP) Program Form Brochure responsibility to determine whether to trade away lies with the Subadviser and is subject to the Subadviser’s fiduciary duty to clients. 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 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, 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 or contact the Advisor. A11 – R – 0326 LPL Financial, member FINRA/SIPC 30 

Optimum Market Portfolios (OMP) Program Form Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. 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. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non- purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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.......................................................................................................................................................... 2 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 ..................................................................................................................... 9 Item 9: Additional Information ................................................................................................................................................. 9 A12 – R – 0326 LPL Financial, member FINRA/SIPC 1  Optimum Market Portfolios (OMP) Program Form 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 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 Research 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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 2  Optimum Market Portfolios (OMP) Program Form Brochure 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 Account 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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 3  Optimum Market Portfolios (OMP) Program Form Brochure 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. 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 • 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: – type and size of the account – 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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 4  Optimum Market Portfolios (OMP) Program Form Brochure 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 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 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. • 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 Research. 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 Research 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. • 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. A12 – R – 0326 LPL Financial, member FINRA/SIPC 5  Optimum Market Portfolios (OMP) Program Form Brochure • 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 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. • 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. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their Advisor of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, Advisor will 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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 6  Optimum Market Portfolios (OMP) Program Form Brochure account. Unless an 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. While an 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long-term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.”” • 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, A12 – R – 0326 LPL Financial, member FINRA/SIPC 7  Optimum Market Portfolios (OMP) Program Form Brochure 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 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. 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. A12 – R – 0326 LPL Financial, member FINRA/SIPC 8  Optimum Market Portfolios (OMP) Program Form Brochure 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: A12 – R – 0326 LPL Financial, member FINRA/SIPC 9  Optimum Market Portfolios (OMP) Program Form Brochure • 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, 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). A12 – R – 0326 LPL Financial, member FINRA/SIPC 10  Optimum Market Portfolios (OMP) Program Form 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). 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. 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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 11  Optimum Market Portfolios (OMP) Program Form Brochure 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 Research 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 Research. In addition, employees in LPL Research 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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 12  Optimum Market Portfolios (OMP) Program Form Brochure 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 IARs 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. A12 – R – 0326 LPL Financial, member FINRA/SIPC 13  Optimum Market Portfolios (OMP) Program Form 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 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. • 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. • 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, A12 – R – 0326 LPL Financial, member FINRA/SIPC 14  Optimum Market Portfolios (OMP) Program Form Brochure 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. 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. • 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. LPL’s money market mutual fund sweep option automatically sweeps otherwise uninvested cash balances held in the account and invests them 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. The compensation that LPL receives related to ICA, DCA (including from 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, 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. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other, A12 – R – 0326 LPL Financial, member FINRA/SIPC 15  Optimum Market Portfolios (OMP) Program Form Brochure potentially more favorable, financing arrangements. If a client obtains a loan from a non-partner bank, they should notify Advisor of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with Advisor, and therefore, Advisor does not have a financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with Advisor, and therefore, an Advisor has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your Advisor’s compensation on the SCA product is reduced if your interest rate is discounted, so your Advisor has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your Advisor receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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, or alternatively, could incentivize the Advisor to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 16  Optimum Market Portfolios (OMP) Program Form Brochure 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 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 from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 17  Optimum Market Portfolios (OMP) Program Form Brochure • 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 • payments in connection with the transition of Advisor’s business from another firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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. 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, A12 – R – 0326 LPL Financial, member FINRA/SIPC 18  Optimum Market Portfolios (OMP) Program Form Brochure 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 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 IARs of third-party RIA Firms. Clients should ask their IAR 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 A12 – R – 0326 LPL Financial, member FINRA/SIPC 19  Optimum Market Portfolios (OMP) Program Form Brochure 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 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. A12 – R – 0326 LPL Financial, member FINRA/SIPC 20 

Personal Wealth Portfolios (PWP) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 If you have any questions about the contents of This wrap program brochure provides information about the qualifications and business practices of LPL Financial (LPL). 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 6 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 6 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 15 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 15 Item 9: Additional Information ............................................................................................................................................... 15 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 1  Personal Wealth Portfolios Program Brochure Item 4: 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 Personal Wealth Portfolios (PWP) program when offered through an Advisor. For more information about LPL’s advisory services and programs other than PWP, 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 PWP program is a unified managed account program in which LPL and Advisor provide ongoing investment advice and management. In PWP, clients invest in asset allocation portfolios (Portfolios) designed by LPL’s Research Department (LPL Research), which include a combination of mutual funds, exchange-traded funds (ETFs) and investment models (Models) provided to LPL by third party money managers (PWP Advisors). The Models typically consist of equity and fixed income securities, but may include investment company securities. LPL Research selects the mutual funds, ETFs and Models to be made available in a Portfolio. 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, or client with the assistance of the Advisor, selects a Portfolio based on client’s investment objective and then selects among the mutual funds, ETFs and/or Models available in the Portfolio. If client authorizes Advisor to take discretion to make such selections on client’s behalf, the discretionary authority will be set out in the Account Agreement and Application signed by the client. LPL has discretionary authority to purchase and sell securities in the account. The client authorizes LPL to take discretion by executing the Account Agreement and Application. LPL acts as the overlay portfolio manager (OPM) in coordinating the trades among the various securities and sleeves of a PWP account. After a PWP account is opened, and upon deposit of funds by the client, LPL will invest the client’s funds based on the Portfolio selected. It generally will take up to 5 business days from the date the account is fully funded for all assets to be fully allocated across the Portfolio. In certain cases, it may take longer to allocate assets to fixed income securities because of market conditions or the illiquid nature of certain issues. In the case of municipal security Models (“Muni Models”), it typically can take between 30 to 90 days for the Model to be fully invested. Subsequent deposits accumulate and will not be invested in the Portfolio until certain conditions are met, including conditions related to trade size and position deviation from the target allocation. All recommendations by LPL regarding accounts in the PWP program will be in an advisory capacity. During the normal course of business, LPL reviews accounts on a daily basis and executes trades as needed. In addition, each year on the anniversary date of the initial account asset allocation, LPL will examine if any particular asset class in an account has drifted beyond a tolerance limit and determine if the account should be rebalanced to be within acceptable asset allocation tolerances. Except as described below for Muni Models, the role of the PWP Advisors is limited to submitting Models to LPL, who has discretion as OPM for trade execution. However, if a Portfolio is selected that includes a Muni Model, the PWP Advisor for that Model will have discretionary trading authority with respect to the purchase and sale of fixed income securities for the portion of the account invested according to the Muni Model (“Muni Sleeve”). Although the PWP Advisor has discretion over the Muni Sleeve, LPL has ultimate discretion over the entire account and may exercise discretion over securities in the Muni Sleeve (e.g., to rebalance the Account or to liquidate securities for withdrawal requests). LPL may appoint from time to time other PWP Advisors to take discretion over a portion of the account managed according to that PWP Advisor’s Model. 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. AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 2  Personal Wealth Portfolios Program Brochure Fee Schedule Clients in the PWP program pay LPL an annualized fee (the “Account Fee”). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the Advisor changes the PWP Advisor, investment strategy, or model portfolio selected for an account, or if the investment value of the account changes, the overall Account Fee may increase or decrease. 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, IARs and PWP Advisors do not charge performance-based fees to accounts in the PWP program. Advisory Fee. The Advisory Fee is charged for the investment advisory services of Advisor, as well as the investment advisory, administrative, trading, custodial and clearing services of LPL. The Advisory Fee is shared with Advisor. The Advisory Fee is negotiable between the client and the Advisor and is based on the value of assets in the account, including cash holdings, and is payable quarterly in advance. The maximum Advisory Fee is 2.35%. LPL retains a portion of the Advisory Fee, up to 0.675% of the value of the account for its administrative, custody and clearing services, and the portfolio design services of LPL Research. LPL shares up to 100% (typically between 90% and 100%) of the remaining portion of the Advisory Fee with the Advisor based on the agreement between LPL and the Advisor. LPL retains any portion of the Advisory Fee not shared with the Advisor. Manager Fee. Depending on the PWP Advisor selected, clients pay a Manager Fee for a PWP Advisor that is set by the PWP Advisor. The Manager Fee will differ depending on the PWP Advisor selected for the Account and may also differ depending on which investment strategy or model portfolio is selected. Clients do not pay LPL or Advisor brokerage commissions or transaction charges for the execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” The Manager Fee is based on the value of the assets in the Portfolio advised by the PWP Advisor, including cash holdings, and payable quarterly in advance. The Manager Fee currently ranges from 0.15% to 0.60%. For certain models designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL retains portions of the Manager Fee for trading services, there is a conflict of interest for us to recommend such models. The Advisor does not receive any portion of the Manager Fee, including based on recommending a model for which LPL retains this compensation. Please note that if the Account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. The fees paid by LPL to PWP Advisors in the program out of the Manager Fee are generally less than a PWP Advisor would charge a client seeking to establish a direct relationship outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, trading and marketing expenses that would otherwise be borne by the PWP Advisor and the role of the PWP Advisor is generally limited to providing models to LPL. PWP Advisors generally have higher minimum account size requirements when managing direct accounts and higher fees when the PWP Advisor bears those expenses. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a PWP account from the account. LPL pays the applicable portion of the Account Fee to the PWP Advisors whose models are selected for 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 3  Personal Wealth Portfolios Program Brochure 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 Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that may apply to a PWP 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. Clients do not pay LPL brokerage commissions, markups or transaction charges for execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL that apply to investments in PWP accounts. Some of these fees and charges are described below. In PWP, assets may be invested in mutual funds or ETFs 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 fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that may vary depending on the performance of the fund. Client also will pay the Account Fee with respect to assets invested in ETFs and mutual funds. The mutual funds and ETFs available in the program 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, the PWP Advisors and Advisor, and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” If client transfers into a PWP 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 PWP model. 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. When transferring securities into a PWP account, client should be aware that certain securities may 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. AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 4  Personal Wealth Portfolios Program Brochure 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 a PWP 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 Advisor 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. For those Portfolios consisting of mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in PWP charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds (other than the cash sweep money market funds (“Sweep Funds”) described in the section of Item 9 labeled “Participation or Interest in Client Transactions”) will be credited to the client’s account. Certain of the mutual funds available for investment in the program may be affiliated with Advisor. Therefore, investment in an affiliated mutual fund generates additional compensation to the Advisor’s affiliates, including, among other types of compensation, fund-level management fees. A PWP Advisor available in the program may be affiliated with an Advisor. As a consequence, selection of an affiliated PWP Advisor generates additional compensation to Advisor’s affiliates. As described below under “Additional Information – Brokerage Practices,” if a PWP Advisor for a Muni Model chooses to execute a transaction through a broker-dealer other than LPL, the execution price to the client may include a commission, markup/markdown, or other fee imposed by the executing broker-dealer in addition to the Account Fee. If client holds an American Depositary Receipt (“ADR”) in an account, there may be custodial fees or taxes related to the ADR. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Wrap Fees on a PWP Account: • The Account Fee is an ongoing fee for investment advisory services, the execution of transactions and other administrative and custodial services. The Account Fee may cost the client more than purchasing the program services separately, for example, paying a separate advisory fee for each of the services of LPL, Advisor and the PWP Advisor, 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: – type and size of the account – type and number of securities in the Portfolio (whether equities, fixed income securities, mutual funds or ETFs) – 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 5  Personal Wealth Portfolios Program Brochure for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, and the 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 Advisory Fee with Advisor. • 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. For example, LPL may pay additional compensation to Advisor by providing reimbursement of administrative servicing fees that Advisor pays to LPL, free or reduced-cost marketing materials, payments in connection with the transition of Advisor’s business from another firm to LPL, or attendance at LPL’s conferences or events. LPL may pay this compensation based on the Advisor’s overall business production and/or on the amount of assets serviced in LPL advisory programs. Therefore, the amount of this compensation may be more than what Advisor 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 can have a financial incentive to recommend a program account over other programs and services. • Some of the investment products available to be purchased in the program can be purchased by clients outside of a PWP account, through broker-dealers or other investment firms not affiliated with 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 $250,000. In certain instances, LPL will permit a lower minimum account size. An account will not be invested according to the Portfolio until the minimum account size and the targeted funding value of the account 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 ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. Item 6: Portfolio Manager Selection and Evaluation In PWP, LPL and Advisor are responsible for the overall investment advice and management services 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. LPL makes available Models designed by PWP Advisors. LPL selects and reviews on an ongoing basis the PWP Advisors available on PWP based on quantitative, qualitative and infrastructure criteria, which may include: Quantitative Criteria LPL evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style group, including but not limited to: • Rate of return • Consistency of returns and risk AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 6  Personal Wealth Portfolios Program Brochure • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP Advisor can handle operational requirements including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable • Back office review • Client servicing resources • Firm-wide program commitment LPL reviews PWP Advisors currently participating in the program and reviews new PWP Advisors prior to the addition of their Models to the program. LPL may elect to remove a PWP Advisor should it determine that the PWP Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in management staff). In making a decision to remove a PWP Advisor, LPL Research takes into consideration all criteria; no one criteria is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove a PWP Advisor. PWP Advisor Performance LPL Research uses information provided by the PWP Advisor and also may use independent, third party databases when evaluating a PWP Advisor. In order for a PWP Advisor to be selected for the program, LPL generally requires a third party verification letter related to compliance of the PWP Advisor’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performance. However, LPL provides Advisor, and clients, if so directed by Advisor, with individual performance information. Performance information is prepared by LPL using portfolio accounting and reporting software. Client performance information is calculated on a uniform and consistent basis using a time weighted basis. It is important to note that PWP Advisors provide Models to LPL, and, except in the case of Muni Models, LPL is the party with discretion for trade implementation and execution in PWP accounts. Therefore, Models submitted to LPL by PWP Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisor. Because of this fact and because LPL (and not the PWP Advisor) has discretionary authority to implement trades, performance of a PWP account will differ from the performance of PWP Advisor’s discretionary accounts. AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 7  Personal Wealth Portfolios Program Brochure LPL Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL Research. LPL Research provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap programs, Manager Select and Manager Access Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The Advisor, or the client with the assistance of Advisor, selects the Portfolio and provides advice based on the client’s individual needs. LPL Research uses various investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL Research determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the Advisor of the change in status and provide alternatives for the account from which the Advisor, or the client with the assistance of the Advisor, will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. Types of Investments and Risks The Portfolios may include different types of securities, such as mutual funds, closed end funds, ETFs, ETNs, and equity and fixed income securities. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • 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. AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 8  Personal Wealth Portfolios Program Brochure • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or unit investment trusts. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 9  Personal Wealth Portfolios Program Brochure varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Closed-End Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax-managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 10  Personal Wealth Portfolios Program Brochure benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products ("ETPs”). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), futures-linked ETPs (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the- counter markets and may not be afforded all of the investor protections of other ETPs. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their Advisor of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non-partner banks, clients borrow from the bank and pay interest to the bank. In some cases, Advisor will 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 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. While an 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 11  Personal Wealth Portfolios Program Brochure as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long-term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 12  Personal Wealth Portfolios Program Brochure 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. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and Advisor generally will earn more compensation for selling one investment product than another. As a result, LPL and Advisor have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. LPL’s Overlay Portfolio Management Services As OPM, LPL provides advisory services tailored to the individual needs of the clients. LPL reviews accounts on a daily basis for rebalancing. LPL accommodates reasonable requests to restrict holdings of specific securities, specific industries, specific sectors, and certain pre-defined categories (e.g., “sin” stocks). In the event that client restrictions prevent the investment in certain securities otherwise recommended by a PWP Advisor, assets will be invested pro- rata across the remaining securities in the Model. Such restrictions do not apply to any mutual funds, ETFs or fixed- income securities that may be held in the account. Restrictions placed on an account may affect the performance of the account. The OPM may choose not to accept an account with restrictions that are inconsistent with the investments chosen by the OPM or as recommended by the PWP Advisor. AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 13  Personal Wealth Portfolios Program Brochure LPL accommodates requests to perform tax harvesting, which may include using the proceeds of tax-related transactions to purchase appropriate securities (such as ETFs) for an account. In such case, proceeds of tax-related transactions may be held in cash or securities until appropriate wash sale periods have expired. Once the wash sale period has expired, the related proceeds will be invested according to the Portfolio selected. Similarly, LPL may delay a tax harvesting request to sell securities acquired in the previous 30 days until the wash sale period has expired. In certain circumstances, LPL also accommodates requests for all or a portion of the account to remain allocated to cash for a period of time. After the expiration of that time period, LPL will reinvest the Account according to the model portfolio selected. Such customized requests and changes to and withdrawals from the Portfolios selected may take up to 5 days to process, and, in certain circumstances, may take longer. As LPL generally has discretion to implement a Model, an account’s holdings may differ from the Model submitted. For example, LPL may limit small trades (defined by minimum dollar amounts, share amounts, percentage of account, or percentage of individual asset class). In addition, due to market conditions or the illiquid nature of certain issues, there may be times when LPL will not be able to invest in specific taxable fixed income securities that appear in a Model. In those circumstances LPL will attempt to invest in fixed income securities with similar characteristics as those in the Models. For clients in California and New York, if tax-free fixed income securities are selected for a Muni Model, the PWP Advisor will attempt to limit the fixed income securities purchased to state-specific, tax free fixed income securities; however, the PWP Advisor may also include non-state-specific securities. Voting Client Securities Unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures to in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. A copy of LPL’s proxy voting policies is available upon request to LPL through Advisor. A client may obtain information about how LPL voted with respect to securities held in the client’s account by contacting LPL through 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of the PWP Advisors without reviewing individual client interests, unless LPL determines that such instructions are overtly contrary to our client’s best interest. In such case, LPL will determine whether or how to act consistent with the best interests of our clients. LPL, Advisor and the PWP Advisors are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the account, or the issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the account. AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 14  Personal Wealth 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 an appropriate investment objective 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. Because the PWP Advisor’s role generally is limited to providing Models to LPL, and the PWP Advisor does not provide individualized discretionary advisory services to PWP clients, LPL generally does not communicate specific client information to PWP Advisors. However, in the case of PWP Advisors for the Muni Models, the PWP Advisor does provide individualized discretionary advisory services with respect to the Muni Sleeve. If a Muni Model is selected, LPL forwards client information from the Account Application to the PWP Advisor. If client communicates to the Advisor regarding material changes in the client’s financial circumstances, investment objectives or investment restrictions, such information is forwarded to the PWP Advisor for the Muni Model. Clients may communicate such information to the Advisor or otherwise communicate directly with the PWP Advisor, although clients are encouraged to direct communication through their Advisor. 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 client’s ability to contact and consult with Advisors. Because the PWP Advisor’s role generally is limited to providing Models to LPL, and the PWP Advisor does not provide individualized discretionary advisory services to PWP clients, PWP Advisors generally are not available to be contacted or consulted by PWP clients. However, in the case of PWP Advisors for the Muni Models, the PWP Advisor does provide individualized discretionary advisory services with respect to the Muni Sleeve. If a Muni Model is selected, clients may consult directly with the PWP Advisor, although clients are encouraged to direct contact with the PWP Advisor through OPM or their Advisor. 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 15  Personal Wealth Portfolios Program Brochure 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 was 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 16  Personal Wealth Portfolios Program Brochure 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, 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). • 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 17  Personal Wealth Portfolios Program Brochure 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). 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 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 this program. 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-PWP 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 18  Personal Wealth Portfolios Program Brochure security on or about the same time as trading by a client can disadvantage the client. LPL addresses this conflict of interest by requiring in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL has procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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 Holdings Inc., is a publicly traded company. PWP advisors are not prevented from purchasing LPL Financial Holdings Inc. stock in PWP accounts. In addition, a PWP account may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in PWP charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds (other than the Sweep Funds) will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of PWP clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of PWP client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by PWP clients in the fund (up to $25 per position). 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 ETPs, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per product and up to $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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 19  Personal Wealth Portfolios Program Brochure $15,000 as a sponsor level due diligence fee and a setup fee of $7,500 per fund. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with Advisor or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL representatives so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds (other than the Sweep Funds) consists of flat and/or asset based fees totaling up to 0.15% annually, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 20  Personal Wealth Portfolios Program Brochure these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with the Advisor who selects or recommends the investment products for client accounts. The revenue that LPL receives from LPL’s receipt of 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds (other than the Sweep Funds), and therefore, LPL does not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with Advisors or PWP Advisors, and therefore, there is no financial incentive for an Advisor or a PWP Advisor to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments with Advisor or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisor and 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. 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 IARs 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 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 21  Personal Wealth Portfolios Program Brochure 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. 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. 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 22  Personal Wealth Portfolios Program Brochure DCA as the sole service option for certain account types, in part because of the additional compensation LPL earns from the use of DCA. • 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. LPL’s money market mutual fund sweep option automatically sweeps otherwise uninvested cash balances held in the account and invests them 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. The compensation that LPL receives related to the ICA, DCA (including from any 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, 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 Funds. However, the compensation LPL receives on ICA, DCA and Sweep Funds is retained by LPL and is not shared with Advisors. LPL Research does not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s program, and can work directly with non-partner 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 Advisor of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 23  Personal Wealth Portfolios Program Brochure documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with Advisor, and therefore, Advisor does not have a direct financial incentive if one bank is selected over another. For the SCA product, LPL does share compensation with its Advisor, and therefore, an Advisor has a financial incentive for clients specifically to choose the SCA product over any partner or non-partner bank loan. Your Advisor’s compensation on the SCA product is reduced if your interest rate is discounted, so your Advisor has an incentive not to request your interest rate be discounted below a certain level or at all. Neither LPL nor your Advisor receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance call. This presents 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, or alternatively, could incentivize the Advisor to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. In addition, LPL sends 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 PWP Advisors reimburse LPL for costs associated with the use of technology necessary for a PWP Advisor to perform its services under the program. LPL and LPL employees also receive additional compensation from product sponsors, such AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 24  Personal Wealth Portfolios Program Brochure as a PWP Advisor. Such compensation may not be tied to the sales of any products or services. Compensation may include 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 receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to Advisor and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to Advisor and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. Advisor and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. 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 sales employees have an incentive to promote PWP to Advisor over other advisory programs. These employees also earn more compensation when Advisors transition client assets from brokerage accounts to advisory accounts, and have a financial incentive to encourage Advisors 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 balance. In such cases, LPL receives compensation in the form of earnings on cash. LPL does not share this compensation with Advisor. 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 may pay additional compensation to Advisor or its IARs by providing, for example: • payments based on production • • 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 25  Personal Wealth Portfolios Program Brochure free or reduced-cost marketing materials • • payments in connection with the transition of Advisor’s business from another firm to LPL • advances of advisory fees • payments in the form of repayable or forgivable loans • 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. 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 PWP than other programs or services. In such cases, Advisor has a financial incentive to recommend advisory services in PWP 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 PWP 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 is 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 AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 26  Personal Wealth Portfolios Program Brochure 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 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 IARs of third-party RIA Firms. Clients should ask their IAR 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 PWP 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 PWP, LPL requires that clients direct LPL as broker-dealer to execute transactions in the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. The fact that LPL is both the investment advisor and 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission for executing transactions in PWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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. AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 27  Personal Wealth Portfolios Program Brochure 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. If a Portfolio is selected that includes a Muni Model, the PWP Advisor will have discretion to purchase and sell securities in the Muni Sleeve of the account. In connection with its duty to seek to achieve best execution, the PWP Adviser may choose to execute transactions through a broker-dealer other than LPL. In such case, the execution price may include a commission, markup or markdown, or other charges in addition to the Account Fee. Clients should read and understand the brokerage practices and other disclosures in the Firm Brochure of the PWP Advisor for the Muni Model. LPL will aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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. 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, 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, client should contact the Advisor. AP – PWP – R – 0326 LPL Financial, member FINRA/SIPC 28 

Guided Wealth Portfolios (GWP) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. Item 9 was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 8 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 9 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 14 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 14 Item 9: Additional Information ............................................................................................................................................... 14 GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 1  Guided Wealth Portfolios Program Brochure 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, an advisor-enhanced digital advice program, advisory programs offered by affiliated and unaffiliated investment advisor 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 the advisory services offered under LPL’s Guided Wealth Portfolios (GWP) program (Program) when offered through LPLE. In instances where programs are managed by affiliates, such as this Program, affiliates are compensated for performing 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 GWP, please contact LPL or LPLE, respectively, for a copy of a similar brochure that describes such services or program or go to https://adviserinfo.sec.gov/. LPL’s advisory services are made available to clients primarily through individuals associated with LPL or LPLE as investment adviser representatives (IARs). For more information about the IAR providing advisory services, client should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time client engages the IAR. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPLE at lplenterprise.adv@lplfinancial.com. 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. 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 services the client’s investment needs and goals. All recommendations regarding advisory accounts will be in an advisory capacity, and any recommendation 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. For more information about LPL’s or LPLE’s advisory services and programs other than GWP, please contact your IAR or LPLE, respectively for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov/. LPLE is a broker-dealer registered with the Financial Industry Regulatory Authority (FINRA), and your IAR 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 a client opens with LPL 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 LPL. Not all LPL IARs have access to all products and services. In addition, as described below, the Program is made available through a web-based portal, and communications concerning the Program are intended to occur primarily through electronic means (including but not limited to, through email communications or through such portal), although an IAR of LPLE will be available to discuss investment strategies, objectives, or the account in general in person or via telephone. Therefore, the Program differs from more traditional advisory relationships in which an IAR has more frequent personal interactions with a client. Potential clients should consider whether GWP will provide the type of advisory relationship they desire. The Program offers clients the ability to participate in a centrally managed investment program, which is made available to users and clients through a web-based, interactive account management portal (the “Portal”). Clients are required to maintain an active profile in the Portal to participate in the Program. The Program generates investment recommendations based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 2  Guided Wealth Portfolios Program Brochure A preview of the Program (the “Prospect Tool”) is provided to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL by opening a GWP account. The Prospect Tool and features of a GWP account are described in more detail below. Users of the Prospect Tool are not considered to be advisory clients of LPL, LPLE or the IAR, do not enter into an advisory agreement with LPL, LPLE or the IAR, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. IARs may, in their sole discretion and as agreed from time to time with clients, provide financial planning or financial consulting services on behalf of LPLE to clients in connection with the program at no additional cost. IARs may also require clients to enter into a separate agreement with LPLE 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. LPL and LPLE each reserve the right to accept or reject this Agreement in its sole discretion and for any reason. Features of the Prospect Tool Prospective clients that use the Prospect Tool (each, a “user”) agree to a terms of use (Terms of Use) and complete an investor profile. Users must select from one of the following goals for each account: retirement (Retirement Goal), major purchase (Major Purchase Goal), or general investing (Build Wealth Goal). Based on the investor profile completed, the Prospect Tool generates sample asset allocation recommendations (Sample Recommendations). The Prospect Tool provides Sample Recommendations that may assist users in determining whether to open a GWP Account. The Prospect Tool is intended to be used for educational and informational purposes only. The Prospect Tool does not provide comprehensive financial planning and is not intended to constitute legal, financial or tax advice. To use the Prospect Tool, users are responsible for providing information about, among other things, their goals, age, risk tolerance, and investment horizon. The Prospect Tool is only one of many tools that users may use as part of a comprehensive investment analysis process. Users should not rely on the Prospect Tool as the sole basis for investment decisions. Alternatively, the IAR can directly open a GWP account for a client without requiring a client to first use the Prospect tool. Although LPL and LPLE are investment advisers and broker-dealers registered with the SEC and members of the Financial Industry Regulatory Authority, the Prospect Tool does not establish an investment advisory contract or relationship between you and LPL, LPLE or IAR. The scope of any investment advisory relationship with LPL and LPLE begins when complete an Account Application, enter into an account agreement (the “Account Agreement”) with LPLE, LPL and IAR . The output that users receive by using the Prospect Tool, including the Sample Recommendations, may differ materially from the advice users would receive as an advisory client of LPL or LPLE. LPL and LPLE do not provide ongoing investment management or trading services for assets of users of the Prospect Tool, does not make any determination as to whether the website through which the Program is accessed or the Prospect Tool is appropriate for any user, cannot access any assets in any accounts of users, does not place any trades on behalf of users of the Prospect Tool, and does not provide ongoing supervision of assets of users of the Prospect Tool. Features of a GWP Account Investors that open a GWP account (“clients” and each, a “client”) complete an Account Application and enter into the Account Agreement with LPL, LPLE and IAR. As part of the account opening process, clients are responsible for providing complete and accurate information regarding, among other things, their goal for the account, age, risk tolerance, and investment horizon (collectively, “Client Profile”). LPL, LPLE and IAR rely on the information in the Client Profile in order to provide services under the Program, including but not limited to, determination of suitability of the Program for clients. Based on the Client Profile, the IAR selects an appropriate investment allocation track (Investment Allocation Track) and model portfolio (Model Portfolio) for a client. LPLE, through the IAR, is required to review and accept the account, including the Investment Allocation Track and Model Portfolio, prior to account opening. The GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 3  Guided Wealth Portfolios Program Brochure Model Portfolios have been designed and are maintained by LPL Research (the “Portfolio Strategist”) and include a list of exchange-traded funds (ETFs) holdings and may in the future include open-end mutual funds (Mutual Funds) holdings (collectively, “Program Securities”), and include relative weightings and a list of potential replacement securities for tax harvesting purposes. LPL Research currently serves as the sole Portfolio Strategist and does not charge a fee for its services. Only one Model Portfolio is permitted per account. As a client approaches the Retirement Age or the specified date of the major purchase, LPL will automatically adjust the client’s asset allocation annually based upon the client’s associated investment allocation track (described below under “LPL as Portfolio Strategist”). For the Major Purchase Goal, after reaching the specified date of the major purchase, LPL will automatically allocate up to 70% of the account to cash and cash equivalents, unless the client extends the timing for the major purchase. For the General Investing Goal, the client’s asset allocation generally remains static, subject to rebalancing and tax loss harvesting as described below. The Investment Allocation Track selected for the account seeks to achieve an overall investment objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time and may be inconsistent with other asset allocations suggested to client by LPL, LPLE or IAR prior to client entering into the Account Agreement. The Investment Allocation Tracks are designed as long-term goals for the account, and asset withdrawals may impair the achievement of client’s investment objectives. A Client Profile that includes a conservative Investment Allocation Track over a long-term investment horizon may result in the selection of riskier investments than would be selected based on the same conservative Investment Allocation Track but over a shorter-term investment horizon. Clients should contact LPLE through their IAR if they believe the Investment Allocation Track does not appropriately reflect the Client Profile. By executing the Account Agreement, clients authorize LPL to have discretion to buy and sell Program Securities in accordance with the Model Portfolio and to liquidate previously purchased non-model securities that are transferred into the account. Mutual Funds and ETFs that are not Program Securities or that are not included within the Model Portfolio selected for the client’s account will not be purchased for the account. LPL has full discretion to invest according to the Model Portfolio. LPL expects to closely track the Model Portfolios, applying discretion only to address particular account issues, including tax loss harvesting, short-term gain avoidance, cash inflows and outflows, and investment restrictions placed on the account. LPL may also deviate from the Model Portfolios in smaller accounts, in which it is not possible or impractical to be invested in all of a Model Portfolio’s holdings. In addition, uninvested cash may be invested in the Multi-Bank Insured Cash Account (ICA) or the Deposit Cash Account (DCA), as applicable, as described in the Account Agreement. Dividends paid by the Program Securities in the account will be contributed to the cash allocation and ultimately reinvested into the account based on the Model Portfolio once the tolerance within cash allocation is surpassed. Pursuant to the Account Agreement, client authorizes LPL to perform tax harvesting based on the guidelines LPL establishes for the Program, on a systematic and periodic basis. LPL will perform tax loss harvesting only when total account unrealized losses and individual positions available losses each exceed thresholds set by LPL for the Program. LPL will seek to re-invest proceeds from tax loss harvesting into a substitute Program Security for the 30-day period from the initial sale of the harvested security, but will hold such proceeds in cash if proceeds cannot be reinvested into a substitute Program Security. In implementing the Investment Allocation Track or processing client requests, including withdrawal requests, LPL may determine the securities for liquidation based in-part on avoiding short-term gain realization. During the term of the Account Agreement, LPL will perform a daily review of the account to determine if rebalancing is appropriate based on tolerance thresholds established by LPL. The account will be rebalanced following a rebalancing review if the Account has available cash for investment and at least one of the account positions, including cash, is outside LPL’s set tolerance thresholds, subject to a minimum transaction amount established by LPL. LPL will also perform an annual rebalancing of the Account if Account positions are outside of LPL’s set tolerance thresholds. In addition, LPL may review the account for rebalancing in the event that a Model Portfolio is changed. LPL may delay placing rebalancing transactions for non-qualified accounts by a number of days, to be determined by LPL, in an attempt to limit the tax treatment of realized short-term gains for any position being sold. In addition, trading in the GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 4  Guided Wealth Portfolios Program Brochure account at any given time is also subject to certain conditions, including but not limited to, conditions related to trade size, compliance tests, the target cash allocation and allocation tolerances. LPL, LPLE, the IAR, and clients cannot alter the rebalancing frequency. LPLE, through its IAR, is responsible on an ongoing basis as investment adviser and fiduciary for the client relationship, including for recommending the Program to the client; providing ongoing monitoring of the Program, the performance of client accounts, and the services of LPL; determining initial and ongoing suitability of the program for clients; reviewing clients’ suggested portfolio allocations; reviewing any change in Investment Allocation Track due to changes clients make to their Client Profile; answering questions regarding the Program, assisting with paperwork and administrative and operational details for accounts; and being available to clients to discuss investment strategies, changes in financial circumstances, objectives or accounts generally in person or via telephone. LPLE or the IAR may also recommend other suitable investment programs. Clients may make cash additions to an account and may withdraw account assets at any time, subject to meeting the required account minimum balance of $5,000 and certain other conditions described in the Account Agreement. Liquidation requests in connection with withdrawals, and changes to the Model Portfolio or Investment Allocation Track selected may take up to 5 business days to process, and, in certain circumstances, may take longer to allocate assets. Clients may also fund an account with previously purchased, non-model securities. Clients authorize LPL in the Account Agreement to liquidate previously purchased, non-model securities as soon as reasonably practicable. In some circumstances, LPL will take into consideration the tax implications of realized gain and loss exposure of liquidating previously purchased, non-model securities when effecting liquidations. The Program is designed as a long-term investment vehicle and asset withdrawals may impair the achievement of client’s investment objectives. LPL is appointed by each client as custodian of account assets and broker-dealer with respect to processing securities transactions for a GWP account. LPL also provides administrative services, such as performance reporting, to clients. LPL may aggregate transactions with other clients to improve the quality of execution. Fee Schedule Users of the Prospect Tool do not pay any fees or expenses. Clients that open a GWP account pay an annualized account fee (Account Fee). The Account Fee is made up of an Advisor Fee and an LPL Program Fee. LPL reserve the right to increase the upper limits of the Advisor Fee and/or LPL Program Fee range(s) upon 30 days’ prior notice to clients. No performance-based fees are charged to accounts in the Program. Advisor Fee. The Advisor Fee is charged for the investment advisory services of LPL, LPLE and IAR. The Advisor Fee is shared with LPLE and the IAR. The Advisor Fee is negotiable between the client and the IAR and is based on the value of assets in the account, including cash holdings. The maximum Advisor Fee is 1.00%. LPL shares between 90% and 100% of the Advisor Fee with the unaffiliated financial institution with which IAR is associated, or its affiliate, based on the agreement between LPLE and the financial institution. LPL Program Fee. Clients will pay a fee of 0.35% for the investment advisory, administrative, trading, custodial, and clearing services of LPL. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a GWP account from the account. LPL retains amounts described above under “Fee Schedule” for services provided and pays the applicable of the Advisor Fee to LPLE and unaffiliated financial institutions with whom LPLE has agreement as described herein. LPL calculates and deducts the Account Fee in the method described in the Account Agreement. Alternative payment methods that may be offered in other advisory platforms are not available in GWP. Payment in Advance and Refund of Pre-Paid Fees LPL deducts the Account Fee quarterly in advance. For purposes of calculating the quarterly Account Fee and providing performance information, the account quarter will begin on the first day of the month in which the account is accepted GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 5  Guided Wealth Portfolios Program Brochure by LPL and LPLE. The initial Account Fee is deducted at the end of the first quarter in which the account is accepted and will include the prorated amount for the initial quarter. Subsequent Account Fees will be assessed at the beginning of each quarter thereafter and will be based on the value of the account assets under management as of the close of business on the last business day of the preceding quarter (as valued by an independent pricing service, where available, or otherwise in good faith as reflected in Client’s account statement) and based on the fee rate in effect at the time of assessment. At the time of a subsequent Account Fee assessment, the Account Fee will be adjusted for deposits and withdrawals during the prior quarter pro -rata based on the asset value of the transaction and based on the fee rate in effect at the time of the assessment. If there is a change in the Account Fee rate negotiated between IAR and Client during the quarter, the effective date of any increase or decrease will be at the beginning of the next quarterly cycle. If the Account Agreement is terminated before the end of the quarterly period, LPL will pay the client a pro-rated 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, and re-registration of positions). Other Types of Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to a GWP 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 miscellaneous 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. These fees are subject to change at the discretion of LPL. Clients are notified of these charges and any changes through information provided with their periodic statements. These fees and charges shall continue until thirty (30) days after LPL has notified client in writing of any change in the amount of the fees or charges applicable to the account, at which time the new fees or charges will become effective unless client notifies LPL in writing that the account is to be closed. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL and LPLE that apply to investments in GWP accounts. Some of these fees and charges are described below. In GWP, assets are invested in Model Portfolios that currently are comprised of ETFs and may include mutual funds in the future, and, therefore, there are two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Clients will pay an advisory fee to the fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Clients will also pay LPL, LPLE and IAR the Account Fee with respect to assets invested in ETFs and mutual funds. The ETFs and mutual funds available in the Program can be purchased directly outside of the Program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL, LPLE and IAR and by making their own decisions regarding the investment. If client transfers into a GWP 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, recordkeeping fees and revenue sharing from the previously purchased mutual fund until the position is liquidated and subsequently invested according to the GWP model. 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 GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 6  Guided Wealth Portfolios Program Brochure the fees and expenses of an ETF or mutual fund in the fund’s prospectus, which is available upon request from LPL, or directly from the fund. When transferring securities into a GWP account, client should be aware that certain securities are not 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 previously purchased, non-model securities transferred into an account may have been subject to a commission or sales load when the security was originally purchased. If client has paid a commission on the purchase of a security in an LPL brokerage account within up to two years of the transfer of the security into the account, client may be entitled to a credit for a portion of the Account Fee. After transfer into a GWP account, client should understand that an advisory fee will be charged based on the total assets in the account, including the transferred securities. 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. In the future, for Model Portfolios consisting of mutual funds, LPL intends to select only no-load and load-waived mutual funds. In some cases, a mutual fund in GWP will charge shareholders an asset based sales charge or service fee (e.g., 12b-1 fee) that is paid to LPL. Any 12b-1 fees paid to LPL by mutual funds are credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on a GWP Account • The Account Fee is a wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. Clients do not pay a commission or transaction charge to LPL or LPLE for the execution of transactions in the account. 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: – type and size of the account – type of securities in the Model Portfolio (currently ETFs and possibly mutual funds in the future) – 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. Clients could generally pay a lower advisory fee for investment advisory services through other investment advisers, including algorithm-driven, automated (robo) providers. However, clients using other robo services will forgo opportunities to utilize LPL-constructed model portfolios or to work directly with a financial advisor. In addition, the Account Fee may be higher than fees charged by other advisors, particularly if the Advisor Fee component of GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 7  Guided Wealth Portfolios Program Brochure the Account Fee is at or near the maximum fee set out above. The IAR is responsible for determining the Advisor Fee to charge each client based on factors such as total amount of assets involved in the relationship and the 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 Advisor Fee with 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 can 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. • The investment products available to be purchased in the Program can be purchased by clients outside of a GWP account, through broker-dealers or other investment firms not affiliated with LPL or LPLE. • 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 The Program is available for individuals (individually or jointly with another person) and their traditional individual retirement accounts (IRAs), Roth IRAs, and owner-only Simplified Employer Pension IRAs where the only eligible participants of the SEP IRA are the business owners and their spouses. Employee benefit plans subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA) (ERISA Plans) (including SEP IRAs for employees other than business owners and their spouses) are not eligible to participate in the Program. Participation in the Program is subject to LPL’s and LPLE’s discretion, and LPL or LPLE may prohibit any person from participating for any reason or no reason at all. Use of the Prospect Tool is governed by the Terms of Use. For the avoidance of doubt, clients that open a GWP account be provided under and governed by the Account Agreement entered into at the time of enrollment. A GWP account is governed by the Account Agreement, which may be terminated by any party effective upon written notice to the other parties or by client calling the operational support desk, as set forth in the Account Agreement and as described below in the event certain minimums are not maintained. In the event that a client’s country of residence or citizenship status changes, such notification to LPL as required under the Account Agreement may result in termination of his or her account by LPL if LPL does not service accounts in the new jurisdiction. In addition, if a client revokes his or her consent to electronic delivery of communications, such revocation will be deemed to be a notice from the client to terminate his or her account. Promptly upon termination, accounts will be deactivated. In a deactivated account, no advisory fees are charged, and LPL, LPLE and IAR have no responsibility to provide ongoing investment advice. In order to open a GWP account, LPL requires a minimum value for a Program account to begin being managed. In certain instances, LPL will permit a lower minimum account value. Note that an account will not be invested according to a Model Portfolio until the applicable minimum for the Model Portfolio and allocation has been reached. If LPL and LPLE have not received all paperwork in good order within the timeframe required by LPL and LPLE from the day a client submits its Account Application, LPL or LPLE will discard the Account Application and terminate the account immediately. In addition, if the account has not reached the required minimum value within the timeframe required by LPL, LPL will terminate the account immediately. In the event client withdrawals cause the account asset value to fall GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 8  Guided Wealth Portfolios Program Brochure below required minimum for a period of 30 days, client understands that the account will be deactivated. In a deactivated account, no advisory fees are charged, and LPL, LPLE, and its IAR have no responsibility to provide ongoing investment advice. Withdrawals from the account may be made to the extent that the account value does not fall below the required minimum. Withdrawal requests for accounts with a value at the required minimum or less will result in account deactivation. Item 6: Portfolio Manager Selection and Evaluation In GWP, the client selects the IAR. 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 along with this Brochure at the time client opened the account. For more information about LPLE, clients should refer to LPLE’s Form ADV brochure or contact LPLE for more information. LPL makes available Model Portfolios designed by LPL in GWP. LPL has discretionary authority to implement trades in GWP. LPL as a Portfolio Strategist In GWP, clients invest in Model Portfolios designed by LPL Research. LPL Research provides various types of advisory services. LPL Research provides research recommendations on asset allocation and ETFs and mutual funds. LPL Research provides investment advice on ETF and mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios, Personal Wealth Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap program, Manager Select. Based upon a client’s risk tolerance as indicated in the Client Profile, the client is assigned an investment allocation track (currently conservative, moderate, or aggressive) for a Retirement Goal or a Major Purchase Goal, the purpose of which is to slowly rotate the client’s equity exposure allocation to fixed income exposure and cash over time. LPL Research created these tracks using academic research on optimal retirement allocations, the industry averages as calculated by Morningstar for the target date fund universe, and input from other third parties. Within the applicable allocation track and based upon either a client’s chosen Retirement Age in the Client Profile or the desired date of a major purchase, as applicable, the client will be assigned a Model Portfolio and one of five of LPL’s standard investment objectives: • Income with capital preservation. Designed as a longer term accumulation account, this investment objective is considered generally the most conservative. Emphasis is placed on generation of current income with minimal risk of capital loss. Lowering the risk generally means lowering the potential income and overall return. • Income with moderate growth. This investment objective emphasizes generation of current income with a secondary focus on moderate capital growth. • Growth with income. This investment objective emphasizes modest capital growth with some focus on generation of current income. • Growth. This investment objective emphasizes achieving high long-term growth and capital appreciation. There is little focus on generation of current income. • Aggressive growth. This investment objective emphasizes aggressive growth and maximum capital appreciation, with no focus on generation of current income. This objective has a high level of risk and is for investors with a longer timer horizon. For the General Investing Goal, the client is assigned one of the Investment Allocation Tracks (currently, conservative, moderate conservative, moderate, moderate aggressive or aggressive) and a Model Portfolio based upon the client’s GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 9  Guided Wealth Portfolios Program Brochure risk tolerance as indicated in the Client Profile. In the General Investing Goal, the client’s asset allocations generally remain static, subject to rebalancing and tax loss harvesting as described below. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research does not charge a fee for its Model Portfolios. IAR and clients cannot change or customize the Model Portfolios. Types of Investments and Risks The Model Portfolios include ETFs and may include mutual funds in the future. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that are available in the Program. Although LPL, LPLE and the IAR will not make any investment decisions for, or engage in any trading activity on behalf of, users of the Prospect Tool, the investment risks described below are generally applicable to the information provided to users of the Prospect Tool. • 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 fixed income 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). • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as ‐ a whole. • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political, or regulatory events. A client’s account performance could GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 10  Guided Wealth Portfolios Program Brochure sectors do not perform as expected. Alternatively, the lack of be affected if the sectors, industries, or sub exposure to one or more sectors or industries may adversely affect performance. ‐ • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open- end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Tax-Loss Harvesting. The tax-loss harvesting feature of a GWP account involves a variety or risks. You should confer with your personal tax advisor regarding the tax consequences of investing with the Program and engaging in the tax-loss harvesting strategy, based on your particular circumstances. You and your personal tax advisors are responsible for how the transactions in your account are reported to the IRS or any other taxing authority. Neither LPL, nor LPLE, nor the IAR assume any responsibility to you for the tax consequences of any transaction. The Program’s tax-loss harvesting strategy is not intended as tax advice, and neither LPL, nor LPLE, nor the IAR represents in any manner that the tax consequences described will be obtained or that the Program’s investment strategy will result in any particular tax consequence. The tax consequences of this strategy are complex and may be subject to challenge by the IRS. This strategy was not developed to be used by, and it cannot be used by, any investor to avoid penalties or interest. You should be aware that if you and/or your spouse have other taxable or non-taxable accounts, and you hold in those accounts any of the securities (including options contracts) held in your GWP account, you cannot trade any of those securities 30 days before or after the Program account trades those same securities as part of the tax-loss harvesting strategy to avoid possible wash sales and, as a result, a nullification of any tax benefits of the strategy. For more information on the wash sale rule, please read IRS Publication 550. In addition, when LPL replaces investments with “similar” investments as part of the tax-loss harvesting strategy, it is a reference to investments that are expected, but are not guaranteed, to perform similarly and that might lower an investor’s tax bill while maintaining a similar expected risk and return on investor’s portfolio. Expected returns and risk characteristics are no guarantee of actual performance. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their IAR of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. 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. There are risks, costs and conflicts of interest GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 11  Guided Wealth Portfolios Program Brochure associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time without prior notice in order to maintain required maintenance levels. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL for the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” In addition to the risks described above, the Program involves certain additional risks due to its reliance technology systems. • Reliance on Electronic Communications and Delivery. Both the Prospect Tool and a GWP account are primarily online services, and communications concerning the Program are intended to occur primarily through electronic means (including but not limited to, email communications and the Portal, although the IAR or LPLE will be available to discuss investment strategies, objectives or the account in general in person or via telephone. Additionally, clients are required to create and maintain an active Portal profile to use the Prospect Tool or open a GWP account. Therefore, the Program differs from more traditional advisory relationships in which an IAR has more frequent personal interactions with a client. Persons looking for more personal communications should consider whether the Prospect Tool or opening a GWP account, as applicable, will meet their communication preferences. As set forth in the Terms of Use or the Account Agreement, as applicable, users and clients consent to the electronic delivery of all current and future Form ADVs, brochure supplements, privacy notices, prospectuses and offering documents, tax forms and other legal and regulatory notices, disclosures, reports and other communications, including delivery through the Portal, to your e-mail address of record or to such other password-protected website as LPL or LPLE may designate. • Investment Horizon. The Retirement Goal and the Major Purchase Goal are only appropriate for investors with medium- to long-term investment horizons, before such investors plan to access assets that are invested pursuant to the Program. If investors need access to the assets in their accounts at any point prior to the end of the investment horizon, the prices at which these assets are liquidated may cause them to experience a material loss and will negatively compromise the ability of LPL to help them meet their investing goals. • Reliance on Information Provided by User or Client; Protecting Your Account. LPL, LPLE and the IAR provide advice and recommendations based on the information you provide to us regarding your investment objectives, financial condition, income, other investments, and all other information requested of you when using the GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 12  Guided Wealth Portfolios Program Brochure Prospect Tool or opening a GWP account. If a user or client were to provide LPL, LPLE and the IAR with incomplete or inaccurate information, such omissions or inaccuracies could materially impact the quality and applicability of recommendations of LPL, LPLE or the IAR. In addition, users and clients are responsible for monitoring and updating information provided in the event of changes (e.g., contact information or life event changes, such as a change to Retirement Age), that could impact the recommendations made by the Program. You are solely responsible for additions to and withdrawals from your account and for maintaining the confidentiality of any password you select for your account. You are required to notify LPL, LPLE and the IAR in the event you become aware of unauthorized use of your account or any other security breach related to your use of the Prospect Tool or opening a GWP account. • Limitations of a GWP Account. With respect to a GWP account, the recommendations provided by LPL, LPLE, and the IAR are not intended to comprise the client’s complete investment program to the extent that a client has investible and invested assets held in ERISA Plans, or other accounts that the client has not transferred into the account. In addition, recommendations of LPL, LPLE and the IAR are generally limited in scope to the information that users and clients provide. There may be additional information or other financial circumstances not considered by LPL, LPLE and the IAR based on the questions asked at the time a user or client establishes their Investment Allocation Track that would inform the investment advice and recommendations provided by LPL, LPLE and the IAR. Clients should contact their IAR to discuss any such additional information or other financial circumstances that they believe may be relevant to the advice provided through the Program. • Reliance on Technology; Back-up Measures; Cyber Security Breaches and Identity Theft. The Program’s investment activities and investment strategies are dependent upon various computer and telecommunications technologies, many of which are provided by or are dependent upon third parties, data feed, data center, telecommunications, or utility providers. The successful deployment, implementation, and/or operation of such activities and strategies, and various other critical activities provided by LPL, LPLE and the IAR, could be severely compromised, damaged or interrupted by system, network or component failure, computer and telecommunications failure, power loss, a software-related “system crash,” unauthorized system access or use (such as “hacking”), computer viruses and similar programs, other security breaches, fire or water damage or other catastrophic events, power outages, human errors in using or accessing relevant systems, or various other events or circumstances. 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 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 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. GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 13  Guided Wealth Portfolios Program Brochure Voting Client Securities In GWP, LPL, LPLE and IAR do not accept authority to vote client securities. Clients retain the right to vote all proxies that are solicited for securities held in the account. Clients will receive proxies or other solicitations from LPL. When LPL delivers mutual fund shareholder reports and proxies to clients, LPL is reimbursed by the mutual fund for the delivery costs. 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 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 IAR. In addition, clients retain the right and obligation to take action with respect to legal proceedings relating to securities held in the account. Item 7: Client Information Provided to Portfolio Managers Users of the Prospect Tool complete an investor profile, including risk tolerance and Retirement Age or desired date of a major purchase, if applicable. Clients that open a GWP account complete the investor profile and also complete an Account Application which is a part of the Account Agreement. In quarterly communications with clients that have GWP account, LPL or LPLE asks clients to contact them if there have been any changes in the client’s financial situation or investment objective. Users and clients should understand that the Investment Allocation Track seeks to achieve an overall objective for the entire account and may be inconsistent with a particular Sample Recommendation or holding and, for clients, the account’s performance at any time. Users and clients also should be aware that Investment Allocation Tracks are designed to achieve long-term goals for the account. Item 8: Client Contact with Portfolio Managers LPL does not place any restrictions on a user’s or client’s ability to contact and consult with LPL, LPLE, or IARs and users and clients should contact their IAR with any questions regarding the Program. 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 GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 14  Guided Wealth Portfolios Program Brochure 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: • 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 GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 15  Guided Wealth Portfolios Program Brochure 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, 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). • 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). GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 16  Guided Wealth Portfolios Program Brochure • 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). For more information about those state events and other disciplinary and legal events involving LPL and its IARs, users and clients 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 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. 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, 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. 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, 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. PTC also provides personal trustee services to clients for a variety of administrative fiduciary service, 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 adviser. PTC’s IRA custodian and trustee services and 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-GWP 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 program, and uses LPL or LPLE 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. LPL and LPLE have an affiliated insurance agency, LPL Insurance Associates, Inc. (LPLIA) through which their respective IARs may sell insurance products. LPL and LPLE receive compensation from issuers of life insurance (universal, variable universal, whole life, and term) and other insurance contracts that are made available by their respective 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 or LPLE provides and/or payments made in connection with LPL’s marketing and sales-force education and training efforts, including annual national sales and education conference and other conferences of LPL and LPLE. IARs receive a percentage of the commissions or trailing commissions paid to LPL, LPLE 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 GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 17  Guided Wealth Portfolios Program Brochure through LPL, LPLE or the third-party insurance agency and may have an incentive to recommend you purchase or sell insurance products with LPL, LPLE or 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 IARs. The code of ethics permits employees and IARs to invest for their own personal accounts in the same securities that are purchased for clients in Program accounts (or that are recommended to users). 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 holding. LPL and LPLE each have procedures to review personal trading accounts for front-running. However, since LPL Research 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 Research. In addition, employees in LPL Research 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 LPL’s and LPLE’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPL and LPLE do not permit its IARs to recommend or solicit orders of LPL Financial Holdings Inc. stock in GWP accounts. However, a model may include an ETF or mutual fund that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. Purchases of mutual fund shares are typically 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 GWP. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL and LPLE do not receive any compensation other than advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some previously purchased, non-model mutual funds charge shareholders a 12b-1 fee, and, in the future, mutual funds selected in a Model Portfolio may charge shareholders a 12b-1 fee. To the extent a mutual fund charges a 12b- 1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of GWP clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 18  Guided Wealth Portfolios Program Brochure all pertinent shareholder information for the fund. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative, and shareholder services is based on the amount of GWP client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by GWP clients in the fund (up to $25 per position). 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 fund for complex exchange-traded products 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. LPL does not share this compensation with LPLE or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of ETFs, mutual funds, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL representatives so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to 0.15% annually, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Model Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 19  Guided Wealth Portfolios Program Brochure with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with LPLE or the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the retention of previously purchased mutual funds and, in the future, the selection of funds and share classes for a Model Portfolio. In particular, LPL has a financial incentive: (i) to retain or select a product or a share class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to retain or select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to retain or select a product or a share class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or share class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL and LPLE to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the products that pay recordkeeping compensation and the mutual fund sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds , and therefore, LPL and LPLE do not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with LPLE or IARs, and therefore, there is no financial incentive for LPLE or an IAR to select a participating fund over another fund because of this fee arrangement. Although LPL does not share recordkeeping fees or revenue sharing payments with LPLE or its IARs, such fees and payments will increase LPL’s profits and indirectly benefit LPLE and 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. 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 or the LPL Deposit Cash Account (DCA) Program, 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 IARs 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. GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 20  Guided Wealth 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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 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. 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 GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 21  Guided Wealth Portfolios Program Brochure 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. 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. • 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. The compensation that LPL receives related to ICA and DCA (including from any overflow mechanisms) is in addition to the Account Fee that LPL, LPLE and IAR receive with respect to the assets in the sweep investment. This compensation related to ICA and DCA 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 or DCA. In addition, LPL will not take into account this compensation when it makes decisions on a Model Portfolio’s allocation to cash. LPL will not share this compensation with LPLE or its IARs. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s collateralized lending program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the collateralized lending program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with LPLE or its IARs, and GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 22  Guided Wealth Portfolios Program Brochure therefore, IARs of LPLE do not have a direct financial incentive if one bank is selected over another. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. LPLE and its IARs 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 LPLE and its IARs are compensated primarily through advisory fees paid on clients’ accounts, LPLE 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 maintenance 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, or alternatively, could incentivize IARs to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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. 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 client and other information or data related to the client’s account and investment objectives. Client may access account statements, showing account activity and month or quarter-end positions, and confirmations of the transactions that occurred within the account through the Portal. Confirmations of transactions will be consolidated in the case of rebalancing transactions. Detailed performance information is generally available in electronic form through the Portal and is available on year-end statements. IARs have access to review accounts statements and performance information. Users of the Prospect Tool do not receive any reporting. Other Compensation LPL and LPLE employees and their 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 also pay for, or reimburse LPL and LPLE for the costs associated with, education or training events that are 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. LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to LPL, LPLE and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to LPL, LPLE and its IARs, including conference GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 23  Guided Wealth Portfolios Program Brochure recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. LPL, LPLE and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL and LPLE employees provide sales support resources to IARs of LPLE that use LPL advisory programs. The compensation that LPL and LPLE pay 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 typically 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 an 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. If a Model Portfolio is selected that only consists of ETFs and/or mutual funds within the same fund family or within affiliated fund families, the Portfolio Strategist will select only those funds within the affiliated fund families. 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 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 GWP than other programs or GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 24  Guided Wealth Portfolios Program Brochure services. In such cases, the IAR has a financial incentive to recommend advisory services in GWP 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 GWP at a lower overall fee rate than the fee rate for a program offering a third-party manager. 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. institution and IAR have a financial 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 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 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.” GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 25  Guided Wealth Portfolios Program Brochure 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 GWP 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. LPL will not have custody of any funds and securities of users of the Prospect Tool. Brokerage Practices LPLE requires that clients direct LPL as custodian of account assets and broker-dealer with respect to processing securities transactions for a GWP account. When securities transactions are effected through LPL, there are no brokerage commissions charged to the 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL and LPLE are not paid commissions or transaction charges for executing transactions in GWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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 what parameters to set for rebalancing transactions that occur in an account. LPL will aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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 which may result in price differences. 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. Dividends paid by securities in a client’s account may be automatically reinvested or may be paid to the client in cash. In general, mutual fund dividends will be reinvested in the specific mutual fund paying the dividend, while dividends for ETFs will generally be paid in cash. 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. 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 GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 26  Guided Wealth Portfolios Program Brochure 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. 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 investment advice provided for your account. 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(s) or LPLE at lplenterprise.adv@lplfinancial.com. GWP – ADV – LPLE – 0326 LPL Financial, member FINRA/SIPC 27 

Manager Select Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This wrap fee 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. Item 9 was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 7 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 7 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 16 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 17 Item 9: Additional Information ............................................................................................................................................... 17 MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 1  Manager Select Program Brochure Item 4: 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 client directly and also through affiliated and unaffiliated investment advisor 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 IARs. This Brochure provides a description of LPL’s Manager Select program (Program) when offered through an LPLE. In instances where programs are managed by affiliates, such as this Program, affiliates are compensated for performing 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 Manager Select, 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. In the Manager Select Program, LPL makes available the investment advisory services and/or model portfolios of third-party portfolio management firms. Within the Program, LPL offers two alternatives – the Separately Managed Account Platform (the “SMA Platform”) and the Model Portfolio Platform (the “MP Platform” and collectively, the “Platforms”). In connection with the Platforms, LPL acts as an investment adviser, serves as the custodian of the assets, provides brokerage and execution services as a broker-dealer on transactions, and performs administrative services, such as reporting to clients. LPLE, through its IAR, assists the client to determine the client’s investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and, in the case of the SMA Platform, to select an investment strategy and SMA Portfolio Manager, or in the case of the MP Platform, to select a model portfolio (Model Portfolio) provided by LPL Research or third-party investment advisors (Model Advisors). All recommendations by LPLE, through its IAR, regarding accounts in the Platforms will be in an advisory capacity. 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. LPLE, LPL and IAR cannot change the SMA Portfolio Manager or Model Advisor you select for your Account without your approval. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 2  Manager Select Program Brochure SMA Platform In the SMA Platform, LPLE, through its IAR, assists the client to determine the client’s investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and to select an investment strategy and SMA Portfolio Manager. LPLE, through its IAR, provides the client with ongoing advice and monitoring relating to the SMA Portfolio Manager’s services and serves as the point of contact between the client and the SMA Portfolio Manager with regards to changes in the client’s investment objective, financial situation, and investment restrictions. The SMA Portfolio Manager selected by the client provides ongoing discretionary investment advice regarding the investment and reinvestment of account assets in accordance with the investment objective, restrictions and guidelines set forth in the Application or in other agreed-upon written instructions. The SMA Portfolio Manager independently determines whether to accept the client account based on the content of the Account Application, suitability, and whatever other factors the SMA Portfolio Manager deems appropriate. The SMA Portfolio Manager has the sole authority to determine the securities to be purchased, sold, or exchanged and which portion, if any, of the assets shall be held uninvested. The SMA Portfolio Manager has discretion to invest among a broad variety of security types, including equities, fixed-income securities, options, mutual funds and exchange-traded funds (“ETFs”). LPL and LPLE do not play a role in the selection of particular securities to be purchased or sold. The SMA Portfolio Manager may hire one or more sub-advisors to manage all or a portion of a client’s account. MP Platform In the MP Platform, LPLE, through its IAR, assists the client in setting an appropriate investment objective and selecting a model portfolio (“Model Portfolio”) provided by LPL Research or third-party investment advisors (“Model Advisors”). LPLE provides the client with ongoing advice and monitoring relating to the Model Portfolio, is available on an ongoing basis to receive deposit and withdrawal instructions, and to convey to LPL any changes in Client’s financial circumstances, investment objectives or investment restrictions. Under the MP Platform, LPL provides ongoing discretionary investment advice regarding the investment, reinvestment, and the rebalancing of account assets in accordance with the Model Portfolio selected by the client. LPL is expected to closely track the Model Portfolio, making modifications only to address particular account issues, including tax loss harvesting, rebalancing, short term gain avoidance, cash inflows and outflows, and tracking error from the Model Portfolio, and to ensure that investment restrictions are being followed. 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. Fee Schedule In the Platforms, clients pay an annualized fee (Account Fee). The Account Fee is made up of an Advisory Fee and a Manager Fee. If the client changes the model selected for the Account, or if the model investment value changes, the overall Account Fee may increase or decrease. 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, LPLE, IARs, SMA Portfolio Managers and Model Advisors do not charge performance-based fees to accounts in the Platforms. Advisory Fee. The Advisory Fee is charged for the investment advisory services of LPLE, as well as the investment advisory, administrative, trading, and custodial services of LPL. The Advisory Fee is shared with LPLE. The Advisory Fee is negotiable between the client and LPLE and is based on the value of all assets in the account, including cash holdings, and is payable quarterly in advance. The maximum Advisory Fee is 2.35%, although certain legacy accounts may remain higher, so long as the maximum combined Advisory Fee and Manager Fee is no more than 2.95%. Upon request, the Advisory Fee also can be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds in the Account. LPL retains a portion of the Advisory Fee, up to 0.35% of the value of the assets of the account, for its investment advisory, administrative, custody and clearing services. LPLE shares between 90% to 100% of the remaining portion of the Advisory Fee with the unaffiliated financial institution with which IAR is associated, or its affiliate, based on the agreement between LPLE and the financial institution. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 3  Manager Select Program Brochure Manager Fee. The Manager Fee is charged for the services provided by Model Advisor or SMA Portfolio Manager, as applicable. Clients do not pay LPL, LPLE or IARs brokerage commissions or transaction charges for execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Clients pay a Manager Fee set by LPL for services provided by the SMA Portfolio Manager in the case of the SMA Platform and for use of the model portfolio of the Model Advisor in the case of the MP Platform. The Manager Fee is based on the value of all assets in the Account, including cash holdings, and payable quarterly in advance. This fee ranges from 0% to 0.60%. The amount of the Manager Fee will differ depending on the SMA Portfolio Manager or Model Advisor selected for Account, and also may vary depending on which investment strategy or Model Portfolio is selected. For Model Portfolios in the MP Platform, LPL charges a fee of up to 0.05% of account assets per year for the costs and services associated with effecting trades to implement the models, such as order formation, execution, settlement and sleeving of transactions. This LPL fee trading services is reflected in the Manager Fee on client statements. Generally, LPL charges 0.05% of account assets per year for models transacting primarily in equities, and LPL charges 0.03% of model assets per year for models transacting primarily in fixed income or other over-the-counter securities.. In addition, for certain Model Portfolios designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL either charges a Manager Fee as Model Advisor or charges a fee for trading services, there is a conflict of interest for LPL to recommend such models that benefit its affiliate. When acting as Model Advisor, LPL does not charge the Manager Fee to retirement accounts; however, LPL charges the fee for trading services to retirement and nonretirement accounts to the extent permissible under applicable law. LPLE and its IARs do not receive any portion of the Manager Fee, including based on recommending a model for which LPL retains this compensation. Information about the client’s model and fee rates can be requested from IAR. Certain Model Advisors or SMA Portfolio Managers receive a reduced Manager Fee or do not receive a Manager Fee. This is often because the Model Advisor or SMA Portfolio Manager has included proprietary or affiliated mutual funds or exchange-traded funds in the Model or Investment Strategy which charges a management fee. This management fee can be found in the prospectuses of the mutual funds or exchange traded funds included in the Model or Investment Strategy. Because a Model Advisor, SMA Portfolio Manager or their affiliates benefit financially when an affiliated fund is selected, there is a conflict of interest that affects the Model Advisor or SMA Portfolio Manager’s ability to provide unbiased, objective investment advice concerning the selection of funds for a Model or Investment Strategy. The fees paid to SMA Portfolio Managers in the SMA Platform and to Model Advisors in the MP Platform are generally less than fees those advisors would charge a client seeking to establish a direct relationship with them outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, and marketing expenses that would otherwise be borne by those advisors, including trading expenses for Model Advisors. SMA Portfolio Managers and Model Advisors generally have higher minimum account size requirements and fees for direct accounts because of such additional expenses. From time to time, LPL may make available Model Portfolios provided by third-party Model Advisors with associated persons who are also associated persons of LPL or LPLE; however, if a client selects one of these associated persons to act as the IAR for their account, such Model Advisor will not receive a separate fee for its services as a model provider. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a Manager Select account from the account. LPL retains amounts described above under “Fee Schedule” for serviced provided and pays the applicable portion of the Advisory Fee to LPLE and unaffiliated financial institutions with whom LPLE has agreements described herein, and the applicable portion of the Manager Fee to the SMA Portfolio Manager or Model Advisor. 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. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 4  Manager Select Program Brochure 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). Other Types of Fees and Expenses of LPL LPL charges fees related to a Manager Select account in addition to the Account Fee, such as miscellaneous administrative or custodial-related fees and charges. 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, an annual Individual Retirement Account (“IRA”) maintenance fee, an annual qualified retirement plan maintenance fee, 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 miscellaneous 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. As described below under “Additional Information - Participation in Client Transactions,” if LPL as broker-dealer executes a principal transaction in a Manager Select account, LPL may earn a markup or markdown in addition to the Account Fee. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL and LPLE that apply to investments in Manager Select accounts. As described below under “Additional Information – Brokerage Practices,” if a SMA Portfolio Manager chooses to execute a transaction through a broker-dealer other than LPL, the execution price to the client may include a commission, markup/markdown, or other fee imposed by the executing broker-dealer in addition to the Account Fee. If client holds an American Depositary Receipt (“ADR”) in an account, there may be custodial fees or taxes related to the ADR. If a client’s assets are invested in mutual funds, ETFs or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Client will pay an advisory fee to the fund manager and other expenses charged by the fund. Client will also pay the Account Fee with respect to assets invested in such mutual funds, ETFs or other pooled investment products. Clients generally can purchase mutual funds directly outside of the Program. Therefore, clients could avoid the second layer of fees by not using the advisory services of LPL, LPLE, SMA Portfolio Manager, and/or Model Advisor and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 5  Manager Select Program Brochure If client transfers into a Manager Select 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 Manager Select model. 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 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 a Manager Select 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 a Manager Select 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: • 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. For those Manager Select accounts investing in mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in Manager Select charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds will be credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on a Manager Select Account • The Account Fee is an ongoing wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. The Account Fee may cost the client more than purchasing the program services separately, for example, paying fees for the advisory services of LPL, LPLE, and the SMA Portfolio Manager or Model Advisor, as applicable, plus commissions 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: – type and size of the account – 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. • It is important to note that a client may not be able to purchase advisory services directly from the SMA Portfolio Managers or Model Advisors. SMA Portfolio Managers and Model Advisors often do not offer such services for client MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 6  Manager Select Program Brochure accounts of the size typically associated with wrap programs. If they do offer such services to accounts the size of a Manager Select account, the SMA Portfolio Managers and Model Advisors often charge a higher fee as they do not enjoy the economies of scale related to providing services to clients of a wrap program. • 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 Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, the fees associated with the SMA Portfolio Manager or Model Advisor, and the 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 Advisory 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 can 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. • 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 A minimum account value of $25,000 generally is required for the Program. In certain instances, the minimum account size may be lower or higher. Note that an account will not be invested until the applicable minimum for the investment strategy or Model Portfolio has been reached. Clients should consult with LPLE through its IAR to obtain more information about the applicable investment minimum based on the strategy or Model Portfolio selected. The Program is available for individuals, 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 Manager Select, LPL and LPLE are responsible for the investment advisory services related to the selection and retention of the SMA Portfolio Manager (in the case of the SMA Platform) and selection of the Model Portfolio (in the case of the MP Platform). The client selects the LPLE 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 servicing the account, client should refer to the Brochure Supplement for the IAR, which client should have received along with this Brochure at the time client opened the account. LPL makes available the advisory services of SMA Portfolio Managers. LPL does not act as a portfolio manager for the SMA Platform. LPL does, however, act as portfolio manager for the MP Platform. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 7  Manager Select Program Brochure Criteria for Participating and Recommended SMA Portfolio Managers and Model Advisors LPL selects and reviews SMA Portfolio Managers and Model Advisors for the Program based on quantitative, qualitative and infrastructure criteria, which may include the criteria listed below. Quantitative Criteria LPL evaluates quantitative criteria, including but not limited to: • Rate of return • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Investment philosophy • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether an SMA Portfolio Manager or Model Advisor can handle operational requirements, including but not limited to: • Composite calculation methodology • Trade rotation policy • Back office review • Client servicing resources • Firm-wide program commitment Additional Criteria for Recommended SMA Managers or Model Advisors SMA Portfolio Managers and Model Advisors that are “Recommended” by LPL Research are subject to a more rigorous selection and review process than the criteria set out above that applies to all SMA Portfolio Managers and Model Advisors available in the Program. In addition to the criteria noted above, additional evaluation criteria for Recommended SMA Portfolio Managers and Model Advisors include: • Sound investment philosophy and process that drives performance • Consistency of returns and risk • Qualitative assessment of the investment manager and team Clients should speak to LPLE, through its IAR regarding whether the SMA Portfolio Manager or Model Advisor being considered for selection or that has been selected by the client is Recommended or Participating. LPL as a Model Advisor Clients may invest in Model Portfolios designed by LPL Research. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Model Portfolios to meet different investor needs. LPL Research Model Portfolios are built by seeking certain quantitative characteristics for each portfolio using a rules-based, disciplined process for security selection and portfolio construction. LPL Research looks for specific characteristics or investment factors and designs a Model Portfolio to capture the investment results of that characteristic or factor. For example, one such Model Portfolio seeks to have MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 8  Manager Select Program Brochure index-like representation to reasonably track large cap index returns such as the Russell 1000 Index, while another focuses on dividends by seeking a yield premium over the index. The LPL Research Model Portfolios are managed tactically, which means they are flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of trading as frequently as monthly. The participation of LPL Research as a Model Advisor under the MP Platform gives rise to conflicts of interests. For certain LPL Research model portfolios, LPL charges clients a Manager Fee. However, LPL will not charge this fee to retirement accounts. In addition, LPLE has a financial incentive to select its affiliate’s Research Department and further grow LPL’s assets under management, in part because as assets under management at LPL increase, LPL is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. However, the selection of LPL Research model portfolios has no impact on your IAR’s compensation and/or employment status, and your IAR may only recommend a model portfolio that he or she believes is appropriate for you and in your best interest. Removal of a SMA Portfolio Manager or Model Advisor LPL may elect to remove or replace a SMA Portfolio Manager or Model Advisor should it determine that the SMA Portfolio Manager or Model Advisor has failed to meet one or more of the above selection criteria or if the SMA Portfolio Manager or Model Advisor has failed to maintain sufficient assets under management at LPL to maintain profitability on the Manager Select platform. In making a decision to remove or replace a SMA Portfolio Manager or Model Advisor, LPL takes into consideration all criteria; no one criteria, other than the maintenance of assets under management at LPL, is necessarily determinant in the decision. Short-term developments are monitored but are not necessarily sufficient for a decision to remove or replace a SMA Portfolio Manager or Model Advisor. While LPL would have the authority to remove LPL Research as a Model Advisor, it is unlikely to do so. SMA Portfolio Manager and Model Advisor Performance LPL Research uses information provided by the SMA Portfolio Manager or Model Advisor and may also use independent, third-party databases when evaluating an SMA Portfolio Manager or Model Advisor. In order for a SMA Portfolio Manager or Model Advisor to be selected for the Program, LPL generally requires a third-party verification letter related to compliance of the performance information of the SMA Portfolio Manager or Model Advisor with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. This requirement may be waived by LPL for various reasons including alternative methods of verifying the experience and/or performance of the SMA Portfolio Manager or Model Advisor. Performance information used by SMA Portfolio Managers and Model Advisors is not calculated on a uniform and consistent basis. LPL does not calculate the performance record of SMA Portfolio Managers or Model Advisors. However, LPLE provides clients, with individual account performance information. Performance information is prepared by LPL using portfolio accounting and performance reporting software. Client performance is reported on a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that third-party Model Advisors provide Model Portfolios to LPL, and it is LPL that has discretion for trade implementation and execution in MP Platform accounts. Therefore, Model Portfolios submitted to LPL by third-party Model Advisors represent activity that has already been implemented on behalf of other clients of such Model Advisors. Because of this fact and because LPL (and not the third-party Model Advisor) has discretionary authority to implement trades, performance of an MP Platform account will differ from and may be worse than the performance of such Model Advisor’s discretionary accounts. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 9  Manager Select Program Brochure Investment Strategies SMA Portfolio Managers and Model Advisors may provide advisory services based on the following types of investment strategies. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Small Cap Blend Small Cap Growth Small Cap Value Tax Free Fixed Income Taxable Fixed Income All Cap Core All Cap Growth All Cap Value Balanced Convertibles Global Balanced Global Equity Growth Equity Income Preferred Large Cap Core Large Cap Foreign Large Cap Growth Large Cap Value Mid Cap Core Mid Cap Growth Mid Cap Value REIT Sector Types of Investments and Risks In the Platforms, SMA Portfolio Managers (in the case of the SMA Platform) or LPL (in the case of the MP Platform) invest in many different types of securities, including equities, fixed-income securities, options, mutual funds, closed- end funds, interval funds and ETFs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the Program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sector of the market may be more sectors, industries, or sub sectors. An individual sector, industry, or sub ‐ ‐ MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 10  Manager Select Program Brochure volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could sectors do not perform as expected. Alternatively, the lack of be affected if the sectors, industries, or sub exposure to one or more sectors or industries may adversely affect performance. ‐ • Alternative Strategy Mutual Funds. Certain mutual funds available in the Programs invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the Program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • 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. • 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 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. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 11  Manager Select Program Brochure “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency, and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Leveraged and Inverse ETFs, ETNs, and Mutual Funds. Leveraged ETFs, ETNs, and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 12  Manager Select Program Brochure products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts, and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • Options. Option trading is permitted in the Program. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and a Program account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 13  Manager Select Program Brochure your account and can cause your portfolio to underperform the index, including as a result of customization. LPL and LPLE cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (“ETPs”). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), futures-linked ETPs (“Futures Linked ETPs”), and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other ETPs. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their IAR of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 14  Manager Select Program Brochure interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL for the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Blockchain Technology. Blockchain is a novel technology for which its uses, opportunities, applications, and abilities are unknown and unproven. There can be no assurances that companies investing in this technology will be able to benefit from it. The amount and type of investment restrictions are subject to change and manager’s acceptance. Companies investing in blockchain tend to be concentrated in the technology and financial sectors. As a result, the portfolio will be subject to the concentration risk described above and the portfolio’s performance may vary materially from that of its MSCI World Index benchmark. This portfolio invests in American depositary receipts (ADRs), negotiable certificates traded on a U.S. exchange which are issued by U.S. banks and which represent a specified number of shares (or one share) in a foreign stock. As a result, the portfolio will be subject to the Non-U.S. securities risk described below. U.S. Securities Risk. Non • Non ‐ ‐ ‐ U.S. securities involve risks in addition to those associated with comparable U.S. securities and can be more volatile and experience more rapid and extreme changes in price than U.S. securities. Additional risks include exposure to less developed or less efficient trading markets; social, political, or economic instability; fluctuations in non U.S. currencies and in the U.S. dollar exchange rate to those currencies; nationalization or expropriation of assets; settlement, custodial or other operational risks; less stringent auditing, accounting, financial reporting, and legal standards; excessive taxation; and exchange control regulations. Adverse conditions in a particular region could negatively affect securities of countries whose economies appear to be unrelated or not interdependent. In many countries, there is less publicly available and lower quality information about issuers than is available in the reports and ratings published about issuers in the U.S. • 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. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 15  Manager Select Program Brochure • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL generally will earn more compensation for selling one investment product than another. As a result, LPL and LPLE have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. Voting Client Securities In the case of the SMA Platform, the SMA Portfolio Manager, and not LPL, is responsible for voting proxies with respect to issuers held in an account, unless a client directs otherwise in writing. The SMA Portfolio Manager, and not LPL, likewise determines how to respond to any voluntary corporate actions. LPL does not assume responsibility for reviewing the SMA Portfolio Manager’s proxy voting decisions or policies, including for compliance with law. In the case of the MP Platform, unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. 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 the mutual fund on LPL’s behalf and in certain cases remits a portion of the reimbursement to LPL. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of third-party Model Advisors without reviewing individual client interests, unless LPL believes that such instructions are overtly contrary to our clients’ best interests. In such case, LPL will determine whether or how to act consistent with the best interests of our clients. LPL, LPLE, IARs and Model Advisors are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the Account, or issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the Account. Item 7: Client Information Provided to Portfolio Managers When a client opens an account, LPLE, through its IAR, obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective for the account. LPLE, through its IAR, obtains this information MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 16  Manager Select Program Brochure by having the client complete an Account Application which is a part of the Account Agreement. In the case of SMA Platform accounts, LPL forwards this information to the selected SMA Portfolio Manager. In the case of MP Platform accounts, LPLE uses this information to assist the client in selecting an investment strategy and Model Portfolio for the account. LPL typically will not provide client information to third-party Model Advisors. After the account opening, LPL asks clients quarterly to contact LPLE if there have been any changes in the client’s financial situation or investment objectives or if the client wishes to impose any reasonable restrictions on the management of the account or modify existing restrictions. If client communicates to LPLE regarding material changes in the client’s financial circumstances, investment objective or investment restrictions, such information is forwarded to the SMA Portfolio Manager for SMA Platform accounts. Clients may communicate such information to LPLE, or SMA Platform clients may otherwise communicate directly with the SMA Portfolio Manager, although clients are encouraged to direct communication through LPLE. Client should be aware 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 should further be aware that achievement of the stated investment objective is a long-term goal for the account. Item 8: Client Contact with Portfolio Managers In the case of SMA Platform accounts, SMA Portfolio Managers are reasonably available to consult with LPL, LPLE, IAR and clients regarding accounts. Clients may consult directly with the SMA Portfolio Manager, although clients are encouraged to direct contact with SMA Portfolio Manager through LPLE and their IAR. In the case of MP Platform accounts, LPL does not place any restrictions on a client’s ability to contact and consult with LPLE. Because the Model Advisor’s role is solely to provide Model Portfolios to LPL, and not to provide individualized discretionary advisory services to MP Platform clients, third party Model Advisors generally are not available to be contacted or consulted by MP Platform clients. 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). MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 17  Manager Select Program Brochure 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: • 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). MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 18  Manager Select Program Brochure • 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, 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). • 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). 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. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 19  Manager Select Program Brochure 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, 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. 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 adviser representatives dispersed throughout the United 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 service, 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-Manager Select 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 adviser 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 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. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 20  Manager Select Program Brochure In addition, employees in LPL Research 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 In the case of the SMA Platform, LPL, as principal, buys securities from and sells securities to clients in Program accounts. This practice could put LPL in a position where its own interests are in conflict with clients. However, LPL is not a market maker in securities and does not carry an inventory. In addition, it is the SMA Portfolio Manager (and not LPL) who as investment advisor determines the securities to be traded in the account. It is also the SMA Portfolio Manager who has a duty of best execution in negotiating transactions for Program clients. In the case of the MP Platform, LPL as investment adviser determines the securities to be traded in the account; however, LPL is expected to closely track the Model Portfolio, applying discretion only to address particular account issues, including tax loss harvesting, rebalancing, short term gain avoidance, cash inflows and outflows, and tracking error from the Model Portfolio, and to ensure that investment restrictions are being followed. 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. Though LPL also processes securities transactions, as broker-dealer, for MP Platform accounts, LPL does not charge commissions. When LPL executes trades for an SMA Portfolio Manager in a principal capacity on the SMA Platform, it receives a markup or markdown on the transaction. This means, for example, if LPL sells a security at a price higher than what LPL paid, LPL will earn a markup. Conversely, if LPL buys a security at a price lower than what LPL sells it for, LPL will receive a markdown. The maximum markup or markdown that LPL receives when acting in a principal capacity in a Program account is $2.00 per bond. In many cases, this maximum does not apply, and the actual markup or markdown is lower, typically $1.00 per bond. Details about a markup or markdown for a particular transaction will be furnished upon request. The IAR does not share in this markup or markdown. Purchases of mutual fund shares are typically 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 for the mutual fund purchase. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL and LPLE do not receive any compensation other than advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when: a client is also trading whole shares of the security; in connection with a dividend reinvestment plan; or to sell remaining fractional shares to close a position. Trades in whole and fractional shares typically happen on the same day and will be executed at the same price as a trade in whole shares, or otherwise at market closing price. LPL’s and LPLE’s parent company, LPL Financial Holdings Inc., is a publicly traded company. SMA Portfolio Managers are not prevented from purchasing LPL Financial Holdings Inc. stock in Program accounts. In addition, a Manager Select account may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in Manager Select charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b- 1 fees paid to LPL by mutual funds will be credited to the account. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 21  Manager Select Program Brochure LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by clients in the fund (up to $25 per position). 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. SMA Portfolio Managers and Model Providers pay LPL initial diligence and setup fees of up to $5,000 per strategy or Model Portfolio and up to a $5,000 per strategy fee for onboarding and annual due diligence reviews to make their services available in the Program. In the case of ETPs, 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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with LPLE or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL and LPLE IARs so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to 0.15% annually, or up to $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for an Account. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 22  Manager Select Program Brochure receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with LPLE or the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Model Portfolio in the case of Model Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL and LPLE to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds, and therefore, LPL and LPLE do not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with third party SMA Portfolio Managers, Model Advisors, or LPLE and its IARs, therefore, there is no financial incentive for an a third party SMA Portfolio Manager or Model Advisor, LPLE, or its IARs to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. LPL also does not share these payments with LPLE. Although LPL does not share recordkeeping fees or revenue sharing payments with LPLE or its IARs, such fees and payments will increase LPL’s profits and indirectly benefit LPLE and its 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. 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 MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 23  Manager Select Program Brochure 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 or the LPL Deposit Cash Account (“DCA”) Program, 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 IARs 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. 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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 or DCA are eligible for FDIC insurance (subject to applicable limits). Eligibility for pass-through deposit insurance coverage for ICA or DCA deposits is subject to fulfilling specific conditions. Client Cash Accounts 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. 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 MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 24  Manager Select Program Brochure (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. 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. • 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. This compensation that LPL receives related to the ICA and DCA (including from overflow mechanisms), is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to the ICA and DCA, 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 or DCA. However, this compensation is retained by LPL and is not shared with LPLE, LPLE IARs, SMA Portfolio Managers or Model Advisors. Therefore, this compensation does not cause an SMA Portfolio Manager or Model Advisor to have a financial incentive to recommend that cash be held in the account instead of holding securities. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s collateralized lending program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 25  Manager Select Program Brochure For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the collateralized lending program instead, LPL has a financial incentive for the customer to selecta participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with LPLE or its IARs, and therefore, IARs of LPLE do not have a direct financial incentive if one bank is selected over another. Neither LPL, LPLE nor LPLE IARs receive loan-based compensation if you borrow through a non-partner bank. 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, LPLE 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 maintenance 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 or alternatively, could incentivize IARs to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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 SMA Portfolio Managers, Model Advisors, LPL, and LPLE perform advisory and/or brokerage services for various other clients, and they may give advice or take actions for those other clients that differ from the advice given to the client. The timing or 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 information available upon request. In addition, LPL transmits to clients account statements showing transactions, positions, and deposits and withdrawals of principal and income. IARs review monthly or quarterly account statements as well as performance information. 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. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 26  Manager Select Program Brochure Other Compensation LPL and LPLE employees and their IARs also receive additional compensation from product sponsors, including SMA Portfolio Managers or firms affiliated with SMA Portfolio Managers and third party Model Advisors or firms affiliated with third party Model Advisors. Such compensation may not be tied to the sales of any products or services. Compensation may include 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. SMA Portfolio Managers, Model Advisors and other 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 receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to LPL, LPLE and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to LPL, LPLE and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. LPL, LPLE and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL and LPLE employees provide sales support resources to IARs of LPLE that use LPL advisory programs. The compensation that LPL and LPLE pay 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 an 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 MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 27  Manager Select Program Brochure 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 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 Manager Select than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in Manager Select 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 Manager Select at a lower overall fee rate than the fee rate for a program offering a third-party manager. 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 MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 28  Manager Select Program Brochure 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 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. Some of these financial institutions are affiliated with investment advisory firms that act as a Model Advisor or an SMA Portfolio Manager. An IAR offering advisory services on the premises of a financial institution has a potential conflict of interest when the IAR recommends that clients utilize an affiliated Model Advisor or SMA Portfolio Manager because the financial institution has the ability to influence the IAR’s compensation and employment status. However, an IAR may only recommend a model portfolio that they believe is in the best interest of clients. Affiliated Model Advisors and SMA Portfolio Managers sometimes receive a reduced Manager Fee or do not receive a Manager Fee at all. This is often because the affiliated Model Advisor or SMA Portfolio Manager has included proprietary or affiliated mutual funds or exchange-traded funds in the model portfolio which charges a separate fee. The absence of a Manager Fee creates a conflict of interest for the IARs insofar as IARs can negotiate a higher LPL Advisory Fee than they could for an account subject to a higher third-party Manager Fee. In addition, model portfolios benefit from having increased assets under management even if they do not charge a Manager Fee. Specifically, if your IAR is associated with the Prudential Insurance Company of America (“PICA”), you should note that certain model portfolios created by PGIM Investments LLC (“PGIM”), an affiliate of PICA, are available in the Program. These model portfolios include mutual funds that are advised and/or sub-advised by affiliates of PICA (“PICA Proprietary Funds”). PICA Proprietary Funds can represent all of the investments in the portfolio. PGIM, as a Model Advisor, has an incentive to select PICA Proprietary Funds for its models due to the compensation and benefits it and/or its affiliates receive(s). As a Model Advisor, PGIM charges a Manager Fee for PGIM model strategies. However, PGIM will not charge this fee to retirement accounts advised by IARS associated with PICA. PGIM is also compensated by the fees associated with the underlying PICA Proprietary Funds it selects for the strategies. Your IAR has an incentive to select the PGIM model portfolios for your account due to their association with PICA, which can influence their compensation or terminate their relationship altogether. However, your IAR may only recommend a model portfolio that he or she believes is appropriate for you and in your best interest. Qualified retirement accounts receive a credit in an amount equal to the mutual fund advisory and administrative services fees that PICA affiliates receive in connection with the affiliated mutual funds held in the account. In addition, PGIM has ownership interests in other SEC-registered investment advisers. In the future, your IAR may offer products or utilize Model Portfolios or SMA Managers from these investment advisers. However, PGIM will not charge retirement accounts that utilize these investments advisers a Manager Fee. 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 Manager Select client funds and securities in a separate MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 29  Manager Select Program Brochure 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 the case of the MP Platform, all transactions will be executed through LPL, and Client directs that securities transactions for the Account be initiated through LPL. In the case of the SMA Platform, Client directs SMA Portfolio Managers to execute transactions through LPL, subject to the SMA Portfolio Manager’s duty as an investment advisor to seek to achieve best execution. Clients should understand that an SMA Portfolio Manager may choose to place some or all trades for accounts with broker-dealer firms other than LPL (“trade away” or “step outs”). Some SMA Portfolio Managers have historically placed nearly all client trades with broker-dealer firms other than LPL for execution, in particular, if the SMA Portfolio Manager follows a fixed-income, foreign or small cap investment strategy. In addition, SMA Portfolio Managers may choose to trade away from LPL in order to aggregate all client transactions into one or more larger “block trades” that are executed through one broker-dealer. This practice may enable an SMA Portfolio Manager to obtain more favorable execution, including a more advantageous net price, than would otherwise be available if orders were not aggregated into a single “block trade.” It may also assist the SMA Portfolio Manager in potentially avoiding an adverse effect on the price of a security which could result from simultaneously placing a number of separate, successive or competing client orders. When securities transactions are effected through LPL, there are no brokerage commissions charged to the account. If an SMA Portfolio Manager chooses to execute a transaction through a broker-dealer other than LPL, the execution price will usually include a commission or fee imposed by the executing broker-dealer. Clients should understand that the client will bear any such additional trading cost, in addition to the Account Fee paid to LPL. The additional expenses charged by the broker-dealer executing the transaction may include commissions, mark-ups, mark-downs or “spreads” paid to executing broker dealer firm. Additionally, if a foreign currency transaction is required, there may be foreign exchange or similar fees, including but not limited to fees for foreign ordinary conversion and creation of American Depositary Receipts (“ADRs”) charged by third parties as well as foreign tax charges. In many cases, the commission, mark-up, mark-down or other additional expenses charged by the executing broker-dealer or third party will be embedded in the purchase or sale price of such transactions, and not separately indicated on trade confirmations and custodial account statements provided by LPL. In evaluating whether to execute a trade through a broker-dealer other than LPL, an SMA Portfolio Manager will consider the fact that an account will not be charged any additional expenses (such as a commission) if effected directly through LPL. 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. Clients should understand that LPL and LPLE are not able to fully evaluate whether an SMA Portfolio Manager is meeting its best execution obligations to clients for specific transactions when trading away, as it is not a party to such transactions and is not in a position to negotiate the price or transaction related charges with the executing broker. The responsibility to determine whether to trade away lies with the SMA Portfolio Manager and arises out of an SMA Portfolio Manager’s individual fiduciary duty to clients. Additional information regarding equity trading away practices of SMA Portfolio Managers is available at lpl.com/disclosures.html under “Market & Trading Disclosures” and “Third-Party Portfolio Manager Trading Practices.” Clients should consider whether or not the appointment of LPL as the broker-dealer may or may not result in certain costs or disadvantages as a result of possibly less favorable executions. Clients should understand that not all wrap program sponsors require brokerage to be directed to the sponsor. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution of client transactions. In particular, a client’s account may not be able MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 30  Manager Select Program Brochure to participate in block trades placed by a SMA Portfolio Manager for its other accounts, which may result in a difference between prices charged to a Program account and SMA Portfolio Manager’s other accounts. For these reasons, directed brokerage may cost clients more money. SMA Portfolio Managers (in the case of the SMA Platform) and LPL (in the case of the MP Platform) may aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. Clients should read and understand the brokerage practices disclosed in the Firm Brochure of each SMA Portfolio Manager selected by the client (if applicable). 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 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 investment advice for your account. For more information about the SMA Portfolio Manager managing the account or Model Advisor providing a Model Portfolio, client should review the Brochure of the SMA Portfolio Manager or Model Advisor provided to you when you opened your Program account. For more information about the IAR(s) managing your account, please refer to the Brochure Supplement 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(s) or LPLE at LPLEnterprise.ADV@lpl.com. MS302 – LPLE – 0326 LPL Financial, member FINRA/SIPC 31 

Model Wealth Portfolios (MWP) Program Form Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. Item 9 was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 8 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 9 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 17 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 17 Item 9: Additional Information ............................................................................................................................................... 17 A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 1  Model Wealth Portfolios (MWP) Program Form 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 and an advisor-enhanced digital advice program. 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 Model Wealth Portfolios program (“MWP” or “Program”) when offered through LPLE. In instances where programs are managed by affiliates, such as this Program, affiliates are compensated for performing 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 MWP, 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 MWP Program is a unified managed account program in which LPL and LPLE provide ongoing investment advice. LPLE, through 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 selects one or more model portfolios of securities (each, a “Portfolio”) designed by LPL Research, a third-party investment strategist, or LPLE, through IAR (each, a “Portfolio Strategist”) consistent with the client’s stated investment objective. These Portfolios may contain mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), closed-end funds, equities, or fixed-income securities. LPLE, through IAR, provides ongoing advice on the selection or replacement of a Portfolio based on the client’s individual needs and may choose more than one Portfolio to be managed within a single MWP account. A Portfolio also may be comprised of one or more underlying models. Clients grant LPLE and IAR discretion to choose among the available models designed by the Portfolio Strategists. LPLE and IAR are subject to a fiduciary duty to act in a client’s best interest when selecting one or more models for the Account. The Portfolio Strategist is responsible for selecting the securities within a Portfolio and for making changes to the securities selected. Each Portfolio Strategist provides its model portfolio to LPL, and LPL makes the decisions on how to implement the model on behalf of clients. Except for LPL and LPLE, the Portfolio Strategists are independent investment adviser firms or unaffiliated financial institutions. Portfolio Strategists provide LPL on an ongoing basis with a Portfolio that includes recommended asset allocations and securities. LPL enters into an agreement with the Portfolio Strategist for these Portfolio services. Except for LPL and LPLE, and except for Subadvisers (defined below), a, Portfolio Strategist does not have discretion from the client to implement the Portfolio and does not provide individualized investment advice to specific program clients. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 2  Model Wealth Portfolios (MWP) Program Form Brochure Some third-party investment strategists have entered into subadvisory agreements with LPL to manage, on a discretionary basis, accounts or portions of accounts in the Program allocated to their fixed-income Portfolios (“Subadvisers”). If LPLE, or a client, chooses to allocate all or a portion of an account to a Portfolio provided by a Subadviser, LPL will delegate some of its responsibilities to the Subadviser, subject at all times to oversight by LPL. Subadvisers will have discretion to make decisions about how to implement their Portfolios, including decisions on purchasing and selling fixed-income securities, executing trades through brokerage firms selected by the Subadviser and rebalancing the assets in the Account allocated to their models, which may occur on a different frequency than as determined by LPL. Subadvisers have discretion whether to consider state preferences (if client provides to IAR) when selecting from the inventory of bonds, if applicable. Not all states will carry inventory to suffice for a selection. Please note that there is no guaranty that state preference will be considered. The discretion to consider state preferences is not intended as tax advice, and neither LPL nor any Subadviser represents in any manner that implementation of state preferences will achieve tax-advantaged returns. Notwithstanding LPL’s delegation of some of its responsibilities to the Subadviser, LPL and LPLE will remain responsible for all advisory services provided in the Program. LPL conducts initial and ongoing due diligence of Subadvisers and has the ultimate authority to hire and fire Subadvisers to accounts in the Program, and may terminate a Subadviser’s authority to manage client assets at its discretion. A client who wishes not to engage a Subadviser would be required to select a different Portfolio. If LPLE through IAR chooses to invest in a Portfolio provided by a Subadviser, please carefully review the Subadviser’s Form ADV Part 2 Brochure for information on the Subadviser’s investment strategies, risks, brokerage practices and conflicts of interest. LPL acts as the overlay portfolio manager in coordinating the trades in the account and performing tax harvesting services. LPL expects to closely track the Portfolios, applying discretion only to address particular account issues, including tax rebalancing, tax loss harvesting, short-term gain avoidance, cash inflows and outflows, and tracking error from the Portfolio, customized requests, and investment restrictions placed on the account. 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. LPL is responsible for rebalancing accounts in accordance with the allocations in the Portfolio. LPL will review an account to determine if rebalancing is appropriate based on the frequency selected by the client at account opening or as altered by the client or LPLE through IAR from time to time. The choices for frequency of rebalancing review are quarterly (four times per year), semiannually (two times per year) or annually (once per year). At each rebalancing review date, LPL will rebalance the account if the account has available cash for investment and if at least one security position, including cash, is outside a pre-determined range, subject to a minimum transaction amount established by LPL in its discretion. In addition, LPL will review an account for rebalancing in the event that the Portfolio Strategist changes the allocation targets. LPL accommodates reasonable requests to restrict holdings of specific securities, specific industries, specific sectors, and certain pre-defined categories (e.g., “sin” stocks). In the event that client restrictions prevent the investment in certain securities otherwise specified by a Portfolio Strategist, assets will be invested pro-rata across the remaining securities in the model. Such restrictions do not apply to any mutual funds, ETFs or fixed-income securities that are held in the account. Restrictions placed on an account can affect the performance of the account. LPL may choose not to accept an account with restrictions that are inconsistent with the investments chosen by LPL or as recommended by the Portfolio Strategist. LPL, at the request of LPLE, performs tax harvesting, which may include using the proceeds of tax-related transactions to purchase appropriate securities (such as ETFs or mutual funds) for an account. Client may also request LPLE to initiate tax harvesting with LPL. In such case, proceeds of tax-related transactions may be held in cash or securities until appropriate wash sale periods have expired. Once the wash sale period has expired, the related proceeds will be invested according to the current targeted allocation for the Portfolio. Similarly, LPL may delay a tax harvesting request to sell securities acquired in the previous 30 days until the wash sale period has expired. Under certain conditions, LPL also will accommodate requests for all or a portion of an account to remain allocated to cash for a period of time. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 3  Model Wealth Portfolios (MWP) Program Form Brochure In addition to general tax harvesting requests described above, clients may authorize LPL to provide more comprehensive tax overlay services (“LPL Tax Overlay Services”). If directed by client, LPL will provide LPL Tax Overlay Services to the client’s account. The end objective of LPL Tax Overlay Services is to improve the after-tax return for the client while staying consistent with the investment strategies of the Portfolios. LPL Tax Overlay Services is available only to clients subject to U.S. capital gains tax. Neither LPL nor LPLE provides tax planning advice or services. Neither LPL nor LPLE represents in any manner that the desired tax objectives will be obtained or that MWP’s investment strategy will result in any particular tax outcome. Clients should discuss any questions with or request further information from their IAR or their tax consultant in using the LPL Tax Overlay Services. LPL charges 0.08% of the value of the account to provide LPL Tax Overlay Services, which it retains from the Advisory Fee, as described under the section titled “Fee Schedule” below. This charge will not be separately indicated on account statements or otherwise. When IAR recommends discontinuing LPL Tax Overlay Services, IAR has a conflict of interest since discontinuing this service will increase the portion of the Advisory Fee paid to IAR’s financial institution or its affiliate. Clients will be notified when services are discontinued, including a reminder to discuss whether a reduction of the Advisory Fee is appropriate. Please ask your IAR for additional information. In some cases, clients may experience significant performance differences from the selected investment strategy for one or more Portfolios and/or the overall account, due to participation in LPL Tax Overlay Services. If a client chooses to participate in this service, LPL makes no assurances that the client’s account performance will be within any range of the selected investment strategy or the strategy’s benchmark. A client’s returns will likely differ from, and could be lower than, the Portfolio Strategist’s model when enrolled in Tax Overlay Services. In addition, LPL may manage the client’s account using tools and processes which may result in the client’s trades being executed at a different time or in a different manner than other LPL trades, including the potential to not participate in LPL’s standard trade rotation processes (if such trades would have been otherwise eligible to participate). In connection with the Program, LPL, acts as custodian to accounts, provides research information to LPLE and its IARs, provides brokerage and execution services as the broker-dealer on transactions, and performs administrative services, such as performance reporting. LPLE IARs may, in their sole discretion and as agreed from time to time with clients, provide financial planning or financial consulting services on behalf of LPLE to clients in connection with the program at no additional cost. IARs may also require clients to enter into a separate agreement with LPLE 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 MWP Program pay an annualized fee (Account Fee). The Account Fee is made up of an Advisory Fee and a Manager Fee. If LPLE, through its IAR, changes the model selected for an account, or if the model investment value changes, the overall Account Fee may increase or decrease. 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, LPLE, IAR, and Portfolio Strategists do not charge performance-based fees to accounts in the Program. Advisory Fee. The Advisory Fee is charged for the investment advisory services of LPLE, as well as the investment advisory, administrative, trading, custodial and clearing services of LPL. The Advisory Fee is shared with LPLE. The Advisory Fee is negotiable between the client and LPLE and is based on the value of assets in the account, including cash holdings. The maximum Advisory Fee is 2.35%. Upon request, the Advisory Fee may be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 4  Model Wealth Portfolios (MWP) Program Form Brochure LPL retains a portion of the Advisory Fee, up to 0.43% of the value of the account, for its investment advisory, administrative, trading, custodial, and clearing services. LPLE shares between 90% and 100% of the remaining portion of the Advisory Fee with the unaffiliated financial institution with which IAR is associated, or its affiliate, based on the agreement between LPL and the financial institution. Manager Fee. Depending upon the model(s) selected for the account, clients pay a Manager Fee set by LPL for the use of each model portfolio. The Manager Fee is based on the value of the assets in the account, including cash holdings, and payable quarterly in advance. This fee ranges from 0% to 0.60%. LPL pays all or a portion of the Manager Fee to the Portfolio Strategist. For certain models, LPL charges up to 0.05% of model assets per year for the costs and services associated with effecting trades to implement the models, such as order formation, execution, settlement and sleeving of transactions. This LPL fee for trading services is reflected in the Manager Fee on client statements. Generally, LPL charges 0.05% of model assets per year for models transacting primarily in equities, and LPL charges 0.03% of model assets per year for models transacting primarily in fixed income or other over-the-counter securities. For certain models designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL either charges a Manager Fee as Portfolio Strategist or charges a fee for trading services , there is a conflict of interest for LPLE to recommend such models that benefit its affiliate. When acting as Portfolio Strategist, LPL does not charge the Manager Fee to retirement accounts; however, LPL charges the fee for trading services to retirement and nonretirement accounts to the extent permissible under applicable law. LPLE and its IARs do not receive any portion of the Manager Fee, including based on recommending a model for which LPL charges this compensation. A list of client’s current model(s) and associated fee rates will be reflected on client account statements or can be requested from IAR. Please note that if an account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. Clients do not pay LPL or LPLE brokerage commissions or transaction charges for the execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Certain Portfolio Strategists charge a reduced Manager Fee or do not charge a Manager Fee for their models. This is often because the Portfolio Strategist earns a management fee from proprietary or affiliated mutual funds or exchange-traded funds included in the model. This management fee can be found in the prospectuses of the mutual funds or exchange traded funds included in the model. Because a Portfolio Strategist or their affiliates benefit financially when an affiliated fund is selected, there is a conflict of interest that affects the Portfolio Strategist’s ability to provide unbiased, objective investment advice concerning the selection of funds for a model. If a Portfolio is selected that consists of mutual funds and/or ETFs primarily or only within the same fund family or within affiliated fund families (typically as indicated by the title of the model portfolio), the Portfolio Strategist will select at least a majority of funds within that fund family or affiliated fund families. In such case, because mutual funds or ETFs in a Portfolio are affiliated with a third-party Portfolio Strategist that designs the Portfolio, an investment in the affiliated fund generates compensation to that third party Portfolio Strategist or its affiliates, including, among other types of compensation, fund-level management fees, in addition to any portion of the Account Fee it receives. The fees paid to Portfolio Strategists are generally less than fees those strategists would charge a client seeking to establish a direct relationship with them outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, marketing and trading expenses that would otherwise be borne by those strategists. Portfolio Strategists generally have higher minimum account size requirements and fees for direct accounts because of such additional expenses. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with an MWP account from the account. LPL retains amounts described above under “Fee Schedule” for services provided and pays the applicable portion of the Advisory Fee to LPLE and unaffiliated financial institutions with whom LPLE has agreements described herein, and the A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 5  Model Wealth Portfolios (MWP) Program Form Brochure applicable portion of the Manager Fee to the Portfolio Strategists. 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 pro-rated 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). Other Types of Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative and custodial- related fees and charges that apply to an MWP 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 miscellaneous 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. Other LPL and LPLE advisory programs and/or other financial services firms separately offer certain models available through the Program, in some cases at a lower overall costs to investors. When the same model is offered in different LPL and LPLE advisory programs, the difference in the Manager Fee for use of that model is typically up to five basis points. Advisory programs differ significantly in the overall features and functionalities offered, and LPLE and its IARs may only recommend a program or service that he or she believes is suitable and in the best interest of a client in accordance with the applicable standards under the Advisers Act. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL and LPLE that apply to investments in MWP accounts. Some of these fees and charges are described below. In MWP, assets are often invested in mutual funds or ETFs 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 fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay the Account Fee with respect to assets invested in mutual funds and ETFs. The mutual funds and ETFs available in the Program can be purchased directly outside of the Program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPL, LPLE and Portfolio Strategist and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 6  Model Wealth Portfolios (MWP) Program Form Brochure offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” If client transfers into an MWP 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 MWP model. 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 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 MWP account, client should be aware that certain securities may 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 MWP 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: • 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 an account that is not managed and not subject to an advisory fee. For those Portfolios consisting of mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in MWP charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds will be credited to the client’s account. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Fees on a MWP Account • The Account Fee is a wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. Clients do not pay a commission or transaction charge to LPL or LPLE for the execution of transactions in the account. 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: – type and size of the account – type of securities in the Portfolio (whether mutual funds, ETFs, equities, or fixed income) A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 7  Model Wealth Portfolios (MWP) Program Form Brochure – 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 fee set out above. LPLE, through its IAR, is responsible for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, the number, complexity and mix of the portfolio, the selection of the particular Portfolios, and the 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 Advisory Fee with LPLE through its IAR. • 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 fee set out above. LPLE, through its IAR, is responsible for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, the number, complexity and mix of the portfolio, the selection of the particular Portfolios, and the 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 Advisory 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 can 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. • The investment products available to be purchased in the Program can be purchased by clients outside of an MWP account, through broker-dealers or other investment firms not affiliated with 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 requires a minimum asset value for a Program account to be managed. The minimums vary depending on the Portfolio(s) selected and the account’s allocation amongst Portfolios. The lowest minimum for a Portfolio is $10,000. In certain instances, LPL will permit a lower minimum for a Portfolio. Note that an account will not be invested according to a Portfolio or Portfolios until the applicable minimum for the Portfolio(s) and allocation has been reached. Clients should consult with LPLE and IAR to obtain more information about the applicable investment minimum based on the Portfolio(s) selected and the allocation amongst Portfolios. The Program is available for individuals, Individual Retirement Accounts (“IRAs”), banks and thrift institutions, credit unions, pension and profit sharing plans, including plans subject to ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 8  Model Wealth Portfolios (MWP) Program Form Brochure Item 6: Portfolio Manager Selection and Evaluation In MWP, LPL and LPLE are responsible for the overall investment advice and management services offered to clients, and the client selects the IAR who manages 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 along with this Brochure at the time client opened the account. LPL makes available Portfolios designed by LPL Research, third-party Portfolio Strategists (including Subadvisers), and LPLE through its IARs for a particular account. LPL reviews on a periodic basis LPLE acting as Portfolio Strategist on MWP. In addition, LPL selects and reviews on a periodic basis the third-party Portfolio Strategists available on MWP. A third-party Portfolio Strategist may provide services to LPL, LPLE and the Program as a Subadviser. In addition to deciding on the securities and asset allocation for a Portfolio, Subadvisers are responsible for determining when and how to execute transactions and selecting broker-dealers through which to execute transactions. LPL uses information provided by the third-party Portfolio Strategist and also may use independent, third-party data sources when evaluating such Portfolio Strategist. Third party Portfolio Strategist performance information is not calculated on a uniform and consistent basis. LPL does not review performance information to determine or verify its accuracy and does not calculate third-party Portfolio Strategist performance. However, LPL provides clients with individual performance information. Performance information is prepared by LPL using portfolio accounting and performance reporting software. Client performance information is calculated on a uniform and consistent basis using a time weighted basis. It is important to note that, except for Subadvisers, third-party Portfolio Strategists provide the Portfolios to LPL, and it is LPL that has discretion for trade implementation and execution in MWP accounts. Therefore, Portfolios submitted to LPL by third-party Portfolio Strategists may represent activity that has already been implemented on behalf of other clients of such Portfolio Strategists. Because of this fact and because LPL (and not the third-party Portfolio Strategist) has discretionary authority to implement trades, performance of an MWP account will differ from the performance of such Portfolio Strategist’s discretionary accounts. Performance information is intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to investment indices. LPL as a Portfolio Strategist In MWP, clients may invest in Portfolios designed by LPL Research. LPL Research designs many types of mutual fund, ETF, fixed-income and equity Portfolios to meet the varying needs of clients. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Portfolios for different timeframes, needs or themes that have meaning to investors. LPL Research generally designates portfolios as either strategic or tactical model styles. The allocations in strategic Portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout a 3 to 5 year timeframe and are intended for investors who take a longer term view or who are more tax sensitive. Tactical Portfolios are more flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of more frequent trading. Within the strategic and tactical model styles, LPL Research focuses each model on an investment theme or objective. For example, LPL Research designs alpha-focused Portfolios that are structured for more aggressive investors. There are also downside risk aware Portfolios that are intended to be structured more conservatively to help provide more protection in the event of a down market. LPL Research designs portfolios that are largely allocated to alternative strategies to provide diversified exposure to those more esoteric asset classes. LPL Research also designs Portfolios intended for investors who place a priority on income generation and Portfolios for investors seeking to minimize tax impacts. Such income generation Portfolios are also available in investment objectives that are not typically focused on income. Additionally, LPL Research designs portfolios intended for investors who want to invest primarily with A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 9  Model Wealth Portfolios (MWP) Program Form Brochure certain mutual fund families. There are also Portfolios that emphasize socially responsible investing and sustainability. LPL Research also designs portfolios that follow a “direct indexing” strategy, or a strategy that seeks to replicate a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the market index. In a direct indexing strategy, LPL Research partners with an index provider to license an index and pays a portion of the Manager Fee to the index provider. For a complete list of the current models provided by LPL Research, please discuss with IAR. The participation of LPL Research as a Portfolio Strategist gives rise to conflicts of interests. For certain LPL Research model portfolios, LPL charges clients a Manager Fee. However, LPL will not charge this fee to retirement accounts. In addition, LPL has a financial incentive to select its affiliate’s LPL Research and further grow LPL’s assets under management, in part because as assets under management at LPL increase, LPL is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. However, the selection of LPL Research model portfolios has no impact on your IAR’s compensation and/or employment status, and your IAR may only recommend a model portfolio that he or she believes is appropriate for you and in your best interest. LPLE, through its IAR, as Portfolio Strategist In addition to portfolios designed by LPL Research and third-party Portfolio Strategists, clients can invest in portfolios managed by LPLE, through its IAR, for their account. LPLE, through its IAR, is responsible for selecting the mutual funds, ETFs, ETNs, closed-end funds, equities or fixed-income securities within a Portfolio, the asset allocation for the Portfolio, and for making changes to the funds selected and asset allocation over time. LPLE, through its IAR, will typically manage Portfolios tailored to an investment theme or particular style that is core to the IAR’s beliefs and expertise. LPLE, through its IAR, chooses research methods, investment strategy and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPLE and its IARs have access to various research reports, including those provided by LPL Research, to which IAR may refer in determining which securities to purchase or sell. LPL has discretion to buy and sell securities in the Account (according to the Portfolio selected) and to liquidate previously purchased securities that are transferred into the Account. LPL expects to closely track the Portfolios, applying discretion only to address particular account issues, including tax rebalancing, loss harvesting, tracking error from the Portfolio, customized requests, and investment restrictions placed on the account. 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. Types of Investments and Risks The Portfolios may include different types of securities, such as mutual funds, ETFs, ETNs, closed-end funds, equities and fixed-income securities. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the Program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 10  Model Wealth Portfolios (MWP) Program Form Brochure risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Cybersecurity Risk. Failures or breaches of the electronic systems LPL or LPLE, its service providers, of 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 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 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. • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 11  Model Wealth Portfolios (MWP) Program Form Brochure “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sector of the market may be more sectors, industries, or sub volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and LPLE generally will earn more compensation for selling one investment product than another. As a result, LPL and LPLE have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. • Alternative Strategy Mutual Funds. Certain mutual funds available in the Program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 12  Model Wealth Portfolios (MWP) Program Form Brochure speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End Funds. Client should be aware that closed-end funds available within the Program may not be readily marketable. In an effort to provide investor liquidity, the funds may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, clients may be unable to liquidate all or a portion of their shares in these types of funds. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 13  Model Wealth Portfolios (MWP) Program Form Brochure the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL and LPLE cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (Single Inverse ETPs), futures-linked ETPs (Futures Linked ETPs) and cryptocurrency-related ETPs (Cryptocurrency ETPs). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 14  Model Wealth Portfolios (MWP) Program Form Brochure Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their IAR of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 15  Model Wealth Portfolios (MWP) Program Form Brochure encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL for the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Tax-Loss Harvesting and LPL Tax Overlay Services. The tax-loss harvesting and LPL Tax Overlay Services features of MWP involves a variety of risks. You should confer with your personal tax advisor regarding the tax consequences of investing and engaging in the tax-loss harvesting strategy and tax overlay services, based on your particular circumstances. You and your personal tax advisors are responsible for how the transactions in your account are reported to the IRS or any other taxing authority. Neither LPL nor LPLE assumes any responsibility to you for the tax consequences of any transaction. MWP’s tax-loss harvesting strategy and its tax overlay services are not intended as tax advice, and neither LPL nor LPLE represents in any manner that the tax consequences described will be obtained or that MWP’s investment strategy will result in any particular tax consequence. The tax consequences of these features are complex and may be subject to challenge by the IRS. These features were not developed to be used by, and it cannot be used by, any investor to avoid penalties or interest. You should be aware that if you and/or your spouse have other taxable or non-taxable accounts, and you hold in those accounts any of the securities (including options contracts) held in your MWP account, you cannot trade any of those securities 30 days before or after the MWP account trades those same securities as part of the tax-loss harvesting strategy to avoid possible wash sales and, as a result, a nullification of any tax benefits of the strategy. For more information on the wash sale rule, please read IRS Publication 550. In addition, when LPL replaces investments with “similar” investments as part of the tax-loss harvesting strategy, it is a reference to investments that are expected, but are not guaranteed, to perform similarly and that might lower an investor’s tax bill while maintaining a similar expected risk and return on investor’s portfolio. Expected returns and risk characteristics are no guarantee of actual performance. Voting Client Securities Unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of the Portfolio Strategist without reviewing individual client interests, unless LPL determines that such instructions are overtly contrary to our clients’ best interest. In such case, LPL will determine whether or how to act consistent with the best interest of our clients. LPL and LPLE are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 16  Model Wealth Portfolios (MWP) Program Form Brochure account, or the issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the account. 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 objective or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Because third party Portfolio Strategist’s role is limited to providing Portfolios to LPL, and does not provide individualized discretionary advisory services to MWP clients, LPL generally does not communicate specific client information to third-party Portfolio Strategists. 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 model in the account, 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 client’s ability to contact and consult with LPL, LPLE or IAR. Because a third- party Portfolio Strategist’s role is solely to provide Portfolios to LPL, and not to provide individualized discretionary advisory services to MWP clients, third party Portfolio Strategists, except for Subadvisers, generally are not available to be contacted or consulted by MWP clients. 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). A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 17  Model Wealth Portfolios (MWP) Program Form Brochure 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: • 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). A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 18  Model Wealth Portfolios (MWP) Program Form Brochure • 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, 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). • 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). A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 19  Model Wealth Portfolios (MWP) Program Form Brochure 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. 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 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. 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 adviser 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, 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 individual retirement accounts. PTC also provides personal trustee services to clients for a variety of administrative fiduciary service, 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 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-MWP 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 adviser 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. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 20  Model Wealth Portfolios (MWP) Program Form Brochure 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 IARs. The code of ethics permits employees and 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. In addition, employees in LPL Research 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 each of the LPL and LPLE 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 the firm’s use of a proprietary account. LPL and LPLE do not otherwise engage in principal transactions with its clients in MWP. LPL Financial Holdings Inc., is a publicly traded company. Third-party Portfolio Strategists are not prevented from purchasing LPL Financial Holdings Inc. stock in MWP accounts. In addition, a model may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL and LPLE do not receive any compensation other than advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements. Some mutual funds and Program Share Classes in MWP charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of MWP clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases, LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of MWP client assets that are invested in the fund (up to 0.30% annually), or the number of positions held A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 21  Model Wealth Portfolios (MWP) Program Form Brochure by MWP clients in the fund (up to $25 per position). 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. Portfolio Strategists pay LPL initial diligence and setup fees of up to $5,000 per strategy or model portfolio and up to a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance to make their services available in the Program. In the case of exchange traded products, LPL receives up to $15,000 as a sponsor level due diligence fee, $7,500 per fund and up to an additional $15,000 per product for complex exchange-traded products. In the case of mutual funds, LPL receives a one-time set up fee of up $15,000 as a sponsor level due diligence fee and a setup fee of $7,500 per fund. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with LPLE or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (sponsors) of mutual funds and ETFs that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL and LPLE IARs so that the sponsor can promote such products. This type of arrangement gives LPLE a financial incentive to have LPLE clients invest in participating products instead of products whose sponsors do not make such payments to LPL. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to is 0.15% annually of LPL clients’ investments in the investment product, or up to $1,000,000 . LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective financial professionals to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 22  Model Wealth Portfolios (MWP) Program Form Brochure arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with LPLE or the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL and LPLE to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds, and therefore, LPL and LPLE do not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with LPLE, its IARs or third-party Portfolio Strategists, and therefore, there is no financial incentive for LPLE, its IARs or a third party Portfolio Strategist to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments with LPLE or its IARs, such fees and payments will increase LPL’s profits and indirectly benefit LPLE and its 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. 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 or the LPL Deposit Cash Account (DCA) Program 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. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 23  Model Wealth Portfolios (MWP) Program Form 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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 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. 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 A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 24  Model Wealth Portfolios (MWP) Program Form Brochure 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. 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 LPs 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. • 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. The compensation that LPL receives related to the ICA and DCA (including from any overflow mechanisms) is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to the ICA and DCA 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 or DCA. However, the compensation LPL receives on ICA and DCA is retained by LPL and is not shared with Portfolio Strategists, LPLE or its IARs. In addition, LPL does not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s collateralized lending program, and can work directly with non-partner 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 LPLE, through their IAR, of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the lender, whether LPL, a partner bank or a non- partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select a the SCA product, and if a client selects a bank in the collateralized lending program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with LPLE or its IARs, A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 25  Model Wealth Portfolios (MWP) Program Form Brochure and therefore, IARs of LPLE do not have a direct financial incentive if one bank is selected over another. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. 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, LPLE 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 maintenance 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, or alternatively, could incentivize IARs to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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 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 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 as an unaffiliated Portfolio Strategist. Such compensation may not be tied to the sales of any products or services. Compensation may include 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 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 A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 26  Model Wealth Portfolios (MWP) Program Form Brochure 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 from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to LPL, LPLE and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to LPL, LPLE and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. LPL, LPLE and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL and LPLE employees provide sales support resources to IARs of LPLE that use LPL advisory programs. The compensation that LPL and LPLE pay to these employees varies based on the assets in LPL’s different advisory programs. These sales employees have an incentive to promote MWP 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 an 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. LPL and BlackRock Advisors, LLC (“BlackRock”) entered into an agreement pursuant to which BlackRock agreed to pay LPL an annual a fixed amount for analytical data pertaining to BlackRock proprietary ETFs on LPL’s platform during the term of the agreement. BlackRock Investment Management, LLC, an affiliate of BlackRock, is one of the Portfolio Strategists available in the Program. BlackRock is also affiliated with mutual funds and ETFs that may be included in the Portfolios it designs and those model portfolios designed by LPL or the other Portfolio Strategists. Because LPL benefits from these payments, the amount of which is significant, LPLE’s financial interests conflict with its ability to use strictly objective factors in making the selection and retention of a BlackRock affiliate as a Portfolio Strategist and its selection of ETFs in its Portfolios. However, LPL and LPLE did not agree to guarantee that BlackRock’s affiliated Portfolios will be used for any MWP client account. In addition, LPL, LPLE and the other Portfolio Strategists are not required to include BlackRock-affiliated funds or ETFs in their Portfolios. The BlackRock affiliate is required to satisfy the same review as all other third-party Portfolio Strategists. LPL has sole discretion to select Portfolio Strategists that are made available in MWP. 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. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 27  Model Wealth Portfolios (MWP) Program Form Brochure 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 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 MWP than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in MWP 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 MWP at a lower overall fee rate than the fee rate for a program offering a third-party manager. 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 A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 28  Model Wealth Portfolios (MWP) Program Form Brochure 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 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. Some of these financial institutions are affiliated with investment advisory firms that act as a Portfolio Strategist. An IAR offering advisory services on the premises of a financial institution has a potential conflict of interest when the IAR recommends that clients utilize an affiliated Portfolio Strategist because the financial institution has the ability to influence the IAR’s compensation and employment status. However, an IAR may only recommend a model portfolio that they believe is in the best interest of clients. Affiliated Portfolio Strategists sometimes receive a reduced Manager Fee or do not receive a Manager Fee at all. This is often because the Portfolio Strategist has included proprietary or affiliated mutual funds or exchange-traded funds in the model portfolio which charges a separate fee. The absence of a Manager Fee creates a conflict of interest for the IARs insofar as IARs can negotiate a higher LPL Advisory Fee than they could for an account subject to a higher third-party Manager Fee. In addition, model portfolios benefit from having increased assets under management even if they do not charge a Manager Fee. Specifically, if your IAR is associated with the Prudential Insurance Company of America (PICA), you should note that certain model strategies created by PGIM Investments LLC (PGIM), an affiliate of PICA, are available in the Program. These models include mutual funds that are advised and/or sub-advised by affiliates of PICA (PICA Proprietary Funds). PICA Proprietary Funds can represent all of the investments in the portfolio. PGIM , as a Portfolio Strategist, has an incentive to select PICA Proprietary Funds for its models due to the compensation and benefits it and/or its affiliates receive(s). As a Portfolio Strategist, PGIM does not charge a Manager Fee for PGIM model strategies, but PGIM is compensated by the fees associated with the underlying PICA Proprietary Funds it selects for the strategies. Your IAR has an incentive to select the PGIM model strategies for your account due to their association with PICA, which can influence their compensation or terminate their relationship altogether. However, your IAR may only recommend a model strategy that he or she believes is appropriate for you and in your best interest. Qualified retirement accounts receive a credit in an amount equal to the mutual fund advisory and administrative services fees that PICA affiliates receive in connection with the affiliated mutual funds held in the account. In addition, PGIM has ownership interests in other SEC-registered investment advisers. In the future, your IAR may offer products or utilize a Portfolio Strategist from these investment advisers. However, PGIM will not charge retirement accounts that utilize these investments advisers a Manager Fee. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 29  Model Wealth Portfolios (MWP) Program Form Brochure 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 MWP 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 broker-dealer to execute transactions in an MWP 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission or transaction charge for executing transactions in MWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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 to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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. Subadvisers who have discretion to trade fixed income Portfolios for clients may choose to place some or all trades for accounts with broker-dealer firms other than LPL (“trade away” or “step out”). This practice may enable a Subadviser to obtain more favorable execution, including a more advantageous net price, than would otherwise be available. If a Subadviser chooses to execute a transaction through a broker-dealer other than LPL, the execution price will usually include fees or expenses imposed by the executing broker-dealer, which the client will bear, in addition to the account fee paid to LPL. The additional expenses charged by the broker-dealer executing the transaction include mark-ups, mark-downs or “spreads” paid to the executing broker dealer firm, which are typically embedded in the purchase or sale price of such transactions, and not separately indicated on trade confirmations and custodial account statements provided by LPL. In evaluating whether to execute a trade through a broker-dealer other than LPL, a Subadviser will consider the fact that an account will not be charged additional trading expenses if effected directly through LPL. Clients should understand that LPL is not able to fully evaluate whether a Subadviser is meeting its best execution obligations to clients for specific transactions when trading away, as it is not a party to trading away transactions and is not in a position to negotiate the price or transaction related charges with the executing broker. The responsibility to determine whether to trade away lies with the Subadviser and is subject to the Subadviser’s fiduciary duty to clients. 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 A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 30  Model Wealth Portfolios (MWP) Program Form Brochure 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, 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 their 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 their IAR, the client should contact that IAR or LPLE at lplfinancial.adv@lplfinancial.com. A11 – LPLE – 0326 LPL Financial, member FINRA/SIPC 31 

Optimum Market Portfolios (OMP) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. 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. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non- purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. Item 9 was also updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 1  Guided Wealth 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 its 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 Research 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 2  Optimum Market Portfolios Program Brochure 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 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). A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 3  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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 4  Optimum Market Portfolios Program Brochure 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 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 its 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 • 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: – type and size of the account – 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. 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. • 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.” A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 5  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 Research. 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 Research 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. • 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 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. A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 6  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. • 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. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their IAR of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non- partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 7  Optimum Market Portfolios Program Brochure A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL for the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • 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. • 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 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. • 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 8  Optimum Market Portfolios Program Brochure 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. 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 9  Optimum Market Portfolios Program Brochure 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: • 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 10  Optimum Market Portfolios Program Brochure 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, 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). • 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 11  Optimum Market Portfolios Program Brochure $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). 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, 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. A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 12  Optimum Market Portfolios Program Brochure 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 Research 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 Research. In addition, employees in LPL Research 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 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 13  Optimum Market Portfolios Program Brochure 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 or the LPL Deposit Cash Account (DCA) Program, 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 IARs 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. 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 14  Optimum Market Portfolios Program Brochure 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 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. 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. 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. • 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 15  Optimum Market Portfolios Program Brochure 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. The compensation that LPL receives related to ICA and DCA (including from any overflow mechanisms) is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to ICA and DCA 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 or DCA. However, the compensation LPL receives on ICA and DCA 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. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s collateralized lending program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if client selects a bank instead 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. Neither LPL, LPLE nor your LPLE IAR receive loan-based compensation if you borrow through a non-partner bank. 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 maintenance 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, or alternatively, could incentivize IARs to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures and “Third Party Compensation and Related Conflicts of Interest.” A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 16  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. 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 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 receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to LPL, LPLE and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to LPL, LPLE and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. LPL, LPLE and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 17  Optimum Market Portfolios Program Brochure 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 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 Account 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 A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 18  Optimum Market Portfolios Program Brochure 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 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. A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 19  Optimum Market Portfolios Program Brochure 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. 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. A12 – LPLE – 0326 LPL Financial, member FINRA/SIPC 20 

Personal Wealth Portfolios (PWP) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 This wrap 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 31, 2025. Items 6 and 9 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. Item 9 was updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts and 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.......................................................................................................................................................... 2 Item 4: Services, Fees and Compensation ............................................................................................................................... 2 Item 5: Account Requirements and Types of Clients .............................................................................................................. 7 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................. 7 Item 7: Client Information Provided to Portfolio Managers................................................................................................. 15 Item 8: Client Contact with Portfolio Managers ................................................................................................................... 15 Item 9: Additional Information ............................................................................................................................................... 15 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 1  Personal Wealth Portfolios Program Brochure Item 4: 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 advisor firms, including LPLE, and its associated persons. This Brochure provides a description of LPL’s Personal Wealth Portfolios (PWP) program when offered through LPLE. For more information about LPL’s advisory services and programs other than PWP, 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 PWP Program is a unified managed account program in which LPL and LPLE provide ongoing investment advice and management. In PWP, clients invest in asset allocation portfolios (Portfolios) designed by LPL’s Research Department (LPL Research), which include a combination of mutual funds, exchange-traded funds (ETFs) and investment models ( Models) provided to LPL by third party money managers (PWP Advisors). The Models typically consist of equity and fixed income securities, but may include investment company securities. LPL Research selects the mutual funds, ETFs and Models to be made available in a Portfolio. 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 its IAR, selects a Portfolio based on client’s investment objective and then selects among the mutual funds, ETFs and/or Models available in the Portfolio. LPL has discretionary authority to purchase and sell securities in the account. The client authorizes LPL to take discretion by executing the Account Agreement and Application. LPL coordinates trades among the various securities and sleeves of a PWP account. After a PWP account is opened, and upon deposit of funds by the client, LPL will invest the client’s funds based on the Portfolio selected. It generally will take up to 5 business days from the date the account is fully funded for all assets to be fully allocated across the Portfolio. In certain cases, it may take longer to allocate assets to fixed income securities because of market conditions or the illiquid nature of certain issues. In the case of municipal security Models (Muni Models), it typically can take between 30 to 90 days for the Model to be fully invested. Subsequent deposits accumulate and will not be invested in the Portfolio until certain conditions are met, including conditions related to trade size and position deviation from the target allocation. During the normal course of business, LPL reviews accounts on a daily basis and executes trades as needed. In addition, each year on the anniversary date of the initial account asset allocation, LPL will examine if any particular asset class in an account has drifted beyond a tolerance limit and determine if the account should be rebalanced to be within acceptable asset allocation tolerances. Except as described below for Muni Models, the role of the PWP Advisors is limited to submitting Models to LPL, who has discretion over trade execution. However, if a Portfolio is selected that includes a Muni Model, the PWP Advisor for that Model will have discretionary trading authority with respect to the purchase and sale of fixed income securities A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 2  Personal Wealth Portfolios Program Brochure for the portion of the account invested according to the Muni Model (Muni Sleeve). Although the PWP Advisor has discretion over the Muni Sleeve, LPL has ultimate discretion over the entire account and may exercise discretion over securities in the Muni Sleeve (e.g., to rebalance the Account or to liquidate securities for withdrawal requests). LPL may appoint from time to time other PWP Advisors to take discretion over a portion of the account managed according to that PWP Advisor’s Model. In connection with the program, LPL also acts as custodian to accounts, provides research information to LPLE and its IARs, provides brokerage services as the broker-dealer on transactions, and performs administrative services, such as performance reporting. LPL and LPLE provide advisory services tailored to the individual needs of the clients. LPL reviews accounts on a daily basis for rebalancing. LPL accommodates reasonable requests to restrict holdings of specific securities, specific industries, specific sectors, and certain pre-defined categories (e.g., “sin” stocks). In the event that client restrictions prevent the investment in certain securities otherwise recommended by a PWP Advisor, assets will be invested pro- rata across the remaining securities in the Model. Such restrictions do not apply to any mutual funds, ETFs or fixed- income securities that may be held in the account. Restrictions placed on an account may affect the performance of the account. LPL may choose not to accept an account with restrictions that are inconsistent with the investments chosen by LPL or as recommended by the PWP Advisor. LPL accommodates requests to perform tax harvesting, which may include using the proceeds of tax-related transactions to purchase appropriate securities (such as ETFs) for an account. In such case, proceeds of tax-related transactions may be held in cash or securities until appropriate wash sale periods have expired. Once the wash sale period has expired, the related proceeds will be invested according to the Portfolio selected. Similarly, LPL may delay a tax harvesting request to sell securities acquired in the previous 30 days until the wash sale period has expired. In certain circumstances, LPL also accommodates requests for all or a portion of the account to remain allocated to cash for a period of time. After the expiration of that time period, LPL will reinvest the Account according to the model portfolio selected. Such customized requests and changes to and withdrawals from the Portfolios selected may take up to 5 business days to process, and, in certain circumstances, may take longer. As LPL generally has discretion to implement a Model, an account’s holdings may differ from the Model submitted. For example, LPL may limit small trades (defined by minimum dollar amounts, share amounts, percentage of account, or percentage of individual asset class). In addition, due to market conditions or the illiquid nature of certain issues, there may be times when LPL will not be able to invest in specific taxable fixed income securities that appear in a Model. In those circumstances LPL will attempt to invest in fixed income securities with similar characteristics as those in the Models. For clients in California and New York, if tax-free fixed income securities are selected for a Muni Model, the PWP Advisor will attempt to limit the fixed income securities purchased to state-specific, tax free fixed income securities; however, the PWP Advisor may also include non-state-specific securities. IARs may, in its sole discretion and as agreed from time to time with clients, provide financial planning or financial consulting services on behalf of LPLE 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 PWP Program pay an annualized fee (the “Account Fee”). The Account Fee is made up of an Advisory Fee and a Manager Fee. If LPLE, through its IAR, changes the PWP Advisor, investment strategy, or model portfolio selected for an account, or if the investment value of the account changes, the overall Account Fee may increase or decrease. LPL reserves the right to increase the upper limit of the Advisory Fee and/or Manager Fee range(s) upon 30 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 3  Personal Wealth Portfolios Program Brochure days’ prior notice to clients. LPL, LPLE, IARs, and PWP Advisors do not charge performance-based fees to accounts in the Program. Advisory Fee. The Advisory Fee is charged for the investment advisory services of LPLE, as well as the investment advisory, administrative, trading, custodial and clearing services of LPL. The Advisory Fee is shared with LPLE. The Advisory Fee is negotiable between the client and LPLE and is based on the value of assets in the account, including cash holdings, and is payable quarterly in advance. The maximum Advisory Fee is 2.35%. LPL retains a portion of the Advisory Fee, up to 0.675% of the value of the account for its administrative, custody and clearing services, and the portfolio design services of LPL Research. LPLE shares between 90% and 100% of the remaining portion of the Advisory Fee with the unaffiliated financial institution with which IAR is associated, or its affiliate, based on the agreement between LPLE and the financial institution. Manager Fee. Depending on the PWP Advisor selected, clients pay a Manager Fee for a PWP Advisor that is set by the PWP Advisor. The Manager Fee will differ depending on the PWP Advisor selected for the Account and may also differ depending on which investment strategy or model portfolio is selected. Clients do not pay LPL or LPLE brokerage commissions or transaction charges for the execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” The Manager Fee is based on the value of the assets in the Portfolio advised by the PWP Advisor, including cash holdings, and payable quarterly in advance. The Manager Fee currently ranges from 0.15% to 0.60%. For certain models designed by LPL, LPL will pay up to 0.02% of the Manager Fee to market index providers as a licensing fee. Where LPL retains portions of the Manager Fee for trading services, there is a conflict of interest for LPLE to recommend such models that benefit its affiliate. LPLE and its IARs do not receive any portion of the Manager Fee, including based on recommending a model for which LPL retains this compensation. Please note that if the Account includes more than one model, the applicable Manager Fee rate applies to the assets invested in that model. The fees paid by LPL to PWP Advisors in the program out of the Manager Fee are generally less than a PWP Advisor would charge a client seeking to establish a direct relationship outside of a wrap program. This is principally due to the fact that LPL absorbs many of the billing, administrative, trading and marketing expenses that would otherwise be borne by the PWP Advisor and the role of the PWP Advisor is generally limited to providing models to LPL. PWP Advisors generally have higher minimum account size requirements when managing direct accounts and higher fees when the PWP Advisor bears those expenses. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a PWP account from the account. LPL retains amounts described under “Fee Schedule” for services provided and pays the applicable portion of the Advisory Fee to LPLE and unaffiliated financial institutions with whom LPLE has agreements described herein, and the applicable portion of the Manager Fee to the PWP Advisors whose models are selected for 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 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). A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 4  Personal Wealth Portfolios Program Brochure Other Types of Fees and Expenses of LPL In addition to the Account Fee, clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that may apply to a PWP 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. Clients do not pay LPL or LPLE brokerage commissions, markups or transaction charges for execution of transactions in addition to the Account Fee. For more information, see below under “Additional Information – Brokerage Practices.” Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL and LPLE that apply to investments in PWP accounts. Some of these fees and charges are described below. In PWP, assets may be invested in mutual funds or ETFs 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 fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that may vary depending on the performance of the fund. Client also will pay the Account Fee with respect to assets invested in ETFs and mutual funds. The mutual funds and ETFs available in the Program 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, LPLE, LPLE IARs, and the PWP Advisors, and by making their own decisions regarding the investment. 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” If client transfers into a PWP 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 PWP model. 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. When transferring securities into a PWP account, client should be aware that certain securities are not be eligible for the account. In such case, the securities will 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 a PWP account, client should understand that an A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 5  Personal Wealth Portfolios Program Brochure 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: • 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. For those Portfolios consisting of mutual funds, LPL selects only no-load and load-waived mutual funds. Some mutual funds and Program Share Classes in PWP charge shareholders an asset-based fee, known as a “12b-1” fee, to cover distribution expenses and, in some cases, shareholder servicing expenses. A portion of such 12b-1 fees will ultimately be paid to LPL by the funds. Any 12b-1 fees paid to LPL by funds will be credited to the client’s account. As described below under “Additional Information – Brokerage Practices,” if a PWP Advisor for a Muni Model chooses to execute a transaction through a broker-dealer other than LPL, the execution price to the client may include a commission, markup/markdown, or other fee imposed by the executing broker-dealer in addition to the Account Fee. If client holds an American Depositary Receipt (“ADR”) in an account, there are custodial fees or taxes related to the ADR. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Important Things to Consider About Wrap Fees on a PWP Account: • The Account Fee is an ongoing fee for investment advisory services, the execution of transactions and other administrative and custodial services. The Account Fee may cost the client more than purchasing the program services separately, for example, paying a separate advisory fee for each of the services of LPL, LPLE and the PWP Advisor, 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: – type and size of the account – type and number of securities in the Portfolio (whether equities, fixed income securities, mutual funds or ETFs) – 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. LPLE, through its IAR, is responsible for determining the Advisory Fee to charge each client based on factors such as total amount of assets involved in the relationship, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, and the 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 Advisory Fee with LPLE through IAR. • LPLE and IAR receive compensations 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 6  Personal Wealth Portfolios Program Brochure 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. • The investment products available to be purchased in the Program can be purchased by clients outside of a PWP account, through broker-dealers or other investment firms not affiliated with 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 $250,000. In certain instances, LPL will permit a lower minimum account size. An account will not be invested according to the Portfolio until the minimum account size and the targeted funding value of the account 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 ERISA, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. Item 6: Portfolio Manager Selection and Evaluation In PWP, LPL and LPLE are responsible for the overall investment advice and management services offered to clients, and the client selects the LPLE IAR who manages the account. Each IAR is generally required to possess a FINRA 65 or 66 license (to the extent required). For more information about IAR managing the account, client should refer to the Brochure Supplement for the IAR, which client should have received along with this Brochure at the time client opened the account. LPL makes available Models designed by PWP Advisors. LPL selects and reviews on an ongoing basis the PWP Advisors available on PWP based on quantitative, qualitative and infrastructure criteria, which include: Quantitative Criteria LPL evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style group, including but not limited to: • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 7  Personal Wealth Portfolios Program Brochure Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP Advisor can handle operational requirements including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable • Back office review • Client servicing resources • Firm-wide program commitment LPL reviews PWP Advisors currently participating in the program and reviews new PWP Advisors prior to the addition of their Models to the program. LPL may elect to remove a PWP Advisor should it determine that the PWP Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in management staff). In making a decision to remove a PWP Advisor, LPL Research takes into consideration all criteria; no one criteria is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove a PWP Advisor. PWP Advisor Performance LPL Research uses information provided by the PWP Advisor and also may use independent, third-party databases when evaluating a PWP Advisor. In order for a PWP Advisor to be selected for the program, LPL generally requires a third-party verification letter related to compliance of the PWP Advisor’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performance. However, LPL provides clients with individual performance information. Performance information is prepared by LPL using portfolio accounting and reporting software. Client performance information is calculated on a uniform and consistent basis using a time weighted basis. It is important to note that PWP Advisors provide Models to LPL, and, except in the case of Muni Models, LPL is the party with discretion for trade implementation and execution in PWP accounts. Therefore, Models submitted to LPL by PWP Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisor. Because of this fact and because LPL (and not the PWP Advisor) has discretionary authority to implement trades, performance of a PWP account will differ from the performance of PWP Advisor’s discretionary accounts. Performance information is intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to investment indices. LPL Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL Research. LPL Research provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs. LPL Research designs different types of Portfolios for PWP 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 Research uses various investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 8  Personal Wealth Portfolios Program Brochure Standard Portfolios, for example, for investors who wish to allocate to mid caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL Research determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify LPLE of the change in status and provide alternatives for the account from which LPLE, through IAR, will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. Types of Investments and Risks The Portfolios include different types of securities, such as mutual funds, closed end funds, ETFs, ETNs, and equity and fixed income securities. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the Program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. ‐ • 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 9  Personal Wealth Portfolios Program Brochure 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors. An individual sector, industry, or sub ‐ ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. ‐ • Alternative Strategy Mutual Funds. Certain mutual funds available in the Program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or unit investment trusts. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Closed-End Funds. Clients should be aware that closed-end funds available within the Program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 10  Personal Wealth Portfolios Program Brochure shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows: The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax-managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPL and LPLE cannot guarantee that the dividend yield in your portfolio will accurately track a market index. • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (Single Inverse ETPs), futures-linked ETPs (Futures Linked ETPs) and cryptocurrency-related ETPs (Cryptocurrency ETPs). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 11  Personal Wealth Portfolios Program Brochure returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the- counter markets and may not be afforded all of the investor protections of other ETPs. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (SCA) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their IAR of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non-partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a maintenance call) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities-based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 12  Personal Wealth Portfolios Program Brochure paid to LPL the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • 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. • 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 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. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 13  Personal Wealth Portfolios Program Brochure 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL and LPLE generally will earn more compensation for selling one investment product than another. As a result, LPL and LPLE have a conflict of interest because of the financial incentive to recommend investment products that pay more compensation if a less expensive comparable product could be used to achieve a customer’s investment objective. Voting Client Securities Unless a client instructs otherwise, LPL will vote proxies on the client’s behalf. LPL has adopted policies and procedures to in order for LPL to vote securities in the best interest of clients. LPL engages third party vendor(s) to make proxy voting recommendations and handle the administrative functions of voting proxies. Although LPL retains authority to vote client proxies, it is LPL’s general policy to vote according to the recommendations of its third-party proxy advisor vendor, so long as LPL reasonably determines that doing so is in the client’s best interest. Any exceptions to this general policy are referred to LPL Research, which makes the determination as to whether or how to vote the proxy in accordance with the best interest of the client. If the client is an employee benefit plan subject to ERISA, LPL will vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. 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. In the case of voluntary corporate actions, LPL intends to follow the instructions or default election of the PWP Advisors without reviewing individual client interests, unless LPL determines that such instructions are overtly contrary to our client’s best interest. In such case, LPL will determine whether or how to act consistent with the best interests of our clients. LPL, LPLE and the PWP Advisors are not obligated to render any advice or take any action on behalf of a client with respect to any legal proceedings, including bankruptcies, involving securities or other investments held in the account, or the issuers thereof. The client retains the right and obligation to take action with respect to legal proceedings relating to securities held in the account. A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 14  Personal Wealth 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 an appropriate investment objective 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. Because the PWP Advisor’s role generally is limited to providing Models to LPL, and the PWP Advisor does not provide individualized discretionary advisory services to PWP clients, LPL generally does not communicate specific client information to PWP Advisors. However, in the case of PWP Advisors for the Muni Models, the PWP Advisor does provide individualized discretionary advisory services with respect to the Muni Sleeve. If a Muni Model is selected, LPL forwards client information from the Account Application to the PWP Advisor. If client communicates to LPLE, through its IAR, regarding material changes in the client’s financial circumstances, investment objectives or investment restrictions, such information is forwarded to the PWP Advisor for the Muni Model. Clients may communicate such information to LPLE, through its IAR, or otherwise communicate directly with the PWP Advisor, although clients are encouraged to direct communication through their IAR. 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 IARs. Because the PWP Advisor’s role generally is limited to providing Models to LPL, and the PWP Advisor does not provide individualized discretionary advisory services to PWP clients, PWP Advisors generally are not available to be contacted or consulted by PWP clients. However, in the case of PWP Advisors for the Muni Models, the PWP Advisor does provide individualized discretionary advisory services with respect to the Muni Sleeve. If a Muni Model is selected, clients may consult directly with the PWP Advisor, although clients are encouraged to direct contact with the PWP Advisor through LPL or LPLE. 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 15  Personal Wealth Portfolios Program Brochure 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 was 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 16  Personal Wealth Portfolios Program Brochure 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, 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). • 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 17  Personal Wealth Portfolios Program Brochure 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). 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 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. 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, 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 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 and LPLE. FTC provides custodial and various other recordkeeping and services to IRAs and certain employer-sponsored plans maintained through non-PWP 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 program, and uses LPL or LPLE as the registered 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. 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. A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 18  Personal Wealth Portfolios Program Brochure 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 IARs. The code of ethics permits employees and 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. In addition, employees in LPL Research 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 and LPLE 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 LPL’s parent company, LPL Holdings Inc., is a publicly traded company. PWP Advisors are not prevented from purchasing LPL Financial Holdings Inc. stock in PWP accounts. In addition, a PWP account may include a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. Purchases of mutual fund shares are typically 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. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL and LPLE do not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements Some mutual funds and Program Share Classes in PWP charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b-1 fees paid to LPL by mutual funds will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of PWP clients. These services include establishing and maintaining accounts with the 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. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 19  Personal Wealth Portfolios Program Brochure The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of PWP client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by PWP clients in the fund (up to $25 per position). 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 ETPs, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per fund and up to $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. For UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with LPLE or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (sponsors) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee based on the amount of client sales or assets invested in the sponsor’s products or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL and LPLE IARs so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to 0.15% annually, or $1,000,000. LPL does not accept revenue sharing fees for assets held in retirement accounts. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 20  Personal Wealth Portfolios Program Brochure of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with LPLE or the IAR who selects or recommends the investment products for client accounts. The revenue that LPL receives 12b-1 fees, recordkeeping compensation, and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of funds and share classes for a Portfolio in the case of Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable product or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable fund or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL and LPLE to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds, and therefore, LPL and LPLE do not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees, or revenue sharing payments with LPLE, its IARs or PWP Advisors, and therefore, there is no financial incentive for LPLE, its IARs, or a PWP Advisor to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation, and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments with LPLE or its IARs, such fees and payments will increase LPL’s profits and indirectly benefit LPLE and its 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. 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 or the LPL Deposit Cash Account (DCA) Program, 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 IARs 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. 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 21  Personal Wealth Portfolios Program Brochure rates for ICA and DCA,. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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 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. 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. 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 22  Personal Wealth Portfolios Program Brochure DCA as the sole service option for certain account types, in part because of the additional compensation LPL earns from the use of DCA. • 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. The compensation that LPL receives related to the ICA and DCA (including from any overflow mechanisms) is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to the ICA and DCA 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 or DCA. However, the compensation LPL receives on ICA and DCA is retained by LPL and is not shared with LPLE or its IARs. LPL Research does not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. Collateralized Lending Program LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s collateralized lending program, and can work directly with non-partner 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 lender, whether LPL, a partner bank or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the collateralized lending program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with LPLE or its IARs, and therefore, IARs of LPLE do not have a direct financial incentive if one bank is selected over another. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. LPLE and its IARs 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 23  Personal Wealth Portfolios Program Brochure should liquidate assets or instead hold their securities investments and utilize a line of credit secured by assets in their account. Because LPLE and its IARs are compensated primarily through advisory fees paid on clients’ accounts, LPLE 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 maintenance 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, or alternatively, could incentivize IARs to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “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 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 sends 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 PWP Advisors reimburse LPL for costs associated with the use of technology necessary for a PWP Advisor to perform its services under the Program. LPL and LPLE employees and their IARs also receive additional compensation from product sponsors, such as a PWP Advisors. Such compensation may not be tied to the sales of any products or services. Compensation may include 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 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. LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to LPL, LPLE and its IARs. A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 24  Personal Wealth Portfolios Program Brochure These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to LPL, LPLE and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. LPL, LPLE and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL and LPLE employees and their IARs provide sales support resources to IARs of LPLE that use LPL advisory programs. The compensation that LPL and LPLE pay to these employees varies based on the assets in LPL’s different advisory programs. These sales employees have an incentive to promote PWP 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 typically remain in free credit balance. In such cases, 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 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. A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 25  Personal Wealth Portfolios Program Brochure 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 PWP than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in PWP 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 PWP at a lower overall fee rate than the fee rate for a program offering a third-party manager. 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 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 A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 26  Personal Wealth Portfolios Program Brochure 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. Specifically, if your IAR is associated with the Prudential Insurance Company of America (“PICA”), you should note that certain model portfolios created by PGIM Investments LLC (“PGIM Investments”), an affiliate of PICA, are available in the Program. These model portfolios include mutual funds that are advised and/or sub-advised by affiliates of PICA (“PICA Proprietary Funds”). PICA Proprietary Funds can represent all of the investments in the portfolio. PGIM Investments, as a Model Advisor, has an incentive to select PICA Proprietary Funds for its models due to the compensation and benefits it and/or its affiliates receive(s). As a Model Advisor, PGIM Investments does not charge a Manager Fee for PGIM Investments model strategies, but PGIM is compensated by the fees associated with the underlying PICA Proprietary Funds it selects for the strategies. Your IAR has an incentive to select the PGIM model portfolios for your account due to their association with PICA, which can influence their compensation or terminate their relationship altogether. However, your IAR may only recommend a model portfolio that he or she believes is appropriate for you and in your best interest. Qualified retirement accounts receive a credit in an amount equal to the mutual fund advisory and administrative services fees that PICA affiliates receive in connection with the affiliated mutual funds held in the account. 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 PWP 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 broker-dealer to execute transactions in a PWP 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 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. Therefore, directed brokerage may cost clients more money. However, clients should understand that LPL is not paid a commission for executing transactions in PWP accounts. In addition, in the case of mutual funds, execution is made at the net asset value of the 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 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. If a Portfolio is selected that includes a Muni Model, the PWP Advisor will have discretion to purchase and sell securities in the Muni Sleeve of the account. In connection with its duty to seek to achieve best execution, the PWP Advisor may choose to execute transactions through a broker-dealer other than LPL. In such case, the execution price may include A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 27  Personal Wealth Portfolios Program Brochure a commission, markup or markdown, or other charges in addition to the Account Fee. Clients should read and understand the brokerage practices and other disclosures in the Firm Brochure of the PWP Advisor for the Muni Model. LPL will aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. 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. 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 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 investment advice provided for your account. For more information about the IAR 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 the account. If you did not receive a Brochure Supplement for your IAR, please contact your IAR or LPLE at lplenterprise.adv@lplfinancial.com. A9 – LPLE – 0326 LPL Financial, member FINRA/SIPC 28 

Strategic Asset Management (SAM) Program Brochure LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 March 31, 2026 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 31, 2025. Items 8 and 11 were updated to disclose risks and conflicts of interest related to a client using securities in advisory accounts as collateral for non-purpose loans through an LPL Secured Credit Account, which is a security-based lending program available through LPL. Item 11 was also updated to reflect the removal of the Money Market Mutual Fund Sweep Program previously available to a limited group of eligible Accounts. Item 12 was updated to include additional information about LPL’s Dividend Reinvestment Program (DRP) A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 1  Strategic Asset Management (SAM) Program Brochure Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................................... 1 Item 2: Material Changes .......................................................................................................................................................... 1 Item 3: Table of Contents.......................................................................................................................................................... 2 Item 4: Advisory Business ......................................................................................................................................................... 2 Item 5: Fees and Compensation ............................................................................................................................................... 4 Item 6: Performance Based Fees and Side-by-Side Management ..................................................................................... 12 Item 7: Types of Clients ........................................................................................................................................................... 13 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................... 13 Item 9: Disciplinary Information ............................................................................................................................................. 22 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................... 24 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................... 25 Item 12: Brokerage Practices .................................................................................................................................................. 30 Item 13: Review of Accounts................................................................................................................................................... 31 Item 14: Client Referrals and Other Compensation .............................................................................................................. 31 Item 16: Investment Discretion ............................................................................................................................................... 34 Item 17: Voting Client Securities ............................................................................................................................................ 34 Item 18: Financial Information ............................................................................................................................................... 35 Item 4: Advisory Business Introduction LPL Financial LLC (LPL) is an investment adviser registered with the SEC pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”). LPL has provided advisory services as a registered investment adviser since 1975. Note that registration as an investment adviser with the SEC does not imply a certain level of skill or training. As of December 31, 2025, LPL managed approximately $818,320,000,000 of client assets on a discretionary basis and approximately $797,900,000 of client assets on a non-discretionary basis. LPL is owned 100% by LPL Holdings, Inc., which is owned 100% by LPL Financial Holdings Inc., a publicly held company. Types of Advisory Services LPL sponsors various types of advisory programs, including wrap fee programs and mutual fund asset allocation programs and an advisor-enhanced digital advice program. 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 Strategic Asset Management program (“SAM” or “Program”) when offered through LPLE. In instances where programs are sponsored by affiliates, such as this Program, affiliates are compensated for performing 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 SAM, 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/. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 2  Strategic Asset Management (SAM) Program Brochure LPLE’s advisory services are made available to clients primarily through individuals associated with LPLE as investment adviser representatives (“IARs”). For more information about the IAR providing advisory services, client should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time the client engages the IAR. If client did not receive a Brochure Supplement for the IAR, client should contact the IAR or LPL at lplfinancial.adv@lpl.com. 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 you 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, investments, programs or services. Please ask your IAR whether any limitations apply. In the Program, LPLE, through its IARs, provides ongoing investment advice and management of assets in the client’s account. LPLE, through its IARs, provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes ("ETNs"), interval funds, variable annuity subaccounts, business development companies (“BDCs”), private equity, real estate investment trusts (“REITs”), equities, and fixed income securities. LPLE, through its IARs, provides advice that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients may impose restrictions on investing in certain securities or groups of securities by contacting their IAR and providing the necessary written instructions. LPLE, through its IAR, obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective 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, clients are reminded that they should 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 be aware 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. Clients should further be aware that achievement of the stated investment objective is a long-term goal for the account. LPL acts as custodian to accounts, provides research information to LPLE and its IARs, provides brokerage and execution 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. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 3  Strategic Asset Management (SAM) Program Brochure Item 5: Fees and Compensation Fee Schedule Clients in the SAM Program pay LPL and LPLE an annualized fee (Account Fee) for the investment advisory services of LPLE, as well as the administrative, custody and clearing services of LPL. The Account Fee is negotiable between the client and LPLE and is typically a straight percentage based on the value of all assets in the account, including cash holdings, but excluding certain assets that are not billed upon in certain instances, and payable quarterly in advance. The maximum Account Fee is 2.50%. Upon request, the Account Fee may be structured on a tiered basis and/or grouped basis, with a reduced percentage rate based on reaching certain thresholds in the Account or in a group of eligible advisory accounts. LPL reserves the right to increase the upper limit of the Account Fee upon 30 days’ prior notice to clients. LPL, LPLE and IARs do not charge performance-based fees to accounts in the SAM program. LPL retains a portion of the Account Fee, up to 0.20%, which is not shared with LPLE or IAR, for its administrative, custody and clearing services. A portion of the Account Fee is then shared with third parties, including the financial institution with which your IAR is associated. LPLE shares between 90% and 100% of the remaining portion of the Account Fee with the unaffiliated financial institution with which IAR is associated, or its affiliate, based on the agreement between LPL and the financial institution. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with a Program account from the account. LPL retains amounts described above under “Fee Schedule” for services provided and pays the applicable portion of the Advisory 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 their IAR. The Account Fee for certain alternative investments (such as non-exchange traded REITs, BDCs or hedge funds, each a “Non-Traded Alternative Investment”) is calculated based on unaudited net asset values provided as estimates by the sponsor of the Non-Traded Alternative Investment (such unaudited net asset values, a “Fair Value”). Fair Values are provided by Non-Traded Alternative Investment sponsors on a reporting period basis, such as monthly or quarterly. LPL does not audit or confirm the accuracy of the Fair Values provided by the sponsors of Non-Traded Alternative Investments. Sponsors of Non-Traded Alternative Investments do not adjust previously determined Fair Values. The portion of the Account Fee calculated on a Non-Traded Alternative Investment reflects the Fair Value of the prior reporting period and will not reflect the current net asset value of the Non-Traded Alternative Investment as of the date of the Account Fee’s calculation. 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). Other Types of Fees and Expenses of LPL LPL charges fees related to a Program account in addition to the Account Fee. • In the Program, clients do not pay brokerage commissions to LPL, LPLE or IAR for transactions in the account; however, the client pays LPL a transaction charge for the purchase and sale of certain securities in the account. The transaction charges are set out in the Account Agreement and the Miscellaneous Account and Service Fee Schedule-Advisory. The transaction charges are paid to LPL to defray costs associated with trade A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 4  Strategic Asset Management (SAM) Program Brochure execution; however, they are not directly related to transaction-related expenses of LPL and are a source of revenue to LPL. Transaction charges present conflicts of interest. For example, transaction charges vary depending on the type of security being purchased or sold (e.g., $7 for equities, $50 for fixed income), and therefore LPL earns more from transactions that result in an investment with a higher charge. In addition, where transaction charges apply, the more transactions a client enters into, the more compensation LPL receives. Transaction charges will not reduce the Account Fee you pay. Transaction charges are not shared with LPLE or IARs. In the case of mutual funds and ETFs, the transaction charges vary depending on the fund purchased or sold. For more information, see the section of this Item 4 titled “Understanding Share Classes and Transaction Charges in SAM Accounts”. • In the Program, the IAR may also separately agree with clients to bear the transaction charges for purchases and sales of certain securities in the account. If the IAR pays the transaction charges in an account, there is a different conflict of interest than if the client pays the transaction charges. Clients should understand that the cost to IAR of transaction charges will in certain instances be a factor that the IAR considers when deciding which securities to select and how frequently to place transactions in an account. For more information, see the section of this Item 5 titled “Understanding Share Classes and Transaction Charges in SAM Accounts” and the section of Item 12 titled “Brokerage Practices.” • LPL charges accounts with assets valued at less than $100,000 an additional $10 quarterly fee at the end of the quarter. • Clients that hold hedge funds, managed futures, BDCs, and certain REITs pay a processing fee per transaction and an annual alternative investment administrative fee per position, subject to a maximum per account per year. • If an account is approved for trading on margin and the client has entered into a margin agreement with LPL, the client will be charged margin interest on any credit extended to or maintained by the client. LPL will retain a portion of any interest charged. This interest charge is in addition to the Account Fee. The Account Fee is not charged on any margin debit balance, rather only on the net equity of the account. • Clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to a SAM 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 cash sweep fees, retirement account fees and termination fees, including, as applicable, an annual individual retirement account (“IRA”) maintenance fee, an annual qualified retirement plan maintenance fee, 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 miscellaneous fees are not directly based on the costs of the transaction or service by LPL, will include a profit to LPL in certain instances, and certain of the fees will be lowered or waived for certain customers. • LPL and LPLE, respectively, may waive any fee it charges to Client or IAR in its sole discretion in whole or in part. Fees Charged by Third Parties There are other fees and charges that are imposed by third parties other than LPL and LPLE that apply to investments in Program accounts. Some of these fees and charges are described below. If a client’s assets are invested in mutual funds, ETFs or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. As a shareholder of a fund, Client will pay an advisory fee to the fund manager and other expenses charged by the fund. In the case of mutual funds that are funds of funds, there could be an additional layer of fees, including performance fees that vary depending on the performance of the fund. Client will also pay the Account Fee with respect to assets invested in mutual funds, ETFs and other pooled products. The mutual funds, ETFs and other pooled funds available in the Program can be purchased directly outside of the Program. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of LPLE and IAR and by making their own decisions regarding the investment. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 5  Strategic Asset Management (SAM) Program Brochure 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, a portion of the fees and expenses charged by certain mutual funds in the Program will be paid to LPL. Other financial services firms 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. Clients should also understand that in many cases the share class offered for a particular mutual fund available through the Program (the “Program Share Class”) charges higher fees and expenses than other share classes that are offered by the same fund but are not available through the Program. Program Share Classes are selected by LPL, in certain cases, because the mutual funds pay to LPL a portion of the fees and expenses charged by Program Share Classes as compensation for the administrative and recordkeeping services LPL provides with respect to LPL clients who invest in the Program Share Classes, as discussed below under “Participation or Interest in Client Transactions.” 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 under a fund’s frequent trading policy, client will be charged a redemption fee. 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). If client holds a variable annuity as part of an account, there are mortality, expense and administrative charges, subaccount management fees, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. If a client holds a REIT or BDC as part of an account, there are dealer management fees and other organizational, offering and pricing expenses imposed by the REIT or BDC, as applicable. If client holds a UIT in an account, UIT sponsors charge creation and development fees or similar fees. Further information regarding fees assessed by a mutual fund, variable annuity, alternative investment (such as a REIT, BDC or hedge fund) or UIT is available in the appropriate prospectus or offering document, which is available upon request from LPLE or from the product sponsor directly. Important Information When Funding an Account Ineligible Securities. When transferring securities into a Program account, client should be aware that certain securities may 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 Program account. Surrender Charges or CDSCs. If client transfers a previously purchased investment into a Program account, such as a mutual fund, annuity or alternative investment, or liquidates the previously purchased investment and transfers the proceeds into an account, client may be charged a fee (sometimes called a “surrender charge,” “contingent deferred sales charge” or “CDSC”) upon the sale or redemption in accordance with the investment product’s prospectus. In many cases, the CDSC is only charged if a client does not hold the security for a minimum period of time. In particular, if a client transfers a previously purchased mutual fund (such as a Class C share) into an account that is subject to a CDSC, then the client will pay that charge when the mutual fund is sold. Previously Paid Commissions. Clients 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. Client should understand that, after the transfer into an account, an advisory fee will be charged based on the total assets in the account, including the transferred security. Depending on the share class and fee structure of the previously purchased mutual fund, LPL can receive fees such as 12b-1 fees, recordkeeping fees and revenue sharing from the previously purchased mutual fund until the position is liquidated and subsequently invested. In other words, if you paid IAR or another financial professional recently an upfront commission on the previously purchased security, you will be paying a new ongoing advisory fee going forward to IAR for advice on that same security. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 6  Strategic Asset Management (SAM) Program Brochure Loss of Benefits. If client will be funding the account with the proceeds of a sale or liquidation of an annuity, client should understand that client may be giving up guaranteed living or death benefits that were provided through the annuity, and will not be provided through a Program account. When transferring securities into an account, client should consider and speak to IAR about whether: • a CDSC will apply, and the length of time before the CDSC expires; • there will be a loss of a guaranteed benefit, in the case of an annuity; • 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. Clients also incur charges imposed by third parties or LPL in connection with investments made through their accounts, including, but not limited to, taxes and charges required by law or imposed by exchanges or regulatory bodies. For example, an industry-wide charge mandated by a regulator applies to sales of certain securities. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to LPL, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, LPL retains the excess. These charges will be reflected on transaction confirmations and/or periodic statements. Understanding Share Classes in SAM Accounts LPL makes available for purchase only one share class per mutual fund in the Program, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Program Shares”). Program Shares are no-load or load-waived share classes and therefore not subject to any upfront sales charge. A client also may transfer non-Program Share Classes into client’s account. Any 12b-1 fees received by LPL from mutual funds in the Program will be credited to the client account. Because the non-Program Share Class could have a higher overall expense ratio than the Program Shares, the non-Program Share class could cost the client more than Program Shares, even after the 12b-1 fees is credited to the account. Clients should understand that the Program Share class offered for a particular mutual fund through the Program in many cases will not be the least expensive share class that the mutual fund makes available. Program Share classes are selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Other financial services firms may offer the same mutual fund at a lower overall cost to the investor than is available through the Program. Understanding Transaction Charges in SAM Accounts Clients, when participating in the Program, should understand that LPL charges clients a transaction charge of $0, $4.50 or $26.50 for mutual fund purchases and redemptions. The applicable transaction charge varies depending on the amount of recordkeeping fees that LPL receives from the mutual fund and/or whether the sponsor of the mutual fund participates in LPL’s Mutual Fund No Transaction Fee Network (“MF NTF Network”) described below. When a mutual fund participating in the MF NTF Network is purchased in an account, the mutual fund’s sponsor directs a payment to LPL on behalf and for the benefit of the client that is used exclusively as a credit to defray the bona fide transaction charge obligations of the client’s account. When a participating mutual fund is sold in an account, LPL waives the transaction charge. Clients also should be aware that mutual funds participating in the MF NTF Network typically have higher ongoing internal expenses that can be used to offset payments made by sponsors for transaction charge waivers, and this can reduce the investment returns over time relative to other share classes of the same fund. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 7  Strategic Asset Management (SAM) Program Brochure The Program also offers an ETF No Transaction Fee Network (“ETF NTF Network”). LPL typically charges a transaction charge of $9 for transactions in ETFs, however, for certain ETFs in the ETF NTF Network, the ETF sponsors direct a payment to LPL on behalf and for the benefit of Client that is used as a credit to defray all or a portion of the bona fide transaction charge obligations of the Account. To the extent the sponsor does not pay the entire transaction charge amount, LPL waives the remaining portion to bring the cost to Client to $0. For purchases of other ETFs in the ETF NTF Network in the Program, the sponsor pays LPL a flat annual amount and/or a fee based on the non-retirement client account assets invested in ETF NTF Network funds, and LPL waives the transaction charge. In the case of certain of these fee arrangements, the sponsor pays LPL a combination of a flat fee and asset-based fee for ETFs. The asset-based fee paid to LPL for certain ETFs will be higher based on the ETF’s expense ratio. These arrangements present a conflict of interest because LPL has an incentive to select more expensive ETFs. In addition, as described in more detail below in Item 8, LPL’s Research Department (LPL Research) provides asset allocation model portfolios that LPLE, through its IARs, may use with clients. Certain of these model portfolios include ETFs participating in the ETF NTF Network that are more expensive and pay more fees to LPL. However, these conflicts are mitigated insofar as the sponsor fees are not shared with LPLE or the IAR who selects the ETFs for Client. For further details and an updated list of ETF sponsors for the ETF NTF Network, please refer to the Disclosures page on lpl.com/disclosures.html. The ETF NTF Network creates a conflict of interest because IAR has a financial incentive to select ETFs participating in the ETF NTF Network to avoid paying the transaction charges. Clients should consider such conflict when monitoring the purchase of ETFs in recognition of the overall fee and other arrangements with LPL, LPLE and IAR for management of the account. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of the account. In particular, clients should be aware that participating ETFs typically have higher ongoing internal expenses than other ETFs that can be used to offset payments made by sponsors for transaction charge waivers. To the extent that LPL receives from a sponsor of an ETF participating in the ETF NTF Network a flat fee or an asset-based fee that exceeds bona fide transaction charge obligations of the participating client accounts, the payment creates a conflict of interest as further described below as revenue sharing. When an IAR agrees to bear transaction charges on behalf of a client and a participating mutual fund or ETF is purchased in the account, the mutual fund or ETF sponsor defrays all or a portion of the transaction charge otherwise borne by the IAR, and LPL waives the remaining amount of the transaction charge. For all ERISA Accounts for which an IAR agrees to bear transaction costs on behalf of a client, LPL waives the transaction charge to the IAR when a participating mutual fund or ETF is purchased or sold. Transaction Charge Considerations When the client pays the transaction charges, an IAR may recommend greater volume of trading activity than when it has a financial incentive to limit such transactions. Moreover, clients should understand that engaging in frequent trading will result in paying more transaction charges and will increase the overall costs associated with the Account. These costs impact the performance of the Account. LPLE, through its IAR, has a conflict of interest insofar as it has a financial incentive to engage in trading for the Account to generate transaction charges for its affiliate, LPL. Clients should also note that the Account Fee being charged in the Program may take the payment of transaction charges into consideration. That is, the Account Fee charged to SAM accounts may be lower than the Account Fee charged to other types of accounts to the extent that the transaction charges are factored into the overall Account Fee charged to such accounts. If the IAR has agreed to pay transaction costs on behalf of the client, the cost to the IAR of transaction charges may be a factor that the IAR considers when deciding which securities, mutual funds or ETFs to select and whether or not to place transactions in the account. Similar to clients, the transaction charges borne by the IAR vary based on the type of transaction (e.g., mutual fund, ETF, equity or fixed income security). The IAR has a financial incentive to recommend transactions in certain securities that carry lower fees (e.g., transactions involving equity securities may be recommended over fixed income securities because of the lower transaction charge) or to limit the overall number of transactions it recommends to clients. In particular, the IAR has a financial incentive to select NTF Funds or ETFs that participate in the ETF NTF Network to avoid paying or to lower the transaction charges over others that may be A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 8  Strategic Asset Management (SAM) Program Brochure more suitable for the client. Clients should consider such conflict when monitoring the purchase of NTF Funds or ETFs that participate in the ETF NTF Network in recognition of the overall fee and other arrangements with LPL and IAR for management of the account. All such conflicts may have an impact on the investment performance of the client’s account. Mutual Fund 12b-1 Fees; Recordkeeping Services and Compensation; Revenue Sharing Arrangements; Other Product Related Compensation Some mutual funds and Program Share Classes in the Program charge shareholders a 12b-1 fee. To the extent a mutual fund or a Program Share Class charges a 12b-1 fee, the fee will be paid to LPL by the mutual fund. Any 12b- 1 fees paid to LPL by mutual funds that are held in Program accounts will be credited to the account. LPL performs recordkeeping, administrative and shareholder services on behalf of mutual funds and receives compensation for the services based on mutual fund holdings of Program clients. These services include establishing and maintaining accounts with the 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 the Program account. A type of recordkeeping service that LPL provides to certain mutual fund families is to process transactions on an omnibus basis, which means that LPL consolidates client trades into one daily trade with a fund, and maintains all pertinent shareholder information for the fund. In some cases, LPL earns recordkeeping compensation with respect to a Program Share Class but does not earn recordkeeping compensation, or earns less recordkeeping compensation, with respect to other share classes of the same fund that are not offered through the Program. The compensation LPL receives from a fund for recordkeeping, administrative and shareholder services is based on the amount of Program client assets that are invested in the fund (up to 0.30% annually), or the number of positions held by Program clients in the fund (up to $25 per position). If LPL does not provide omnibus services to a mutual fund, then fund shares are traded on a networked basis, which means LPL submits a separate trade for each individual client trade to the fund. In that case, LPL maintains only certain elements of the fund’s shareholder information. 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 $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. In the case of annuities, LPL typically receives a one-time onboarding/networking setup fee of up to $100,000 from the annuity product sponsor to reimburse LPL for associated technology-related costs. In the case of alternative investments, LPL receives up to $35,000 for initial products, and up to $15,000 for follow-on product offerings or additional share classes. LPL also receives a one-time payment of up to $25,000 from certain alternative investment sponsors for training and education and other benefits such as prominent placement of sponsor logos, website links or content on materials disseminated to LPL’s and LPLE’s respective IARs and priority access to education programs and events and conference speaking opportunities. LPL does not share this compensation with LPLE or its IARs. When LPL incurs technology development related costs associated with the launch or maintenance of a platform, tool or service, LPL sometimes receives reimbursements from product sponsors for such costs. Because LPL benefits from product sponsors’ reimbursements of technology development-related costs, LPL’s financial interests are conflicted with its ability to use strictly objective factors when selecting product sponsors to make available on the applicable platforms. LPL has fee arrangements with investment advisors or distributors (“sponsors”) of mutual funds, ETFs, annuities, alternative investment products and structured products that are available for purchase through the Program, called revenue sharing. Under these arrangements, the sponsor pays LPL a fee (typically quarterly) based on the amount of client sales or assets invested in the sponsor’s products and/or a fixed fee, and LPL provides marketing support, data analytics, and administrative services to the sponsor and allows the sponsor to access LPL IARs so that the sponsor can promote such products. The amount and form of revenue sharing fee received by LPL can vary depending on many factors, including the services provided by LPL and the sponsor’s investment products. LPL marketing support A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 9  Strategic Asset Management (SAM) Program Brochure compensation for mutual funds, interval funds, ETFs and positional money market funds consists of flat and/or asset based fees totaling up to 0.15% annually of LPL clients’ investments in the investment product, or up to $1,000,000. For alternative investments, the maximum revenue sharing fee received by LPL under these arrangements is up to 0.35% on assets or 1.50% on new sales. Certain sponsors of alternative investments are not required to pay such fees. For annuities, the maximum revenue sharing fee received by LPL under these arrangements is up to 0.25% of assets or up to 0.50% of new sales. LPL does not require that a sponsor participate in revenue sharing arrangements for the sponsor’s products to be selected for a Portfolio. However, LPL has a financial incentive to recommend participating products instead of those whose sponsors do not make such payments to LPL. In general, sponsors pay LPL a revenue sharing fee in addition to other product-related fees paid by a client, which include sales charges, deferred sales charges, distribution and service fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Revenue sharing fees may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate. LPL accepts revenue sharing fees for assets held in retirement accounts to the extent permitted by applicable law, including ERISA. 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. LPL receipt of revenue sharing fees creates a conflict of interest for LPL, which means that there is an incentive for LPL and its respective IARs to recommend investment products that pay revenue sharing fees. LPL or its affiliate receives significantly more revenue sharing fees from the sponsors for which clients have the largest holdings, which creates a conflict of interest for LPL to promote and recommend these sponsors’ investments. Revenue sharing payments are generally higher for investment products with higher expense ratios (the overall fee paid by an investor in the product). Additionally, revenue sharing payments for some ETFs are based on management fees and will be higher for ETFs with higher expense ratios, both because LPL is paid a portion of the higher fees and because generally the percentage rate that LPL gets paid increases for investment products with higher expense ratios. As a result, LPL has an increased incentive to choose investment products that charge more in fees and to promote or recommend these investment products so that LPL earns more, and that could cause lower performance for client accounts. Other investment products with lower fees that are not party to revenue sharing agreements are available. Higher expense ratios will cause an investor to earn less on an investment than a comparable investment with a lower expense ratio. This results in a conflict of interest between clients and LPL because the revenue sharing arrangements give LPL an incentive to recommend investments that could cause lower performance for client accounts. The variations between amounts and forms of revenue sharing payments also create an incentive for LPL to recommend holding products which pay revenue sharing payments to LPL or its affiliate as an ongoing percentage of client assets. This conflict can cause clients to pay higher overall fees and expenses and have an impact on the investment performance of an account. Additionally, LPL receives significantly more revenue sharing from firms for which clients have the largest holdings, and some of LPL’s contracts pay increased asset based fees when certain threshold are met. This creates a conflict of interest for LPL to promote and recommend those investments. However, these conflicts are mitigated insofar as the revenue sharing payments LPL receives are not shared with LPLE or the IAR who selects or recommends the investment products for client accounts. LPL has network fee arrangements with sponsors of fee-based variable annuities, pursuant to which LPL receives compensation based on the number of LPL customer positions held with the variable annuity sponsor (up to $6.00 per position per year). LPL does not share this compensation with its IARs. From time to time, LPL receives a reallowance of the public offering price per unit on units of certain UITs and structured products sold by LPL during the initial offering period. The revenue that LPL receives from 12b-1 fees, recordkeeping compensation and revenue sharing arrangements is an important revenue stream and presents conflicts of interest that affect LPL’s ability to provide clients with unbiased, objective investment advice concerning the selection of products and share classes for a Portfolio in the case of A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 10  Strategic Asset Management (SAM) Program Brochure Portfolios designed by LPL. In particular, LPL has a financial incentive: (i) to select a product or a Program Share Class that charges a 12b-1 fee and/or pays recordkeeping compensation to LPL over another comparable fund or a share class that does not charge 12b-1 fees or pay recordkeeping compensation; (ii) to select a product sponsored by a company that makes revenue sharing payments to LPL, instead of another comparable product whose sponsor does not make such payments; and (iii) to select a product or a Program Share Class that charges 12b-1 fees, pays recordkeeping compensation to LPL, or whose sponsor makes revenue sharing payments to LPL that, in each case, are comparatively higher than those charged or paid by another comparable product or share class or a sponsor of such products or share classes. Such other comparable products and/or share classes may be more appropriate for a client than the product or Program Share Class offered through the Program. Additionally, LPL receives significantly more revenue sharing from fund sponsors for which LPL’s clients have the largest holdings, which creates a conflict of interest for LPL and LPLE to promote and recommend those investments. LPL’s website at lpl.com/disclosures.html identifies the mutual funds that pay recordkeeping compensation and the sponsors that make revenue sharing payments to LPL. LPL credits to clients any 12b-1 fees it receives from mutual funds, and therefore, LPL and LPLE do not have an incentive to select one fund or Program Share Class over another solely on the basis of the 12b-1 fee. In addition, LPL does not share 12b-1 fees, recordkeeping fees or revenue sharing payments with LPLE or IARs, and, therefore, there is no financial incentive for LPLE or its IARs to select one fund or a Program Share Class over another comparable fund or share class on the basis of the 12b-1 fee, recordkeeping compensation and revenue sharing payments that the fund or Program Share Class charges or provides to LPL. Although LPL does not share recordkeeping fees or revenue sharing payments with LPLE or its IARs, such fees and payments will increase LPL’s profits and indirectly benefit LPLE and 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. LPL provides investment consulting services to the investment advisor of the Optimum Funds mutual fund family. 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 fund assets from the investment advisor to the Optimum Funds. The receipt of this investment consulting compensation by LPL presents a conflict of interest, because LPL has a financial benefit if an Optimum Fund is purchased in an account. This fee is not shared with LPLE or its IARs. In addition, a senior executive officer of LPL serves as a Trustee of the Optimum Funds. The Optimum Funds are available to be purchased and sold in a Program account. LPL receives a fee from the issuers of structured products for administrative services and related support LPL provides in connection with the structuring and distribution of these products. This fee can be up to 0.75% of the principal amount of a trade and generally varies among products according to the complexity of the structuring. This fee creates a conflict of interest because LPL has an incentive to recommend structured products over other products that do not pay LPL a similar fee. This conflict is mitigated insofar as the amount LPL receives is consistent for similar types of structured products across different product issuers, and is not shared with LPLE or its IARs. Client should review the product offering documents for additional details. Important Things to Consider About Fees on a SAM Account • The Account Fee is an ongoing fee for investment advisory services and other administrative and custodial services. The Account Fee may cost the client more than purchasing the Program’s services separately. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the: • type and size of the account • 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. • Clients participating in the Program do not pay LPL, LPLE or IAR commissions on transactions but do pay LPL transaction charges. Transaction charges for the securities purchased and sold in an account may also cost A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 11  Strategic Asset Management (SAM) Program Brochure the client more than purchasing the Program’s services separately. As with any fee, transaction charges reduce the overall amount of your investment portfolio. • The Account Fee may cost the client more than if assets were held in a traditional brokerage account. In a brokerage account, a client pays the brokerage representative a commission for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than a Program account. In addition, LPL may only offer certain products in an advisory account, even though there is a version of the product or a similar product that may be lower cost and could be available in a brokerage account, and vice versa. • LPL offers certain alternative products, including certain non-traded alternative investments, in certain accounts offering solely brokerage services and in certain accounts offering solely investment advisory services. This means that clients can only purchase those investments by paying a commission or other brokerage fee in the case of a brokerage account or advisory fee in the case of an advisory account. Depending on the length of time that a client holds such an investment, it may cost more to pay the commission than it would if the investment was available in a SAM program account and the client paid the annual Account Fee on the investment. • 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, type of securities to be held in the account (e.g., mutual funds vs. individual securities), the complexity and mix of the portfolio, and the number and range of supplementary advisory and client-related services to be provided to the account. The IAR may charge a client more or less than another client. 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 can include other compensation, such as bonuses, awards or other things of value offered by LPL or LPLE to IARs. However, LPLE and IARs intend to make all recommendations independent of such considerations and based solely on their obligations to consider Client’s objectives and needs. • The investment products available to be purchased in the Program can be purchased by clients outside of a SAM account, through broker-dealers or other investment firms not affiliated with LPL or LPLE. • 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 “Regulatory Educational Resources.” Item 6: Performance Based Fees and Side-by-Side Management This Item is not applicable. LPL , LPLE, and its IARs do not accept performance-based fees. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 12  Strategic Asset Management (SAM) Program Brochure Item 7: Types of Clients The Program is available for individuals, 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. A minimum account value of $10,000 is generally required for the Programs. In certain instances, LPL will permit a lower minimum account size. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss LPLE, through its IARs, chooses the research methods, investment strategy and management philosophy used to manage a SAM account. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPLE and its IARs have access to various research reports, including but not limited to those provided by LPL Research, to which they may refer in determining which securities to purchase or sell. LPL Research makes available its recommendations regarding asset allocation, mutual funds, model portfolios, and variable annuity subaccounts. LPLE and its IARs may or may not choose to follow these recommendations in managing program accounts. LPL Research also constructs asset allocation model portfolios and provides recommendations on the funds to populate the model portfolios. In constructing these models, LPL Research uses the following investment strategies: Diversified and Alternative Strategy. Although these descriptions are written in terms of individual equities and/or bonds, they include mutual funds or ETFs whose portfolios consist of the type of equities or bonds referenced. • Diversified. The Diversified investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. The strategy is subject to minimal constraints, which allows for a relatively pure implementation of LPL Research’s recommendations. In general, Diversified portfolios should be considered by investors seeking investments in primarily stocks and bonds, along with the occasional non-traditional asset class to take advantage of potential market opportunities. Diversified portfolios will hold primarily traditional asset classes. Secondarily, if a non-traditional asset class represents the investment that provides the best means of taking advantage of a market opportunity, it will be included in the recommendation. The non-traditional investments included in Diversified portfolios are more standard, such as conservative balanced strategies. Diversified portfolios tend to be steady in their number of positions. These portfolios tend to remain consistently diversified. • Alternative Strategy. The Alternative Strategy investment strategy seeks to promote capital appreciation while taking a reasonable amount of risk to achieve that goal. Unlike the Diversified investment strategy which may have an allocation to alternative strategy or non-traditional assets classes, this portfolio typically has an allocation to non-traditional asset classes. This strategy extends the diversification beyond the core style box asset classes into strategies with lower correlation to stocks and bonds in order to lower risk, as defined by standard deviation and maximum drawdown (peak to trough loss), while attempting to maintain long-term performance similar to other portfolios in the same investment objective. For each of the above investment strategies, LPL Research recommends a strategic or tactical version. • Strategic. Strategic portfolios typically have a three- to five-year time horizon. The allocations within these portfolios are intended to help take advantage of market opportunities LPL Research believes will occur or persist throughout that time frame. Although LPL Research recommends investments through a three- to five- year lens, LPL Research may recommend that these portfolios be traded for fine tuning throughout the year. For clients who take a longer term view or are more tax sensitive, a strategic implementation may be more appropriate. • Tactical. Tactical portfolios are more flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present. LPL Research recommends that these portfolios invest in opportunities for as short as one week and as long as five years. Due to the tactical nature, the trading is A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 13  Strategic Asset Management (SAM) Program Brochure notably more frequent than strategic portfolios. Tactically managed portfolios should be considered by clients who wish to take advantage of shorter-term market opportunities that may arise and are not opposed to the prospect of more frequent trading. It is important to note that although LPL Research makes available its recommendations and investment strategies, LPLE and its IARs will not necessarily take into consideration these recommendations and strategies. Clients should contact the IAR managing his/her accounts for additional information on the IAR’s particular investment strategy used for the account. It is also important to note that LPLE and its IARs may use a combination of investment strategies. Types of Investments and Risks In the Program, LPLE, through its IARs, can recommend many different types of securities, including mutual funds, unit investment trusts (“UITs”), closed end funds, ETFs, ETNs, variable annuity subaccounts, equities, fixed income securities, interval funds, options, hedge funds, managed futures, BDCs, private equity, REITs, and structured products. LPL and LPLE determine the types of investments that are eligible to be purchased in program accounts. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that are available in the Program. • 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. • Liquidity Risk. This is the risk that an investor would not be able to sell or redeem an investment quickly, or would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities or mutual funds or ETFs. • ‐ Issuer Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • 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. • Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub ‐ sectors of the market, its performance will be especially sensitive to developments that significantly affect those sector of the market may be more sectors, industries, or sub sectors. An individual sector, industry, or sub ‐ ‐ A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 14  Strategic Asset Management (SAM) Program Brochure volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance sectors do not perform as expected. Alternatively, the lack could be affected if the sectors, industries, or sub of exposure to one or more sectors or industries may adversely affect performance. ‐ • Equity Securities. Common and preferred stock represents the equity ownership of a company. Stock markets are volatile and the price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. The value of equity securities may also decline due to factors that affect particular industries or particular issuers. The values of equity securities may be more volatile than those of other asset classes. • Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures and the investor may lose income. • Foreign Securities Risk. Foreign investments involve special risks not present in U.S. investments that increase an investor’s potential to lose money. Among other issues, custody of securities in foreign markets, changes in foreign currency exchange rates, foreign economic and market conditions, actions adverse to investors taken by foreign governments, lack of governmental oversight or regulation of securities markets, underdeveloped settlement and clearing services, and foreign withholding taxes may negatively affect the value of investments in foreign securities. • Alternative Strategy Mutual Funds. Certain mutual funds available in the Program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. Clients should be aware that alternative investments and/or strategies are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. • Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the Program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. In some cases, there may be an additional cost to investors who redeem before holding shares for a specified amount of time. The repurchase offer program may be suspended under certain circumstances. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 15  Strategic Asset Management (SAM) Program Brochure of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. • Unit Investment Trusts (UITs). UITs are investment companies that generally offer a fixed portfolio of stocks and bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. ETNs may be closed and liquidated at the discretion of the issuing company. • Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. • Tax-Managed Investing Risk. Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax- managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 16  Strategic Asset Management (SAM) Program Brochure cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. • Options. Option trading is permitted in the Program. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and a Program account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (or “writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • Direct Indexing. Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. LPLE cannot guarantee that the dividend yield in your portfolio will accurately track a market index. futures-linked ETPs • Other Complex Exchange Traded Products (ETPs). Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (“Single Inverse ETPs”), (“Futures Linked ETPs”) and cryptocurrency-related ETPs (“Cryptocurrency ETPs”). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. • Structured Products. Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 17  Strategic Asset Management (SAM) Program Brochure held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • High-Yield Debt. High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. • Hedge Funds and Non-Traded Managed Futures. Hedge funds and non-traded managed futures funds are available to clients meeting certain qualification standards. Investing in these securities involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices, currency and interest rate risk, lack of liquidity and performance volatility. In some cases, there may be an additional cost to investors who redeem before holding shares for a specified amount of time. In addition, these securities may not be required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Clients should be aware that these securities may not be liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the security, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the security during the repurchase offer. Issuers typically accept redemption requests only periodically (monthly or quarterly), and often have the discretion to suspend redemptions in times of market stress. Even after a redemption request is accepted, the redemption proceeds may not be available for a significant period of time following the effective date of the redemption. A portion of the redemption proceeds may also be withheld to account for potential future adjustments to the valuation of the security. Funds of hedge funds are pooled investments in several hedge funds. Expenses in funds of hedge funds are typically higher than mutual funds. Because they may invest in a number of private hedge funds, funds of funds also bear a part of the fees and expenses of those underlying hedge funds. • Business Development Companies (BDCs). BDCs are types of closed-end investment companies, which are available to clients meeting certain qualification standards. Generally, BDCs invest primarily in the debt and equity of private and/or small U.S. companies and may offer distribution rates generated through potentially significant credit and liquidity risk exposures amplified through leverage. As with other high-yield investments, such as floating-rate/leveraged loan funds, private REITs and limited partnerships, investors are exposed to significant market, credit, interest rate and liquidity risks. In addition, BDCs run the risk of over- leveraging their relatively illiquid portfolios. Due to the illiquid nature of non-traded BDCs, investors’ exit opportunities may be limited only to periodic share repurchases by the BDC. A tender offer pursuant to a share redemption program may be oversubscribed so that the BDC accepts only a pro rata portion of the shares a client tenders during a redemption program. In such cases, a client may experience significant delays A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 18  Strategic Asset Management (SAM) Program Brochure (including, potentially, indefinite delays) to exit from the investment. In addition, share redemption programs may be shut down at any time at the discretion of the issuer’s board. Also, BDCs may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to make investments. In some cases, there may be an additional cost to investors who redeem before holding the shares for a specified number of years. • REITs. REITs invest in real estate, and there are special risks associated with investing in real estate, including, but not limited to, sensitivity to changes in real estate values, the risk of investment loss due to the use of leveraging and other speculative investment practices, interest rate risk, lack of liquidity and performance volatility. Non-Traded REITs are not required to provide annual valuations until two years and 150 days after reaching the minimum capital raise required to begin purchasing properties. This threshold is generally outlined in the product’s prospectus. Non-Traded REITs, which are available to clients meeting certain qualification standards, may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to invest in new assets. Clients should be aware that these securities may not be liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the security, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the security during the repurchase offer. Issuers may repurchase shares at a price below net asset value. The repurchase program may also be suspended under certain circumstances. • Private Equity Funds. Private equity investments are speculative and involve significant risks. It is possible that investors may lose some or all of their investment. The risks associated with private equity include: limited diversification, the use of leverage, and limited liquidity. The investment timeline for private equity can be a decade or more. Some issuers or general partners may penalize limited partners who redeem before holding units for a specified amount of time, or may disallow redemptions entirely. • Variable Annuities. If client purchases a variable annuity that is part of the Program, client will receive a prospectus and should rely solely on the disclosure contained in the prospectus with respect to the terms and conditions of the variable annuity. Clients should also be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. Some products may charge a recapture or redemption fee for contracts or benefits not held for a specified period of time or that do not follow stated withdrawal terms. • Non-traded Products. Non-traded products do not trade on a securities exchange and are not publicly traded. Consequently, non-traded products can be riskier than products that are publicly traded because the product cannot be sold readily in a market by the investor. The non-traded product may offer to redeem shares from investors, but such share redemptions are typically subject to limitations. Share redemptions may also require that shares be redeemed at a discount and there is no guarantee that client will be able to redeem the security during the repurchase offer. In addition, non-traded products may lack share value transparency because there is no market price readily available. Without share value transparency, investors may not be able to assess the value or performance of the non-traded product. • Margin Accounts. Clients should be aware that margin borrowing involves additional risks. Margin borrowing will result in increased gain if the value of the securities in the account go up, but will result in increased losses if the value of the securities in the account goes down. LPL, acting as the client’s creditor, will have the authority to liquidate all or part of the account to repay any portion of the margin loan, even if the timing would be disadvantageous to the client. For performance illustration purposes, the margin interest charge will be treated as a withdrawal and will, therefore, not negatively impact performance reports. • Collateralized Lending Program. LPL allows clients to pledge securities in their accounts as collateral for non- purpose lines of credit through its collateralized lending program, in each case subject to certain terms and conditions. The collateralized lending program includes LPL’s Secured Credit Account (“SCA”) product, offered by LPL Financial LLC, as well as lending options through third-party banks with which LPL has partnered to A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 19  Strategic Asset Management (SAM) Program Brochure facilitate clients’ access to credit (partner banks) and other banks (non-partner banks). Clients are not required to use the SCA product or partner banks in LPL’s program, and can work directly with non-partner banks to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their IAR of the amount of the line of credit. Loans through the collateralized lending program may be used by clients only for purposes other than buying, trading, or carrying securities. For the SCA product, clients borrow directly from LPL and pay interest to LPL. For lines of credit obtained through partner or non-partner banks, clients borrow from the bank and pay interest to the bank. In some cases, an IAR will 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. 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. There are risks, costs and conflicts of interest associated with the collateralized lending program and securities-based borrowing generally. The holder of the loan, whether that be LPL or a bank, may require clients to provide additional funds or collateral to secure the loan (referred to as a “maintenance call”) and has the authority to liquidate all or part of the securities at any time in accordance with the terms of the lending arrangement. As a practical matter, this may cause you to be required to contribute cash to the account or to sell assets and realize losses in a declining market. Maintenance calls can result in the loss of more funds than the pledged assets. The risk of a maintenance call is heightened when you hold concentrated positions in your pledged account(s). You are not entitled to choose which securities are liquidated or sold to meet a maintenance call, and you are not entitled to an extension of time on a maintenance call. The lender may change maintenance requirements at any time. If the sale of assets does not fully satisfy the maintenance call, you are responsible for the shortfall. A forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. For an SCA, any action taken by LPL, or an affiliate, as lender against the assets in your advisory account pursuant to your SCA loan agreement is separate from your advisory relationship and therefore not subject to the fiduciary duty requirements under your investment advisory agreement. 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 lending program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the governing loan agreement, loan application and any forms required by the lender and any other forms and disclosures provided by LPL. Clients are encouraged to weigh carefully the potential investment, tax or other benefits of the collateralized lending program against the overall risks of securities- based borrowing, tax consequences of liquidation and the total cost of the loan, inclusive of the existing fees that will continue to be paid to LPL for the pledged assets. For a list of the third-party 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.” For additional disclosures regarding LPL’s Secured Credit Account, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Secured Credit Account Disclosures.” • 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 A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 20  Strategic Asset Management (SAM) Program Brochure 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 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. • 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. • Comparable Products. LPL offers various mutual funds, ETFs, and other investment products that have similar or identical investment strategies but different fee and expense arrangements. For example, LPL sells both mutual funds and ETFs that are designed to track an index of securities, such as the S&P 500 Index. A mutual fund and an ETF following an identical strategy have different fees and expenses that affect your investment return. Those fees and expenses include direct costs like sales loads, commissions, and other transaction costs, and indirect costs at the product level like advisory or management fees, distribution expenses (12b-1 fees), and other administrative, shareholder servicing and transfer agent fees. The impact of those fee and expenses on your investment returns also varies based on the size of your initial investment, the length of time you hold the investment, and other factors. The differences in fees and expenses, and additional differences in compensation paid directly by product sponsors like revenue sharing, mean that LPL generally will earn more compensation when LPLE sells one investment product compared to another. As a result, LPLE has a conflict of interest because of the financial incentive to recommend investment products that pay more compensation to its affiliate even if a less expensive comparable product could be used to achieve a customer’s investment objective. • Annuity Products. If client invest in annuity products in a Program account, clients should be aware of the specific risks and limitations of the annuity products. Clients should be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. Some A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 21  Strategic Asset Management (SAM) Program Brochure products may charge a recapture or redemption fee for contracts or benefits not held for a specified period of time or that do not follow stated withdrawal terms. Registered Index Linked Annuities (RILAs) are insurance products tied to the performance of a market index, offering the positive returns of the index up to a cap and providing a buffer for a certain level of negative returns. RILAs are subject to risks associated with other investment products, including market risk, and the total loss of principal is possible. If clients purchase an annuity product that is part of the Program, clients will receive a prospectus with respect to the terms and conditions of the annuity product. Item 9: 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, LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 206(2) and 207 of 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 was 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). A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 22  Strategic Asset Management (SAM) Program Brochure • 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, 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). • 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 A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 23  Strategic Asset Management (SAM) Program Brochure 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 Massachusetts (“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). 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/. Item 10: 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 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. 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 also a registered 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 IARs dispersed throughout the United States. In addition, LPLE is qualified to sell insurance products in all 50 states. When LPLE utilizes certain advisory programs sponsored by LPL, including this Program, its affiliate LPL is compensated for performing that service, which creates a potential conflict of interest whereby our affiliate LPL earns additional compensation. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 24  Strategic Asset Management (SAM) Program Brochure 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 SAM 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-SAM 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 their respective IARs may sell insurance products. LPL and LPLE receive compensation from issuers of life insurance (universal, variable universal, whole life, and term) and other insurance contracts that are made available by their respective 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 or LPLE provides and/or payments made in connection with LPL’s marketing and sales-force education and training efforts, including annual national sales and education conference and other conferences of LPL and LPLE. IARs receive a percentage of the commissions or trailing commissions paid to LPL, LPLE 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 LPL, LPLE or the third- party insurance agency and may have an incentive to recommend you purchase or sell insurance products with LPL, LPLE or the independent agency. IARs are permitted to engage in certain LPLE-approved business activities other than the provision of brokerage and advisory services through LPLE, and in certain cases, an IAR could receive greater compensation through the outside business than through LPLE. 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 and consulting services through an independent unaffiliated investment advisory firm or sell insurance. Additionally, LPLE 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, corporate trustee services, 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. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading LPL and LPLE have each adopted a code of ethics that includes guidelines regarding personal securities transactions of its employees and IARs. The code of ethics permits employees and IARs to invest for their own personal accounts in the same securities that are purchased for clients in SAM 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 A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 25  Strategic Asset Management (SAM) Program Brochure LPLE each have procedures to review personal trading accounts for front-running. In addition, employees in LPL Research 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. As described under Brokerage Practices below, IARs may aggregate transactions in equities, options, and fixed income securities for client accounts. Clients should be aware that the IAR’s personal accounts (including related accounts, such as those of family members) can be included in such a block order. Although the same average price would be applied to client accounts and the IAR’s personal accounts, the inclusion of an IAR’s personal account in a block order can present a conflict of interest. It is possible that the inclusion of the personal account could negatively impact the price of the security or result in the client being allocated less of an order. If a partially filled order is allocated on a random basis, the inclusion of the personal account could make it less probable that a client account is randomly selected and the IAR’s personal account could be randomly selected instead of a client account. LPLE addresses this conflict by disclosing it to you. Please ask your IAR if you would like more information on the IAR’s practices in this respect. Participation or Interest in Client Transactions LPL’s and LPLE’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPLE does not permit its IARs to recommend or solicit orders of LPL Financial Holdings Inc. stock in SAM accounts unless expressly directed to do so by the client. In addition, LPLE through its IARs may recommend or purchase for clients a mutual fund or ETF that holds LPL Financial Holdings Inc. stock as an underlying investment, for example, an ETF that seeks to replicate the performance of an investment services index that includes LPL Financial Holdings Inc. Purchases of mutual fund, UIT or alternative investment 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 the firm’s use of a proprietary account. LPL and LPLE do not otherwise engage in principal transactions with its clients in the Program. For certain ETFs and stocks, LPL executes trades in fractional shares of those securities as an accommodation to clients. There is not an active open market for fractional shares, and executing trades with LPL is most often the only form of liquidity for a client that holds fractional shares in his or her account. LPL does not receive any compensation in addition to advisory fees for executing trades in fractional shares for a client’s advisory account. LPL will only buy and sell fractional shares when a client is also trading whole shares of the security, in connection with a dividend reinvestment plan, or to sell remaining fractional shares to close a position. Trades in fractional shares will happen on the same day and at the same price as a trade in whole shares, or otherwise at market closing price. Collateralized Lending Arrangements LPL helps facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts through its collateralized lending program. Because of LPL’s interest as a lender for clients borrowing through the Secured Credit Account (SCA) product and its arrangements with the partner 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 SCA product or the banks in LPL’s collateralized lending program, and can work directly with non-partner 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 lender, whether LPL, a partner bank, or a non-partner 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. For the SCA product, LPL receives all interest and fees as the lender based on the outstanding loan amount. Interest and fee amounts can vary in accordance with market conditions and are subject to the loan agreement, documentation and fee schedules provided by LPL. For partner bank loans, LPL receives third party compensation A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 26  Strategic Asset Management (SAM) Program Brochure from partner 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 the largest financial incentive for the client to select the SCA product, and if a client selects a bank in the collateralized lending program instead, LPL has a financial incentive for the customer to select a participating bank that pays LPL more than other participating banks. For partner banks, LPL does not share this compensation with LPLE or its IARs, and therefore, IARs do not have a financial incentive if one bank is selected over another. Neither LPL nor your IAR receive loan-based compensation if you borrow through a non-partner bank. LPLE and its IARs 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 the IAR. 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 LPLE and its IARs are compensated primarily through advisory fees paid on clients’ accounts, LPLE 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 maintenance 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, or alternatively, could incentivize IARs to invest in more aggressive assets to achieve returns higher than loan interest and costs. 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 both “Secured Credit Account Disclosures” and “Third Party Compensation and Related Conflicts of Interest.” 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 or the LPL Deposit Cash Account (DCA) Program, 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 IARs 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. 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. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA 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. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 27  Strategic Asset Management (SAM) Program Brochure 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 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. 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. 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. • 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 A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 28  Strategic Asset Management (SAM) Program Brochure 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. The compensation that LPL receives related to ICA and DCA (including from any overflow mechanisms) 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 and DCA 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 or DCA. However, this compensation is retained by LPL and is not shared with LPLE or its IARs. Therefore, this compensation does not cause an IAR to have a financial incentive to recommend that cash be held in the account instead of holding securities. Non-Sweep Money Market Mutual Fund Investments (Outside of LPL’s Sweep Service Options) Clients are able to invest cash balances in a limited number of money market mutual funds outside the sweep options offering (such funds, “Non-Sweep Money Market Funds”). Like any other mutual fund transactions at LPL, transaction and other fees may apply. Moreover, unlike under the sweep services, transactions in Non-Sweep Money Market Funds are customer-directed (or directed by customer’s representative) and do not provide for automatic daily sweep. Depending on current interest rates and other market factors, investment returns of money market mutual funds could be lower or higher than the aggregate fees and expenses charged by LPL and LPLE in connection with the transaction. Contact your IAR for information about current fees and investment returns on money market funds. As described above, under “Fees Charged by Third Parties,” clients should understand that the share class offered for a particular Non-Sweep Money Market Fund charges higher fees and expenses than other share classes that are offered by the same Non-Sweep Money Market Fund but are not available on LPL’s platform. LPL receives compensation for the LPL customer assets invested in the Non-Sweep Money Market Funds (up to 0.30% on an annual basis) for distribution, recordkeeping, shareholder servicing and administrative services it provides for the funds and in connection with marketing support services LPL provides to the fund sponsors as described in this disclosure. This compensation related to Money Market Funds presents a conflict of interest to LPL and LPLE because LPL has a financial benefit if cash is invested in the Money Market Funds. However, this compensation is retained by LPL and is not shared with LPLE or its IARs. Therefore, this compensation does not cause an IAR to have a financial incentive to recommend that cash be held in the account instead of holding securities. Unlike other types of mutual funds available on LPL’s platform, LPL makes available Non-Sweep Money Market Funds from only a limited number of mutual fund sponsors. By making available a limited number of Non-Sweep Money Market Funds, LPL is able to negotiate greater compensation from the fund companies for services it provides to the funds. Because of the limited number of Non-Sweep Money Market Funds available on the platform and the fees paid by those funds, other money market mutual funds not available through LPL’s brokerage platform are likely to have higher returns than the Non-Sweep Money Market Funds. In addition, LPL has received a waiver from the Money Market Funds to allow a lower investment minimum for the Program Share class of the than that set out in the prospectus; however, LPL imposes its own minimum investment amounts that are higher than minimums that may apply if a client were to invest in the Money Market Funds through another firm outside of the Program. In light of the investment minimums that LPL imposes with respect to the Money Market Funds, an investment in the Money Market Funds outside of the Program or an investment in one of the many other money market mutual funds offered outside of the Program would likely be more economically advantageous than an investment in the Money Market Funds through the Program. LPL does not charge transaction charges on Money Market Funds. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 29  Strategic Asset Management (SAM) 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 cardholders. Other Clients Clients should understand that LPL, LPLE and IAR perform advisory and/or brokerage services for various other clients, and that LPL, LPLE and IAR may give advice or take actions for those other clients that differ from the advice given to the client. The timing or nature of any action taken for the account may also be different. Item 12: Brokerage Practices LPL and LPLE do not receive research or other products or services other than execution from a broker-dealer in connection with client securities transactions (“soft dollar benefits”). LPL and LPLE do not consider, in selecting or recommending broker-dealers, whether LPL, LPLE or a related person receives client referrals from a broker-dealer or third party. In the Program, LPL requires that clients direct LPL as the sole and exclusive broker-dealer to execute transactions in the SAM account. Clients should understand that not all advisors require their clients to direct brokerage. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution of client transactions. Therefore, directed brokerage may cost clients more money. LPL, LPLE and IAR are not paid a commission for executing transactions in SAM accounts, but LPL is paid transaction charges by the client for processing trades depending on the type of security. Because LPL is an affiliate of LPLE, this presents a conflict of interest. In the case of mutual funds, execution is made at the net asset value of the fund. If LPL as broker purchases a new issue security on behalf of client accounts, the execution price may include a concession to the dealers participating in the syndicate. Although LPL is not part of the syndicate and does not receive this concession, the concession is included in the price and is in addition to the Account Fee. IARs may aggregate transactions in equity, options and fixed income securities for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. For partially filled orders, the IAR will generally allocate trades pro-rata or on a random basis to treat clients fairly and consistent with our fiduciary duty. IARs may determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, the liquidity of the securities and the discretionary or non-discretionary nature of the trades. If IARs do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. 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. For securities transactions, this delay may cause a difference between the execution price and the displayed quote at the time the order was entered. This delay may also result in a limit order becoming ineligible for execution. LPL reserves the right to place restrictions on your account in our sole A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 30  Strategic Asset Management (SAM) 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. Item 13: Review of Accounts LPLE reviews program accounts using a risk-based exception reporting system that flags accounts for criteria such as trading activity and concentration on a quarterly or monthly basis, depending upon the nature of the exception. The Chief Compliance Officer of LPLE oversees the process for reviewing flagged 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 performance information available upon request. LPL also provides an additional year-end report for accounts not established on a calendar quarter basis. In addition, LPL sends to clients trade confirmations and account statements showing transactions, positions, and deposits and withdrawals of principal and income. LPL does not send trade confirmations for systematic purchases, systematic redemptions and systematic exchanges. 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. Item 14: Client Referrals and Other Compensation Other Compensation LPL and LPLE employees and their 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 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 servicing customers. LPL receives compensation from certain third-party vendors, including technology providers and affinity partners, in connection with conferences, educational events, and similar programs made available to LPL, LPLE and its IARs. These arrangements may include sponsorship fees, booth or exhibition fees, payments or participation in breakout sessions or presentations, revenue-sharing arrangements, and other forms of compensation. In exchange for such compensation, vendors may receive opportunities to promote their products or services to LPL, LPLE and its IARs, including conference recognition, exhibit space, participation in educational sessions, access to attendee information (which does not include email addresses), and other marketing or promotional benefits. These arrangements create a conflict of interest because LPL has a financial incentive to feature, promote, or make available certain vendors or service providers over others. LPL, LPLE and its IARs are not required to use any particular vendor, and participation in or exposure to vendor-sponsored events does not constitute an endorsement of the vendor or its products or services by LPL. LPL and LPLE employees provide sales support resources to IARs that use LPL-sponsored advisory programs. The compensation that LPL and LPLE pays to these employees varies based on the assets in LPL’s different sponsored advisory programs. These employees have an incentive to promote certain advisory programs to IARs over other advisory programs. These employees also earn more compensation when IARs of LPLE transition client assets from A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 31  Strategic Asset Management (SAM) Program Brochure 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 a Program 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 financial institution or its affiliate pays part of that amount to the 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 SAM than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in SAM over other programs and services. Although the IAR may factor in the fees that are assessed by LPL or LPLE in the overall Account Fee negotiated by the client, IAR can still earn more for offering SAM at a lower overall fee rate than the fee rate for a program offering a third-party manager. 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. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 32  Strategic Asset Management (SAM) Program Brochure 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. 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 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 and LPLE only approve 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. Specifically, if your IAR is associated with the Prudential Insurance Company of America (“PICA”), you should note that certain mutual funds and Variable Annuity subaccounts are advised and/or sub-advised by affiliates of PICA (“PICA Proprietary Products”). In addition, IARs associated with PICA (“Prudential Financial Professionals”) are limited to the selection of variable annuities that are provided by PICA’s affiliate, Pruco Life Insurance Company (“Proprietary Variable Annuities”). Prudential Financial Professionals have an incentive to select PICA Proprietary A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 33  Strategic Asset Management (SAM) Program Brochure Products and Proprietary Variable Annuities due to their association with PICA, which can influence their compensation or terminate their relationship. However, your IAR may only recommend an investment product that he or she believes is appropriate for you and in your best interest. Qualified retirement accounts receive a credit in an amount equal to the mutual fund advisory and administrative services fees that PICA affiliates receive in connection with the affiliated mutual funds held in the account. Item 15: Custody LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody of Program 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. Although most securities available in Program accounts are custodied at LPL, there are certain securities managed as part of the account that are held at third parties, and not at LPL. For example, variable annuities, hedge funds and managed futures are often held directly with the investment sponsor. For those outside positions, client will receive confirmations and statements directly from the investment sponsor. For outside positions not custodied at LPL, LPL may receive information (e.g., number of shares held and market value) from the investment sponsor and display that information on statements and reports prepared by LPL. Such information also may be used to calculate performance in performance reports prepared by LPL and/or LPLE. Although LPL and LPLE believe that the information received from the investment sponsors is reliable, LPL and LPLE recommend that you refer to the statements and reports you receive directly from the investment sponsor and compare them with the information provided in any statements or reports from LPL or LPLE. The statements and reports you receive from LPL or LPLE with respect to outside positions should not replace the statements and reports you receive directly from the investment sponsor. Item 16: Investment Discretion In the Program, LPLE and the IAR provide advisory services on a discretionary basis for the purchase and sale of mutual funds, UITs, closed-end funds, ETFs, and variable annuity subaccounts. The IAR provides advisory services on a non-discretionary basis for all other types of securities for investment in the account. In some cases, the client may provide discretionary authorization to the IAR for equities, fixed income, certificates of deposit, and options securities. Alternatively, the client may elect that the IAR manage the account on a non-discretionary basis, so that the client directs the purchase and sale of securities in the account. The client authorizes the IAR to have discretion by executing the Account Agreement and Application. Item 17: Voting Client Securities In the Program, LPL, LPLE and IARs do not accept authority to vote client securities. Clients retain the right to vote all proxies that are solicited for securities held in the account. Clients will receive proxies or other solicitations from LPL. When LPL delivers mutual fund shareholder reports and proxies to clients, LPL is reimbursed by the mutual fund for the delivery costs. 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 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 IAR. In addition, LPL, LPLE and IARs do not accept authority to take action with respect to legal proceedings relating to securities held in the account. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 34  Strategic Asset Management (SAM) Program Brochure Item 18: Financial Information LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and is therefore not required to include a balance sheet for its most recent financial fiscal year. LPL is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has it been the subject of a bankruptcy petition at any time during the past ten years. Brochure Supplements Accompanying this Brochure are Brochure Supplements for members of the LPL Research team. Note that although these individuals provide investment advice to LPL and LPLE, and may meet with LPLE clients from time to time, LPLE and your LPLE IAR(s) are responsible for all investment advice and management of assets in your account, whether choosing to implement LPL Research’s advice, implementing such advice with modifications, or implementing other customized advice. The LPL Research team members are not your IAR(s) responsible for your ongoing individualized investment advice. For more information about the IAR managing your account, please should refer to the Brochure Supplement 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(s) or LPLE at LPLEnterprise.ADV@lpl.com. A7 – LPLE – 0326 LPL Financial, Member FINRA/SIPC 35