LSIA

Item 1. Cover Page Part 2A of Form ADV: Firm Brochure LS Investment Advisors, LLC d/b/a LSIA 39533 Woodward Avenue, Suite 307 Bloomfield Hills, MI 48304 Contact: Joann Kayser (414) 459-1759 or jkayser@my-LSIA.com Website: https://my-LSIA.com Date of Brochure: February 26, 2026 This brochure provides information about the qualifications and business practices of LSIA (referred to in this brochure as “LSIA,” “us,” “we,” “our” or the “firm”). If you have any questions about the contents of this brochure, please contact Joann Kayser, our Chief Compliance Officer, at (414) 459-1759 or jkayser@my-LSIA.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. We are a registered investment advisor. Registration as an investment advisor does not imply any level of skill or training. The oral and written communications of an advisor provide you with information which you may use in determining whether to hire or retain an investment advisor. Additional information about us is available on the SEC’s web site at www.adviserinfo.sec.gov. LSIA PAGE i  Item 2. Summary of Material Changes The date of our last annual update to Form ADV, Part 2 was March 17, 2025. Since that date, we have made certain changes to the brochure. There have been no material changes made since that filing but the brochure has been updated to reflect the current practices of the firm. You may request a complete copy of our brochure by contacting Joann Kayser at (414) 459-1759 or jkayser@my-LSIA.com. Additional information about our firm is also available via the SEC’s web site www.adviserinfo.sec.gov. LSIA PAGE ii  Item 3. Table of Contents Item 1. Cover Page ..................................................................................................... i Item 2. Summary of Material Changes ....................................................................... ii Item 3. Table of Contents .......................................................................................... iii Item 4. Advisory Business ......................................................................................... 4 Item 5. Fees and Compensation ............................................................................... 6 Item 6. Performance-Based Fees and Side-By-Side Management ........................... 6 Item 7. Types of Clients ............................................................................................ 6 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ....................... 7 Item 9. Disciplinary Information ................................................................................10 Item 10. Other Financial Industry Activities and Affiliations ...................................10 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..........................................................................................10 Item 12. Brokerage Practices ................................................................................11 Item 13. Review of Accounts .................................................................................15 Item 14. Client Referrals and Other Compensation ...............................................15 Item 15. Custody ...................................................................................................16 Item 16. Investment Discretion ..............................................................................16 Item 17. Voting Client Securities ...........................................................................17 Item 18. Financial Information ...............................................................................17 LSIA PAGE iii  Item 4. Advisory Business OUR OWNERS LSIA was organized in October 2008 as part of a spin-off transaction involving the personal wealth division of a large institutional investment advisory firm. We currently maintain offices in Bloomfield Hills, MI, Milwaukee, WI, and Coral Springs, FL. Our current owners, who are all founders of the firm, include: Mark Shank, Daniel Kostaroff, Kristine Hollister, and Joann Kayser. We are required to disclose the persons owning twenty-five percent (25%) or more of our firm’s membership interests. Mark Shank currently holds 49.5% of the firm’s membership interests ASSETS UNDER MANAGEMENT As of December 31, 2025, LSIA had $932,114,909 of assets under management, all of which we managed on a discretionary basis. TYPES OF ADVISORY SERVICES Currently, we offer the following investment advisory services, which are personalized to each individual Client: • Portfolio Management Services • Financial Planning Services • Retirement Planning Services for Held Away Accounts Portfolio Management LSIA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. LSIA creates an Investment Policy Statement for each client and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy Asset allocation Risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring LSIA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. LSIA PAGE 4  Financial Planning Services We offer financial planning services, which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based on an analysis of their individual needs. These services can range from broad, comprehensive, financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation when we present the plan to you and on the financial information you provide us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Pontera – Held Away Account Services We use a third-party platform (“Platform”), via Pontera, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The Platform allows us to avoid being considered to have custody of client funds since we do not have direct access to client log-in credentials to affect trades. We are not affiliated with the Platform in any way and receive no compensation from them for using their Platform. A link is provided to the client allowing them to connect an account(s) to the Platform. Once the client account(s) is connected to the Platform, their advisor will review the current account allocations. When deemed necessary, he/she will rebalance the account considering client investment goals and risk tolerance, and current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. LSIA PAGE 5  Item 5. Fees and Compensation As compensation for our portfolio management services, we charge an advisory fee, which is stated as a percentage of our client’s assets under our management. Effective March 31, 2022, our standard advisory fee schedule is as follows: ANNUAL FEE ASSETS UNDER MANAGEMENT 0.95% On the first $2 million 0.80% On the next $3 million 0.60% On the next $5 million 0.50% On value over $10 million The minimum annual fee is $10,000. Fees are negotiable. The specific fee charged will be agreed upon between the client and LSIA as described in the contract. Please note that the above does not include any fees or expenses within the individual investments that may be used or fees or costs required by custodian. Portfolio management fees are withdrawn directly from the client’s accounts with the client’s written authorization. Lower fees for comparable services may be available from other sources. The Firm does not require or routinely recommend the use of margin. However, if margin is utilized, the Firm’s advisory fee will be calculated on total assets including borrowed funds, which increases the Firm’s compensation. LSIA offers financial planning as part of the portfolio management services. This service is available as part of the fees for this service. No additional fee is added. See Item 12. Brokerage Practices below for more information regarding brokerage. Item 6. Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7. Types of Clients LSIA offers portfolio management services to high-net-worth individuals and families, including trusts and estates. LSIA also offers portfolio management services to institutional investors, such as charitable organizations, including foundations and endowments, pension and profit-sharing plans, insurance companies, and corporations. LSIA PAGE 6  LSIA does not have a minimum account size. Instead, all accounts are subject to a minimum fee, as described above under Item 5. Fees and Compensation. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss LSIA may discuss the risk factors applicable to investing, generally. Clients are also encouraged to carefully read the prospectus of each investment selected before they invest. Some of these general risks associated with investing in securities include: ➢ Market Risk. The price of a security may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. ➢ Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. ➢ Inflation Risk. When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. ➢ Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. LSIA does not guarantee the results of the advice given. Thus, significant losses can occur by investing in any security, or by following any strategy, including those recommended by LSIA. LSIA’s method of analysis includes fundamental analysis. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. TYPES OF INVESTMENTS AND RISK OF LOSS In managing client accounts, LSIA may discuss the risk factors applicable to investing assets and diversifying client accounts. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic environments. Fixed Income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This includes corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured LSIA PAGE 7  products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile, and fixed income securities carry significant interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting, but these bonds still carry a risk of losing share price value. Risks of investing in foreign fixed income securities also include the general risks inherent in non-U.S. investing. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond (fixed income) nature or stock (equity) nature, or a mix of multiple underlying security types. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Because ETFs use "authorized participants" (APs) as agents to facilitate creations or redemptions (primary market), there is a risk that an AP decides to no longer participate for a particular ETF; however, that risk is mitigated by the fact that other APs can step in to fill the vacancy of the withdrawing AP [an ETF typically has multiple APs] and ETF transactions predominantly take place in the secondary market without need for an AP. Like other liquid securities, ETF pricing changes throughout the trading day and there can be no guarantee that an ETF is purchased at the optimal time in terms of market movements. Moreover, due to market fluctuations, ETF brokerage costs, differing demand and characteristics of underlying securities, and other factors, the price of an ETF can be lower that the aggregate market price of its cash and component individual securities (net asset value – NAV). An ETF is subject to the same market risks as those of its underlying individual securities and also has internal expenses that can lower investment returns. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; LSIA PAGE 8  adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Treasury Inflation Protected/Inflation Linked Bonds are treasury bonds indexed to an inflationary gauge, with the aim of protecting the bond holder from declines in the purchasing power of the holder’s money. The principal value of these bonds will typically increase with inflation and decrease with deflation, whereas the interest payment varies with the adjusted principal value of the bond. The risk of default on these bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. An American depositary receipt (ADR) is a negotiable security that represents securities of a non-US company that trades in the US financial markets, which has certain of the same risks as investing directly in non-U.S. securities. Cryptocurrency Exchange Traded Funds For certain clients, LSIA may recommend ETFs that track the price performance of one or more cryptocurrencies by investing in a portfolio linked to their instruments. Crypto ETFs can track the value of cryptocurrencies by investing in futures contracts for digital currency, or by investing in digital currencies directly. Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, that are not backed by real assets or tangible securities and are more volatile than traditional currencies and financial assets. In general, investing in instruments the value of which are derived from or based on crypto assets, is highly speculative and subject to numerous risks. A cryptocurrency is a peer-to-peer, decentralized, cryptocurrency, the implementation of which relies on the principles of cryptography to validate the transactions and generation of the currency itself. A network (or utility) token relies on a network protocol with similar principles to a cryptocurrency but also purports to serve functions other than the storage of value. The creation and use of cryptocurrency is not currently subject to a fully developed set of legal or regulatory requirements, and trading in crypto assets is subject to high levels of volatility and the potential for market abuse. Risks associated with Crypto ETFs include but are not limited to; the cost to own these ETFs may be more than owning the actual crypto (but may eliminate the risk of investors being hacked or losing passwords or private keys needed to access their investment when it is stored in a secure bitcoin wallet), the risk of the individual ETF fund company failure, (which would require liquidation of the fund and the costs associated with the failure of the company), risk of underlying assets being blocked by regulatory authorities, reinvestment risk, high transaction costs and limited historical data. Additionally, Crypto ETFs may have no earnings, dividends, or interest payments generated by underlying holdings. Operational and management costs may decrease the value of the ETF as a whole. Expense ratios should be considered and understood as presented in the ETF Prospectus. LSIA PAGE 9  Due to the above risk factors along with other risk factors, we assess that the value at risk at any given time is always 100% downside, therefore, we must limit total exposure along with carefully considering the risks and needs of each individual investor. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9. Disciplinary Information As a registered investment advisor, we are required to disclose all material facts regarding certain legal or disciplinary events that would be material to the client’s evaluation of our firm or the integrity of our management. We have no such legal or disciplinary events to disclose. Item 10. Other Financial Industry Activities and Affiliations LSIA has no financial industry affiliations to report. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Employees of our firm and certain related individuals, including spouses, children and other persons living in the same household (collectively, “Access Persons”), are, from time to time, permitted to buy or sell securities for their personal account(s) that are the same as or similar to those that we purchase for or recommend to our clients. Personal trading activity gives rise to a conflict of interest due to the fact that the prices or terms on which LSIA Access Persons invest could be more favorable than the prices or terms on which a client may subsequently invest or may have previously invested. That said, due to variations in personal goals, investment horizons, risk tolerance, and the timing of purchases and sales, our Access Persons will make investments in their own accounts that are different from the ones made in client accounts. In order to address the conflict of interest that arises from personal trading by our Access Persons, we have adopted a Code of Ethics, which governs trading in their personal accounts, among other conduct. Under our Code, Access Persons may not directly, or indirectly, purchase or sell most types of securities (each known as a “covered security”) when they know, or reasonably should have known, that such covered securities transaction competes in the market with any actual (or considered) covered securities transaction for any of our clients, or otherwise acts to harm any client’s covered securities transaction. Accordingly, our Code contains LSIA PAGE 10  several provisions that allow us to monitor personal trading and to restrict certain types of trades by Access Persons in their personal accounts. First, the Code requires all Access Persons to report upon hire, and annually thereafter, all holdings of covered securities, as well as all accounts in which covered securities may be held. Transactions in covered securities must be reported quarterly. In addition, Access Persons with actual or imputed knowledge of covered securities trading in one or more client accounts are prohibited from trading in the same securities in their personal accounts within the seven-day period before or after the client trades. All Access Persons must also pre-clear trades in any covered security through a personal trading preclearance system, subject to certain exemptions for open-end mutual funds, exchange-traded funds (“ETFs”), U.S. government and agency securities, and large-cap/de minimis transactions that are unlikely to affect the market of the covered security. Further, our Code of Ethics requires the prior approval of any acquisition of covered securities in a limited offering (e.g., private placement) or an initial public offering. For any transaction requiring pre-approval, failure to obtain such approval will be considered a violation of the Code and may not be approved after the transaction has occurred. In an effort to ensure that all investment decisions for any client are made without bias and in the best interest of the client, we have also adopted policies and procedures designed to limit the type and amount of gifts and entertainment we can provide to or receive from clients or vendors, including brokers. Our Code of Ethics and Policies & Procedures relating to gifts and entertainment are in place and enforced to ensure that neither we nor any of our Access Persons may take advantage of their position or place their own interests above those of our clients. When appropriate, we impose sanctions for violations. Clients and prospective clients may obtain a copy of our Code of Ethics upon request by contacting Joann Kayser, our Chief Compliance Officer, at (414) 459-1759 or jkayser@my-LSIA.com. Item 12. Brokerage Practices As an investment advisory firm, we have a fiduciary duty to seek best execution for client transactions. The SEC has indicated that among the specific obligations that flow from an advisor’s fiduciary duty is the requirement to seek to obtain the best price and execution of client securities transactions where the advisor is able to direct brokerage transactions. LSIA PAGE 11  NON-DIRECTED BROKERAGE CLIENTS Where we have discretion over the choice of broker-dealer, as a matter of policy and practice, we seek to obtain best execution for client transactions (i.e., seeking to obtain not necessarily the lowest commission but the best overall qualitative execution in the particular circumstances). We maintain a list of broker dealers with whom we may place trades for client accounts. Our Trading Oversight Committee (“TOC”) approves additions to the list, monitors and reports on broker-dealer regulatory events, and performs an annual review for each broker-dealer on the list to ensure continued satisfaction with the service being provided. Our advisors and trading personnel are responsible for selecting the brokers through which we execute client trades and negotiating associated broker commissions or yield spreads, as applicable. Our TOC reviews the commission charges and bid/offer spreads applicable to client accounts monthly in order to assure itself that the costs are competitive. The lowest possible commission cost or best spread alone, however, does not determine brokerage selection. In selecting broker-dealers for our approved list, determining the specific firm to execute a portfolio transaction, and assessing the quality of execution, we consider a variety of factors, including, but not limited to: Integrity and reputation • Best available execution price of the security • Commission rate • Size and difficulty of the order • Access to sources of supply or market • Financial condition • • Execution and operational capabilities including electronic trading (e.g., FIX) • Knowledge of the market • Good and timely delivery and payment on trades • Ability to handle block trades • Quality of brokerage services and research materials SOFT DOLLAR BENEFITS Our TOC oversees the use, if any, of soft dollars, which includes a review of overall and average commissions paid to each approved broker-dealer. LSIA has no formal soft dollar arrangements; that is, we do not direct client transactions to any particular broker dealer for the purpose of obtaining soft dollar benefits. Nevertheless, LSIA often receives unsolicited proprietary research reports and other informational materials from broker dealers with whom we trade. We consider these materials routine and ancillary to the relationship and do not include any broker-dealers on our approved list based on the materials they provide to us. Further, we believe that LSIA PAGE 12  these materials are provided at no additional charge and do not impact the commissions we pay. Notwithstanding the foregoing, the research we receive is a benefit that we would otherwise have to produce ourselves or pay for directly if we did not trade with these broker-dealers. Because of this, we have an incentive to select the broker-dealer based on the availability of that research, rather than based on our clients’ interest in receiving the most favorable execution and may pay commissions (or markups or markdowns) in excess of those that other brokers charge for transactional services alone. In practice, however, given the basic nature of the materials received, LSIA would not likely seek to replace any lost materials from termination of any of these brokerage relationships. As a separate matter, since not all of our clients invest in the same market segments to the same extent, not all of our clients benefit equally from our use of certain research materials we receive. Nevertheless, we do not seek to allocate any such benefits proportionately across the accounts we manage. We believe that any soft dollar benefits we receive are eligible research and brokerage services within the definition of research under Section 28(e) of the Securities Exchange Act of 1934, as amended (“Exchange Act”). As such, we must determine in good faith that the amount of any commission paid is reasonable in relation to the value of the research and brokerage services provided, viewed in terms either of a particular transaction or our overall responsibilities with respect to accounts for which we exercise investment discretion. We must also determine that any research and brokerage services we receive provide lawful and appropriate assistance in the performance of our investment decision-making responsibilities. To the extent we receive certain administrative benefits from the services provided by broker dealers, and such benefits would not be considered research under Section 28(e) of the Exchange Act, we will make a good faith determination of the portion the administrative benefits represent of the overall services provided and will use our own resources to pay for such portion. DIRECTED BROKERAGE CLIENTS Many of our clients direct us to use a specific broker dealer for all or certain types of transactions in their accounts. In these cases, we will utilize the designated broker- dealer as directed, except where impracticable or when the broker-dealer is unable to execute the desired transaction. In accordance with client direction, we will not seek better execution services or prices from other broker dealers for that client. As a result, the client may pay higher commissions and transaction costs or receive less favorable net prices on transactions than could otherwise be the case. Clients who LSIA PAGE 13  direct brokerage will only be able to participate in block trades with other clients who direct brokerage to the same broker. While we do not request or require that a client execute transactions through a specified broker-dealer, when a client requests a recommendation, we recommend Schwab Institutional Services, Inc. a division of Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, for custodian and brokerage services. Clients who select Schwab are considered directed brokerage clients. When recommending Schwab or any other broker dealer, we consider their financial strength, reputation, execution, pricing, and services. We do not receive any form of compensation from Schwab for recommending their services; however, investment advisors such as LSIA, whose client base includes a sufficient number of accounts using Schwab, obtain access to the Schwab Institutional Platform. The Schwab Institutional Platform is a website that provides online resources for operations and compliance personnel, as well as advisors, to assist in various aspects of running an investment advisory business and servicing clients. In addition, employees of Schwab Institutional Platform companies receive newsletters regarding industry developments and can attend complimentary educational webinars and industry conferences sponsored by Schwab. As stated under Item 5. Fees and Compensation, the brokerage commissions and/or transaction fees charged by Schwab or any other designated broker-dealer are exclusive of and in addition to our fees. BLOCK TRADING We combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion regarding factual and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. TRADING OVERSIGHT COMMITTEE The TOC was established to review and monitor our trading practices. The TOC regularly reviews best execution and directed brokerage issues, soft dollar LSIA PAGE 14  arrangements, and proxy voting guidelines, and other issues that may arise relating to trading. The TOC is made up of representatives from portfolio management, trading, operations, and compliance. The TOC meets periodically and is responsible for monitoring our firm’s trading practices and periodically reviewing and evaluating the services provided by broker-dealers, the quality of executions, research, commission rates, and overall brokerage relationships. Item 13. Review of Accounts Portfolio management accounts are reviewed on an ongoing basis at least annually by the investment adviser representatives of LSIA with regard to their assigned clients’ respective investment policies and risk tolerance levels. Portfolio management reviews may be triggered by material market, economic, or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Financial plans are reviewed on an ongoing basis for the duration of the engagement. LSIA's Representatives conduct all reviews. Recommendations are generally communicated during the course of conversations with a client, but written reports may be provided upon a client’s request. Each portfolio management client will receive at least quarterly a written report that details the client’s account including assets held and asset value, which report will come from the custodian. Item 14. Client Referrals and Other Compensation We are required to disclose certain compensation our employees may receive in connection with generating new business for LSIA. In addition to normal salary and annual profit sharing, certain LSIA employees are eligible to receive quarterly bonus compensation. This additional compensation is based on the amount of net new LSIA assets under management that were added during the trailing four quarters and attributable to the employees’ relationships. Further, we compensate our Business Development Officer by paying him a percentage of the fees LSIA earns on assets in client accounts he has helped source. In many cases, regular or bonus compensation of this type gives rise to an inherent conflict of interest because potential recipients have a financial incentive to recommend or sell one product or service over another. In this case, however, we believe the conflict of interest is minimal, since the incentive is tied to becoming an LSIA client and/or increasing assets managed by us, and not investment in any LSIA PAGE 15  particular type of security or investment product. Further, in order to ensure that any recommendation to transfer assets from a retirement account into an IRA account to be managed by LSIA is in the client’s best interest, LSIA advisors are required to summarize in writing for the client their recommendation analysis. We are further required to disclose any arrangements pursuant to which LSIA directly or indirectly compensates any third party for client referrals. LSIA does not currently have any such arrangements. See Item 12. Brokerage Practices for a discussion on benefits received from custodians. Item 15. Custody We do not maintain custody of client assets. Rather, each client appoints a qualified custodian to take possession of all client funds and securities. Nevertheless, if authorized by the client, we may bill our advisory fees directly to the client’s custodial account for payment by the custodian, as permitted under Rule 206(4)-2(b)(3) under the Investment Advisers Act. Clients receive statements periodically from the custodian that holds and maintains their investment assets. We urge clients to carefully review such statements and compare such official custodial records to any account statements that we deliver or otherwise make available. Upon request, we will provide clients with annual reports that include holdings, gains and losses, transactions, performance, or other available information. Our statements may differ from the official custodial statements based on accounting procedures, reporting dates and valuation methodologies of certain securities. Item 16. Investment Discretion If a client elects to give us discretionary authority to select the type, amount, and timing of securities to be bought or sold in their account, such a grant of authority will be stated in the investment advisory agreement signed by the client. When a client grants us discretionary authority, we exercise this authority in a manner consistent with the stated investment objectives for the particular account. Each client typically provides a written investment policy statement that includes general investment guidelines from which the advisor has the ability to vary in his/her discretion, and/or strict investment restrictions, to which the advisor must adhere at all times. We can accommodate a variety of client-directed investment guidelines and restrictions, including limitations on investment type, quality, or exposure and/or issuer type, quality, or size. Clients may change their guidelines or restrictions at any time by verbal or written notification, depending on the terms of our engagement. In LSIA PAGE 16  addition, when we send client-wide quarterly communication, we ask clients to notify us promptly, in writing, if their financial situation, investment objectives, goals, or restrictions have changed. Each client also authorizes us in writing, through a limited power of attorney contained in the investment advisory agreement, separate brokerage agreement or other authorization, to carry out our discretionary authority to trade in his or her account. Item 17. Voting Client Securities Advisory clients may elect to delegate their proxy voting authority to us. Alternatively, clients may, at their election, choose to receive proxies related to their own accounts directly from their custodians and vote them as they choose. Clients may consult with their advisor on proxy voting matters as requested. With respect to ERISA employee benefit plan accounts, we will always vote proxies unless the plan fiduciary specifically reserves the right to vote the plan’s proxies. We have adopted policies and procedures for voting proxies to ensure that any proxies for which we have authority to vote are voted in the best interests of the owner of the underlying security. We vote proxies for clients that have delegated to us their proxy voting authority. LSIA relies on a third-party proxy voting service to analyze each proxy proposal, make a voting recommendation for each proposal, and vote all proxies in accordance with our firm’s policies and procedures for proxy voting. LSIA’s policies and procedures provide that all proxies will be voted consistent with the proxy voting service’s recommendations, except where our firm determines that it is not in the best interests of our clients to vote in that manner. Clients may also request, in writing, information on how proxies for their account were voted. Clients may obtain a copy of our Proxy Voting, Corporate Actions, and Class Actions Policies and Procedures by contacting Joann Kayser, our Chief Compliance Officer, at (414) 459-1759 or jkayser@my-LSIA.com. Item 18. Financial Information We are not required to provide a balance sheet or other financial information to our clients because we do not require the prepayment of fees in excess of $1,200 for services that would not be provided within six months; we do not take custody of client funds or securities; and, we do not have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. Moreover, we have never been the subject of a bankruptcy petition. LSIA PAGE 17