NORTHLAND ASSET MANAGEMENT

NORTHLAND SECURITIES, INC 150 S. 5th STREET, SUITE 3300 MINNEAPOLIS, MN 55402 612-851-5900 MEMBER FINRA/SIPC www.northlandsecurities.com This brochure provides information about the qualifications and business practices of Northland Asset Management, the investment advisory business line of Northland Securities, Inc. If you have any questions about the contents of this brochure, please contact us at 612-851-5900. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration with the SEC and/or state entities does not of itself imply a certain level of skill or training. This brochure meets requirements for disclosure as ADV Part 2A. Additional information about Northland Asset Management may be found on the SEC’s website at www.adviserinfo.sec.gov. Effective: March 26, 2026 Last update: July 1. 2025 ITEM 1 – COVER PAGE  ITEM 2 – MATERIAL CHANGES Important Update Regarding Northland’s Revenue Sharing Arrangements Fundvest Platform Northland offers mutual funds through Pershing's Fundvest® platform, which features no-transaction-fee mutual funds with no commissions, front-end sales loads, or deferred sales charges, subject to certain trading restrictions and minimum purchase requirements. When clients' aggregate holdings in Fundvest® mutual funds reach certain asset thresholds, Northland is entitled to receive revenue-sharing payments from Pershing based on those fund investments. While clients do not pay these fees directly to Northland, the revenue-sharing payments are typically paid from fund assets, which reduces overall investment returns to shareholders. This revenue-sharing arrangement creates a conflict of interest because Northland has a financial incentive to recommend and maintain Fundvest® products on our platform, which influence our recommendations regarding mutual fund investments. Individual investment adviser representatives do not directly receive revenue-sharing fees and are not provided additional compensation for recommending Fundvest® products. Northland participates in Pershing's Fundvest® Institutional Program, which typically does not include 12b-1 fees. However, in the event that any 12b-1 fees are received, Northland credits those fees directly to the applicable client account. To address this conflict, our advisors are required to make recommendations based on client best interest standards. We also conduct periodic reviews of fund performance and expenses and monitor for inappropriate recommendations. However, clients should understand that the revenue-sharing arrangement creates an ongoing financial conflict of interest. Our mitigation efforts are designed to ensure recommendations remain in clients' best interests, but they do not eliminate the financial incentive we have to recommend Fundvest® products. Margin Accounts Margin investing allows you to have more assets available in your account to buy marginable securities. Your buying power consists of your money available to trade in your account, plus the amount that can be borrowed against securities held in your margin account. The use of margin in advisory accounts creates conflicts of interest that you should understand. First, margin debit balances do not reduce the market value of assets in your account and therefore increase the asset-based advisory fee you pay. This increased fee creates an incentive for your advisor to recommend margin strategies. Second, Northland receives a portion of the margin interest charged by Pershing on client margin debit balances. This revenue sharing creates a conflict of interest because Northland has a financial incentive to encourage clients to maintain margin loans rather than liquidating assets to pay for securities purchases, as maintaining margin loans increases our revenue. The use of margin is not suitable for all investors, as it increases leverage and risk in your account. Additional details regarding margin are provided in the advisory agreement executed between Northland and the client. 2 Northland Asset Management ADV2A  Relationship with our Sole Clearing/Custody Firm Pershing Pershing LLC serves as the clearing and custody firm for Northland's brokerage and advisory business. Northland introduces client accounts to Pershing on a fully disclosed basis, and Pershing executes and clears transactions for these accounts. Clients are charged various fees for these services, as detailed in Northland's Fee Schedule, which is provided at account opening, published on our website, and available upon request. Conflicts of Interest Related to Pershing Relationship Northland's agreement with Pershing includes financial terms that create conflicts of interest regarding our continued use of Pershing as our clearing and custody provider. These include: • Termination Fees and Deconversion Costs: If Northland terminates its relationship with Pershing, we would incur termination fees and deconversion-related expenses. These costs create a financial disincentive for Northland to change clearing firms, which conflict with our obligation to use custodians that are in our clients' best interests. • Minimum Fee Requirements: Our agreement with Pershing requires minimum quarterly fees, creating a financial incentive to maintain sufficient business volume with Pershing. • Material Adverse Economic Impact Provisions: Our agreement contains provisions that allow Pershing to revise pricing if certain "material adverse economic impact events" occur. These events could include changes in our business volume, regulatory requirements, or market conditions. The potential for price increases creates uncertainty and an additional incentive to avoid actions that might trigger such adjustments. These financial arrangements create an incentive for Northland to continue our exclusive relationship with Pershing even if alternative custodians might offer lower costs or other advantages that would better serve our clients’ interests. Northland addresses these conflicts through our compliance program and written supervisory procedures, which include: • Regular evaluation of Pershing's services, pricing, and platform capabilities • Periodic assessment of alternative custody and clearing providers • Oversight to ensure clients receive expected services and benefits from our Pershing relationship However, clients should understand that the financial penalties and commitments described above influence our decision-making regarding our clearing relationship Thank you for your continued trust in Northland Asset Management (NAM).You will find the full brochure disclosure document at: www.adviserinfo.sec.gov. You can view the document by searching that website for “Northland Asset Management”. You can also request a hardcopy by calling 612-851-5900. 3 Northland Asset Management ADV2A  ITEM 3 – TABLE OF CONTENTS ITEM 1 – Cover Page ..................................................................................................................................... 1 ITEM 2 – Material Changes ........................................................................................................................... 2 ITEM 3 – Table of Contents ........................................................................................................................... 4 ITEM 4 – Advisory Business .......................................................................................................................... 5 ITEM 5 – Fees and Compensation.................................................................................................................. 6 ITEM 6 – Performance-Based Fees .............................................................................................................. 12 ITEM 7 –Types of Clients ............................................................................................................................ 12 ITEM 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 13 ITEM 9 – Disciplinary Information .............................................................................................................. 17 ITEM 10 – Financial Industry Activities and Affiliations ............................................................................ 17 ITEM 11 – Code of Ethics, Participation in Client Transactions & Personal Trading ................................. 17 ITEM 12 – Brokerage Practices .................................................................................................................... 18 ITEM 13 – Review of Accounts ................................................................................................................... 19 ITEM 14 – Client Referrals and Other Compensation ................................................................................. 20 ITEM 15 – Custody ...................................................................................................................................... 20 ITEM 16 – Investment Discretion ................................................................................................................ 20 ITEM 17 – Voting Client Securities ............................................................................................................. 21 ITEM 18 – Financial Information ................................................................................................................. 21 ITEM 19 – Requirements for State-Registered Advisers ............................................................................. 21 4 Northland Asset Management ADV2A  ITEM 4 – ADVISORY BUSINESS Northland Asset Management Background and Ownership Northland Asset Management (Northland) is the trade name used by Northland Securities, Inc. for its investment advisory business. Northland Securities, Inc. (NSI) is a full-service broker dealer, headquartered in Minneapolis, MN. Since the company was organized in 2002, NSI has underwritten over $10 billion of investment securities. Northland began offering investment advisory services in 2008. At the end of 2025, Northland manages client’s assets totaling $445,150,953; with regulatory assets under management of $405,485,184. Northland Securities has approximately 210 employees, with investment sales offices in nine states. Three of the eight offices conduct investment advisory business. Northland Securities, Inc. is privately held by First National of Nebraska, Inc. (FNNI). First National of Nebraska, Inc. (“FNNI”) is a multi-state holding company that owns, among other entities, First National Bank of Omaha. Northland operates as a separate subsidiary under FNNI. FNNI is a holding company with nearly $30 billion in assets, nearly 5,000 employees, locations across 14 states, and a proud history of serving customers for more than 160 years. FNNI is a sixth-generation, family-owned financial holding company with banking, insurance, and financial services companies and allows Northland to better serve you, our valued client. Type of Advisory Services Offered Northland provides discretionary and non-discretionary investment advisory services that typically involve individualized financial goal analysis, asset allocation, formulation of an investment strategy, assistance with implementation of the investment strategy, and ongoing review of performance measures for the strategy adopted. Reviews generally consist of multiple checks such as a comparison between a client’s portfolio and relevant benchmarks, an analysis of the portfolio’s estimated annual income and current yield along with an analysis of the client’s realized and unrealized gains and losses. In addition, a review of the clients’ goals and investment objectives versus the performance and investments in the portfolio. Northland offers a variety of approaches to investing, which are based on the individual needs of each client. We do not specialize in any particular investment strategy. Northland provides investment advice to individuals, trusts, corporations, and other business entities. Tailoring Advice to Individual Clients Northland will custom tailor an investment portfolio specifically designed for the client based on the client’s investment objectives and goals. The process begins when the client fills out a confidential Client Profile. The Client Profile will allow the client to clarify their financial objectives and goals, establish the client’s tolerance for risk, and identify their preferred style of management. The client may also indicate any special instructions or limits that the client requires Northland to follow in managing the client assets. The Client Profile is used by Northland as the primary reference for managing the client portfolio. For portfolios that are managed in-house by Northland, the client may designate specific securities or industries that should be avoided. For accounts that are handled by Outside Managers, this is not always possible. Clients should make their Northland investment advisor representative aware of any restrictions they would impose on investments in order for their representative to develop an appropriate investment strategy or select an Outside Manager who will agree to implement these requests. Clients pay for Northland’s advisory services based on a fee as a percentage of assets in the account. Most clients participate in a general wrap fee program in which the fee covers advisory services, trading and other transaction 5 Northland Asset Management ADV2A  costs. However, there are costs that are passed through to the client by third party investment managers and respective custodian(s). Those costs outlined in Item 5 of this brochure. Northland is paid a fee as a percentage of assets. The RIA Client Services Agreement, which is signed by each investor, specifies what portion of the fees goes to Northland, as well as what portion goes towards the services of a third party investment manager and/or custodian program fees. Some third party outside managers require funds to be held at a separate custodian, which will cause clients to incur additional transaction fees. Clients should discuss their preferences regarding transaction fees and expenses with their Northland representative to ensure their chosen program best meets their specific needs. Discretion It is the client’s choice whether to allow discretionary trading in their accounts. If the client wishes to retain full discretion over the account, the investment advisor representative will provide investment advice, but the client makes all final decisions. The client may elect to allow an advisor to exercise full discretion in trading the client’s account. Discretion will be exercised by an Outside Manager, if the client elects to participate in an outside manager program. As of 12/31/2025, discretionary regulatory assets under management at Northland Asset Management were $387,310,427 and non-discretionary regulatory assets under management were $18,174,756. ITEM 5 – FEES AND COMPENSATION Northland charges an advisory fee that is calculated based on a percentage of the market value of assets under management (AUM) in the client’s account on the last day of each calendar quarter. Generally, accounts are billed quarterly in advance, but may also be billed in arrears to assess the AUM fee to the quarter in which they are opened. When an account is opened or closed, the advisory fee will be pro-rated, omitted, or adjusted appropriately based on the number of days assets are under management. Clients agree to the billing rate and schedule before account(s) are opened. Clients may terminate the advisory contract without penalty within five (5) business days after dated RIA Client Services Agreement. Northland’s basic asset-based fee schedules for Investment Advisory Services are shown below: Investment Advisory Representative (IAR) Managed Program Northland offers an open architecture advisory account to allow client flexibility. Northland Management Fee: Custodian Program Fee: Total Asset Management Fees: Up to 2.00% per annum Up to 0.09% per annum Up to 2.09% plus rebillable fees Custodian Program Fee: HOUSEHOLD First $100K Next $150K Next $250K Next $500K Next $1M Next $3M Over $5M Basis Points 9 8 7 6 4 2 2 6 Northland Asset Management ADV2A  The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee, which varies based on the total household assets under management, includes a range of a 4 basis point markdown to a 3 basis point markup, as applied by Northland. The markup is considered revenue to the firm. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management Fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 9 basis points or 0.09% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. Northland Asset Management ’NAM’ Model Strategy Program In the Northland Asset Management Model Strategy Program, Northland provides asset allocation models designed to allocate funds into a diversified mix of fixed income and/or equity market investments. The allocation may be adjusted to allow for a 10% inclusion of mutual funds which primarily invest in alternative asset classes. With every model, the mix affects the volatility and performance of your portfolio. Each model mix adjusts the equity to fixed income ratio going from 100% Equity/0% Fixed Income to 50% Equity/50% Fixed Income. Additional expenses will be associated with specific instruments held, such as mutual fund and exchange traded fund expense ratios. Northland Management Fee: Custodian Program Fee: Total Asset Management Fees: Up to 2.00% per annum Up to 0.12% per annum Up to 2.12% plus rebillable fees Custodian Program Fee: HOUSEHOLD First $100K Next $150K Next $250K Next $500K Next $1M Next $3M Over $5M Basis Points 12 11 9 7 5.5 4 2.5 The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee, which varies based on the total household assets under management, includes a range of a 3.5 basis point markdown to a 3 basis point markup, as applied by Northland. The markup is considered revenue to the firm. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 12 basis points or 0.12% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. 7 Northland Asset Management ADV2A  Third Party Strategists Models and Separately Managed Accounts (SMAs) Northland provides access to Third Party Portfolio Managers who manage accounts on a discretionary basis. Each Manager offers a specific style or strategy that Northland and the client may select. Northland also provides access to asset allocation models created by Third Party Model Providers. Generally, these models allocate funds into a diversified mix of fixed income and/or equity market investments that are based on the client’s desired risk/return parameters, goals, risk tolerance, etc. Northland Management Fee: Third Party Manager Fee : Custodian Program Fee: Total Asset Management Fees: Up to 2.00% per annum Up to 1.00% per annum Up to 0.20% per annum Up to 3.20% plus rebillable fees Custodian Program Fee: HOUSEHOLD First $100K Next $150K Next $250K Next $500K Next $1M Next $3M Over $5M Basis Points 20 18 15 14 11 8 5 The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee, which varies based on the total household assets under management, includes up to a 6 basis point markup, as applied by Northland. The markup is considered revenue to the firm. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 20 basis points or 0.20% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. BNYMA Portfolios BNY Mellon Target Risk Focus Portfolios (formerly known as Lockwood WealthStart Portfolios) is a discretionary mutual fund and ETF wrap account product with a $10,000 minimum account size that seeks to assist emerging and mass- affluent investors grow their wealth. BNY Mellon / American Funds Core Portfolios (formerly known as Lockwood/American Funds Core Portfolios) are a discretionary mutual fund and ETF wrap account product with a $10,000 minimum account size. BNYMA, serving as the Portfolio Manager, allocates investor assets systematically across multiple asset classes and styles using American Fund’s mutual funds and other select ETFs in a single account. 8 Northland Asset Management ADV2A  Northland Management Fee: Custodian Program Fee: Total Asset Management Fees: Up to 1.00% per annum Up to 0.37% per annum Up to 1.37% plus rebillable fees Custodian Program Fee: HOUSEHOLD First $500,000 Next $500,000 Over $1,000,000 Basis Points 37 33 24 The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee varies based on the total household assets under management. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 37 basis points or 0.37% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. Disclosure of Additional Expenses, Costs and Revenue Sharing Arrangements Clients understanding our fees, charges and other compensation is important to us. Fees such as annual IRA maintenance fees, wire fees, outgoing transfer fees, and others, are not included as part of the management or custodian program fees and will be paid by the client. These rebillable fees are outlined in the Northland Securities fee schedule and can also be found on the “Policies & Disclosures” page of the Northland Securities’ website (www.northlandsecurities.com) under “SEC RIA Program Disclosures.” If client assets are invested in mutual funds (including money market funds), exchange-traded funds, unit investment trusts, annuities or similar investment vehicles, internal management expenses and 12b1 fees will be part of the overall fees that the client will bear. The fees associated with these products will be disclosed in the applicable product’s prospectus. Clients who invest in these types of investment products will therefore pay two levels of advisory fees on these assets, one to the firm managing the assets and one to the investment product’s advisor at the fund level. Northland Securities retains a portion of the total fee assessed for specific rebillable fees; additional details are provided on the RIA Client Services Agreement executed between Northland and the client(s). Options The pass-through cost from Northland Asset Management’s custodian for option trades is currently $9 per trade, plus $0.50 per contract, and will be paid by the client. Use of Margin Margin investing allows you to have more assets available in your account to buy marginable securities. Your buying power consists of your money available to trade in your account, plus the amount that can be borrowed against securities held in your margin account. 9 Northland Asset Management ADV2A  The use of margin in advisory accounts creates conflicts of interest that you should understand. First, margin debit balances do not reduce the market value of assets in your account and therefore increase the asset-based advisory fee you pay. This increased fee creates an incentive for your advisor to recommend margin strategies. Second, Northland receives a portion of the margin interest charged by BNY Pershing on client margin debit balances. This revenue sharing creates a conflict of interest because Northland has a financial incentive to encourage clients to maintain margin loans rather than liquidating assets to pay for securities purchases, as maintaining margin loans increases our revenue. The use of margin is not suitable for all investors, as it increases leverage and risk in your account. Additional details regarding margin are provided in the advisory agreement executed between Northland and the client. Foreign Securities Clients will also be responsible for fees or expenses related to trading in foreign securities, which will include pass-through fees charged by third parties (portfolio managers and custodians), with respect to foreign securities. Clients will also be responsible for any additional cost and fees associated with cash management services that will be outlined under separate agreements, including but not limited to check-writing, debit and credit card services. Northland does not receive compensation or have a revenue sharing arrangement with BNY Pershing for cash sweep money market products offered in our investment advisory program. Fundvest® Platform Northland offers products from BNY Pershing’s Fundvest® mutual fund platform featuring no-transaction-fee mutual funds (e.g., no commissions, no front-end sales loads or deferred sales charges) subject to certain restrictions on short term trading and below minimum purchase amounts. Once certain asset thresholds of Fundvest® mutual funds are met, we receive revenue-sharing fees from BNY Pershing related to certain Fundvest investments. Our customers do not pay these fees directly but the revenue-sharing fees are often deducted from the total assets in the fund and therefore reduce investment returns. The receipt of revenue- sharing fees by Northland creates a conflict of interest because it creates an incentive for Northland to support these products on its platform. Northland advisors do not directly receive the revenue-sharing fees nor are they compensated more for selling a Fundvest® product. Under the current agreement with BNY Pershing, Northland also receives 12b-1 fees from BNY Pershing on certain share classes in the Fundvest® mutual fund platform. As with all 12b-1 fees received for customers in our advisory platform, Northland credits back 12b- 1 fees paid to our customer accounts. Relationship with our Sole Clearing/Custody Firm BNY Pershing BNY Pershing LLC serves as the clearing and custody firm for Northland's brokerage and advisory business. Northland introduces client accounts to BNY Pershing on a fully disclosed basis, and BNY Pershing executes and clears transactions for these accounts. Clients are charged various fees for these services, as detailed in Northland's Fee Schedule, which is provided at account opening, published on our website, and available upon request. Conflicts of Interest Related to BNY Pershing Relationship Northland's agreement with BNY Pershing includes financial terms that create conflicts of interest regarding our continued use of BNY Pershing as our clearing and custody provider. These include: 10 Northland Asset Management ADV2A  • Termination Fees and Deconversion Costs: If Northland terminates its relationship with BNY Pershing, we would incur termination fees and deconversion-related expenses. These costs create a financial disincentive for Northland to change clearing firms, which conflict with our obligation to use custodians that are in our clients' best interests. • Minimum Fee Requirements: Our agreement with BNY Pershing requires minimum quarterly fees, creating a financial incentive to maintain sufficient business volume with BNY Pershing. • Material Adverse Economic Impact Provisions: Our agreement contains provisions that allow BNY Pershing to revise pricing if certain "material adverse economic impact events" occur. These events could include changes in our business volume, regulatory requirements, or market conditions. The potential for price increases creates uncertainty and an additional incentive to avoid actions that might trigger such adjustments. These financial arrangements create an incentive for Northland to continue our exclusive relationship with BNY Pershing even if alternative custodians might offer lower costs or other advantages that would better serve our clients’ interests. Northland addresses these conflicts through our compliance program and written supervisory procedures, which include: • Regular evaluation of BNY Pershing's services, pricing, and platform capabilities • Periodic assessment of alternative custody and clearing providers • Oversight to ensure clients receive expected services and benefits from our BNY Pershing relationship However, clients should understand that the financial penalties and commitments described above influence our decision-making regarding our clearing relationship Selected Third Party Outside Managers Northland Asset Management currently has agreements in place with two outside managers that provide our clients with unique investment opportunities. These accounts are not held at BNY Pershing, our custodian. • Minneapolis Portfolio Management Group (MPMG) • SEI Investments All clients will receive the applicable ADV documents relating to each outside manager upon solicitation and/or account opening. Management and advisory fees are outlined in applicable client agreements. Northland Management Fee: Third Party Manager Fee Total Asset Management Fees: 2.00% per annum 1.50% per annum 3.50% plus applicable fees of selected custodian. 11 Northland Asset Management ADV2A  Fees charged by Northland may be negotiated and agreed to based upon factors such as the overall complexity of the client’s financial situation, the types of investments, and the number of investing entities. Fees paid to Northland do not necessarily include fees and expenses charged by independent third party managers for certain investments such as mutual funds, exchange traded funds, and/or other index-based investments selected by clients, nor any fees due to brokers or to custodians of those assets including those that are related to Northland. Either party may terminate the investment advisory agreement by written notice and will be effective upon receipt. Any fees that have been prepaid by the client shall be refunded on a pro-rata basis based upon the number of calendar days remaining after the termination date in the period for which fees have been prepaid. Northland may provide financial planning or other advisory services on an hourly basis or based on a one-time charge for service, as agreed to by written agreement. Additional information regarding various options in the Wrap Fee Program can be found in Appendix 1. More information about brokerage fees can be found in Item 12 of this brochure. Northland generally does not receive additional compensation for advisory accounts, other than from its basic fee. However, one exception involves the payment of due diligence fees or other fees from a product originator(s). An example of this would be a Real Estate Investment Trust that provides compensation to Northland to assist with costs in completing our due diligence on the product. Due diligence fees of this nature do not provide a significant source of revenue for the firm. Any fee of this type is fully disclosed in the product prospectus. Northland does not receive any ‘soft dollar’ benefits or other types of compensation that would be unknown to the client. If any additional fee or compensation is received by Northland, as a consequence of the advisory business, it is not used to offset or discount the client fees. Investment Advisor Representatives at Northland receive compensation based on the amount of revenue they generate for the firm. They are rewarded for bringing clients to the firm and for increasing assets under management. While representatives are to serve the best interests of their clients, they are also motivated to receive personal compensation and to contribute to the profitability of the firm. A conflict of interest could occur if the representative or the firm promoted products and services based on a profit motive rather than service to the client. The primary way to address this potential conflict is through transparency of information regarding investment options and fees. ITEM 6 – PERFORMANCE-BASED FEES Northland Asset Management does not charge performance-based fees. ITEM 7 –TYPES OF CLIENTS Northland provides investment advice to individuals, trusts, charitable organizations, corporations, and other business entities. Northland’s minimum account size is $10,000. Certain programs, strategies or managers may require investment minimums from $25,000 to $100,000 or more. At its discretion, Northland may allow smaller investment minimum to participate in the program. 12 Northland Asset Management ADV2A  ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Investment Advisory Representative (IAR) Managed Program Northland as your Investment Advisor Representative provides discretionary and non-discretionary investment advisory services that typically involve; individualized financial goal analysis, asset allocation, formulation of an investment strategy, assistance with implementation of the investment strategy, and ongoing review of performance measures for the strategy adopted. Reviews generally consist of comparisons between a client’s portfolio and relevant benchmarks, an analysis of the portfolio’s estimated annual income and current yield along with an analysis of the client’s realized and unrealized gains and losses. Northland Asset Management ’NAM’ Model Strategy and Third Party Managed Programs Northland may utilize a variety of different managers, both internal, (within Northland) and external. This gives our clients access to different managers and strategies, in order to provide the best opportunities for our clients. A Northland Investment Advisor Representative will evaluate a client’s investment profile and will work with them to determine a strategy and manager that will help fulfill the client’s investment goals. Northland’s programs offer clients tailored options to meet their investment goals. In general, risk in client’s portfolios are reduced through diversification of investments. Entire markets and sectors can decline, and there can be no assurance that the client will not suffer a loss. By working closely with their Investment Advisor Representative, clients will develop portfolios that are designed to meet their needs and are adjusted for risk concerns. ************************************************************************ Northland Asset Management ’NAM’ Model Strategy In the Northland Asset Management Model Strategy Program, Northland provides asset allocation models designed to allocate funds into a diversified mix of fixed income and/or equity market investments. The allocation may be adjusted to allow for a 10% inclusion of mutual funds which primarily invest in alternative asset classes. With every model, the mix affects the volatility and performance of the portfolio. Each model mix adjusts the equity to fixed income ratio going from 100% Equity/0% Fixed Income to 50% Equity/50% Fixed Income. The higher the equity percentage, the more an investor is seeking to take advantage of higher potential for growth. This also means there is more exposure to risk and therefore more potential for fluctuation. The more a model is weighted with a fixed income position, the investor is seeking more opportunities for stable growth and less volatility but with less upside potential than its higher equity counterpart. When choosing which model fits your needs, there are many factors that you and your advisor will discuss such as your risk tolerance, investment time horizon, and personal goals. Each strategy may be implemented within a separate account managed by your advisor to help achieve a range of personal goals. Model Mix Strategy 100 This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 100% equity assets. The portfolio manager invests exclusively in various Equity Mutual Funds and Equity Exchange Traded Funds. Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request 13 Northland Asset Management ADV2A  90/10 This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 90% equities and 10% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request 80/20 This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 80% equities and 20% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request 70/30 This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 70% equities and 30% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request 60/40 This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 60% equities and 40% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request 50/50 This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 50% equities and 50% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request ************************************************************************ Our third-party program is available to our investors through our custodial relationship with BNY Pershing, and BNYMA Advisors. Northland’s responsibility as Sponsor for these programs include gathering a full description of client financials, risk tolerance and investment objectives to assist in determining the suitability of the program that Northland and the client select. Northland will also facilitate account opening and continued monitoring of 14 Northland Asset Management ADV2A  client financial situation and investment objectives. The client will agree to provide discretionary authority to BNYMA to facilitate trading of their selected portfolio and/or strategy. BNYMA’s range of investment offerings includes, but is not limited to the following: • Separately Managed Accounts (“SMA”) – Researched SMA managers and open architecture managers; • Third Party Model Providers – Open architecture mutual fund and ETF models; • BNY Mellon Target Risk Focus Portfolios – A fixed mutual fund and ETF wrap product with a low minimum account size; • The BNY Mellon/American Funds Core Portfolios – a mutual fund and ETF wrap product constructed using American Funds mutual funds; Third Party Separately Managed Accounts (SMAs) Northland Asset Management has access to Managers through the BNYMA Managed Account Command program. These managers specialize in investment strategies that are expected to meet the client’s goal. Northland Asset Management conducts due diligence on the Managers as part of the selection process to evaluate what Managers are best suited to meet our client’s goals and objectives. Northland’s Investment Advisor representatives make recommendations to each client, based on an individual suitability analysis. The selected Outside Manger is granted limited discretionary trading authority, with respect to assets in the clients account(s), however the client and Northland retains final authority for the Manager selection. Based on the Manager’s policies, clients may have the option to restrict investments in their accounts, to avoid certain companies and/or industries. Disclosure of fees and costs will be specified in the RIA Client Services Agreement, along with the standard fee schedule and this document. Third Party Strategists Model Providers Northland will make available to its client, Third Party Model Portfolios, which are open architecture mutual fund and ETF models. These portfolio models and managers are available through an agreement between Northland, BNYMA, and the Model Providers. The models are designed to invest assets according to the selected model that the client and Northland believe will achieve certain objectives and investment goals. Each Model consists of a unique asset class mix, and has a distinctive risk profile. Assets are invested in accordance with the client’s investment objective and level of risk. Once the client has selected the Third Party Model Providers Models program, the account is invested in a combination of some or all of the following investment products, pursuant to the Model you have selected: Equity or fixed income securities; ETFs; and mutual funds. Certain Third Party Model Providers have a minimum account size of $10,000. BNYMA is granted limited discretionary trading authority with respect to assets in the clients Third Party Model Providers Model account(s). The client and Northland retain final authority for the Third Party Model Providers and Model selections. Pursuant to its discretionary trading authority, BNYMA will invest the assets in the account according to the Model the client has selected. BNYMA will also periodically buy and sell securities in the account so that the assets owned are in line with the Model without receiving prior approval from the client. This process is known as “rebalancing.” Asset allocations will differ depending on the Model selected. Once a particular Third Party Model Provider notifies BNYMA of model portfolio changes, BNYMA will make corresponding changes to the account. BNYMA reserves the right to not accept a particular change to a Model. 15 Northland Asset Management ADV2A  For example, if a security is subject to a reasonable restriction imposed, BNYMA will not purchase that security for the account. When a Third Party Model Provider makes model portfolio changes, the Third Party Model Providers may notify BNYMA after the Third Party Model Providers has bought and sold securities in its other clients’ accounts. As a result of the timing of Model change notifications and BNYMA’s processes, Third Party Model Providers may effect trades on behalf of their other clients’ accounts before BNYMA effects corresponding trades in your account. Therefore, in connection with model portfolio changes, due to the potential for the markets to react to the trades effected by a Third Party Model Provider, you may be at a disadvantage when compared to the Third Party Model Provider’s other clients with respect to the timing of the trades. Third Party Model Providers are not responsible for determining the appropriateness or suitability of investment model(s), or of any of the securities included in the investment model(s) for the client specifically. Notwithstanding the foregoing, the client and Northland may wish to review each Third Party Model Provider’s ADV Part 2A or alternative disclosure document for more information regarding a Third Party Model Provider. BNY Mellon Target Risk Focus Portfolios BNY Mellon Target Risk Focus Portfolios allow advisors and their clients access to multi-manager solutions and strategies. With this solution, advisors will be able to assist clients in growing their wealth. Investors have access to mutual fund and / or exchange traded fund accounts that allocates client assets across multiple asset classes and styles and bundles them into one single account. BNYMA is the Discretionary Portfolio Manager for BNY Mellon Target Risk Focus Portfolios. Northland is the Sponsor of the program The minimum account size is $10,000, with minimum subsequent investment of $1,000 each. BNYMA/American Funds Core Portfolios The BNYMA/American Funds Core Portfolio is a discretionary mutual fund and ETF wrap account product with a $10,000 minimum account size. BNYMA, serving as the Portfolio Manager, allocates investor assets systematically across multiple asset classes and styles using American Funds mutual funds and other select ETFs in a single account. BNYMA determines the asset allocation strategy and selects investment vehicles for each investment style in the portfolio, based upon proprietary modeling strategies, economic outlook and investment research discipline. BNYMA is solely responsible for the fund selection and construction of the BNYMA/American Funds Core Portfolios and neither American Funds Distributors, Inc. or its affiliates are involved in such activities, nor do American Funds Distributors, Inc. or its affiliates serve as investment adviser to client accounts. The BNYMA/American Funds Core Portfolios consist of three models designed to align with key stages of the investor lifecycle, which may consist of open and closed-end mutual funds, exchange-traded funds and other types of securities. BNYMA is the Discretionary Portfolio Manager for the BNYMA/American Funds Core Portfolios. Northland is the Sponsor of the program ************************************************************************ Northland Asset Management currently has agreements in place with the following two strategic outside third party managers: Minneapolis Portfolio Management Group (MPMG) • MPMG invests in both domestic and international small, mid and large-cap value equity securities. 16 Northland Asset Management ADV2A  SEI Investments • SEI is a global asset manager that provides diversified portfolios and strategies across equity, fixed income and alternative investments. ITEM 9 – DISCIPLINARY INFORMATION Northland Securities does not have any criminal history nor has the Firm been subject to any civil litigation or administrative proceedings. However, Northland Securities has been subject to disciplinary action due to some inaccurate books and records in relation to equity trading and investment banking activity. The Firm also was subject to an enforcement action for the Municipal Continuing Disclosure review. We do not believe these violations are of a material nature that reflects poor judgment on the part of Northland’s investment advisor representatives nor the management team of the Firm. A full description of these violations can be found in the Investors section of the Financial Industry Regulatory Authority’s (“FINRA”) web site by accessing their BrokerCheck® link, which can be found at: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ . Or you may request a copy of the disciplinary action from your Investment Advisor Representative or by sending a request to the following address: Northland Securities, Inc. Attn: Compliance 150 South 5th Street Suite 3300 Minneapolis, MN 55402 ITEM 10 – FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Northland Asset Management is the trade name for the investment advisory business line of Northland Securities, Inc. Northland Securities, Inc. is a full-service broker dealer and member of FINRA/SIPC. Potential conflicts of interest occur when principal trades are conducted in RIA accounts. Procedures to protect clients from this conflict of interest are described in Item 12. Northland at times recommends the purchase of non-traded Real Estate Investment Trusts that pay a due diligence fee to the firm. When non-traded REITS are purchased in RIA accounts, the REIT will be specifically designed for wrap accounts; it will have an annual fee, rather than an up-front commission charge. Beyond its broker dealer activities, Northland is not involved in other outside business, and is not aware of any business relationship conflicts of interest. ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS & PERSONAL TRADING Northland has established a standard of conduct for its advisory personnel, which is outlined in the Northland Asset Management Code of Ethics. The Code outlines our way of doing business, which is to serve our clients with honesty, integrity and competence. The Code addresses areas where a conflict of interest may arise, and 17 Northland Asset Management ADV2A  provides guidance in these areas. Some conflicts of interest arise from the personal trading of the advisory personnel. Northland has put in place the following restrictions in order to ensure its fiduciary responsibilities: No associated person of Northland shall put his or her own interest ahead of an advisory client. Investment opportunities must be offered first to clients before Northland or its associated persons may participate in such transactions; Associated persons or their immediate family members shall not buy or sell securities for their personal portfolio(s) where their decision is derived in whole or in part, by reason of the associated person's employment, unless the information is also available to the investing public upon reasonable inquiry; Northland and its employees will not participate in private placements or initial public offerings (IPOs) without prior approval from Northland’s senior management; Northland requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices; Records will be maintained of all securities bought or sold by Northland and its associated persons. A qualified representative of Northland will review these records on a regular basis; Fee discounts not generally available to our advisory clients may be offered to family members and friends of associated persons of our firm. Any individual not in observance of the above may be subject to disciplinary action up to and including termination. The full text of Northland’s Code of Ethics is available to you upon request. ITEM 12 – BROKERAGE PRACTICES Northland Securities, Inc. is a broker dealer as well as a registered investment advisor, and is actively engaged in buying and selling securities for its own account as well as for clients. (Northland Securities, Inc., a full service broker dealer, does its investment advisory business as Northland Asset Management.) The firm has a responsibility to all its clients to operate in an ethical manner. Northland recognizes its fiduciary responsibilities to its advisory clients. Northland primarily routes all trades for advisory clients to BNY Pershing (our custodian) for trade execution. We must execute securities transactions in such a manner that the total cost or proceeds in each transaction is the most favorable under the circumstances. Best execution does not necessarily mean the lowest available price. It is important to understand that Northland only uses a single custodian, as such the firm cannot choose between custodians to obtain the least clearing and execution costs so consequently the client could be paying more per transaction. In very limited circumstances, trades are routed to Northland Securities equity trading desk for execution, and that would only be in circumstances where a large trade over 10,000 shares would require execution. In those circumstances the client could pay higher costs for execution, but Northland feels the client would receive a more favorable execution versus sending it via BNY Pershing’s trading system for execution. We have determined that having BNY Pershing execute most trades is consistent with our duty to seek “best execution” of client trades. Best execution means seeking the most favorable terms for a transaction based on all relevant factors, including products and services available through our custodian to assist us in managing and administering our client’s accounts. The custodian makes available software and other technology that provide access to client account data, facilitates 18 Northland Asset Management ADV2A  trade execution for client accounts, provides pricing and other market data, facilitates payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. Northland Asset Management does not receive any ‘soft dollar’ compensation from any third party. Northland does not receive any referral fees from broker dealers for directed brokerage. Policies for order aggregation would generally follow the procedures of Outside Managers. Northland internal account management is not of a volume to necessitate aggregation procedures. We may utilize cross trades for securities that are hard to purchase or sell in the open market (ie small bond lots or thinly traded stocks or bonds). Cross trades will be done through Northland Securities trading desk at current bid/ask pricing. Northland Asset Management or Northland Securities will receive no compensation for these trades. Written client notification will be provided in these limited circumstances. There are other fees that Northland will mark up from what the clearing firm charges. These are marked up to defray Northland’s processing costs. Those fees are outlined and identified in the fee schedule that is provided at account opening, and on Northland’s public website. Northland charges up to $140.00 (dependent on account type) termination fee when clients transfer their accounts to another investment advisory firm. ITEM 13 – REVIEW OF ACCOUNTS Client accounts are monitored on a continuous basis by a designated principal. All accounts handled by Northland Asset Management are under ongoing supervision. When a client opens an account, a supervisor reviews the new account forms, including the investment objectives and risk parameters of the account. InvestEdge, an electronic system, is used to monitor trades for suitability and to monitor accounts for changes in value. Daily account activity is reviewed as part of the general review of trades at the firm. At a minimum, annual supervisory reviews are conducted to review the performance of accounts. The firm has procedures to review for appropriate share class in Mutual Fund products. If an exception is identified during a quarterly review, the firm will take steps to remediate, if necessary. Remediation could include a conversion to a different share class, or refund/rebate of compensation (if deemed material) received by the firm and the investment advisor. A supplemental review is conducted by the Chief Compliance Officer or delegate as part of the inspection process. Clients or their independent representatives are provided with a statement from the custodian holding the client's funds/securities at least quarterly and may be provided with a monthly written report generated by Northland, showing client holdings. Investment advice may only be rendered by qualified investment advisory professionals who have been approved by Northland. Generally, a college degree and/or equivalent business experience is required for investment advisory professionals, other than those performing clerical or ministerial services. Most states require licensing. The independent custodian provides clients with a statement (at least quarterly) identifying the amount of funds and of each security in their accounts at the end of the reporting period and setting forth all transactions in the account during the reporting period. Northland also makes various reports and quarterly performance evaluations accessible to its clients. Trade Confirmations: Individual trade confirmations and reports of account activity will be provided by the custodian. Northland will generally communicate with its clients via letters, market up-dates and other Northland generated literature. 19 Northland Asset Management ADV2A  Under circumstances where the client has expressly consented, client correspondence and notifications may be sent via electronic means (such as e-mail). In addition, when an outside manager is selected, the client may choose suppression of confirmations on the RIA Client Services Agreement. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Northland does not pay compensation for referrals. ITEM 15 – CUSTODY Northland does not and will not have custody of client funds or securities, excepting payment of fees in advance as described in this brochure. To help the firm provide accurate and timely management of the client’s invested assets, the client will be asked to establish a custodial account with our designated custodian, BNY Pershing, with whom Northland Securities, Inc. has a fully-disclosed clearing relationship. Northland only uses a single custodian, as such the firm cannot choose between custodians to obtain the least clearing and execution costs so consequently the client could pay more per transaction Third party managed accounts may have other custodial relationships dependent on the relationship the client chooses to select. The custodian maintains the underlying records for the assets held in the account. Northland does not serve as the custodian for those clients’ managed assets. The client is solely responsible for paying all the fees and charges of the custodian as stated in the third party agreement with the custodian. Northland strives to maintain the account data as accurately as possible; however, the firm must rely on accurate reporting provided to it by the custodian through electronic or other means. Northland is not responsible for inaccurate data provided by a custodian. Clients are requested to promptly submit to Northland in writing any changes to the Client Profile, or any changes to any information that was provided to the firm regarding management of the client assets. Maintaining proper records and documentation regarding each account is vitally important. ITEM 16 – INVESTMENT DISCRETION In order for Northland to actively manage client assets, the firm prefers that clients provide it with discretionary trading authority. This allows Northland or the selected Outside Manager to buy or sell securities, as well as specify the amount of securities to invest, without first obtaining the client’s specific consent. This authority is limited to the transfer or exchange of your funds between securities and asset classes agreed to by you in accordance with the investment management service selected by you. For assets held by a designated custodian, firm discretion extends to the transfer or exchange from one fund family to another so long as it is done at net asset value (NAV) and no commissions are generated. In cases where Northland determines the broker or dealer to be used, the firm will seek to obtain the best execution possible under the circumstances. This discretionary authority in no way restricts clients, from establishing special limitations on the types of investments that may be recommended or made on the client’s behalf. Clients may send Northland specific written instruction at any time regarding securities that may be purchased or sold, and may also instruct the firm not to purchase specific securities or types of securities. If Northland is unable to accommodate client requests for any reason, the Investment Advisor Representative will notify the client promptly. 20 Northland Asset Management ADV2A  Upon termination of the Firm’s investment management services, Northland has no obligation or authority to recommend or take any action with regard to the previously managed assets. ITEM 17 – VOTING CLIENT SECURITIES Northland does not vote proxies for clients, and does not provide advice to clients about how to vote proxies. Clients retain the authority to vote proxies, and will be required to ensure that proxy materials are sent directly to them, except as noted in the following paragraphs. If client is a tax-qualified retirement plan subject to ERISA, an Outside Manager is engaged, the Outside Manager can be responsible for voting proxies; however, each client may opt to retain such proxy voting rights. With respect to clients which are not governed by ERISA, each client may either retain the right to vote proxies or delegate such authority to each Outside Manager. The proxy delegation must be evidenced in writing, and may be rescinded based on a written request from the client. ITEM 18 – FINANCIAL INFORMATION Northland Securities, Inc., is a subsidiary of Northland Capital Holdings, Inc. First National of Nebraska, Inc., is the parent company of Northland Capital Holdings, Inc. and First National Bank of Omaha. We are a privately held company and our financial information is not made available to the public. Advisory firms who do not require payment of fees six months or more in advance are not required to furnish a balance sheet to clients. Northland requires payment of fees monthly and quarterly in advance, so a balance sheet need not be provided. ITEM 19 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS This is not applicable to Northland Asset Management. 21 Northland Asset Management ADV2A 

ADV2 APPENDIX 1 WRAP FEE PROGRAM BROCHURE NORTHLAND SECURITIES, INC 150 S. 5th STREET, SUITE 3300 MINNEAPOLIS, MN 55402 612-851-5900 MEMBER FINRA/SIPC www.northlandsecurities.com This wrap fee program brochure provides information about the qualifications and business practices of Northland Asset Management. If you have any questions about the contents of this brochure, please contact us at 612-851-5900. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration with the SEC and/or state entities does not of itself imply a certain level of skill or training. This brochure meets requirements for disclosure as ADV2 Appendix 1. Northland Securities, Inc. does its Registered Investment Advisory business as Northland Asset Management. Additional information about Northland Asset Management may be found on the SEC’s website at www.adviserinfo.sec.gov. Effective: March 26, 2026 Last update: July 1, 2025 ITEM 1 – COVER PAGE  ITEM 2 – MATERIAL CHANGES Important Update Regarding Northland’s Revenue Sharing Arrangements Fundvest Platform Northland offers mutual funds through BNY Pershing's Fundvest® platform, which features no-transaction- fee mutual funds with no commissions, front-end sales loads, or deferred sales charges, subject to certain trading restrictions and minimum purchase requirements. When clients' aggregate holdings in Fundvest® mutual funds reach certain asset thresholds, Northland is entitled to receive revenue-sharing payments from BNY Pershing based on those fund investments. While clients do not pay these fees directly to Northland, the revenue-sharing payments are typically paid from fund assets, which reduces overall investment returns to shareholders. This revenue-sharing arrangement creates a conflict of interest because Northland has a financial incentive to recommend and maintain Fundvest® products on our platform, which influence our recommendations regarding mutual fund investments. Individual investment adviser representatives do not directly receive revenue-sharing fees and are not provided additional compensation for recommending Fundvest® products. Northland participates in BNY Pershing's Fundvest® Institutional Program, which typically does not include 12b-1 fees. However, in the event that any 12b-1 fees are received, Northland credits those fees directly to the applicable client account. To address this conflict, our advisors are required to make recommendations based on client best interest standards. We also conduct periodic reviews of fund performance and expenses and monitor for inappropriate recommendations. However, clients should understand that the revenue-sharing arrangement creates an ongoing financial conflict of interest. Our mitigation efforts are designed to ensure recommendations remain in clients' best interests, but they do not eliminate the financial incentive we have to recommend Fundvest® products. Margin Accounts Margin investing allows you to have more assets available in your account to buy marginable securities. Your buying power consists of your money available to trade in your account, plus the amount that can be borrowed against securities held in your margin account. The use of margin in advisory accounts creates conflicts of interest that you should understand. First, margin debit balances do not reduce the market value of assets in your account and therefore increase the asset-based advisory fee you pay. This increased fee creates an incentive for your advisor to recommend margin strategies. Second, Northland receives a portion of the margin interest charged by BNY Pershing on client margin debit balances. This revenue sharing creates a conflict of interest because Northland has a financial incentive to encourage clients to maintain margin loans rather than liquidating assets to pay for securities purchases, as maintaining margin loans increases our revenue. The use of margin is not suitable for all investors, as it increases leverage and risk in your account. Additional details regarding margin are provided in the advisory agreement executed between Northland and the client. 2 ADV2 Appendix 1 Wrap Fee Brochure 03/26  Relationship with our Sole Clearing/Custody Firm BNY Pershing BNY Pershing LLC serves as the clearing and custody firm for Northland's brokerage and advisory business. Northland introduces client accounts to BNY Pershing on a fully disclosed basis, and BNY Pershing executes and clears transactions for these accounts. Clients are charged various fees for these services, as detailed in Northland's Fee Schedule, which is provided at account opening, published on our website, and available upon request. Conflicts of Interest Related to BNY Pershing Relationship Northland's agreement with BNY Pershing includes financial terms that create conflicts of interest regarding our continued use of BNY Pershing as our clearing and custody provider. These include: • Termination Fees and Deconversion Costs: If Northland terminates its relationship with BNY Pershing, we would incur termination fees and deconversion-related expenses. These costs create a financial disincentive for Northland to change clearing firms, which conflict with our obligation to use custodians that are in our clients' best interests. • Minimum Fee Requirements: Our agreement with BNY Pershing requires minimum quarterly fees, creating a financial incentive to maintain sufficient business volume with BNY Pershing. • Material Adverse Economic Impact Provisions: Our agreement contains provisions that allow BNY Pershing to revise pricing if certain "material adverse economic impact events" occur. These events could include changes in our business volume, regulatory requirements, or market conditions. The potential for price increases creates uncertainty and an additional incentive to avoid actions that might trigger such adjustments. These financial arrangements create an incentive for Northland to continue our exclusive relationship with BNY Pershing even if alternative custodians might offer lower costs or other advantages that would better serve our clients’ interests. Northland addresses these conflicts through our compliance program and written supervisory procedures, which include: • Regular evaluation of BNY Pershing's services, pricing, and platform capabilities • Periodic assessment of alternative custody and clearing providers • Oversight to ensure clients receive expected services and benefits from our BNY Pershing relationship However, clients should understand that the financial penalties and commitments described above influence our decision-making regarding our clearing relationship You will find the full brochure disclosure document at: www.adviserinfo.sec.gov. You can view the document by searching that website for “Northland Asset Management”. You can also request a hardcopy by calling 612- 851-5900. 3 ADV2 Appendix 1 Wrap Fee Brochure 03/26  ITEM 3 – TABLE OF CONTENTS ITEM 1 – Cover Page ............................................................................................................................................. 1 ITEM 2 – Material Changes ................................................................................................................................... 2 ITEM 3 – Table of Contents ................................................................................................................................... 4 ITEM 4 – Services, Fees and Compensation .......................................................................................................... 5 ITEM 5 – Account Requirements and Types of Clients ....................................................................................... 10 ITEM 6 – Portfolio Manager Selection and Evaluation ....................................................................................... 10 ITEM 7 – Client Information Provided to Portfolio Managers ............................................................................ 11 ITEM 8 – Client Contact with Portfolio Managers .............................................................................................. 11 ITEM 9 – Additional Information......................................................................................................................... 11 ITEM 10 – Requirements for State Registered Advisers ...................................................................................... 13 4 ADV2 Appendix 1 Wrap Fee Brochure 03/26  ITEM 4 – SERVICES, FEES AND COMPENSATION Northland Asset Management is a Registered Investment Advisor offering portfolio management solutions primarily to individuals. Northland Investment Advisor Representatives (IARs) work with clients to understand their investment goals, time horizons, tax status, need for liquidity, and other factors. They also assist the client in understanding the risks and rewards associated with different market types and sectors, and assist them in developing portfolios that will help to achieve their goals, within the appropriate risk constraints. Portfolios may be made up entirely of equities or fixed income investments, or they may include a combination of securities, as well as mutual funds, real estate investment trusts, options and alternative investments. Clients who have a wrap fee account pay one fee that covers investment advice as well as transaction costs. Additional fees are charged for custodial services, such as an annual IRA custodial fee. Some products, such as mutual funds, may have additional fees and expenses within the product structure. In these cases, every effort is made to select products with minimal internal fees. Northland may utilize a variety of different managers to be able to provide the best opportunities for our clients. A Northland Investment Advisor Representative will evaluate a client’s investment profile and will work with them to determine a strategy and manager that will help fulfill the client’s investment goals. Clients have several options for portfolio management solutions; a brief summary is given below: Northland Asset Management Model Strategies In the Northland Asset Management Model Strategy Program, Northland provides asset allocation models designed to allocate funds into a diversified mix of fixed income and/or equity market investments. The allocation may be adjusted to allow for a 10% inclusion of mutual funds which primarily invest in alternative asset classes. With every model, the mix affects the volatility and performance of your portfolio. Each model mix adjusts the equity to fixed income ratio going from 100% Equity/0% Fixed Income to 50% Equity/50% Fixed Income. Additional expenses will be associated with specific instruments held, such as mutual fund and exchange traded fund expense ratios. Northland Asset Management NAM’ Model Strategy Program Northland Management Fee: Custodian Program Fee: Total Asset Management Fees: Up to 2.00% per annum (maximum) Up to 0.12% per annum Up to 2.12% plus custodial and rebillable fees NAM Models Custodian Program Fee: HOUSEHOLD First $100K Basis points 12 Next $150K 11 Next $250K 9 Next $500K 7 Next $1M 5.5 Next $3M 4 Over $5M 2.5 5 ADV2 Appendix 1 Wrap Fee Brochure 03/26  The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee, which varies based on the total household assets under management, includes a range of a 3.5 basis point markdown to a 3 basis point markup, as applied by Northland. The markup is considered revenue to the firm. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 12 basis points or 0.12% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. Third Party Strategists Models and Separately Managed Accounts (SMAs) Northland provides access to Third Party Portfolio Managers who manage accounts on a discretionary basis. Each Manager offers a specific style or strategy that Northland and the client may select. Northland also provides access to asset allocation models created by Third Party Model Providers. Generally, these models allocate funds into a diversified mix of fixed income and/or equity market investments that are based on the client’s desired risk/return parameters, goals, risk tolerance, etc. Northland Management Fee: Third Party Manager Fee: Custodian Program Fee: Total Asset Management Fees: Up to 2.00% per annum Up to 1.00% per annum Up to 0.20% per annum Up to 3.20% plus rebillable fees Custodian Program Fee: HOUSEHOLD First $100K Basis Points 20 Next $150K 18 Next $250K 15 Next $500K 14 Next $1M 11 Next $3M 8 Over $5M 5 The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee, which varies based on the total household assets under management, includes up to a 6 basis point markup, as applied by Northland. The markup is considered revenue to the firm. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 20 basis points or 0.20% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. 6 ADV2 Appendix 1 Wrap Fee Brochure 03/26  BNYMA Portfolios BNY Mellon Target Risk Focus Portfolios (formerly known as Lockwood WealthStart Portfolios) is a discretionary mutual fund and ETF wrap account product with a $10,000 minimum account size that seeks to assist emerging and mass- affluent investors grow their wealth. BNY Mellon / American Funds Core Portfolios (formerly known as Lockwood/American Funds Core Portfolios) are a discretionary mutual fund and ETF wrap account product with a $10,000 minimum account size. BNYMA, serving as the Portfolio Manager, allocates investor assets systematically across multiple asset classes and styles using American Fund’s mutual funds and other select ETFs in a single account. Northland Management Fee: Custodian Program Fee: Total Asset Management Fees: Up to 1.00% per annum Up to 0.37% per annum Up to 1.37% plus rebillable fees Custodian Program Fee: HOUSEHOLD First $500,000 Basis Points 37 Next $500,000 33 Over $1,000,000 24 The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee varies based on the total household assets under management. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 37 basis points or 0.37% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. Disclosure of Additional Expenses, Costs and Revenue Sharing Arrangements Clients understanding our fees, charges and other compensation is important to us. Fees such as annual IRA maintenance fees, wire fees, outgoing transfer fees, and others, are not included as part of the management or custodian program fees and will be paid by the client. These rebillable fees are outlined in the Northland Securities fee schedule and can also be found on the “Policies & Disclosures” page of the Northland Securities’ website (www.northlandsecurities.com) under “SEC RIA Program Disclosures.” If client assets are invested in mutual funds (including money market funds), exchange-traded funds, unit investment trusts, annuities or similar investment vehicles, internal management expenses and 12b1 fees will be part of the overall fees that the client will bear. The fees associated with these products will be disclosed in the applicable product’s prospectus. Clients who invest in these types of investment products will therefore pay two levels of advisory fees on these assets, one to the firm managing the assets and one to the investment product’s advisor at the fund level. Northland Securities retains a portion of the total fee assessed for specific rebillable fees; additional details are provided on the RIA Client Services Agreement executed between Northland and the client(s). Options 7 ADV2 Appendix 1 Wrap Fee Brochure 03/26  The pass-through cost from Northland Asset Management’s custodian for option trades is currently $9 per trade, plus $0.50 per contract, and will be paid by the client. Use of Margin Margin investing allows you to have more assets available in your account to buy marginable securities. Your buying power consists of your money available to trade in your account, plus the amount that can be borrowed against securities held in your margin account. The use of margin in advisory accounts creates conflicts of interest that you should understand. First, margin debit balances do not reduce the market value of assets in your account and therefore increase the asset-based advisory fee you pay. This increased fee creates an incentive for your advisor to recommend margin strategies. Second, Northland receives a portion of the margin interest charged by BNY Pershing on client margin debit balances. This revenue sharing creates a conflict of interest because Northland has a financial incentive to encourage clients to maintain margin loans rather than liquidating assets to pay for securities purchases, as maintaining margin loans increases our revenue. The use of margin is not suitable for all investors, as it increases leverage and risk in your account. Additional details regarding margin are provided in the advisory agreement executed between Northland and the client. Foreign Securities Clients will also be responsible for fees or expenses related to trading in foreign securities, which will include pass-through fees charged by third parties (portfolio managers and custodians), with respect to foreign securities. Clients will also be responsible for any additional cost and fees associated with cash management services that will be outlined under separate agreements, including but not limited to check-writing, debit and credit card services. Northland does not receive compensation or have a revenue sharing arrangement with BNY Pershing for cash sweep money market products offered in our investment advisory program. Fundvest® Platform Northland offers products from BNY Pershing’s Fundvest® mutual fund platform featuring no-transaction- fee mutual funds (e.g., no commissions, no front-end sales loads or deferred sales charges) subject to certain restrictions on short term trading and below minimum purchase amounts. Once certain asset thresholds of Fundvest® mutual funds are met, we receive revenue-sharing fees from BNY Pershing related to certain Fundvest investments. Our customers do not pay these fees directly but the revenue-sharing fees are often deducted from the total assets in the fund and therefore reduce investment returns. The receipt of revenue- sharing fees by Northland creates a conflict of interest because it creates an incentive for Northland to support these products on its platform. Northland advisors do not directly receive the revenue-sharing fees nor are they compensated more for selling a Fundvest® product. Under the current agreement with BNY Pershing, Northland also receives 12b-1 fees from BNY Pershing on certain share classes in the Fundvest® mutual fund platform. As with all 12b-1 fees received for customers in our advisory platform, Northland credits back 12b- 1 fees paid to our customer accounts. Relationship with our Sole Clearing/Custody Firm BNY Pershing BNY Pershing LLC serves as the clearing and custody firm for Northland's brokerage and advisory business. Northland introduces client accounts to BNY Pershing on a fully disclosed basis, and BNY Pershing executes and clears transactions for these accounts. Clients are charged various fees for these services, as detailed in 8 ADV2 Appendix 1 Wrap Fee Brochure 03/26  Northland's Fee Schedule, which is provided at account opening, published on our website, and available upon request. Conflicts of Interest Related to BNY Pershing Relationship Northland's agreement with BNY Pershing includes financial terms that create conflicts of interest regarding our continued use of BNY Pershing as our clearing and custody provider. These include: • Termination Fees and Deconversion Costs: If Northland terminates its relationship with BNY Pershing, we would incur termination fees and deconversion-related expenses. These costs create a financial disincentive for Northland to change clearing firms, which conflict with our obligation to use custodians that are in our clients' best interests. • Minimum Fee Requirements: Our agreement with BNY Pershing requires minimum quarterly fees, creating a financial incentive to maintain sufficient business volume with BNY Pershing. • Material Adverse Economic Impact Provisions: Our agreement contains provisions that allow BNY Pershing to revise pricing if certain "material adverse economic impact events" occur. These events could include changes in our business volume, regulatory requirements, or market conditions. The potential for price increases creates uncertainty and an additional incentive to avoid actions that might trigger such adjustments. These financial arrangements create an incentive for Northland to continue our exclusive relationship with BNY Pershing even if alternative custodians might offer lower costs or other advantages that would better serve our clients’ interests. Northland addresses these conflicts through our compliance program and written supervisory procedures, which include: • Regular evaluation of BNY Pershing's services, pricing, and platform capabilities • Periodic assessment of alternative custody and clearing providers • Oversight to ensure clients receive expected services and benefits from our BNY Pershing relationship However, clients should understand that the financial penalties and commitments described above influence our decision-making regarding our clearing relationship. Selected Third Party Outside Managers Northland Asset Management currently has agreements in place with two outside managers that provide our clients with unique investment opportunities. These accounts are not held at BNY BNY Pershing, our custodian. Minneapolis Portfolio Management Group (MPMG) SEI Investments All clients will receive the applicable ADV documents relating to each outside manager upon solicitation and/or account opening. Management and advisory fees are outlined in applicable client agreements. 9 ADV2 Appendix 1 Wrap Fee Brochure 03/26  Northland Management Fee: Third Party Manager Fee Total Asset Management Fees: 2.00% per annum (maximum) 1.50% per annum (maximum) 3.50% plus applicable fees of selected custodian. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Northland provides investment advice to individuals, trusts, charitable organizations, corporations, and other business entities. Northland’s minimum account size is $10,000. Certain programs, strategies and managers may require investment minimums from $25,000 to $100,000 or more. At its discretion, Northland may allow smaller investment minimum to participate in the program. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION Northland’s review of outside Portfolio Managers begins with a selection of firms that are available through its clearing firm, BNY Pershing. From this list, the Northland RIA Management Committee selects a diverse group of Managers reflecting both general and specific investment styles. The Managers are reviewed based on publicly available information, including company web sites and Morningstar Reports. Clients, based on consultation with their IAR, select a Manager or Managers from this list. They may also select a particular management style, when available. A Northland principal reviews performance of the outside Portfolio Managers for each account on a regular basis, generally quarterly and no less than annually. A quarterly report is provided to the client and the IAR, showing performance against an established benchmark. On a regular basis, performance reports are compared against client account statements, to verify accuracy of holdings and values. If the client or the IAR is unsatisfied with the Outside Manager performance, or if the client’s goals or strategies have changed, the IAR notifies a Northland Principal, and the change is initiated. On an annual basis, the Northland RIA Management Committee reviews Portfolio Managers that are currently being used or actively recommended to clients. Changes to the list are made annually, unless a specific situation requires earlier attention. At times, IARs and clients may choose to work with a Portfolio Manager who is not currently available on the Northland platform. To accommodate this request, the Northland RIA Management Committee performs due diligence on the Manager and when appropriate contacts BNY Pershing to add them to our program. Occasionally, a Manager is not available through BNY Pershing, and client accounts may be held with a separate custodian. Northland does not collect performance-based fees and does not vote for clients by proxy. Outside Managers may vote proxies for clients who give approval for this on their Client Services Agreement. 10 ADV2 Appendix 1 Wrap Fee Brochure 03/26  ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Northland collects a broad range of client information in order to make suitable investment recommendations to clients. This information includes income, net worth, investment experience, tax status, marital status, risk acceptance and investment objectives. Northland updates this information as client situations change. Outside Managers are given information on the client amount of investment, liquidity needs, investment time horizon and any investment restrictions on either individual stocks or sectors. The Outside Manager is also given client identification information along client approvals regarding proxy voting and confirm or statement suppression. ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Outside Managers generally are not available for discussions with individual clients. Some Managers may arrange for an individual consultation in a special situation, but this is highly unusual. Outside Managers communicate through publicly available information on their strategies and through individual account statements. Investment Adviser Representatives are available on a regular basis for review of the account activity and performance with the client. ITEM 9 – ADDITIONAL INFORMATION Disciplinary Information Northland Securities does not have any criminal history nor has the Firm been subject to any civil litigation or administrative proceedings. However, Northland Securities has been subject to disciplinary action due to some inaccurate books and records in relation to equity trading and investment banking activity. The Firm also was subject to an enforcement action for the Municipal Continuing Disclosure review. We do not believe these violations are of a material nature that reflects poor judgment on the part of Northland’s investment adviser representatives nor the management team of the Firm. their BrokerCheck® link, which can be A full description of these violations can be found in the Investors section of the Financial Industry Regulatory found (“FINRA”) web site by accessing Authority’s at:http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/. Or you may request a copy of the disciplinary action from your Investment Adviser Representative or by sending a request to the following address: Northland Securities, Inc. Attn: Compliance 150 South 5th Street Suite 3300 Minneapolis, MN 55402 Other Financial Industry Activities and Affiliations Northland Asset Management is the trade name for the investment advisory business line of Northland Securities, Inc. Northland Securities, Inc. is a full service broker dealer and member of FINRA/SIPC. Procedures to protect clients from this conflict of interest are described in Item 12 of Northland Asset Management’s ADV Part 2A. 11 ADV2 Appendix 1 Wrap Fee Brochure 03/26  Northland at times recommends the purchase of non-traded Real Estate Investment Trusts that may pay a due diligence fee to the firm. When non-traded REITS are purchased in RIA accounts, the REIT will be specifically designed for wrap accounts; it will have an annual fee, rather than an up-front commission charge. Beyond its broker dealer activities, Northland is not involved in other outside business, and is not aware of any business relationship conflicts of interest. Code of Ethics Northland has established a standard of conduct for its advisory personnel, which is outlined in the Northland Asset Management Code of Ethics. The Code outlines our way of doing business, which is to serve our clients with honesty, integrity and competence. The Code addresses areas where a conflict of interest may arise, and provides guidance in these areas. Some conflicts of interest may arise from the personal trading of the advisory personnel. Northland has put in place the following restrictions in order to ensure its fiduciary responsibilities: No associated person of Northland shall prefer his or her own interest to that of an advisory Client. Investment opportunities must be offered first to Clients before Northland or its associated persons may participate in such transactions; Associated persons or their immediate family members shall not buy or sell securities for their personal portfolio(s) where their decision is derived in whole or in part, by reason of the associated person's employment, unless the information is also available to the investing public on reasonable inquiry; Northland and its employees may not participate in private placements or initial public offerings (IPOs) without prior approval from Northland’s designated supervisor; Northland requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices; Records will be maintained of all securities bought or sold by Northland, its associated persons, and related entities. A qualified representative of Northland will review these records on a regular basis; and Any individual not in observance of the above may be subject to disciplinary action up to and including termination. The full text of Northland’s Code of Ethics is available to you upon request. Review of Accounts Client accounts are monitored on a continuous basis by a designated principal. A formal review is conducted by the Chief Compliance Officer or designee as part of the inspection process. Clients or their investment representatives are provided with a statement from the custodian holding the Client's funds/securities at least quarterly. It sets forth all transactions in your account during the reporting period. Northland also makes quarterly performance evaluations available to its clients. Additional reviews may be provided at the Client's request, or upon material changes in the Client's financial condition or pursuant to the terms of the executed agreement for services. Investment advice may only be rendered by qualified investment advisory professionals who have been approved by Northland. Generally, a college degree and/or equivalent business experience is required for investment advisory professionals, other than those performing clerical or ministerial services. 12 ADV2 Appendix 1 Wrap Fee Brochure 03/26  Trade Confirmations: Individual trade confirmations and reports of account activity will be provided by the custodian. Northland will generally communicate with its clients via letters, market updates and other Northland generated literature. Under circumstances where the client has expressly consented, client correspondence and notifications may be sent via electronic means (such as e-mail). In addition, when an Outside Manager is selected, the client may choose suppression of confirmations on the Client Agreement. Financial Information Northland Securities, Inc., is a subsidiary of Northland Capital Holdings, Inc. First National of Nebraska, Inc., is the parent company of Northland Capital Holdings, Inc. and First National Bank of Omaha. We are a privately held company and our financial information is not made available to the public. Advisory firms who require payment of fees six months or more in advance are required to furnish a balance sheet to clients. Northland requires payment of fees monthly and quarterly in advance, so a balance sheet is not required disclosure. Termination of Account Services Either party may terminate the investment advisory agreement by written notice and will be effective upon receipt. Any fees that may have been prepaid by the client shall be refunded on a pro-rata basis based upon the number of calendar days remaining after the termination date in the period as to which fees may have been prepaid. ITEM 10 – REQUIREMENTS FOR STATE REGISTERED ADVISERS Not applicable 13 ADV2 Appendix 1 Wrap Fee Brochure 03/26 

NORTHLAND SECURITIES, INC 150 S. 5th STREET, SUITE 3300 MINNEAPOLIS, MN 55402 612-851-5900 www.northlandsecurities.com FORM ADV PART 2A RESEARCH SERVICES BROCHURE This brochure provides information about the qualifications and business practices of Northland Asset Management, the investment advisory business line of Northland Securities, Inc. If you have any questions about the contents of this brochure, please contact us at 612-851-5900. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration with the SEC and/or state entities does not of itself imply a certain level of skill or training. This brochure meets requirements for disclosure as ADV Part 2A. Additional information about Northland Asset Management may be found on the SEC’s website at www.adviserinfo.sec.gov. Effective: March 26, 2026 Last update: March 28, 2025 ITEM 1 – COVER PAGE  ITEM 2 – MATERIAL CHANGES Northland Asset Management had no material change in their Research Services business model since their last published brochure.  ITEM 3 – TABLE OF CONTENTS Item 1 – Cover Page……………………………………................................................................................................................1 Item 2 – Material Changes.……………………………………………….………………………….………………….........................................2 Item 3 – Table of Contents……………………......................................................................................................................3 Item 4 – Advisory Business…………………………………………………………………….................................................................... 4 Item 5 – Fees and Compensation……………………………………...........................................................................................5 Item 6 – Performance-Based Fees………………...……………………..…..................................................................................5 Item 7 – Types of Clients…………….…………………………………………….……………………………….…………………….........................5 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss...……………………………………………..…….…………….6 Item 9 – Disciplinary Information………………………….……………………………………………………………………………………………......6 Item 10 – Financial Industry Activities and Affiliations……………………………………………………………….……………………………7 Item 11 – Code of Ethics…………………………………………………………………………………………………………………….……………………7 Item 12 – Brokerage Practices……………………………………………………………………………………………………………….………..........8 Item 13 – Review of Accounts………………………………………………………………………………………….……………………………………...8 Item 14 – Client Referrals and Other Compensation…………………………………………………….……………………….………………...8 Item 15 – Custody…………………………………………………………………………………………………………………………………………….…....8 Item 16 – Investment Discretion………………………………………………………………………………….……………………….…………………8 Item 17 – Voting Client Securities……………………………………………………………………….….…….…………………………………………8 Item 18 – Financial Information………………………………...................................................................................................8 Item 19 – Requirements for State-Registered Adviser…...............................................................................................8  ITEM 4 – ADVISORY BUSINESS Description of Advisory Firm Northland Asset Management (NAM) is the trade name used by Northland Securities, Inc., (Northland) for its investment advisory business. Northland Securities is registered with the SEC and MSRB as a broker-dealer and is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Northland Securities, Inc. is privately held by First National of Nebraska, Inc. (FNNI). First National of Nebraska, Inc. (“FNNI”) is a multi-state holding company that owns, among other entities, First National Bank of Omaha. Northland will operate as a separate subsidiary under FNNI. Advisory Services Offered This Brochure relates to the receipt of compensation for services of receiving affiliate or third-party research reports (“Advisory Research Services”). Such services are limited to the distribution of impersonal research created by our broker-dealer and approved for institutional investors. The firm provides NAM Research Services for a fee to certain institutional clients (“Advisory Research Clients”). Advisory Research Services may include any or all the following: (1) written equity research reports prepared by our affiliates, (2) research-related communications from affiliate research analysts relating to such research reports, (3) direct access to affiliate research analysts, and (4) corporate access or meetings with company. Advisory Research Services are not customized for any institutional client. Advisory Research Services is strictly limited to the receipt of Advisory Research Services and does not include trade execution or other brokerage services. It does not include any services or communications provided by any institutional sales representatives. We do not provide investment advice or maintain accounts for Advisory Research Client. We do not have custody of any Advisory Research Client assets or securities. Should any Advisory Research Clients require or desire trade-related services, they may receive those services through our affiliate broker-dealer Northland Securities and handled solely in a broker-dealer capacity. Advisory Research Services do not include any services or communications by Northland’s Equity Sales or Equity Trading personnel. No activities related to execution services are directly or indirectly attributable to Advisory Research Services. Research Products and Services Services to clients are through the distribution of affiliate research providers by obtaining certain research products. In turn Advisory Research Services provides services that include, but are not limited to, written reports on individual companies, compendium reports with multiple companies, reports on industries or sectors, communications on market, political, or economic conditions, and other matters relevant to investment analysis. Advisory Research Services include direct access to affiliate research analysts, financial models, and meetings with company management. All Services are distributed as-is, with a generalized view to broad, sophisticated institutional clients. No Services are tailored to any specific client objective or strategy.  We offer meetings with our affiliate research analysts. Meetings are available individually or in small groups, but the content is not tailored to specific meeting participants. As discussed above, research analyst content is intended for broad institutional audiences and does not purport to address any specific objective or strategy. Research Advisory Services are not provided to any retail or non-institutional investors, and discretionary or non- discretionary investment advisory services are not provided as a part of Research Advisory Services. Research Advisory Services are not tailored to individual portfolios and does not make considerations for any one client’s investment objectives or goals. Assets Under Management Not applicable. We do not provide investment advice or maintain accounts for Advisory Research Clients. ITEM 5 – FEES AND COMPENSATION Fee Schedule and Billing We provide Advisory Research Services for a fee. Research Advisory Services has no set fee schedule. Fees for such services are determined on a negotiated basis and invoiced in arrears. Fees are due upon receipt. Neither Northland nor any institutional investor, incur any obligation to any broker-dealer to pay for research by generating trading commissions. All Research Advisory Services fees paid are exclusively for those services. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Performance-Based Fees We do not charge any performance-based fees for Advisory Research Services. ITEM 7 – TYPES OF CLIENTS Types of Clients Research Advisory Services are provided to institutional clients only. Institutional investors as defined by FINRA 4512(c), "institutional account" shall mean the account of: 1. a bank, savings and loan association, insurance company or registered investment company. 2. an investment adviser registered either with the SEC under Section 203 of the Investment Advisers Act or with a state securities commission); or 3. any other person (whether a natural person, corporation, partnership, trust or otherwise) with total assets of at least $50 million. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS  Methods of Analysis Research analysts prepare reports by studying the industry and the company, employing various methods of analysis, and utilizing numerous sources of information. Analysts will utilize sources of information such as regulatory filings, press releases, earnings calls and announcements, news articles, litigation or legal issues, discussions with company management, conduct channel checks with suppliers, customers, and other industry sources. Analysts will analyze historical trends, forecasts, projections, strength of the management team, competitors, and product pipeline. Analysts prepare financial models, run historical and forecasted results through a model, and arrive at a valuation through various methods, including sum-of-the-parts and discounted cash flow analysis. Investment Strategies Research Advisory Services are not tailored to individual portfolios and do not make considerations for any one client’s investment objectives or goals. No investment strategies are offered. RISK OF LOSS Investing in securities involves risk and may result in losses. Investors should be prepared to bear any losses that may result from those investments. Research Advisory Services as a whole and in part are provided on a stand- alone basis. Services do not consider the totality of information being received by Research Advisory Clients. Clients may receive information from various sources, reports, trade recommendations from affiliates or non- affiliates. Research Advisory Services are not tailored and do not consider any client’s objective or goals. Research Advisory Services may provide information that conflicts with other information received as part of Services or affiliate relationships or recommendations. No assurances can be made regarding the reports, projections, or analysis. Research Services Clients should consider all information, factors, and objectives when investing in securities. Past results of Northland’s research products and services are not necessarily indicative of future performance. ITEM 9 – DISCIPLINARY INFORMATION Disciplinary Information Northland has no legal or disciplinary matters that would be considered material to a client’s or prospective client’s assessment of our advisory business or the integrity of our management team. However, Northland’s broker-dealer has been subject to disciplinary action due to some inaccurate books and records in relation to equity trading and investment banking activity. The Firm also was subject to an enforcement action for the Municipal Continuing Disclosure review. (“FINRA”) web site by accessing their BrokerCheck® link, which can be A full description of these violations can be found in the Investors section of the Financial Industry Regulatory found at: Authority’s http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ . Or you may request a copy of the disciplinary action by sending a request to the following address: Northland Securities, Inc. Attn: Compliance 150 South 5th Street Suite 3300  Minneapolis, MN 55402 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Dual Registration as a Broker-Dealer Our affiliate is Northland Securities Inc., a full-service broker dealer, member FINRA/SIPC, registered with SEC and MSRB. A segment of its principal business includes market making, acting as a primary dealer of municipal securities, equities, underwriting corporate debt and equity securities, placement of private investments in public securities (PIPEs), and provides investment banking and corporate advisory services. All Advisory Research Services are intended to be exempt from the principal and agency trading restrictions under Section 206(3) and 206(3)-1 of the Investment Advisers Act of 1940. Advisory Research Clients are hereby notified that Northland Securities may act as principal or agent in connection of any subject security provided through Advisory Research Services. As stated above Advisory Research Services do not include execution or brokerage services. ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS & PERSONAL TRADING NAM has established a standard of conduct for its advisory personnel, which is outlined in the Northland Asset Management Code of Ethics. The Code outlines our way of doing business, which is to serve our clients with honesty, integrity, and competence. The Code addresses areas where a conflict of interest may arise and provides guidance in these areas. Some conflicts of interest arise from the personal trading of the advisory personnel. Northland has put in place the following restrictions to ensure its fiduciary responsibilities: No associated person of NAM shall put his or her own interest ahead of an advisory client. Investment opportunities must be offered first to clients before NAM, or its associated persons may participate in such transactions. Associated persons or their immediate family members shall not buy or sell securities for their personal portfolio(s) where their decision is derived in whole or in part, by reason of the associated person's employment, unless the information is also available to the investing public upon reasonable inquiry. NAM and its employees will not participate in private placements or initial public offerings (IPOs) without prior approval from Northland’s senior management. NAM requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. Records will be maintained of all securities bought or sold by NAM and its associated persons. A qualified representative of NAM will review these records on a regular basis. Any individual not in observance of the above may be subject to disciplinary action up to and including termination. The full text of NAM’s Code of Ethics is available to you upon request. ITEM 12 – BROKERAGE PRACTICES  Northland has written supervisory procedures surrounding soft-dollar arrangements. ITEM 13 – REVIEW OF ACCOUNTS Managed Account Reviews and Account Reporting Not applicable at this time. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Not applicable at this time. ITEM 15 – CUSTODY Not applicable at this time. ITEM 16 – INVESTMENT DISCRETION Not applicable at this time. ITEM 17 – VOTING CLIENT SECURITIES Not applicable at this time. ITEM 18 – FINANCIAL INFORMATION Not applicable at this time. ITEM 19 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS Not applicable at this time.