PRINCIPAL ADVISED SERVICES, LLC

PRINCIPAL ADVISED SERVICES, LLC FORM ADV PART 2A: ADVICE BROCHURE Legal Address 655 9th Street Des Moines, IA 50309 Mailing Address 711 High Street Des Moines, IA 50392 866-412-0770 www.principal.com January 1, 2026 This brochure (the "Brochure") provides information about the qualifications and business practices of Principal Advised Services, LLC (“Principal Advised Services,” “us,” “our,” or “we”). The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Principal Advised Services is also available on the SEC’s website at: www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for Principal Advised Services is 297324. If there are questions about the contents of this Brochure, please contact us at 866-412-0770 or AdvisedServices@principal.com. Any reference to Principal Advised Services as a “registered investment adviser” or as being “registered” does not imply a certain level of skill or training.  Form ADV Part 2A Advice | Principal Advised Services Item 2: Material Changes No material changes. Item 3: Table of Contents Item 2: Material Changes ............................................................................................................................................................................. 2 Item 3: Table of Contents ............................................................................................................................................................................. 2 Item 4: Advisory Business ............................................................................................................................................................................. 3 Item 5: Fees and Compensation ................................................................................................................................................................... 7 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................................................ 7 Item 7: Types of Clients ................................................................................................................................................................................ 7 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ......................................................................................................... 8 Item 9: Disciplinary Information ................................................................................................................................................................. 10 Item 10: Other Financial Industry Activities and Affiliations ....................................................................................................................... 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................. 12 Item 12: Brokerage Practices ...................................................................................................................................................................... 14 Item 13: Review of Accounts ...................................................................................................................................................................... 14 Item 14: Client Referrals and Other Compensation .................................................................................................................................... 15 Item 15: Custody ........................................................................................................................................................................................ 15 Item 16: Investment Discretion .................................................................................................................................................................. 15 Item 17: Voting Client Securities................................................................................................................................................................. 16 Item 18: Financial Information ................................................................................................................................................................... 16 2  Form ADV Part 2A Advice | Principal Advised Services Item 4: Advisory Business Principal Advised Services is a member company of Principal Financial Group, Inc. (“Principal Financial Group”), a diverse family of financial services companies offering businesses, individuals, and institutional customers a wide range of financial products and services, including retirement, insurance, and asset management. Principal Financial Group provides recordkeeping services to retirement plans. As part of these recordkeeping services, Principal Financial Group specializes in offering educational and advisory services to retirement plan participants and IRA investors. Principal Advised Services was formed in 2017. Its principal place of business is in Des Moines, Iowa. Principal Advised Services is a subsidiary of Principal Financial Group (NASDAQ: PFG), through intermediate holding companies. Please see Schedule A to Part 1 of Principal Advised Services' Form ADV for details. Description of Services Offered Principal Advised Services offers advice through multiple programs and services to both retirement plan participants and retail customers. When an investment adviser representative (“IAR”) of Principal Advised Services is providing a recommendation regarding a retirement plan account or IRA, Principal Advised Services is both a fiduciary under the Investment Advisers Act of 1940 (“Advisers Act”) and within the meaning of Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“the Code”), as applicable, which are laws governing retirement accounts. The programs and services we offer include both non- discretionary and discretionary advice services. 1. Non-Discretionary Advice to Participants in Plans Recordkept by Principal Financial Group. Principal Advised Services, through our IARs who are staff of our call centers, offer five (5) forms of nondiscretionary investment advice to participants in employer- sponsored retirement plans recordkept by Principal Financial Group: i. Advice about Target My Retirement – We provide plan participants with advice regarding whether they should enroll in Target My Retirement, a discretionary managed account service that primarily creates asset allocation portfolios for participants from all or a portion of the plan’s investment lineup. Target My Retirement is offered by Morningstar Investment Management, LLC (“Morningstar”). Morningstar is an SEC-registered investment adviser and subsidiary of Morningstar Inc., neither of which are affiliates of Principal Financial Group nor Principal Advised Services. The plan sponsor must make the Target My Retirement service available to participants as a plan feature, and if a plan participant chooses to enroll in Target My Retirement, Morningstar provides investment management services directly to the plan participant. ii. Savings Rates – We provide participants with advice regarding the amount of money they should contribute to their plans, including savings rate recommendations. iii. “Point-in-Time” Plan Account Advice – We provide participants with recommendations regarding the funds they should select from the Plan’s available investment choices. A participant receives the ability to view a recommended investment portfolio that includes allocations among all, or a portion of the plan’s investment options. The portfolio recommendation is limited because it will rarely include an allocation to a target date fund and will not recommend a full allocation to a target date fund. Unlike the Target My Retirement service, the Point-in-Time service is non- discretionary and will not automatically implement any asset allocation, nor will it automatically rebalance a participant’s portfolio. In formulating advice about the amount of money a participant should contribute to the plan, and in formulating its advice about the funds that a participant should select in the plan, Principal Advised Services leverages investment methodology provided to it by Morningstar. The advice described above is informed by factors including a participant’s retirement profile information, situation, objectives, investment experience, the level of engagement the participant plans to have in managing their retirement savings, their outlook on volatility, and whether the participant finds value in professional management. When constructing the non-discretionary advice for the participant’s investment portfolio, the Point-in-Time advice will take into consideration any other investments the participant holds inside their plan account, and any assets held outside the plan account, if the participant provides this information. In 3  Form ADV Part 2A Advice | Principal Advised Services addition, a participant may receive education on the features of their plan account. iv. Distribution Options and Rollovers - If we are authorized to do so by the plan sponsor, we provide retirement plan participants with recommendations on their four (4) options when they are eligible for a distribution from the plan, which are to retain their assets in the current plan, roll over to another employer’s plan (if available), roll over to an IRA, or cash out their retirement savings. In this case, the call center staff providing this service are IARs of Principal Advised Services and are also employees of Principal Bank and registered representatives of our affiliated broker- dealer, Principal Securities, Inc. (“PSI”). v. Financial Planning Services – As part of the Financial Wellness services offered to all recordkept plans of Principal, we offer optional financial planning services to plan participants for a subscription fee. Financial advice is provided on relevant topics, including: budgeting, emergency savings, debt management, life and disability insurance, retirement, and basic estate planning concepts. Participants are offered a digital enrollment process, online scheduling, phone and/or virtual discovery session and plan delivery, ongoing plan support and service, and 6-month check-ins. Generally, the financial planners providing this service are IARs of Principal Advised Services and registered representatives of our affiliated broker-dealer, PSI, and may be considered employees of Principal Bank. 2. Non-Discretionary Advice to Other Retail Clients and Prospective Retail Clients. We also offer nondiscretionary investment advice to plan participants whose plans are not recordkept at Principal Financial Group, as well as Principal Financial Group IRA account holders, other retail clients and prospective retail clients: i. Distribution Options and Rollovers – We provide retirement plan participants with recommendations on their options when they are eligible for a distribution from a former employer’s plan not held with Principal Financial Group, which are the same four (4) options noted above. We also provide retail clients and prospective retail clients with recommendations about whether they should roll over assets from IRAs with third-party financial institutions to IRAs that are offered by Principal Financial Group. Principal Advised Services does not automatically update or monitor any of the advice services described above; Principal Advised Services must be reengaged to receive updated advice. With respect to advising on Distribution Options and Rollovers, we determine the appropriateness of specific products for an individual’s needs and objectives. The factors that determine the appropriateness of products include fees and expenses, desire for investment advice or management, risk tolerance, investor involvement, and whether automatic rebalancing is preferred. Based on these needs and objectives, we will compare the applicable product(s) to the other options the individual has, including leaving the account with the prior employer’s retirement plan or in a current IRA or account, rolling over to another employer’s retirement plan, rolling over to an IRA with Principal Financial Group or cashing out their retirement plan savings. Our staff will provide recommendations in the best interest of the individual and formulate recommendations through a third-party tool configured to demonstrate which recommendation is in the individual’s best interest. Where we recommend a plan-to-IRA rollover or an IRA-to-IRA rollover, the options available are limited. They include IRAs from Principal Financial Group that offer access to Principal® SimpleInvest (“SimpleInvest”), to mutual funds offered by Principal Financial Group, and to a money market account or certificate of deposit (“CD”) offered by Principal Bank. SimpleInvest is offered through Principal Advised Services. Please see the Principal Advised Services Form ADV Part 2A: Wrap Fee Brochure for additional information regarding SimpleInvest. Principal Advised Services is responsible for recommendations to stay in the current plan, IRA or account, move to a new employer’s plan, cash out of the current plan, and to roll over to a SimpleInvest IRA. The other recommended IRAs are offered through PSI and Principal Bank, which are affiliated with Principal Advised Services. Principal Advised Services is not responsible for any rollover recommendations to affiliated IRAs; those recommendations are provided by staff in their capacity as registered representatives of PSI or Principal Bank employees and not in their capacity as IARs of Principal Advised Services. If the recommendation is to roll over to SimpleInvest, the IAR will determine whether SimpleInvest is appropriate for the participant based on an analysis of an individual’s current financial situation, investment goals, risk tolerance and/or investing preferences and the capabilities and expenses associated with the Program. 4  Form ADV Part 2A Advice | Principal Advised Services The recommendation and the reasons for the recommendation are provided to the individual, along with other important disclosures. The individual then decides whether to accept the recommendation. If initially accepted by the individual, recommendations to invest in SimpleInvest are then reviewed by a supervision team to ensure appropriateness prior to implementation. If the supervision team does not approve the recommendation, the individual will not be able to invest in SimpleInvest through the IAR. However, the individual could independently choose to invest in SimpleInvest directly, without the assistance of an IAR, in which case, Principal Advised Services is not responsible for these unsolicited client-directed roll overs. The recommendation is based solely upon the information available at that time and is contingent upon supervision team approval. For “Point-In-Time” advice as to a Plan Account, the investment options will be limited to the funds selected by the plan sponsor. The financial planning service is designed for participants looking for education and advice regarding financial foundation goals, with the capacity and financial ability to implement the advice given, able to navigate digital tools and interactions to collaborate with financial planners, and willing to commit to the 12-month service agreement. If it is determined the financial planning program is no longer suitable for the participant, we will work with the participant to cancel their subscription. The financial plan delivered is as of that specific point- in-time based on information provided by the participant. Principal Advised Services does not automatically update or monitor recommendations. It is the participant’s responsibility to implement the recommendations provided and to reengage with Principal Advised Services to receive updated advice, including changes to their situation that could require changes to the financial plan. Principal Advised Services and the financial planners do not provide legal or tax advice. Participants should consult their accountant or attorney on all tax or legal matters. 3. Discretionary Advice Through SimpleInvest. We offer SimpleInvest within IRAs, which retail clients or plan participants invest through cash contributions, or through plan-to-IRA or IRA-to-IRA rollovers. SimpleInvest is a discretionary investment management service with a “wrap fee” arrangement that is provided by Principal Advised Services. Please see the Principal Advised Services Form ADV Part 2A: Wrap Fee Brochure for important information about SimpleInvest. Any analysis, review, guidance, or recommendations offered by Principal Advised Services creates no duty or other responsibility to advise individuals to take any action or inaction regarding their positions, individual investments, investment strategies or asset allocations at other financial institutions. Principal Advised Services does not manage accounts other than SimpleInvest accounts. Conflicts of Interest Recommendations to invest in SimpleInvest or use Principal Financial Group products or services or any other products or services that involve revenue-sharing arrangements pose conflicts of interest. For example, a recommendation to engage Principal Advised Services or to increase the level of investment assets with Principal Advised Services, including through rollovers or other transfers of retirement plan accounts or IRAs, would pose a conflict, as it would increase the advisory fees paid to Principal Advised Services. Regardless of the investments and services selected, Principal Advised Services, together with our affiliates, will make more money if an individual chooses to roll over assets from a retirement plan or IRA to an IRA or retirement plan for which we provide services. Staff have an incentive to recommend investments that result in greater revenue for Principal Financial Group. These conflicts of interest are mitigated by Principal Advised Services having a dedicated supervision team that reviews transactions where a recommendation of SimpleInvest or of staying in or rolling over to a retirement plan for which we provide services, is made, to ensure it is in the individual’s best interest. If a participant follows our recommendation to enroll in Target My Retirement, Morningstar will earn additional investment management expenses by charging investment management fees against the participant’s account. Pursuant to separate contractual arrangements, Morningstar compensates Principal Financial Group for services it provides relative to Target My Retirement, such as for building and maintaining technology to transmit and receive data. As such, when we recommend Target My Retirement, our affiliate will earn additional revenue if the participant follows our recommendations. This conflict of interest is mitigated by Principal Advised Services having a dedicated supervision team that reviews transactions where a recommendation of Target My Retirement is made to ensure it is in the client’s best interest. Additionally, our recommendation to use Target My Retirement constitutes a promotional relationship under the SEC’s marketing rule. We will provide required disclosure to participants to whom we recommend Target My Retirement. If a participant follows our recommendation to contribute more to their retirement plan account, our affiliate Principal Financial Group earns additional compensation because Principal Financial Group assesses some recordkeeping and related fees as a percentage of a participant’s account, and our recommendation increases the amounts against which Principal Financial Group assesses its fees. 5  Form ADV Part 2A Advice | Principal Advised Services When we make a fund-specific investment recommendations to a plan participant, we make this recommendation considering the funds that the plan’s sponsor or other fiduciary has selected and made available within the plan. Some of these funds are investments offered or advised by our affiliates, including Principal Global Investors, LLC, which does business as Principal Asset Management (“Principal Asset Management”), as such our affiliate earns additional fees (such as investment management fees) when a participant implements our fund-specific recommendation. Other funds we recommend from the plan’s lineup make revenue sharing payments to our affiliates. Because of such revenue sharing arrangements, Principal Advised Services is able to cause its affiliate to receive additional compensation in connection with its fund-specific recommendations, even if the fund is not a proprietary fund of Principal Financial Group. These conflicts of interest are mitigated by Principal Advised Services having a dedicated risk-based supervision program reviewing whether the customer received an appropriate recommendation for an ongoing managed account or a point-in-time recommendation. Principal Advised Services uses Principal Asset Management to develop the investment models available in SimpleInvest and help with ongoing monitoring of model performance. Principal Advised Services also uses Principal Asset Management for trading services for SimpleInvest. Principal Advised Services has an incentive to select Principal Asset Management over comparable unaffiliated third-party providers, because by selecting an affiliate, Principal Advised Services ensures that an affiliate receives compensation for these services. As noted above, these conflicts of interest are mitigated by Principal Advised Services having a dedicated supervision team that reviews transactions where a recommendation of SimpleInvest is made to ensure it is in the client’s best interest. The Principal Advised Services Investment Committee conducts initial and ongoing due diligence of Principal Asset Management as sub-adviser and investment model provider. Conflicts of interest are also prominently disclosed in Principal Advised Services Form ADV Part 2A: Wrap Fee Brochure. Many of the investments available in SimpleInvest are proprietary mutual funds and ETFs. Principal Advised Services has an incentive to select proprietary funds over comparable unaffiliated third-party funds because by selecting an affiliate, Principal Advised Services ensures that an affiliate receives compensation. Levelized fee compensation is used so Principal Advised Services is not incentivized to offer products that generate more compensation for Principal Financial Group. Additionally, Principal Advised Services Investment Committee reviews all relevant investments to ensure they are appropriate for the portfolio. Principal Advised Services Form ADV Part 2A: Wrap Fee Brochure discloses this conflict and describes additional mitigation. The topics that are covered by financial planning services at this time are limited. More in-depth financial plans may be available to the participant, if desired, in other areas of Principal Financial Group or at other financial institutions. Additionally, it is possible that similar financial plans are available through other financial services providers at a lower cost. Principal Advised Services will, if appropriate, suggest that participants execute financial plans through an affiliated broker-dealer or insurance company or other affiliated entity. Participants are free to choose whatever broker-dealer, insurance company or other financial services provider to implement financial plans. If the participant chooses to use Principal Advised Services’ affiliates, Principal Financial Group will earn increased compensation. IARs receive a base salary and benefits. Although IARs do not receive commissions, they are eligible to receive variable compensation in the form of periodic incentive payments that are directly tied to their success in gathering and retaining assets in accounts offered through Principal Financial Group. IARs are eligible to receive an annual bonus, which depends on company and individual performance results. Individual performance measurements for the annual bonus generally include (i) the number of newly opened accounts, and the amount of assets raised and retained (including assets transferred from outside Principal Financial Group or outside Principal Advised Services) in IRAs, and other types of accounts offered through Principal Financial group; (ii) call quality metrics; (iii) call and consultation volume; (iv) time available for calls; and (v) referrals to other parts of the business within Principal Financial Group. A substantial portion of the bonus metrics also depends on the extent to which Plan participants accept staff recommendations. Some IARs are also eligible to receive additional periodic (such as monthly, quarterly, or annual) payments based on individual performance. Individual performance factors considered for periodic payments include the same factors described above. The periodic payment compensation programs create conflicts of interest because IARs have an incentive to recommend retention in or, rollover to, Principal Financial Group accounts when other options may be in a client’s best interest. To mitigate these conflicts of interest, other applicable policies and procedures require IARs to provide recommendations that are in the client’s best interest. Moreover, front-line managers supervise IARs and an independent quality team monitors client calls. In addition, recommendations by IARs are reviewed and analyzed by a risk-based supervision program designed to ensure the recommendation is in the clients’ best interest. Customers, retail clients, prospective retail clients and plan participants (together “Clients”) are not obligated to implement any recommendations made by Principal Advised Services or maintain an ongoing relationship with Principal Advised Services or its affiliates. If a Client elects to act on any recommendations made by Principal Advised Services, the Client is under no obligation to execute the 6  Form ADV Part 2A Advice | Principal Advised Services transaction through Principal Advised Services or our affiliates. However, if the recommendation is to roll over to an IRA with Principal, the comparison will only be of the IRA options available on the platform and not IRA options available at other financial institutions. Staff are only authorized to sell products available on its platform and have a financial interest to sell our products, even if another product may also be in a Client’s best interest but not available on our platform. Certain of our IARs are also registered representatives of PSI, a broker-dealer firm which is under common control with Principal Advised Services. If brokerage services are recommended, the Client should review the PSI Broker-Dealer Disclosure, which describes the material conflicts of interest associated with those brokerage services. As of December 31, 2024, Principal Advised Services managed $887,316,440 of Client assets on a discretionary basis. Item 5: Fees and Compensation There is no additional fee charged by Principal Advised Services for the nondiscretionary investment advice and recommendations described above, with the exception of financial planning services. However, if the participant elects to use Target My Retirement, there is an ongoing investment management fee charged by Morningstar against the participant’s plan account. If the Client elects to roll over to an IRA invested in SimpleInvest, there is an ongoing investment management fee charged by Principal Advised Services. Please see the Principal Advised Services Form ADV Part 2A: Wrap Fee Brochure for important information about the SimpleInvest program. Additionally, the investment recommendations described above will impact the revenue that our affiliates earn, and this causes conflicts of interest. Additional information about these conflicts of interest is provided above and in later sections of this Brochure. Financial planning services are provided for a subscription fee of $385 annually or $35 monthly. Principal Advised Services will also, at its discretion, offer financial planning services at promotional rates different than the fees listed above, including at no cost. Payment is processed through a third-party payment processing vendor. The participant is able to choose between the annual or monthly payment options. The annual subscription will automatically renew when the initial 12-month contract expires unless the participant cancels the subscription. Subscription fees will continuously deduct the annual or monthly fee, depending on what the participant chooses, until the participant cancels the subscription or at the end of the initial two-year period unless the participant consents to resubscribing. The participant can cancel the subscription by logging into their Principal.com account or by calling 877-753-6424. Once payment has been processed, the participant may schedule their discovery session with a financial planner. In the event a participant has paid for the financial planning services but has not received their financial plan within 90 days, the participant’s enrollment in the plan will be terminated and a refund will be issued to the participant for any payments received. If it is determined the financial planning program is no longer suitable for the participant, we will work with the participant to cancel their subscription. In such situations, rebates will be determined on a case- by-case basis. Item 6: Performance-Based Fees and Side-By-Side Management Principal Advised Services does not charge performance-based fees (fees calculated based on a percentage gain in the underlying account). Item 7: Types of Clients Principal Advised Services provides services described herein to plan participants in retirement plans, whose plan sponsors have authorized the services through contractual arrangements with Principal Financial Group, plan participants in retirement plans not recordkept with Principal Financial Group, Principal Financial Group retail account holders and to prospective retail clients. There is currently no minimum balance required for Target My Retirement. In order to invest in SimpleInvest, a Client must initially invest a minimum of $5,000 total in one or more accounts and maintain a balance of at least $1,000 in each account. SimpleInvest is designed to provide investment advisory services to individual investors who reside in the U.S., who have regular internet access, and who are comfortable investing in mutual funds and ETFs through a digital investment 7  Form ADV Part 2A Advice | Principal Advised Services platform. Participation in SimpleInvest requires that the Client completes an account application, enrolls in electronic delivery, and is approved for an account with Apex Clearing Corporation (“Apex”) and with Principal Advised Services. The account application can be accessed online through the account portal. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Principal Advised Services Governance Committee The Principal Advised Services has governance committees appointed by the Principal Advised Services Board of Directors to oversee the nondiscretionary advisory activities described herein. The Committees are comprised of investment and risk professionals working for various business units of member companies of Principal Financial Group, including individuals from PSI. Among other responsibilities, the Committees have the responsibility to oversee the formulation and delivery of the advice described herein, including by overseeing the fiduciary requirements, conflicts of interest and conflict mitigation strategies, disclosures regarding advice, policies and procedures, audit and correction issues, and investment methodology used in formulating the advice. To this end, the Committees reviews and approves the proprietary investment methodology that generates advice about whether a participant should enroll in Target My Retirement, as well as the investment methodology provided by Morningstar that generates advice about savings recommendations, the Point-in-Time fund-specific advice, and the formulation of distribution and rollover advice, including the software settings, customizations and configurations of the third-party software used. Material Risks In general, all Client accounts are subject to risks, including the risks discussed below. This Brochure does not include every potential risk associated with the services described herein. Rather, it is a general description of certain risks inherent with the advice described herein. Clients should refer to the agreements and underlying fund prospectuses and disclosure documents relevant to the services described above for additional information. Model Risk The model asset allocation portfolios available in investment products like SimpleInvest and Target My Retirement are based on generally accepted principles of modern portfolio investment theory. However, like all models, algorithms and/or calculations (“Models”), all investing comes with inherent risks. Models may incorrectly forecast future behavior or produce unexpected results, including losses. The success of using Models depends on numerous factors, including the validity, accuracy and completeness of the Model’s development, implementation and maintenance, the Model’s assumptions, factors, algorithms and methodologies, and the accuracy and reliability of the supplied historical or other data. If incorrect data is entered into even a well- founded Model, the resulting information will be incorrect. Investments selected with the use of Models may perform differently than expected as a result of the design of the Model, inputs into the Model, or other factors. In addition, changes to a Model, although subject to compliance controls and testing, may not have the desired effect with respect to an investor’s account. While this risk increases if changes to a Model are insufficiently tested prior to implementation, even extensively tested changes may not produce the desired effect over time. The advice generated from Models is dependent, in part, upon information received from clients as well as from other third parties and external sources, meaning that the service could be impacted depending on the accuracy of the information provided. Investment Risks Investing in securities, like mutual funds and ETFs or other funds, whether in connection with the advice described above or otherwise, involves risk of loss that Clients should be prepared to bear, including loss of principal. Principal Advised Services does not guarantee the results of any advice or recommendation. In addition, Principal Advised Services does not guarantee that the objectives of the Client will be met. The past performance of investment strategies managed by Principal Advised Services or Principal Asset Management is no guarantee of future results; therefore, a customer should not assume the future performance of an investment strategy will be profitable. Market, interest rate, investment and other related risks may adversely affect the performance of securities held in customer accounts and cause losses in a Client account. While employing a diversified investment portfolio, including the usage of a variety of investment products 8  Form ADV Part 2A Advice | Principal Advised Services representing different asset categories can mitigate some risks for investors, they cannot and do not prevent all loss. Ultimately, such risks are borne by the individual investor. The following is a list of some of the principal risks of investing in mutual funds and ETFs and other funds. The following list of risks is not intended to be a comprehensive list of risks. Investing in funds generally. A Client account bears all the risks of the investment strategies employed by the mutual funds and ETFs and other funds held in the Client account, including the risk that the fund will not meet its investment objectives. The funds held in Client accounts may invest in equities, fixed income, derivatives, and other asset classes; the risks associated with such investments are described below. For the specific risks associated with any particular fund, please refer to its prospectus or other disclosure document. Exchange Traded Funds (“ETF”s). An ETF is subject to the risks of the underlying securities that it holds, as well as the risk that it may fail to closely track the index it follows (tracking error). ETFs are subject to fees and expenses (like management fees and operating expenses) that do not apply to an index, and a Client account will indirectly bear its proportionate share of the fees and expenses of the ETFs in which it invests. Moreover, ETF shares may trade at a premium or discount to their net asset value (“NAV”). Therefore, due to variations in the NAV of the ETF under certain circumstances the ETF could trade for more or less than the value of the underlying investments if bought separately. Although ETFs are required to calculate their NAV on a daily basis, at times the market price of an ETF’s shares may be more than the NAV (trading at a premium) or less than the NAV (trading at a discount). Given the differing nature of the relevant secondary markets for ETFs, certain ETFs may trade at a larger premium or discount to NAV than shares of other ETFs depending on the markets where such ETFs are traded. The risk of deviation from NAV for ETFs generally is heightened in times of market volatility or periods of steep market declines. For example, during periods of market volatility, securities underlying ETFs may be unavailable in the secondary market, market participants may be unable to calculate accurately the NAV per share of such ETFs, and the liquidity of such ETFs may be adversely affected. This kind of market volatility may also disrupt the ability of market participants to create and redeem shares in ETFs. Further, market volatility may adversely affect, sometimes materially, the prices at which market participants are willing to buy and sell shares of ETFs. As a result, under these circumstances, the market value of shares of an ETF may vary substantially from the NAV per share of such ETF, and the Client may incur significant losses from the sale of ETF shares. As an ETF trades on an exchange, it is subject to the risks of any exchange-traded instrument, including: (i) an active trading market for its shares may not develop or be maintained, (ii) market makers or authorized participants may decide to reduce their role or step away from these activities in times of market stress, (iii) the exchange may halt trading of its shares, and (iv) its shares may be delisted from the exchange. This means there may be times when ETFs are not as liquid as other investments. In addition, ETF managers that offer passive investment strategies generally do not seek to outperform their benchmark. As a result, ETF managers may hold securities that are components of their underlying index, regardless of the current or projected performance of the specific security or market sector. Passive managers do not attempt to take defensive positions based upon market conditions, including declining markets. This approach could cause a passive vehicle’s performance to be lower than if it employed an active strategy. Market Risk. The price of any security or the value of an entire asset class can decline for many reasons, including but not limited to interest rates, regulatory changes, unpredictable market sentiment changes, and political, economic, and social conditions. Global markets are interconnected, and events like hurricanes, floods, earthquakes, forest fires and similar natural disturbances, war, terrorism or threats of terrorism, civil disorder, public health crises, and similar “Act of God” events have led and may in the future lead to increased short-term market volatility and may have adverse long-term and widespread effects on world economies and markets generally. Client Accounts may have exposure to countries and markets impacted by such events, which could result in material losses. Equity Investments. Price changes may occur in the market, or in a country, industry, or sector of the market. In addition, different types of stocks tend to shift in and out of favor depending on market and economic conditions, and the types of stocks in which a fund invests may underperform the market. For example, growth stocks can be more volatile than other types of stocks, and the market can undervalue value stocks for long periods of time. Dividends on common stocks are not fixed but are declared at the discretion of an issuer’s board of directors. There is no guarantee that a company will pay dividends, or that if paid they will remain at current levels or increase over time. Investors holding common stock of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer. Fixed Income Investments. In general, the bond market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) The ability of an issuer of a bond to repay principal prior to a security’s maturity can cause greater price volatility if interest rates change, and, if a bond is prepaid, 9  Form ADV Part 2A Advice | Principal Advised Services a bond fund may have to invest the proceeds in securities with lower yields. Fixed income securities also carry inflation risk and credit and default risks for both issuers and counterparties. Unlike individual bonds, most bond funds do not have a maturity date, so holding them until maturity to avoid losses caused by price volatility is not possible. In addition, investments in certain bond structures may be less liquid than other investments, and therefore may be more difficult to trade effectively. Foreign Investments. Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which may be greater in emerging markets. These risks are particularly significant for funds that focus on a single country, region, or emerging markets. Foreign markets may be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Derivatives. Certain mutual funds and ETFs and other funds may invest in derivatives. A derivative is a financial contract whose value is based on the value of a financial asset (such as a stock, bond, or currency); a physical asset (such as gold, oil, or wheat); or a market index (such as the S&P 500® Index). Investments in derivatives may subject these funds to risks different from, and possibly greater than, those of the underlying securities, assets, or market indexes. Some forms of derivatives, such as exchange-traded futures and options on securities, commodities, or indexes, have been trading on regulated exchanges for decades. These types of derivatives are standardized contracts that can easily be bought and/or sold, the market values of which are determined and published daily. Non- standardized derivatives (such as swap agreements), on the other hand, tend to be more specialized or complex, and may be more difficult to value. Derivatives may involve leverage because they can provide investment exposure in an amount exceeding the initial investment. As a result, the use of derivatives may cause funds to be more volatile because leverage tends to exaggerate the effect of any increase or decrease in the value of a fund’s portfolio securities. Item 9: Disciplinary Information Neither Principal Advised Services nor any of its officers, directors, employees, or other management persons has been involved in any legal or disciplinary events that would require disclosure in response to this Item. Item 10: Other Financial Industry Activities and Affiliations As a wholly owned subsidiary in the family of entities of Principal Financial Group, Principal Advised Services is part of a diversified, global financial services organization with many types of affiliated financial services providers, including but not limited to broker- dealers, insurance companies and other investment advisers. Certain of Principal Advised Services’ management persons, including its members of the management team, Investment and Investment Advice Committee members, and other control persons, also hold positions with one or more affiliated entities. These management persons will have significant other duties for our affiliates and allocate a substantial portion of their time to the management of other affiliated entities of Principal Advised Services. Management persons performing work for Principal Advised Services in addition to work performed for other affiliates are not required to devote all their working time to Principal Advised Services. Conflicts of interest from time to time may arise in allocating management time, services, or functions among Principal Advised Services and other affiliates. Principal Advised Services attempts to mitigate such conflicts through its internal controls and by disclosure to Clients. Material Relationships with Related Persons and Potential Conflicts of Interest Principal Advised Services has certain relationships or arrangements with related persons that are material to its investment advisory business. Below is a description of these relationships and some of the conflicts that arise from them. Principal Advised Services mitigates the conflicts of interest discussed below through disclosure in this Brochure and through the implementation, monitoring and review of the policies and procedures that comprise its compliance program. Please see “Conflicts of Interest” above and below for further discussion of the conflicts of interest that arise from using affiliated service providers and offering affiliated mutual funds and ETFs and other funds. 10  Form ADV Part 2A Advice | Principal Advised Services Principal Life Insurance Company is licensed as an insurance company in all 50 states and the District of Columbia. Principal Advised Services has entered into an agreement pursuant to which Principal Life Insurance Company and its global affiliates will furnish certain personnel, services and facilities to Principal Advised Services, and Principal Advised Services will reimburse its affiliates for the costs associated with these services. Principal Life Insurance Company provides recordkeeping services to retirement plans. The majority of services and programs described here are offered to participants of retirement plans that use Principal Life Insurance Company as a recordkeeper. Principal Advised Services directs retirement plan participants to Principal Bank for the purchase of banking products. As Principal Advised Services is an affiliate of Principal Bank, Principal Advised Services and our IARs have an incentive to make these referrals and recommendations as a relationship exists between Principal Bank and Principal Advised Services. Principal Advised Services is an affiliate of PSI, an investment adviser and a broker-dealer registered with the SEC, and a FINRA member firm. Principal Advised Services does not conduct any brokerage business with PSI, although PSI has brokerage relationships with retirement plans recordkept by Principal Financial Group, as more fully described below. However, certain supervised persons or associated persons of Principal Advised Services are registered representatives of PSI as a result of other duties they perform. While not compensated for such activities, Principal Advised Services IARs direct Clients to a life insurance agent of Principal Life Insurance Company to purchase life or disability insurance products. Additionally, Principal Advised Services’ IARs are often also Registered Representatives of PSI, an affiliated broker-dealer through which they sell securities products. Principal Funds Distributor, Inc., is the principal underwriter for an investment company called Principal Funds, Inc. Many of the investments available through SimpleInvest are mutual funds of Principal Funds, Inc. The use of the affiliated mutual funds poses a conflict of interest as an affiliate receives compensation for the sale of the fund shares. The ETFs available through Principal Advised Services are offered by an affiliate, Principal Exchange Traded Funds; an unaffiliated entity distributes these ETFs. To the extent that Principal Advised Services selects lower cost funds or share classes in SimpleInvest, an affiliate of Principal Advised Services receives less compensation. In this case, Principal Advised Services has a conflict of interest and financial incentive to recommend portfolios that have lower cost funds or share classes since the amount of its account management fee will be comparatively greater (as a portion of the overall program fee) than had it recommended higher-fee share classes; an increase in the amount of investment expenses lowers the amount of the program fee that Principal Advised Services receives in the form of the account management fee. However, the overall compensation earned by Principal Advised Services and its affiliates, collectively, does not change based on the investments in the SimpleInvest account, whether from affiliated funds or otherwise, as the compensation is levelized. Thus, Principal Advised Services’ selection of funds and share classes does not change the overall fee Clients pay for SimpleInvest. The trading services for SimpleInvest are provided with the assistance of Principal Asset Management, which is an affiliate of Principal Advised Services. Principal Asset Management is registered as an investment adviser with the SEC. This relationship poses a conflict in that Principal Advised Services has an incentive to select Principal Asset Management as the provider of these services for the Program over comparable unaffiliated third-party providers, because by selecting an affiliate, Principal Advised Services ensures that an affiliate receives compensation for these services. Principal Asset Management also serves as the model provider for SimpleInvest and acts as the investment manager for all of the affiliated mutual funds and ETFs that are available through SimpleInvest. This relationship poses a potential conflict in that Principal Advised Services has an incentive to select Principal Asset Management as the model provider and to offer investments managed by Principal Asset Management through the Program, because these choices generate compensation for a Principal Advised Services affiliate. The Principal Advised Services Investment Committee conducts initial and ongoing due diligence of Principal Asset Management as subadvisor and investment model provider. To the extent that Principal Advised Services selects lower cost funds or share classes, Principal Asset Management will receive less compensation in the form of investment expenses from the affiliated mutual funds and ETFs included in Client Accounts. As a result, Principal Advised Services has a conflict of interest and financial incentive to recommend portfolios that have lower cost funds or share classes since the amount of its account management fee will be comparatively greater (as a portion of the overall program fee) than had it recommended higher-fee share classes; an increase in the amount of investment expenses lowers the amount of the program fee that Principal Advised Services receives in the form of the account management fee. However, the compensation earned by Principal Advised Services and its affiliates, collectively, does not change based on the investments in the Client 11  Form ADV Part 2A Advice | Principal Advised Services account, whether from affiliated funds or otherwise. Thus, Principal Advised Services’ selection of funds and share classes does not change the program fee Clients pay for the Program. Apex Clearing Corporation, an unaffiliated broker-dealer, provides clearing, custody, trade execution and related services to SimpleInvest. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Principal Advised Services has adopted a Code of Ethics (the “Code”). The principal purpose of the Code is to provide policies and procedures consistent with applicable laws and regulations, including Rule 204A-1 under the Advisers Act, to prevent or mitigate conflicts of interests or the appearance of such conflicts when Principal Advised Services officers, directors, employees and certain non- employees of Principal Advised Services with access to Client and trading information of Principal Advised Services (“Access Persons”) own or engage in their own personal transactions involving securities. The Code requires all Access Persons to adhere to high standards of honest and ethical conduct and the interests of our advisory Clients to be placed first always. All Access Persons are required to certify upon association/employment and annually thereafter that they have read, understood, and complied with the Code. This includes certifying that they have complied with the requirements to disclose covered accounts, reportable securities and pre-cleared transactions as required by the Code, when applicable. Access Persons are permitted to personally buy and sell securities of issuers that Principal Advised Services also trades for its Clients, so long as those buy and sell transactions are conducted in accordance with the Code. As such, there are procedures in place to mitigate potential conflicts of interest between the personal securities transactions of the Access Persons and the securities transactions that Principal Advised Services does for Client accounts. The compliance area of Principal Advised Services monitors personal trading. All Access Persons are required to obtain pre-clearance approval to buy and sell any offerings that are exempt from registration under the Securities Act of 1933 pursuant to Regulation D (“private placements”) and are required to report their securities transactions on an ongoing basis through an online monitoring system. There is also a quarterly review of reportable transactions, as well as annual certification of accounts and holdings by Access Persons. Please refer to our Code for a detailed overview of provisions. Clients and prospective Clients of Principal Advised Services may obtain a full copy of the Code by contacting an IAR, or the Compliance Department by request at 866-412-0770. Participation or Interest in Customer Transactions and Other Conflicts of Interest Conflicts of interest or potential conflicts of interest commonly refer to activities or relationships in which the interests of Principal Advised Services and its affiliates compete with the interests of Clients. Members of the Principal Advised Services management team, Investment Committee and Investment Advice Committee will meet on an as needed basis to identify and discuss any actual or potential conflicts of interest. Additionally, such members will review risk controls, policies, and procedures to identify any necessary controls to mitigate or eliminate any actual or potential conflicts of interest. Recommendations or Investments in Securities that Principal Advised Services or its Related Persons may also Purchase and Sell As a wholly-owned subsidiary of Principal Financial Group, Principal Advised Services is part of a diverse family of financial services companies that offers Clients a wide range of financial products and services. Principal Advised Services’ affiliates at times gives investment advice and/or acts in the performance of their duties in a manner that differs from or is inconsistent with the advice given for Client accounts described in this Brochure. In addition, Principal Advised Services’ recommendations described above will differ from its affiliates’ recommendations or guidance. Affiliated Mutual Funds and other Funds If Principal Advised Services selects or recommends affiliated mutual funds or other funds, then its affiliates, including Principal Asset 12  Form ADV Part 2A Advice | Principal Advised Services Management, will, in the aggregate, receive more compensation when Client assets are invested in affiliated funds than they would receive if the Client instead invested in unaffiliated funds. This creates a financial incentive for Principal Advised Services to choose or recommend affiliated funds over non-affiliated funds. We mitigate this conflict of interest by disclosing it to Clients, and in the case of the nondiscretionary investment advice described above, by using third party investment methodology to power fund-specific investment recommendations. Principal Advised Services has a conflict of interest in offering affiliated mutual funds and ETFs through SimpleInvest because the compensation received by Principal Asset Management and its affiliates increases when the assets invested in the affiliated mutual funds and ETFs increase. Principal Asset Management and its affiliates will, in the aggregate, receive more compensation when Client assets are invested in affiliated funds than they would receive if the Client instead invested in unaffiliated funds. This creates a financial incentive for Principal Advised Services to choose affiliated funds for SimpleInvest over non-affiliated funds. We mitigate this conflict of interest by levelizing compensation to Principal, disclosing it to you and making clear that, except for the cash portion of the portfolio, SimpleInvest is limited to proprietary funds. Compensation to Principal is levelized in SimpleInvest for affiliated mutual fund fees. Please see below and the Principal Advised Services ADV Part 2A: Wrap Fee Brochure for additional information. Retention of Affiliated and Unaffiliated Service Providers Principal Advised Services has a financial incentive to select Principal Asset Management as both the model provider and as the provider of trading services for SimpleInvest over comparable providers that are not affiliated with Principal Advised Services because Principal Advised Services’ affiliates will, in the aggregate, receive more total revenue when assets are invested in investment products managed or serviced by affiliated service providers. Principal Advised Services’ Investment Committee members oversee the services provided by Principal Asset Management. In addition to retaining its affiliates to provide certain services, Principal Advised Services also retains unaffiliated service providers to provide various other services. A service provider will provide services to Principal Advised Services while also providing services to affiliates of Principal Advised Services and will negotiate rates in the context of the overall relationship. Alternatively, Principal Advised Services will be unable to obtain the same fee rates from a given service provider that its affiliates negotiated, and Principal Advised Services will not know about these lower negotiated rates. Conflicts of Interest Created by Trading Model Portfolios Our affiliates benefit if your account includes proprietary investment options. A plan can include proprietary investments that are managed or sponsored by a Principal Advised Service affiliate, such as mutual funds or collective investment trusts (CITs). When a proprietary investment option is in a plan lineup, Principal Advised Service’s affiliates receive compensation for services they provide. Principal Advised Services mitigates the conflict by ensuring that neither its affiliates exercise discretion or have responsibility for the selection or monitoring of the investment options available within Target My Retirement. Instead, the plan sponsor is responsible for selecting the investment options available in the plan. Principal Financial Group also benefits if an investor selects Target My Retirement. Principal Financial Group receives a portion of the fee from Morningstar that a participant is charged when they use Target My Retirement, so we have an incentive to recommend Target My Retirement over Point-in-Time advice. Principal Advised Services mitigates this conflict by disclosing this conflict, and by weighing strong investor preferences around fee sensitivity more heavily than other factors when making a recommendation to use Target My Retirement. In addition, as noted above this conflict of interest is also mitigated by Principal Advised Services having a dedicated supervision team that reviews transactions where a recommendation of Target My Retirement is made to ensure it is in the client’s best interest. Principal Asset Management provides model portfolios to affiliated and unaffiliated investment advisers who use model portfolios to assist in developing their own investment recommendations and managing their own accounts. In addition, Principal Asset Management trades in the same or similar securities for its other Clients. Principal Asset Management will (but need not) delay communicating information regarding model portfolios or any updates thereto until after its other Clients have commenced trading. In such circumstances, Principal Advised Services will not have had the chance to evaluate or act upon the model portfolio recommendations prior to the time at which other advisory accounts received such recommendations and had the opportunity to act upon them. It is also possible that Principal Asset Management has already started trading the same or similar securities for its other Clients before Principal 13  Form ADV Part 2A Advice | Principal Advised Services Advised Services has directed Principal Asset Management to trade on behalf of Clients. Such differences in the timing of trades can affect the pricing of the relevant securities and can result in SimpleInvest accounts receiving less favorable pricing. Transactions for which orders have been placed are subject to price movements, particularly with large orders relative to the given security’s trading volume, which can result in SimpleInvest accounts receiving prices that are less favorable than the prices Principal Asset Management’s other Clients receive. Item 12: Brokerage Practices Principal Advised Services provides some of the services described herein within retirement plans recordkept by Principal Financial Group. As part of the recordkeeping arrangement with Principal Financial Group, retirement plan sponsors instruct Principal Financial Group about how to execute trades in plan accounts, and entities within Principal Financial Group may be selected for this purpose. Principal Advised Services does not select or recommend the manner in which plan brokerage functions take place, and some of the services described herein are delivered without regard to the brokerage arrangements selected by the plan sponsor. Principal Advised Services does not receive research or other soft dollar benefits from broker-dealers that place mutual fund transactions. Apex Clearing Corporation, an unaffiliated broker-dealer, provides clearing, custody, trade execution and related services to SimpleInvest. Item 13: Review of Accounts Principal Advised Services does not automatically update or monitor the nondiscretionary advice it provides; a participant must reengage with Principal Advised Services to receive updated advice. Principal Advised Services has practices to periodically confirm that its investment methodology remains appropriate and accurate. Supervision of Advice Principal Advised Services’ Board of Directors has established a committee, called the Investment Advice Committee, to provide governance of investment advice made by IARs. The Investment Advice Committee’s responsibilities are primarily to provide governance over advisory activities outside Principal Advised Services’ discretionary investment management services, which are separately governed by the Investment Committee discussed above. Principal Advised Services generally provides all SimpleInvest Clients with continuous access to its website. Through the website, SimpleInvest Clients can access information about their account status, portfolio allocations, securities, and balances. Proprietary, as well as commercially available, software is used to review the SimpleInvest accounts quarterly to ensure that they are in line with investment objectives. Additional reviews may be triggered by material changes in variables such as a SimpleInvest Client’s individual circumstances, or the market, political or economic environment. As mentioned above, Clients have access to account information through the website. Apex in its capacity as the custodian prepares account statements showing transactions and account balances during the prior quarter. All information relating to SimpleInvest Clients and accounts is provided on the website and/or sent via email or paper as required. Principal Advised Services requests that SimpleInvest Clients reconfirm their current profile information as needed and on an annual basis. Additionally, Principal Advised Services’ Investment Committee, in conjunction with the compliance team, will prepare and review exception reports on an ongoing basis to ensure that SimpleInvest accounts are in line with the asset allocation and risk parameters identified for Clients based on their risk tolerance questionnaire (“RTQ”) scores. The RTQ measures both risk tolerance and capacity. The Investment Committee will also review all material changes to the algorithm prior to implementation. 14  Form ADV Part 2A Advice | Principal Advised Services Item 14: Client Referrals and Other Compensation Principal Advised Services has entered into and is currently a party to referral agreements whereby we receive referral fees as a promoter in accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any corresponding state securities law requirements. In order to make referrals to unaffiliated registered investment advisers, plan sponsors must agree to add this feature to the plan. Principal Advised Services will refer plan participants, as appropriate, to affiliated and unaffiliated registered investment advisers that are able to provide comprehensive wealth management services. The referral fee is a percentage of the asset management fees received by the registered investment adviser is paid to Principal Advised Services when a referred plan participant becomes a new client. Item 15: Custody Principal Advised Services does not act as a custodian for participant assets for the advice described in this Brochure, although its affiliates may be custodian for the retirement plans whose participants may receive nondiscretionary advice through the services described in this Brochure. Principal Advised Services does not act as a custodian for SimpleInvest assets and does not have physical custody of SimpleInvest Client funds or securities at any time. Apex serves as the qualified custodian for all SimpleInvest accounts. Apex will provide regular ongoing statements to Clients showing securities positions and account activity. Clients should promptly and carefully review the statements provided by Apex and compare them against the account information available online through SimpleInvest and notify us promptly in writing via email or physical mail of any errors or discrepancies. Principal Advised Services is deemed to have custody of SimpleInvest Client funds as defined in Rule 206(4)-2 of the Advisers Act (“Custody Rule”) as a result of Clients authorizing Principal Advised Services to withdraw advisory fees from Client accounts, and when Clients initiate third-party transfers out of their Client accounts. Principal Advised Services will comply with all applicable Custody Rule requirements. From time to time, Principal Advised Services will inadvertently receive Client assets from third parties. Principal Advised Services has appropriate policies and procedures which provide for returning such assets to the sender, as permitted by the Custody Rule and guidance thereunder. Item 16: Investment Discretion Principal Advised Services does not have discretionary investment authority regarding a retirement plan participant’s investment, nor does it have discretionary authority over the plan’s investment line-up. Morningstar has discretionary authority if a participant enrolls in Target My Retirement. Morningstar’s discretionary authority is limited to rebalancing a participant’s portfolio and effecting changes in connection with the participant’s asset allocation. Principal Advised Services provides SimpleInvest Clients with discretionary investment advisory services and asset allocation implemented with the assistance of proprietary algorithms. Principal Advised Services uses the services of its affiliates in several capacities in offering SimpleInvest. The trading engine used in SimpleInvest and all the model portfolios available through the SimpleInvest are provided by affiliates of Principal Advised Services. In addition, generally, the underlying investment products offered through the SimpleInvest, except for an FDIC-insured deposit bank account, are proprietary investment products managed by affiliates of Principal Advised Services. As a discretionary adviser, Principal Advised Services has the authority to modify, in its sole discretion and without prior notice to Clients, the selection of investment products that comprise each of the portfolios and the relative weighting of investment options and allocation to cash within the model portfolios. 15  Form ADV Part 2A Advice | Principal Advised Services Item 17: Voting Client Securities Principal Advised Services does not accept authority to vote proxies on investment funds held in client accounts. If a security held in plan account files a proxy statement, the plan sponsor or participant may vote the proxy. Item 18: Financial Information Principal Advised Services does not require or solicit the prepayment of fees, with the exception of financial planning services, and does not have any adverse financial condition that is reasonably likely to impair Principal Advised Services’ ability to continuously meet its contractual commitments. Principal Advised Services has not been the subject of a bankruptcy proceeding. 16 

PRINCIPAL ADVISED SERVICES, LLC FORM ADV PART 2A: WRAP FEE PROGRAM BROCHURE Legal Address 655 9th Street Des Moines, IA 50309 Mailing Address 711 High Street Des Moines, IA 50392 866-412-0770 www.principal.com January 1, 2026 This wrap fee program brochure (the "Brochure") provides information about the qualifications and business practices of Principal Advised Services, LLC (“Principal Advised Services,” “us” or “we”) in connection with the Principal® SimpleInvest Program. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Principal Advised Services is also available on the SEC’s website at: www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for Principal Advised Services is 297324. If there are questions about the contents of this Brochure, please contact us at 866-412-0770 or AdvisedServices@principal.com. Any reference to Principal Advised Services as a “registered investment adviser” or as being “registered” does not imply a certain level of skill or training.  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Item 2: Material Changes This Item will summarize any material changes made to this Brochure as part of an annual or interim update. No material changes 2  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Item 3: Table of Contents Item 2: Material Changes ............................................................................................................................................... 2 Item 3: Table of Contents............................................................................................................................................... 3 Item 4: Service, Fees and Compensation ....................................................................................................................... 4 Item 5: Account Requirements and Types of Clients ................................................................................................... 12 Item 6: Portfolio Manager Selection and Evaluation ................................................................................................... 13 Item 7: Client Information Provided to Portfolio Managers ........................................................................................ 17 Item 8: Client Contact with Portfolio Managers .......................................................................................................... 17 Item 9: Additional Information .................................................................................................................................... 18 3  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Item 4: Service, Fees and Compensation Principal Advised Services is a member company of Principal Financial Group, Inc. (“Principal Financial Group”), a diverse family of financial services companies offering businesses, individuals and institutional clients a wide range of financial products and services, including retirement, insurance, and asset management. Principal Advised Services was formed in 2017. Its principal place of business is in Des Moines, Iowa. Principal Advised Services is a subsidiary of Principal Financial Group (NASDAQ: PFG), through intermediate holding companies. Description of Services Offered Principal Advised Services offers discretionary investment advisory services through the Principal® SimpleInvest Wrap Fee Program (“Program”). This Brochure is meant to help understand the Program and its clients ("Client") should review it carefully. The primary focus of the Program is to provide Client with discretionary investment advisory services implemented with the assistance of proprietary algorithms. Principal Advised Services uses the services of its affiliates in several capacities in offering the Program. The trading engine used in the Program and the model portfolios available through the Program are provided by affiliates of Principal Advised Services. In addition, generally the underlying investment products offered through the Program, except for an FDIC- insured deposit bank account, are proprietary investment products managed by affiliates of Principal Advised Services. As a discretionary adviser, Principal Advised Services has the authority to modify, in its sole discretion and without prior notice to Clients, the selection of investment products that comprise each of the portfolios and the relative weighting of investment options and allocation to cash within the model portfolios. A Client can independently determine whether the Program is appropriate for their use, or our investment adviser representatives (“IARs”) assist Clients by conducting interviews to determine their financial needs and objectives. Please see the Principal Advised Services Advice Form ADV Part 2A Brochure for information regarding the non-discretionary investment advice provided. To begin receiving services through the Program, a Client must complete the digital account opening process, enter into an investment advisory agreement with Principal Advised Services (“Advisory Agreement”) and other related agreements governing the Client’s account in the Program (“Client Account”), invest a minimum of $5,000 total in one or more Client Accounts, and maintain a balance of at least $1,000 in each Client Account. Initial and subsequent deposits will generally not be invested for up to five business days to allow for settlement of funds. Participation in the Program also requires Clients to consent to electronic delivery of communications. Clients can inquire about the services offered through the Program and obtain information about the management of their Client Account at any time by contacting Principal Advised Services through one of its representatives over the phone or email. The discretionary investment management services offered through the Program are goal-based investing driven by either a risk-based or time-based asset allocation model. The risk-based models are driven by the Client’s risk tolerance, which is determined based on a risk tolerance questionnaire (“RTQ”). The time-based models are driven by the Client’s identified goal retirement age, which a Client chooses when accessing the service. Each Client Account can only have one goal-based investment portfolio, either a risk-based allocation model or a time-based allocation model. There cannot be multiple models for the same account. The risk-based investment portfolios that Principal Advised Services offers are based on Client responses to an RTQ. The Program’s five risk-based model portfolios (Conservative, Moderately Conservative, Balanced, Moderately Aggressive, and Aggressive) have asset allocations aligned to risk tolerances. The risk component remains consistent over time and the algorithm will automatically adjust the weighting of the holdings to the target portfolio asset allocation. The time-based investment goals that Principal Advised Services currently provides are “save for retirement” and “use my retirement savings.” The Program allocates Client investments based upon their target retirement year, financial goals and the risk preference selected. If a Client chooses the “save for retirement” goal, they will have access to investment portfolios focused on accumulation of assets. If a Client chooses the “use my retirement savings” goal, they will have access to investment portfolios focused on investment of assets during retirement years. After the retirement age set by the Client in the “save for retirement” goal is met, we automatically transition the Client Account to a more conservative asset allocation through the “use my retirement savings” goal. 4  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Upon enrollment in the Program, the Client Account will be invested in portfolios developed by Principal Global Investors, LLC d/b/a Principal Asset Management (“Principal Asset Management”), a registered investment adviser and affiliate of Principal Advised Services. The specific portfolio that Principal Advised Services recommends to a Client is based on information that the Client provides through the Program website (“Client Inputs”), including, but not limited to: the Client's current age, proposed retirement age (“goal age”), and risk score, which is determined by the Client’s answers to risk tolerance questions. The recommended portfolio represents a mixture of asset classes designed to help the Client achieve their investment goals. Risk-Based Model Portfolios: Each risk-based model portfolio offered through the Program will adhere to the applicable risk tolerance asset allocation assigned. Each Client Account will be reviewed on an ongoing basis with the assistance of proprietary algorithms during days in which the underlying investments trade and rebalanced as needed to minimize portfolio drift. Portfolio drift refers to circumstances where the allocation of the investments held within the portfolio moves out of the target range due to various factors, including market volatility, account contributions and withdrawals. Time-Based Model Portfolios: Each time-based model portfolio offered through the Program follows a “glide path” that will cause a Client’s investment allocation gradually to become more conservative as a Client with a “save for retirement” goal gets closer to their goal age, or as a Client with a “use my retirement savings” goal gets further into retirement. The Client’s risk score will adjust the risk level of their model portfolio up or down (more or less risky) relative to the “glide path” associated with their selected portfolio. After the model portfolio has glided for a pre-determined number of years relative to a Client’s goal date, the investment allocation will reach its most conservative allocation and remain static. Each Client Account will be reviewed on an ongoing basis with the assistance of proprietary algorithms during days in which the underlying investments trade and rebalanced as needed to maintain the glide path for the portfolio and to minimize portfolio drift. Portfolio drift refers to circumstances where the allocation of the portfolio moves out of the target range due to various factors, including the Client aging and glide path progression, market volatility, account contributions and withdrawals. As part of the Program, Principal Advised Services will make general financial material, including budgeting, planning, general savings tips, and similar educational materials available to Clients. In addition, Clients have access to an optional financial wellness tool (“My Hub”), allowing them to view account information for accounts held both at Principal and with unaffiliated third parties. This enables the Client to see an overall, aggregated view of their financial situation. Principal Advised Services offers My Hub through an arrangement with an unaffiliated service provider. To utilize My Hub, Clients must first agree to the My Hub Terms and Conditions of Use. There is no additional fee for My Hub. Clients must log into My Hub periodically to keep the aggregated account information current. While Clients receive guidance on a broad range of subjects, IARs do not monitor accounts in My Hub with an aggregated view or provide guidance related to those accounts held outside of Principal. Only Client Accounts held with the Program will receive ongoing discretionary portfolio management from Principal Advised Services. Additionally, Principal Advised Services does not take account information in My Hub into consideration in managing Client Accounts. Principal Advised Services does not verify the valuations, accuracy, or completeness of information for accounts held with unaffiliated third parties in the aggregated view. Only as it relates to My Hub, by electing to use this tool and as further explained in the My Hub Terms and Conditions of Use, the Client agrees that Principal Advised Services and our service provider can also use, sell, license, reproduce, distribute and disclose aggregated information that is derived through the use of My Hub. Any aggregated information that is used will not include personally identifiable information. Portfolio Construction A critical part of the Program’s time-based portfolio construction methodology is the range of differences between Clients’ ages and their selected goal retirement ages. Because the retirement goals available in the Program are tied to retirement savings, the time- based model portfolios available in the Program are designed to help Clients address a number of risks associated with saving for retirement, including shortfall, longevity, capital and inflation risks. Shortfall risk is the risk of an individual not having enough savings to last throughout retirement. Longevity risk is the risk of an individual outliving their savings, either because they live longer than planned or have a savings shortfall. Capital risk is the risk that an individual will abandon their investment choice because of a negative investment experience. Inflation risk is the risk that an individual will not have sufficient savings in retirement to purchase as much in 5  Wrap Fee Program Form ADV Part 2A | Principal Advised Services the future because of the increase in cost of goods and services over time. Clients should understand that because these risks are taken into account during portfolio construction, there often will be a variance between the risk level of a Client’s portfolio and their risk score. Specifically, time-based model portfolios available in the Program will be weighted—in some cases significantly—to comparatively riskier investments (e.g., equity funds over fixed income funds), despite a Client’s conservative risk score to account for these risks and the operation of the glide path. This is particularly the case when there is a larger difference between a Client’s current age and their goal retirement age. In reviewing assets for portfolio construction, Principal Advised Services evaluates historical returns across a variety of asset classes and uses the expected volatility of returns on these asset classes to anchor the risk of a portfolio. Principal Advised Services analyzes the historical performance and risk attributes of a strategy to both understand the consistency of the strategy as well as evaluate the return profile and expected volatility (risk) of future returns. Principal Advised Services then translates the asset classes and target exposures for the asset classes through a selection of mutual funds and exchange-traded funds (“ETFs”) to build a portfolio. While Principal Advised Services attempts to maintain broad based diversification based on its assessment of historical returns and correlation, past performance does not guarantee of future results. Additionally, in periods of significant market volatility diversification may not help reduce exposure to market loss. Principal Advised Services reviews the performance and risk profile of the underlying investments on an ongoing basis and uses its discretion to add or modify investments within the portfolio as appropriate. Principal Advised Services also intends for the portfolios to include a minimal allocation to cash to facilitate payment of the account management fee. The cash currently is held by the Program Custodian, Apex Clearing Corporation (“Apex”) in an FDIC-insured deposit bank account selected by Apex. Principal Advised Services has the authority to remove or change the use of the Apex bank deposit account at any time. The cash in the Apex bank deposit account could earn interest. Clients should review the Apex FDIC-Insured Sweep Program Disclosure Document for important terms and conditions of the Apex bank deposit account, available on the Apex website or upon request from us. Client Information The Program uses an algorithm that recommends a portfolio to the Client and provides ongoing discretionary investment management from Client Inputs. The Client Inputs include answers to questions designed to assess the Client’s desire to take risk, which is determined by an algorithm that analyzes answers to the RTQ and calculates a risk score. For risk-based model portfolios, this risk score is used as the basis for an investment portfolio recommendation. For time-based model portfolios, this risk score is combined with the Client’s investment time horizon and used by us as the basis for an investment portfolio recommendation. The recommended time-based portfolio is based primarily on age, then on savings goals and lastly, RTQ responses. Each portfolio is designed with an approach that focuses on an appropriate asset allocation. For time-based model portfolios, this approach, especially for longer-term savings needs, means that the portfolios may be significantly weighted to riskier investments (such as equity funds over fixed income funds) despite a Client’s conservative risk score, depending on the difference between the Client’s goal retirement age and current age. Clients are not bound by the recommended model portfolio and can select an alternative portfolio by adjusting their goal retirement age or by overriding their calculated risk score. Clients should understand that their selection of a portfolio other than the portfolio that Principal Advised Services recommends may not be suitable based on their risk score or investment time horizon. Such selected portfolios could perform worse over any time period than the portfolio recommended by Principal Advised Services based on the information initially provided by the Client. Principal Advised Services’ recommendations, and the investment advice offered through the Program is limited based on the information Clients provide through the website or that the Client modifies with the assistance of our IARs. Clients should take into account the limited nature of the Program in evaluating the investment advice and recommendations provided through the Program. Principal Advised Services does not verify the completeness or accuracy of information provided by Clients. Inaccurate or incomplete information provided by Clients will affect the investment recommendations and advice provided through the Program. While Principal Advised Services will collect additional information about Clients’ financial background or outside assets, Principal Advised Services will only provide asset allocation and investment advice on assets held within the Program. Principal Advised Services’ recommendations and investment advice does not consider any outside assets, concentrated positions, debt or other accounts that a Client may have with Principal Advised Services’ affiliates or with any third party. 6  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Client Restrictions Clients can request reasonable restrictions on the management of their Client Account by designating specific ETFs or mutual funds that should not be purchased for the Client Account or directing the Client Account to be out of allocation, for example, a large cash holding for an upcoming purchase. Requested restrictions are subject to the review and approval of Principal Advised Services. Principal Advised Services will reject a requested investment restriction if it deems the request unreasonable, including because the request is clearly inconsistent with the Program’s investment strategy or philosophy or the Client's stated investment objective, or is fundamentally inconsistent with the nature or operation of the Program. Clients cannot impose restrictions on the underlying investments of any mutual fund or ETF available through the Program. Principal Advised Services will continue to manage accounts that are subject to reasonable restrictions in accordance with the terms of the Program, but Client Accounts with restrictions will produce different performance results as compared to a Client Account without restrictions using the same underlying investment portfolio, and ultimately, Client Accounts with restrictions could have a lower return. Depending on the nature of the reasonable restriction it is possible that Client Accounts with restrictions will trade after and will as a result receive better or worse pricing than, unrestricted Client Accounts invested in accordance with the same portfolio. Clients should discuss the impact of reasonable restrictions on the management of their Account with an IAR of Principal Advised Services prior to imposing reasonable restrictions. Updates to Client Information It is the Client’s responsibility to promptly update their Client Account online or by contacting Principal Advised Services if there is a change to their risk tolerance, financial situation or investment objectives that could affect the advisory services Principal Advised Services provides under the Program, or if a Client would like to impose or modify a reasonable restriction. Principal Advised Services will periodically, typically quarterly, prompt its Clients through electronic statements to notify us if there have been any changes in their financial situation or investment objectives or if the Client wishes to impose or modify reasonable investment restrictions on their Client Account. Additionally, Principal Advised Services will contact Clients on at least an annual basis via automated message, email, or phone to request that Clients review, update or confirm that that their responses to the RTQ and account information remain accurate. Investment Services Principal Advised Services has engaged Principal Asset Management to develop model investment portfolios for the Program that are designed to allocate assets among mutual funds and ETFs representing different asset classes, with a minimal allocation to cash. Principal Asset Management has developed the model portfolios to pursue specific investment objectives, time horizons, savings goals and risk tolerances associated with different possible Client profiles. These investment models are generally comprised exclusively of mutual funds and ETFs managed by affiliates of Principal Advised Services, with a minimal allocation to cash held in a nonaffiliated bank deposit account. Principal Asset Management provides ongoing services to us by assisting in the review of the models, asset class weightings, portfolios’ glide paths and investment options underlying the portfolios. Principal Asset Management is not responsible for implementing the models for any Client Account or rendering any investment advice to Clients. Principal Advised Services’ Investment Committee considers the recommendations made by Principal Asset Management and is responsible for reviewing, approving, adjusting as desired, and implementing any recommendations of Principal Asset Management related to the composition of the model investment portfolios offered through the Program and the specific mutual funds and ETFs used in the models. Mutual Funds and Exchange-Traded Funds Principal Advised Services determines the universe of mutual funds and ETFs that are made available to Clients through the Program. The Program offers portfolios comprised of mutual funds and ETFs only of affiliates of Principal Advised Services. We intentionally have a minimal allocation to cash, held in an unaffiliated FDIC-insured bank deposit account for Clients of the Program. Although mutual fund companies typically offer multiple share classes of each mutual fund with varying levels of fees and expenses, we generally choose a single share class of each mutual fund available through the Program. These are generally Institutional share classes (“I- shares”), which typically have a lower expense ratio in comparison to retail share classes. 7  Wrap Fee Program Form ADV Part 2A | Principal Advised Services An expense ratio is the annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for fund expenses, including management fees, administrative fees, operating costs, and all other fees and expenses incurred by the fund. This expense ratio is prorated and deducted from the investments in Client Accounts on an ongoing basis. The Client will bear a proportionate share of each fund’s expenses, including investment management fees, distribution, administration, transfer agency, shareholder services and other fees paid to our affiliates. The compensation received by our affiliates as fund expenses varies among funds and share classes utilized within the Program. Please refer to the “Material Relationships with Related Persons and Potential Conflicts of Interest” section of this Brochure for more information about the conflicts of interest associated with the selection of particular funds and share classes. We seek to address these conflicts of interest through a combination of disclosing them to Clients, our policies and procedures and related controls designed to review whether the fees we charge are fair and reasonable, and our program fee approach, as explained below. If Principal Advised Services’ affiliates did not receive compensation from the underlying funds in the Program, Principal Advised Services might charge higher fees or other amounts for the services we provide. Despite this conflict, however, Principal Advised Services’ selection of funds and share classes does not affect the overall fee (described below) paid for the Program. Principal Advised Services has the ability to use and offer mutual funds with multiple share classes, including but not limited to shares designated as I-shares and comparable share classes. Generally, I-shares and comparable shares are for institutional and other investors and therefore are not always available for a retail advisory account. For certain mutual funds and ETFs, I-shares or comparable shares may not be available for investment for certain Program accounts because (i) I-shares and/or comparable shares are not available for a specific mutual fund family, or (ii) certain mutual funds restrict access to I-shares and comparable shares. In addition, there may be other limitations on the use of I-shares or other share classes with lower expense ratios. Those share classes may have specific eligibility requirements described in the mutual fund's or ETF's prospectus or the statement of additional information. Such eligibility requirements could include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts that the fund considers qualified fee-based programs. Other funds and share classes have different fees and expenses that are lower than the fees and expenses of the funds and share classes we make available through the Program. Clients should not assume that they are invested in the lowest available share class. An investor who holds a less-expensive share class of a fund will pay lower fees over time – and earn higher investment returns – than an investor who holds a more expensive share class of the same fund. It is the policy of Principal Advised Services to assess the fees and expenses Clients will incur in connection with the formulation of Principal Advised Services’ recommendations and the management of Client Accounts on an ongoing basis. This includes an assessment of the available share classes. Over time, certain funds may offer share classes with lower fees. In these instances, we will determine, from time to time in our discretion, whether and in what manner to offer these share classes to our Clients. This may result in shares owned being bought and sold or converted to a share class with lower fees or such lower fee share classes being available only for new purchases. Additionally, there will be a period of time when a new share class becomes available that the Client will remain in the more expensive share class until we are able to take the administrative and operational steps necessary to make the new share class available through the Program and adequately test them in accordance with the algorithm and implementation process. Fractional Share Trading Principal Advised Services will trade fractional shares of ETFs within Client Accounts. The ETF shares purchased or sold on behalf of Clients will be either whole shares or fractional shares, depending upon the asset allocation selected for that Client Account. Principal Advised Services invests Client Accounts in dollar-based quantities, whereby transactions are based on a fixed dollar amount rather than whole shares. Clients who hold fractional shares in their Client Account will receive proxy materials showing the number of fractional votes that they are eligible to vote. Principal Advised Services and Apex each reserve the right, at any time and each in its sole discretion, without prior notice to Clients, to limit or stop trading fractional shares. Fractional shares are typically unrecognized and illiquid outside of a Client Account. Therefore, Clients cannot transfer fractional shares when closing their Client Account. Fractional shares will be converted to cash upon account closing. 8  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Trading Services Principal Advised Services has retained Principal Asset Management, a registered investment adviser and an affiliate of Principal Advised Services, to act as a sub-adviser for the Program and provide trading, rebalancing, and associated services. Principal Asset Management has limited discretionary authority over trading, which includes intelligent rebalancing and target asset allocation services for Client Accounts. These services, some of which are provided using algorithms managed by Principal Asset Management, are further described below. Principal Advised Services’ Investment Committee oversees the services it receives from Principal Asset Management, including approving the parameters that trigger rebalancing and trading. 1. Trading: Principal Asset Management places orders for buying, selling, exchanging, holding, and/or converting the mutual funds and ETFs in Client Accounts based on instructions provided by Principal Advised Services. 2. Target Asset Allocation: Principal Asset Management’s algorithm uses the Client Inputs to determine the target portfolio on any given date, including fractional shares when appropriate. 3. Intelligent Rebalancing: Principal Asset Management’s algorithm considers trading costs and rebalancing costs when rebalancing a portfolio. Rebalancing seeks to keep a Client’s assets invested consistently in line with the Client’s target asset allocation, so rebalancing will occur if the allocation among mutual funds, ETFs, and cash deviates by more than a specified threshold from the target asset allocation. Rebalancing transactions can occur frequently and potentially daily under a variety of market conditions. This means that rebalancing could occur in both significantly declining and appreciating market conditions, when securities prices may be significantly lower or higher, respectively. Principal Asset Management has implemented rules to limit rebalancing activity during periods of high trading costs, which can occur during periods of market-wide or specific security volatility, including events such as market circuit-breaker points being applied by the exchange. Circuit breakers are thresholds wherein trading is halted market-wide for any single-day dramatic drops in an underlying index. Principal Asset Management implements the target asset allocation and directs trading through an algorithm to align the Client Account with the target asset allocation, subject to Principal Advised Services’ direction. Although not required, Principal Advised Services generally aggregates multiple Client orders in the same securities to obtain the most favorable price and/or lower execution costs at the time trading occurs. When an order requires more than one execution, participating accounts will receive the average price for transaction in their particular block order. Principal Asset Management’s trading process is designed to give fair and equitable treatment to Principal Advised Services relative to its other similarly situated Clients, its own accounts, and the accounts of affiliates or any of their directors, officers, agents or employees. Depending on the circumstances, Principal Asset Management will recommend changes or execute transactions for its other Client accounts before directing trading for Clients of Principal Advised Services. Principal Asset Management, in its sole discretion, may not be able to direct trades or otherwise take certain actions for Clients due to (i) regulatory requirements; (ii) Principal Asset Management’s internal policies and procedures; (iii) actual or potential conflicts of interest or the appearance of such conflicts; or (iv) any other reason in Principal Asset Management’s sole discretion. Trade Errors Trade errors and other operational mistakes occasionally occur in connection with the management of Client Accounts. Errors can result from a variety of situations, including portfolio management (e.g., inadvertent violation of investment restrictions), trading, processing, or other functions (e.g., miscommunication of information, such as: incorrect number of shares, wrong price, wrong account, calling the transaction a buy rather than a sell and vice versa, etc.). All such errors affecting a Client Account will be resolved promptly and appropriately upon discovery. Under certain circumstances, Principal Advised Services and Principal Asset Management will consider whether it is possible to adequately address an error through cancellation, correction, reallocation of losses and gains or other means. The intent is to restore a Client Account to the appropriate financial position considering all relevant circumstances surrounding the error, generally by correcting any erroneous allocation to the Client Account or reimbursing the Client Account for any investment losses and costs resulting from the error. Principal Advised Services and Principal Asset Management make their determinations on a case-by-case basis, in their discretion, based on factors they consider reasonable. 9  Wrap Fee Program Form ADV Part 2A | Principal Advised Services The policies and procedures governing the Program generally do not require perfect implementation of investment management decisions, trading, processing or other functions performed by Principal Advised Services or Principal Asset Management. Therefore, not all mistakes will be considered compensable to the Client. Imperfections in the implementation of investment decisions, trade execution, cash movements, portfolio rebalancing, processing instructions or facilitation of securities settlement, issues relating to corporate actions for securities held in a Client Account, or imperfection in the generation of cash or holdings reports resulting in trade decisions may not constitute compensable errors, depending on the facts and circumstances. For example, imperfections in the implementation of investment strategies, including quantitative strategies (e.g., coding errors), that do not result in material departures from the intent of Principal Advised Services will generally not be considered compensable errors. In addition, in offering the Program and managing Client Accounts, Principal Advised Services will establish non-public, formal or informal internal targets, or other parameters that are used to manage risk, manage affiliated service providers or otherwise guide decision-making, and a failure to adhere to such internal parameters will not be considered an error. Algorithm Management One of the primary benefits of a digital investment adviser is the automatic rules governing trading and other aspects of the advisory services. Therefore, Principal Advised Services does not plan to override the algorithms used in the Program as a routine business practice. However, Principal Advised Services or Principal Asset Management will override an algorithm in the event of instances where the algorithm is not performing as expected or an error is discovered in a file used by the algorithm. In addition, in volatile or stressed market conditions or market halts, in response to certain types of operational or technological errors, and under other circumstances that Principal Advised Services or Principal Asset Management determines may negatively affect Client Accounts, Principal Advised Services or Principal Asset Management will override the algorithms, including electing to not trade during periods of market volatility. The Principal Advised Services Investment Committee oversees these procedures and will choose to override an algorithm, including electing to not trade during periods of market volatility, until the circumstances that triggered the decision to override the algorithm are resolved. Clients continue to be able request withdrawals from their Client Accounts during times when Principal Advised Services or Principal Asset Management overrides an algorithm, and Principal Advised Services will seek to continue to process requests based on underlying market conditions, including declining markets. Clients should note, liquidating assets during a period of significant market volatility may be difficult and redeeming assets during a period of market volatility could result in significant losses within the account. Principal Advised Services will execute distribution requests and will seek to obtain the most favorable execution possible during these limited periods. Clearing and Custodial Services Clearing and custody services are provided by Apex, an unaffiliated broker-dealer offering clearing, custody, trade execution and related services. Clients must enter into a service agreement with Apex to participate in the Program. Under the terms of the Program and its related agreements, the Client authorizes and directs Principal Advised Services to execute orders for all Client portfolio transactions through Apex. Clients will bear the risk of such transactions. Clients should understand that Principal Advised Services will trade through Apex even if the use of a different broker-dealer may result in lower prices or more favorable execution. Online Nature of the Program To receive investment advisory services through the Program, prospective Clients will be required to complete an online account application and enter into the Advisory Agreement and other account agreements electronically through the Program website. These agreements along with other disclosures and notices will be delivered to Clients primarily in electronic format by posting the information on the Program website where Clients can access their Client Accounts and through email or other electronic means. Principal Advised Services will not send paper versions of documents to Clients as part of the Program unless required by applicable law or in Principal Advised Services’ sole discretion. Clients must be willing to accept the terms of a global electronic consent, which will require that the Client agrees to electronic delivery of all current and future Program documents and communications, to enroll in the Program. Clients must provide Principal Advised Services with a valid email address to enroll in the Program. Clients are required to notify Principal Advised Services immediately in the event their email address changes, or becomes inaccessible, by visiting the Program 10  Wrap Fee Program Form ADV Part 2A | Principal Advised Services website or by contacting Principal Advised Services at 866-412-0770. Clients will be alerted by email when a new or amended agreement or document is available; therefore, it is important that Clients always maintain an accurate email address. If a Client fails to provide or maintain accurate contact information through the Program website, including an email address, or otherwise revokes consent to electronic delivery, Principal Advised Services reserves the right to terminate that Client’s participation in the Program. Please refer to the Client Disclosure and Consent Regarding Conducting Business Electronically document, which is provided at account opening and accessible online thereafter, for additional terms and conditions regarding electronic delivery of Program communications. Fees and Compensation A Client pays a level annualized fee equal to 0.85 percent of the Client Account balance (the “program fee”), which represents the sum of two fees: (1) an investment advisory fee for Principal Advised Services’ advice and management of Client Accounts (the “account management fee”), and (2) the underlying mutual fund and ETF management fees paid to our affiliates (the “investment expenses”). Investment expenses are inclusive of the investment management, distribution, administration, transfer agency, shareholder services and other fees charged by the affiliated mutual funds and ETFs held in the Client Account. The program fee is not negotiable. However, any portion of the account management fee may be waived or discounted at the sole discretion of Principal Advised Services. Although the annualized program fee is always 0.85 percent, the investment expenses differ for each Client Account based upon the particular fees and expenses associated with the affiliated mutual funds and ETFs held in the Client Account, and the account management fee for each Client Account varies because it is based on the difference between the overall program fee and the Client’s investment expenses. Clients should understand that the account management fee varies among Clients in the Program depending upon the specific investment portfolio that they have selected. However, the total amount of compensation that Principal Advised Services and its affiliates receives from any Client in connection with the Program is always 0.85 percent, or the program fee. The account management fee we debit from a Client Account will vary from month to month as a result of changes to the investment composition and associated investment expenses of the Client Account. We calculate the investment expenses by weighting the market value held in each mutual fund or ETF in a Client Account by the total expense ratio published in the most recent prospectus for each mutual fund and ETF. Investment expenses are subject to change by the fund managers. Further information about investment expenses can be found in the prospectus provided for each mutual fund and ETF. The account management fee is less than the program fee. We calculate the account management fee daily as a prorated amount of a Client Account’s daily closing balance. Monthly, Principal Advised Services will determine the total amount of investment expenses paid by each respective Client Account, and an account management fee that reflects the difference between the monthly investment expenses and the program fee will be automatically debited. The account management fee is assessed monthly in arrears. We do not charge the account management fee in a month where the Client Account is closed, and assets are distributed before that month’s end. Principal Advised Services retains the right to liquidate assets in a Client Account if there are insufficient funds to pay the account management fee or other account maintenance fees. We receive more in fees when Clients invest more assets in advisory accounts. That means we have an incentive to encourage Clients to increase the amount of assets in accounts. Fees and costs will also reduce any amount of money Clients make from investments over time. Clients should make sure they understand what fees and costs they are paying. Principal Advised Services compensates Principal Asset Management and Apex for its services to the account. Clients incur additional fees from Apex as described below. Additionally, Principal Asset Management receives compensation from Clients for its investment management services to the affiliated mutual funds and ETFs within the portfolios through the investment expenses. Miscellaneous Fees The program fee does not account for miscellaneous fees charged by Apex. Please refer to the Apex Clearing Corporation Schedule of Miscellaneous Account Fees for Principal® SimpleInvest, which is provided at account opening and accessible online thereafter, for a complete list of these miscellaneous fees, including annual service fees, maintenance fees (e.g. a transfer, rollover, or termination fee) and other fees required by law. Apex automatically deducts these miscellaneous fees from Client Accounts. In certain circumstances disclosed in the Advisory Agreement, Principal Advised Services charges Clients for special requests or other irregular services. Certain 11  Wrap Fee Program Form ADV Part 2A | Principal Advised Services termination or transfer fees can be waived in a variety of circumstances, at PAS’s sole discretion. This includes termination and transfer fees if moving from the Program to an investment with an affiliate of Principal Advised Services. Relative Cost of the Program The program fee charged for the Program costs the Client more or less relative to similar services purchased separately or from other advisory firms. Clients should consider that, depending on the amount of activity in the Client Account and the value of custodial, trade execution, advisory, and other services that are provided under the arrangement, the program fee could exceed the aggregate cost of such services if they were to be provided separately. To compare the costs of the Program to purchasing the services separately or from other firms, a Client should consider the trading activity within their Client Account, the investment strategy, the relative cost of the strategy, the program fee and other additional fees applicable to Client Accounts and weigh this against the brokerage commissions and/or advisory fees that would be charged by other investment advisers or by broker-dealers. Compensation for Persons Recommending the Program Principal Advised Services' IARs are available by phone or email to answer questions about the Program, the investment strategies, mutual funds, and ETFs available through the Program, and Client Account performance. IARs that make a recommendation or assist Clients in enrolling in the Program or assist with inquiries regarding Client Account do not receive any portion of the program fee as compensation nor are they compensated based on the model portfolio selected. However, the compensation payable to Principal Advised Services in connection with participation in the Program will be more than what PAS would receive if a Client participated in programs or services available through other affiliates, or if a Client paid separately for investment advice, brokerage and other services. Therefore, Principal Advised Services has an incentive to recommend the Program over other programs or services available from our affiliates. IARs receive a base salary and benefits. Although IARs do not receive commissions, they are eligible to receive variable compensation in the form of periodic incentive payments that are directly tied to their success in gathering and retaining assets in accounts offered through Principal Financial Group. IARs are eligible to receive an annual bonus, which depends on company and individual performance results. Individual performance measurements for the annual bonus generally include (i) the number of newly opened accounts, and the amount of assets raised and retained (including assets transferred from outside Principal Financial Group or outside Principal Advised Services) in IRAs, and other types of accounts offered through Principal Financial group; (ii) call quality metrics; (iii) call and consultation volume; (iv) time available for calls; and (v) referrals to other parts of the business within Principal Financial Group. A substantial portion of the bonus metrics also depends on the extent to which Plan participants accept staff recommendations. Some IARs are also eligible to receive additional periodic (such as monthly, quarterly, or annual) payments based on individual performance. Individual performance factors considered for periodic payments include the same factors described above. The periodic payment compensation programs create conflicts of interest because IARs have an incentive to recommend retention in or, rollover to, Principal Financial Group accounts when other options may be in a client’s best interest. To mitigate these conflicts of interest, other applicable policies and procedures require IARs to provide recommendations that are in the client’s best interest. Moreover, front-line managers supervise IARs and an independent quality team monitors client calls. In addition, recommendations by IARs are reviewed and analyzed by a risk-based supervision program designed to ensure the recommendation is in the clients’ best interest. Item 5: Account Requirements and Types of Clients A Client must initially invest a minimum of $5,000 total in one or more Client Accounts and maintain a balance of at least $1,000 in each Client Account. Principal Advised Services will, in its sole discretion, waive or change this minimum investment amount at any time. After a Client Account is established, we reserve the right to suspend trading, discontinue management and/or close a Client Account if a Client fails to fund with the minimum or the Client Account balance falls below the specified minimum, and a Client does not deposit additional money into the Client Account. Accounts below $1,000 can cause deviation from the target asset allocation outside of the established portfolio drift parameters. 12  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Not all Clients or prospects will be appropriate for the Program. The Program is designed to provide investment advisory services to individual investors who reside in the U.S., who have regular internet access, and who are comfortable investing in mutual funds and ETFs through a digital investment experience. Participation in the Program requires that the Client completes an account application and is approved for an account with Apex and with Principal Advised Services. The account application can be accessed online through the account portal. As discussed in Item 4 above, Clients are required to enroll in electronic delivery in order to participate in this Program. Item 6: Portfolio Manager Selection and Evaluation Principal Asset Management As described above, Principal Advised Services has hired its affiliate, Principal Asset Management, which acts as an investment model provider for the Program and provides trading services to us (“affiliated service provider”). As the model provider, Principal Asset Management develops the investment models available in the Program, recommends the mutual funds and ETFs that comprise the models, and assists Principal Advised Services in the ongoing monitoring of the performance of the models and their underlying mutual funds and ETFs. All mutual funds and ETFs available in the Program are managed by Principal Asset Management. Where a mutual fund or ETF available in the Program has a third-party sub-adviser unaffiliated with Principal Asset Management, Principal Asset Management conducts the initial due diligence and ongoing monitoring of the sub-adviser. Principal Asset Management also assists Principal Advised Services by providing trading, intelligent rebalancing and reallocation services for Client Accounts. Principal Advised Services Investment Committee The Principal Advised Services Investment Committee is appointed by the Principal Advised Services Board of Directors to direct our investment activities. The Investment Committee is comprised of investment and risk professionals working for various business units of member companies of Principal Financial Group, including individuals from Principal Asset Management. The Investment Committee’s responsibilities include appointing, reviewing, and overseeing the performance of affiliated service providers, reviewing the performance, fees and expenses of the mutual funds and ETFs included in the models, and reviewing th e testing and oversight of any algorithms involved in the formulation of investment advice. The Investment Committee reviews certain aspects of the Program on a quarterly and annual schedule as part of its oversight program. The oversight program is meant to evaluate the necessity of any changes to the Program, including with respect to the affiliated service providers or the processes implemented by such affiliated service providers. The Investment Committee is responsible for reviewing Principal Asset Management’s recommended investment models and approving the models or working with Principal Asset Management to make modifications. The Investment Committee also monitors the performance of the investment models, at least annually, to ensure the expected returns and risk are appropriate for the targeted risk tolerance and time-horizon. The Investment Committee performs oversight of the Principal Asset Management’s algorithms used to set risk scores, determine target portfolios for Clients, and trigger trading activities. This oversight includes review of periodic testing of the algorithm outputs to confirm they are consistent with expectations. The Investment Committee oversees Apex’s provision of clearing, custody, trade execution, and related services to Clients and will periodically evaluate Apex’s execution quality as part of its ongoing oversight. The Investment Committee reviews the performance of Client Accounts using information provided by Apex and Principal Asset Management. The Investment Committee reviews the account performance to ensure that the risk profiles are aligned appropriately for the models. As the investment model provider, Principal Asset Management has the obligation to review the underlying mutual funds and ETFs and to recommend any changes and to provide information regarding these underlying funds to the Investment Committee for its review. Principal Advised Services does not verify, or rely on a third-party to verify, the accuracy of the performance information provided by Apex and Principal Asset Management relating to the Client Accounts or that provided by Principal Asset 13  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Management relating to the underlying mutual funds and ETFs available through the Program. As a result, performance information could not be calculated on a uniform and consistent basis. Please see Item 4 above for a discussion of the types of advisory services and strategies that Principal Advised Services offers in the Program. Principal Advised Services receives a portion of the program fee for the portfolio management services it provides in the Program. Principal Advised Services currently does not intend to manage any accounts that are not program fee accounts. Material Risks In general, all Client Accounts are subject to risks, including the risks discussed below. This Brochure does not include every potential risk associated with the Program or all of the risks applicable to a particular Client Account. Rather, it is a general description of certain risks inherent in the Program. Clients should refer to their Advisory Agreement and the underlying prospectuses for the mutual funds and ETFs offered through the Program for additional information. Investment Risks Investing in securities, like mutual funds and ETFs, whether through the Program or otherwise, involves risk of loss that Clients should be prepared to bear, including loss of original principal. Principal Advised Services does not guarantee the results of any advice or recommendation. In addition, Principal Advised Services does not guarantee that the objectives of the Client will be met. The advice provided to the Client only pertains to the Client Account managed by Principal Advised Services. Clients should be aware that they can lose money by investing in mutual funds and ETFs through the Program. The past performance of Principal Advised Services or Principal Asset Management is no guarantee of future results, therefore, Clients should not assume the future performance of an investment strategy will be profitable. Market, interest rate, investment and other related risks may adversely affect the performance of securities held in Client Accounts and cause losses in a Client Account. The following is a list of some of the principal risks of investing in mutual funds and ETFs and of investing through a digital investment platform. The following list of risks is not intended to be a comprehensive list of risks. Investing in mutual funds and ETFs. A Client Account bears all the risks of the investment strategies employed by the mutual funds and ETFs held in the Client Account, including the risk that a mutual fund or ETF will not meet its investment objectives. If the mutual fund or ETF fails to achieve its investment objective, the Client Account’s investment in the fund may adversely affect its performance. The mutual funds and ETFs held in Client Accounts bear the general risks of owning the underlying securities held by the mutual fund or ETF. Mutual funds and ETFs may invest in equities, fixed income, derivatives, and other asset classes; the risks associated with such investments are described below. For the specific risks associated with any particular mutual fund or ETF, please refer to its prospectus. Mutual funds and ETF investments bear additional expenses based on a pro-rata share of operating expenses, including potential duplication of management fees. ETFs. An ETF is subject to the risks of the underlying securities that it holds, as well as the risk that it may fail to closely track the index it follows (tracking error). ETFs are subject to fees and expenses (like management fees and operating expenses) that do not apply to an index, and a Client Account will indirectly bear its proportionate share of the fees and expenses of the ETFs in which it invests. Moreover, ETF shares may trade at a premium or discount to their net asset value (“NAV”). Therefore, due to variations in the NAV of the ETF under certain circumstances the ETF could trade for more or less than the value of the underlying investments if bought separately. Although ETFs are required to calculate their NAV daily, at times the market price of an ETF’s shares may be more than the NAV (trading at a premium) or less than the NAV (trading at a discount). Given the differing nature of the relevant secondary markets for ETFs, certain ETFs may trade at a larger premium or discount to NAV than shares of other ETFs depending on the markets where such ETFs are traded. The risk of deviation from NAV for ETFs generally is heightened in times of market volatility or periods of steep market declines. For example, during periods of market volatility, securities underlying ETFs may be unavailable in the secondary market, market participants may be unable to calculate accurately the NAV per share of such ETFs, and the liquidity of such ETFs may be adversely affected. This kind of market volatility may also disrupt the ability of market participants to create and redeem shares in ETFs. Further, market volatility may adversely affect, sometimes materially, the prices at which market participants are willing to buy and sell shares of ETFs. As a result, under these circumstances, the market value of shares of an ETF may vary substantially from the NAV per share of such ETF, and the Client may incur significant losses from the sale of ETF shares. 14  Wrap Fee Program Form ADV Part 2A | Principal Advised Services As an ETF trades on an exchange, it is subject to the risks of any exchange-traded instrument, including: (i) an active trading market for its shares may not develop or be maintained, (ii) market makers or authorized participants may decide to reduce their role or step away from these activities in times of market stress, (iii) the exchange may halt trading of its shares, and (iv) its shares may be delisted from the exchange. This means there may be times when ETFs are not as liquid as other investments. In addition, ETF managers that offer passive investment strategies generally do not seek to outperform their benchmark. As a result, ETF managers may hold securities that are components of their underlying index, regardless of the current or projected performance of the specific security or market sector. Passive managers do not attempt to take defensive positions based upon market conditions, including declining markets. This approach could cause a passive vehicle’s performance to be lower than if it employed an active strategy. Market Risk. The price of any security or the value of an entire asset class can decline for many reasons, including but not limited to interest rates, regulatory changes, unpredictable market sentiment changes, and political, economic and social conditions. Global markets are interconnected, and events like hurricanes, floods, earthquakes, forest fires and similar natural disturbances, war, terrorism or threats of terrorism, civil disorder, public health crises, and similar “Act of God” events have led and may in the future lead to increased short-term market volatility and may have adverse long-term and widespread effects on world economies and markets generally. Client Accounts may have exposure to countries and markets impacted by such events, which could result in material losses. Equity Investments. Price changes may occur in the market, or in a country, industry, or sector of the market. In addition, different types of stocks tend to shift in and out of favor depending on market and economic conditions, and the types of stocks in which a fund invests may underperform the market. For example, growth stocks can be more volatile than other types of stocks, and the market can undervalue value stocks for long periods of time. Dividends on common stocks are not fixed but are declared at the discretion of an issuer’s board of directors. There is no guarantee that a company will pay dividends, or that if paid they will remain at current levels or increase over time. Investors holding common stock of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer. Fixed Income Investments. In general, the bond market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) The ability of an issuer of a bond to repay principal prior to a security’s maturity can cause greater price volatility if interest rates change, and, if a bond is prepaid, a bond fund may have to invest the proceeds in securities with lower yields. Fixed income securities also carry inflation risk and credit and default risks for both issuers and counterparties. Unlike individual bonds, most bond funds do not have a maturity date, so holding them until maturity to avoid losses caused by price volatility is not possible. In addition, investments in certain bond structures may be less liquid than other investments and therefore may be more difficult to trade effectively. Foreign Investments. Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which may be greater in emerging markets. These risks are particularly significant for funds that focus on a single country, region, or emerging markets. Foreign markets may be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Derivatives. Certain mutual funds and ETFs may invest in derivatives. A derivative is a financial contract whose value is based on the value of a financial asset (such as a stock, bond, or currency); a physical asset (such as gold, oil, or wheat); or a market index (such as the S&P 500® Index). Investments in derivatives may subject these funds to risks different from, and possibly greater than, those of the underlying securities, assets, or market indexes. Some forms of derivatives, such as exchange-traded futures and options on securities, commodities, or indexes, have been trading on regulated exchanges for decades. These types of derivatives are standardized contracts that can easily be bought and/or sold, the market values of which are determined and published daily. Non- standardized derivatives (such as swap agreements), on the other hand, tend to be more specialized or complex, and may be more difficult to value. Derivatives may involve leverage because they can provide investment exposure in an amount exceeding the initial investment. As a result, the use of derivatives may cause funds to be more volatile because leverage tends to exaggerate the effect of any increase or decrease in the value of a fund’s portfolio securities. 15  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Legislative and Regulatory Risk Client Accounts may be adversely affected by new (or revised) laws or regulations. Changes to laws or regulations can impact the securities markets, specific industries, individual issuers of securities, and Principal Advised Services’ determinations with respect to the expected rate of return, value, or creditworthiness of a security. Algorithm Risk There are inherent limitations to using algorithms to recommend a model and manage a Client Account. For instance, the algorithms used in the Program are designed to manage a Client Account according to the asset allocation selected for that Client Account and are not designed to actively manage asset allocations based on short-term market fluctuations. The algorithms are also not designed to consider certain factors, including individual tax circumstances such as capital gains taxes; rather, their functions consist of proposing a portfolio based on the Client Inputs, identifying opportunities for rebalancing, and generating initial buy/sell orders accordingly. There is also a risk that the algorithms and related software used for strategy selection, intelligent rebalancing, and related functions may not perform within intended parameters, which may result in a recommendation of a portfolio that may be more aggressive or more conservative than necessary, or incorrectly trigger or fail to initiate rebalancing. In addition, changes to an algorithm’s code, although subject to controls and testing, may not have the desired effect with respect to Client Accounts. While this risk increases if changes to an algorithm are insufficiently tested prior to implementation, even extensively tested changes may not produce the desired effect over time. Asset Allocation Risk Asset allocation decisions can result in more portfolio concentration in a certain asset class or classes, which could reduce overall return if the concentrated assets underperform expectations. The more aggressive the investment strategy used for a Client Account, the more likely the Client Account will contain larger weights in riskier asset classes, such as equities. Asset classes can perform differently from each other at any given time (as well as over the long term), so the investment strategy will be affected by its allocation among the asset classes. Depending on market conditions, there may be times when diversified portfolios perform worse than less diversified portfolios. Diversification does not eliminate investment risk. Cybersecurity, Technology, and Operational Risk Principal Advised Services depends upon digital and network technology to conduct its day-to-day business operations and fulfill ongoing obligations to Clients. As such, Clients’ information is susceptible to operational, information security, and related risks. In general, cyber incidents can result from deliberate internal or external attacks or unintentional events and are not limited to gaining unauthorized access to digital systems and misappropriating assets or sensitive information, corrupting data, or causing operational disruption, including denial-of-service attacks on websites. Cybersecurity failures or breaches either internally at Principal Advised Services or externally by a third-party service provider or at or against issuers of securities in which the portfolio invests can cause disruptions and impact business operations. Such events could potentially result in financial losses, the inability to transact business, violations of applicable privacy laws including disclosure of Clients’ personally identifiable information, regulatory fines, violation of other laws, penalties, reputational damage, reimbursement, or other compensation costs, and/or additional compliance costs, including the cost to prevent cyber incidents. Principal Advised Services has developed a Business Continuity Program and an Enterprise Information Security Program that are designed to minimize the disruption of normal business operations in the event of an adverse incident impacting Principal Advised Services or its affiliates. While Principal Advised Services believes that the Business Continuity Program and Enterprise Information Security Program are comprehensive and should enable it to reestablish normal business operations in a timely manner in the event of an adverse incident, there are inherent limitations in such programs (including the possibility that contingencies have not been anticipated and procedures do not work as intended) and under some circumstances, Principal Advised Services and its affiliates, any 16  Wrap Fee Program Form ADV Part 2A | Principal Advised Services vendors used by Principal Advised Services or its affiliates or any service providers to the portfolios Principal Advised Services manages could be prevented or hindered from providing services to the portfolio for extended periods of time. These circumstances may include, without limitation, acts of God, acts of governments, any act of declared or undeclared war or of a public enemy (including acts of terrorism), power shortages or failures, utility or communication failure or delays, labor disputes, strikes, epidemics, shortages, supply shortages, and system failures or malfunctions. These circumstances, including systems failures and malfunctions, could cause disruptions and negatively impact a portfolio’s service providers and a portfolio’s operations, potentially including impediments to trading portfolio securities. A portfolio’s ability to recover any losses or expenses it incurs as a result of a disruption of business operations may be limited by the liability, standard of care and related provisions in its contractual arrangements with service providers. Limited Nature of Program The digital platform offered by Principal Advised Services is not intended as a complete investment program for every Client. Although the IAR will consider material factors such as outside assets in the recommendation of the Program, the advice is provided exclusively on assets in the Program and does not consider other investments the Client has. The RTQ asks fewer questions and elicits less information than Clients might be asked through a traditional advisory program. As a result, the use of the Client Inputs to create a recommended portfolio for a Client could result in a different recommendation than if the Client completed a longer questionnaire and/or had an in-person interview with an adviser. Principal Advised Services representatives are available to help Clients navigate the online RTQ and/or to answer questions about the Program if they chose to enroll on their own. IARs are also available to conduct an interview and make a recommendation to the Client about whether to invest in the Program. Another material limitation of the Program is the fact that the only investment products available within the Program are currently mutual funds and ETFs managed by affiliates of Principal Advised Services, except for the cash position. Other products managed by affiliates of Principal Advised Services or by unaffiliated third parties may be an appropriate investment for a particular Client or may have higher returns than a product available in the Program, but these other products are not available through the Program. Performance Based Fees and Side by Side Management Principal Advised Services does not charge performance-based fees (fees calculated based on a percentage gain in the underlying account). Voting of Client Securities Principal Advised Services does not acquire or exercise proxy voting authority for Clients in the Program. Clients will be sent any proxy materials directly from Apex in its role as custodian. Any proxy voting must be directly exercised by each Client. Principal Advised Services will not advise Clients on the voting of proxies, nor will it advise or act for any Client in any legal proceedings, including bankruptcies or class actions, involving securities held or previously held in a Client Account. In the event Principal Advised Services receives any proxies, it will promptly forward these to Apex. Item 7: Client Information Provided to Portfolio Managers Each Client is asked to answer a series of online multiple-choice questions in the RTQ. These questions are used to assess the Client’s ability and desire to take risk. We use an algorithm to analyze the Client’s responses to the RTQ and provide a risk score. This risk score is combined with other Client Inputs, including the Client’s age, to form the basis for our investment recommendation. Principal Advised Services shares the information provided by the Client with its affiliated service providers to the extent necessary to facilitate their provision of services, including facilitating the algorithm with respect to the relevant Client Account. Item 8: Client Contact with Portfolio Managers All Client contacts and communications regarding participation in the Program will occur through Principal Advised Services via email, its interactive website, or telephone. Clients should contact Principal Advised Services’ IARs if they have specific questions about the way their Client Account is managed. 17  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Item 9: Additional Information Disciplinary Information Neither Principal Advised Services nor any of its officers, directors, employees or other management persons has been involved in any legal or disciplinary events that would require disclosure in response to this Item. Other Financial Industry Activities and Affiliations As a wholly owned subsidiary in the family of entities of Principal Financial Group, Principal Advised Services is part of a diversified, global financial services organization with many types of affiliated financial services providers, including but not limited to broker- dealers, insurance companies and other investment advisers. Certain of Principal Advised Services’ management persons, including its members of the management team, Investment Committee members, and other control persons, also hold positions with one or more affiliated entities. These management persons will have significant other duties for our affiliates and allocate a substantial portion of their time to the management of other affiliated entities of Principal Advised Services. Management persons performing work for Principal Advised Services in addition to work performed for other affiliates are not required to devote all their working time to Principal Advised Services. Conflicts of interest from time to time may arise in allocating management time, services, or functions among Principal Advised Services and other affiliates. Principal Advised Services attempts to mitigate such conflicts through its internal controls and by disclosure. Material Relationships with Related Persons and Potential Conflicts of Interest Principal Advised Services has certain relationships or arrangements with related persons that are material to its investment advisory business. Below is a description of these relationships and some of the conflicts that arise from them. Principal Advised Services mitigates the conflicts of interest discussed below through disclosure in this Brochure and through the implementation, monitoring and review of the policies and procedures that comprise its compliance program. Please see “Conflicts of Interest” below for further discussion of the conflicts of interest that arise from using affiliated service providers and offering affiliated mutual funds and ETFs in the Program. Principal Life Insurance Company is licensed as an insurance company in all 50 states and the District of Columbia. Principal Advised Services has entered into a Subsidiary Expense Reimbursement Agreement pursuant to which Principal Life Insurance Company and its global affiliates will furnish certain personnel, services and facilities to Principal Advised Services, and Principal Advised Services will reimburse its affiliates for the costs associated with these services. Principal Life Insurance Company is also a record keeper to retirement plans. The Program will also be offered to retirement plan participants who wish to withdraw their assets from plans that use Principal Life Insurance Company as a record keeper. Furthermore, Principal Advised Services directs Clients to Principal Bank, an affiliate, for the purchase of banking products. As Principal Advised Services is an affiliate of Principal Bank, IARs may be incentivized to refer Clients as a relationship exists between Principal Bank and Principal Advised Services. Principal Advised Services is an affiliate of Principal Securities, Inc. (“PSI”), a retail investment adviser and a broker-dealer registered with the SEC and a FINRA member firm. Principal Advised Services does not conduct any brokerage business with PSI. However, certain supervised persons or IARs of Principal Advised Services are registered representatives of PSI because of other duties they perform outside of the Program. While not compensated for such activities, Principal Advised Services IARs direct Clients to a life insurance agent of Principal Life Insurance Company to purchase life or disability insurance products. Additionally, certain Principal Advised Services’ IARs are Principal Bank staff who are also Registered Representatives of Principal Securities. 18  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Principal Funds Distributor, Inc., is the principal underwriter for an investment company (Principal Funds, Inc.). Many of the investments available through the Program are mutual funds of Principal Funds, Inc. The use of the affiliated mutual funds poses a conflict of interest as an affiliate receives compensation for the sale of the fund shares. The ETFs available through the Program are offered by an affiliate, Principal Exchange Traded Funds; an unaffiliated entity distributes these ETFs. To the extent that Principal Advised Services selects lower cost funds or share classes, an affiliate of Principal Advised Services may receive less compensation. In this case, Principal Advised Services has a conflict of interest and financial incentive to recommend portfolios that have lower cost funds or share classes since the amount of its account management fee will be comparatively greater (as a portion of the overall program fee) than had it recommended higher-fee share classes; an increase in the amount of investment expenses lowers the amount of the program fee that Principal Advised Services receives in the form of the account management fee. However, the overall compensation earned by Principal Advised Services and its affiliates, collectively, does not change based on the investments in the Client Account, whether from affiliated funds or otherwise. Thus, Principal Advised Services’ selection of funds and share classes does not change the program fee paid for the Program. The trading services for the Program are provided with the assistance of Principal Asset Management, which is an affiliate of Principal Advised Services. Principal Asset Management is registered as an investment adviser with the SEC. This relationship poses a conflict in that Principal Advised Services has an incentive to select Principal Asset Management as the provider of these services for the Program over comparable unaffiliated third-party providers, because by selecting an affiliate, Principal Advised Services ensures that an affiliate receives compensation for these services. Principal Asset Management also serves as the model provider for the Program and acts as the investment manager for all of the affiliated mutual funds and ETFs that are available through the Program. This relationship poses a potential conflict in that Principal Advised Services has an incentive to select Principal Asset Management as the model provider and to offer investments managed by Principal Asset Management through the Program, because these choices generate compensation for a Principal Advised Services affiliate. To the extent that Principal Advised Services selects lower cost funds or share classes, Principal Asset Management will receive less compensation in the form of investment expenses from the affiliated mutual funds and ETFs included in Client Accounts. As a result, Principal Advised Services has a conflict of interest and financial incentive to recommend portfolios that have lower cost funds or share classes since the amount of its account management fee will be comparatively greater (as a portion of the overall program fee) than had it recommended higher-fee share classes; an increase in the amount of investment expenses lowers the amount of the program fee that Principal Advised Services receives in the form of the account management fee. However, the compensation earned by Principal Advised Services and its affiliates, collectively, does not change based on the investments in the Client Account, whether from affiliated funds or otherwise. Thus, Principal Advised Services’ selection of funds and share classes does not change the program fee paid for the Program. Apex Clearing Corporation, an unaffiliated broker-dealer, provides clearing, custody, trade execution and related services to the Program. Code of Ethics and Personal Trading Principal Advised Services has adopted a Code of Ethics (the “Code”). The principal purpose of the Code is to provide policies and procedures consistent with applicable laws and regulations, including Rule 204A-1 under the Investment Advisers Act of 1940 (“Advisers Act”), to prevent or mitigate conflicts of interests or the appearance of such conflicts when Principal Advised Services officers, directors, employees and certain non-employees of Principal Advised Services with access to Client and trading information of Principal Advised Services (“Access Persons”) own or engage in their own personal transactions involving securities. The Code requires all Access Persons to adhere to high standards of honest and ethical conduct and the interests of our advisory Clients to be placed first always. All Access Persons are required to certify upon association/employment and annually thereafter that they have read, understood and complied with the Code. This includes certifying that they have complied with the requirements to disclose covered accounts, reportable securities and pre-cleared transactions as required by the Code, when applicable. Access Persons are permitted to personally buy and sell securities of issuers that Principal Advised Services also trades for its Clients, so long as those buy and sell transactions are conducted in accordance with the Code. 19  Wrap Fee Program Form ADV Part 2A | Principal Advised Services As such, there are procedures in place to prevent instances where potential conflicts of interest arise between the personal securities transactions of the Access Persons and the securities transactions that Principal Advised Services does for Client Accounts. The compliance area of Principal Advised Services monitors personal trading. All Access Persons are required to obtain pre-clearance approval to buy and sell any offerings that are exempt from registration under the Securities Act of 1933 pursuant to Regulation D (“private placements”) and are required to report their securities transactions on an ongoing basis through an online monitoring system. There is also a quarterly review of reportable transactions, as well as annual certification of accounts and holdings by Access Persons. Please refer to our Code for a detailed overview of provisions. Clients and prospective Clients of Principal Advised Services may obtain a full copy of the Code by contacting an IAR or the Compliance Department by request at 866-412-0770. Participation or Interest in Client Transactions and Other Conflicts of Interest Conflicts of interest or potential conflicts of interest commonly refer to activities or relationships in which the interests of Principal Advised Services, and its affiliates compete with the interests of Clients. Members of the Principal Advised Services management team and Investment Committee will meet on an as needed basis to identify and discuss any actual or potential conflicts of interest. Additionally, such members will review risk controls, policies, and procedures to identify any necessary controls to mitigate or eliminate any actual or potential conflicts of interest. Recommendations or Investments in Securities that Principal Advised Services, or its Related Persons may also Purchase and Sell As a wholly owned subsidiary of Principal Financial Group, Principal Advised Services is part of a diverse family of financial services companies that offers Clients a wide range of financial products and services. Principal Advised Services’ affiliates at times may give investment advice and/or act in the performance of their duties in a manner that differs from or is inconsistent with the advice given for Client Accounts. In addition, Principal Advised Services’ recommendations through the Program at times will differ from its affiliates’ recommendations or guidance. Affiliated Mutual Funds and ETFs Principal Advised Services has a conflict of interest in offering affiliated mutual funds and ETFs through the Program because the compensation received by Principal Asset Management and its affiliates increases when the assets invested in the affiliated mutual funds and ETFs increase. Principal Asset Management and its affiliates will, in the aggregate, receive more compensation when Client assets are invested in affiliated funds than they would receive if the Client instead invested in unaffiliated funds. This creates a financial incentive for Principal Advised Services to choose affiliated funds for the Program over non-affiliated funds. We mitigate this conflict of interest by disclosing it to Clients and making clear that, except for the cash portion of the portfolio, the Program is limited to proprietary funds. Retention of Affiliated and Unaffiliated Service Providers Principal Advised Services has a financial incentive to select Principal Asset Management as both the model provider and as the provider of trading services for the Program over comparable providers that are not affiliated with Principal Advised Services because Principal Advised Services’ affiliates will, in the aggregate, receive more total revenue when Client assets are invested in investment products managed or serviced by affiliated service providers. Principal Advised Services’ Investment Committee members oversee the services provided by Principal Asset Management. In addition to retaining its affiliates to provide certain services, Principal Advised Services also retains unaffiliated service providers to provide various other services. A service provider may provide services to Principal Advised Services while also providing services to affiliates of Principal Advised Services and may negotiate rates in the context of the overall relationship. Alternatively, Principal Advised Services may be unable to obtain the same fee rates from a given service provider that its affiliates negotiated, and Principal Advised Services may not know about these lower negotiated rates. 20  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Conflicts of Interest Created by Trading Model Portfolios Principal Asset Management may provide model portfolios to affiliated and unaffiliated investment advisers who use model portfolios to assist in developing their own investment recommendations and managing their own accounts. In addition, Principal Asset Management may trade in the same or similar securities for its other Clients. Principal Asset Management may (but need not) delay communicating information regarding model portfolios or any updates thereto until after its other clients have commenced trading. In such circumstances, Principal Advised Services will not have had the chance to evaluate or act upon the model portfolio recommendations prior to the time at which other advisory accounts received such recommendations and had the opportunity to act upon them. It is also possible that Principal Asset Management may have already started trading the same or similar securities for its other clients before Principal Advised Services has directed Principal Asset Management to trade on behalf of Clients. Such differences in the timing of trades can affect the pricing of the relevant securities and can result in Client Accounts receiving less favorable pricing. Transactions for which orders have been placed could be subject to price movements, particularly with large orders relative to the given security’s trading volume, which could result in Clients receiving prices that are less favorable than the prices Principal Asset Management’s other clients receive. Review of Accounts Principal Advised Services generally provides all Clients with continuous access to its website. Through the website, Clients can access information about their account status, portfolio allocations, securities, and balances. Proprietary as well as commercially available software is used to review the Client Accounts quarterly to ensure that they are in line with investment objectives. Additional reviews may be triggered by material changes in variables such as a Client’s individual circumstances, or the market, political or economic environment. As mentioned above, Clients have access to account information through the website. Apex in its capacity as the custodian prepares account statements showing transactions and account balances during the prior quarter. All information relating to Clients and Client Accounts is provided on the website and/or sent via email or paper as required. Generally, on a quarterly basis, Principal Advised Services will remind Clients to review and update the profile information previously provided. Principal Advised Services requests that Clients reconfirm their current profile information as needed and on an annual basis. Additionally, Principal Advised Services’ Investment Committee, in conjunction with the compliance team, will prepare and review exception reports on an ongoing basis to ensure that Client Accounts are in line with the asset allocation and risk parameters identified for Clients based on their RTQ scores. The Investment Committee will also review relevant material changes to the algorithm prior to implementation. Trusted Contacts Clients can choose to add Trusted Contact(s) to their Client Account at the time the account is established or anytime thereafter. Principal Advised Services is authorized to contact a Trusted Contact and disclose information about the Client Account to address possible financial exploitation, to confirm the specifics of the Client's current contact information, health status, or the identity of any legal guardian, executor, trustee, or holder of a power of attorney, or as otherwise permitted by law. The Trusted Contact(s) are not permitted to make changes to the Client Account or affect any transactions within the Client Account. A Client may change or remove a Trusted Contact with written notice at any time. Client Referrals and Other Compensation Principal Advised Services has entered into and is currently a party to referral agreements whereby we receive referral fees as a promoter in accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any corresponding state securities law requirements. In order to make referrals to unaffiliated registered investment advisers, plan sponsors must agree to add this feature to the plan. Principal Advised Services will refer plan participants, as appropriate, to affiliated and unaffiliated registered investment advisers that are able to provide comprehensive wealth management services. The referral fee is a percentage of the asset management fees received by the registered investment adviser and is paid to Principal Advised Services when a referred plan participant becomes a new client. 21  Wrap Fee Program Form ADV Part 2A | Principal Advised Services Custody Principal Advised Services does not act as a custodian for Client assets and does not have physical custody of Client funds or securities at any time. Apex serves as the qualified custodian for all Client Accounts. Apex will provide regular ongoing statements to Clients showing the securities owned and account activity. Clients should promptly and carefully review the statements provided by Apex and compare them against the Account information available online through the Program and notify us promptly in writing via email or physical mail of any errors or discrepancies. Principal Advised Services is deemed to have custody of Client funds as defined in Rule 206(4)-2 of the Advisers Act (“Custody Rule”) as a result of Clients authorizing Principal Advised Services to withdraw advisory fees from Client Accounts, and when Clients initiate third-party transfers out of their Client Accounts. Principal Advised Services will comply with all applicable Custody Rule requirements. From time to time, Principal Advised Services may inadvertently receive Client assets from third parties. Principal Advised Services has appropriate policies and procedures which provide for returning such assets to the sender, as permitted by the Custody Rule and guidance thereunder. Financial Information Principal Advised Services does not require or solicit the prepayment of any fees, with the exception of financial planning services, as detailed in the Principal Advised Services Advice Brochure, and does not have any adverse financial condition that is reasonably likely to impair Principal Advised Services’ ability to continuously meet its contractual commitments. Principal Advised Services has not been the subject of a bankruptcy proceeding. 22 

PRINCIPAL ADVISED SERVICES, LLC FORM ADV PART 2A: TARGET MY RETIREMENT BROCHURE Legal Address 655 9th Street Des Moines, IA 50309 Mailing Address 711 High Street Des Moines, IA 50392 866-412-0770 www.principal.com January 1, 2026 This brochure (the "Brochure") provides information about the qualifications and business practices of Principal Advised Services, LLC (“Principal Advised Services,” “us,” “our,” or “we”). The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Principal Advised Services is also available on the SEC’s website at: www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for Principal Advised Services is 297324. If there are questions about the contents of this Brochure, please contact us at 866-412-0770 or AdvisedServices@principal.com. Any reference to Principal Advised Services as a “registered investment adviser” or as being “registered” does not imply a certain level of skill or training.  Form ADV Part 2A Target My Retirement | Principal Advised Services Item 3: Table of Contents Item 3: Table of Contents ............................................................................................................................................................................. 2 Item 4: Advisory Business ............................................................................................................................................................................. 3 Item 5: Fees and Compensation ................................................................................................................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................................................ 6 Item 7: Types of Clients ................................................................................................................................................................................ 6 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ......................................................................................................... 6 Item 9: Disciplinary Information ................................................................................................................................................................... 8 Item 10: Other Financial Industry Activities and Affiliations ......................................................................................................................... 8 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................... 9 Item 12: Brokerage Practices ...................................................................................................................................................................... 10 Item 13: Review of Accounts ...................................................................................................................................................................... 10 Supervision of Advice .................................................................................................................................................................................. 10 Item 14: Client Referrals and Other Compensation .................................................................................................................................... 11 Item 15: Custody ........................................................................................................................................................................................ 11 Item 16: Investment Discretion .................................................................................................................................................................. 11 Item 17: Voting Client Securities................................................................................................................................................................. 11 Item 18: Financial Information ................................................................................................................................................................... 11 2  Form ADV Part 2A Target My Retirement | Principal Advised Services Item 4: Advisory Business Principal Advised Services is a member company of Principal Financial Group, Inc. (“Principal Financial Group”), a diverse family of financial services companies offering businesses, individuals, and institutional customers a wide range of financial products and services, including retirement, insurance, and asset management. Principal Life Insurance Company, as a member o f Principal Financial Group provides recordkeeping services to retirement plans. As part of these recordkeeping services, Principal Life Insurance Company specializes in offering educational and advisory services to retirement plan participants and IRA investors. Principal Advised Services was formed in 2017. Its principal place of business is in Des Moines, Iowa. Principal Advised Services is a subsidiary of Principal Financial Group (NASDAQ: PFG), through intermediate holding companies. Please see Schedule A to Part 1 of Principal Advised Services' Form ADV for details. Description of Services Offered Target My Retirement Target My Retirement offers two services: (1) a discretionary Managed Account Service that provides ongoing professionally managed asset allocation portfolios and (2) Point-in-Time Advice that delivers a one-time recommendation on asset allocation, savings rate and retirement age advice. Target My Retirement is available for participants in employer sponsored retirement plans (“Plan”) recordkept by Principal Life Insurance Company (“PLIC”). The Managed Account Service offers discretionary investment management, through which Principal Advised Services will allocate enrolled participant accounts among the investment options available in their Plan. Each participant enrolled in the Managed Account Service will receive an investment portfolio reflecting their personal retirement timeframe and overall financial picture, if that information is provided by the participant. As a part of the Managed Account Service, a participant’s account will be monitored, rebalanced and reallocated periodically through a series of portfolios personalized with the objectives of meeting the participant’s desired retirement goals. Target My Retirement considers Plan assets and, if provided by the participant, other assets and investments not included in the Plan. Participants are encouraged to review their personal information to ensure that it is accurate and consistent with their goals, as changes to this information could impact the service’s asset allocation and how their Plan account is invested. Point-in-Time Advice is available to participants who want to manage their own accounts but receive advice in doing so. Participants will be able to view proposed asset allocation portfolios that are based upon the data they have provided during the subscription process without enrolling in Target My Retirement. This snapshot of the proposed asset allocation portfolio is point-in-time, nondiscretionary, view-only asset allocation advice that will include allocations among the Plan’s investment options. The portfolio recommendation is limited because it will rarely include an allocation to a target date fund and will not recommend a full allocation to a target date fund. Unlike the Managed Account Service, Point-in-Time Advice is nondiscretionary and will not automatically implement any asset allocation, nor will it monitor or automatically rebalance a participant’s portfolio. Should the participant determine that the proposed Point-in- Time Advice asset allocation is appropriate, the participant can choose to implement the proposed allocations by making self-directed transactions through the Plan’s website. Point-in-Time Advice may also provide recommendations about other financial matters, such as savings rates, targeted retirement age, and retirement income recommendations. The Plan sponsor must affirmatively elect to make Target My Retirement available to its Plan participants. If the Plan has selected Target My Retirement as a Plan service, participants can voluntarily enroll in the service. During the enrollment process, participants will have the opportunity to provide detailed information about their personal and financial situation. Plan sponsors can also designate Target My Retirement Managed Account Service as the Plan’s Qualified Default Investment Alternative (“QDIA”). A QDIA is a default investment selected by the Plan sponsor and is used when a Plan participant has not made an investment election. If designated as the QDIA and directed by the Plan sponsor, Principal Advised Services will automatically enroll any participants that have not made an investment election and place them into the Managed Account Service. A participant can subsequently unenroll from Target My Retirement and can manage their own account within the Plan. Principal Advised Services utilizes personal information provided by the Plan, if available, including salary, date of birth, gender and state of residence for participants who are automatically enrolled in the service. 3  Form ADV Part 2A Target My Retirement | Principal Advised Services Principal Advised Services has hired Morningstar Investment Management, LLC (“Morningstar”) to provide sub-advisory services in connection with Target My Retirement. Morningstar is an SEC registered investment adviser and subsidiary of Morningstar, Inc., neither of which are affiliates of Principal Advised Services. Principal Advised Servies relies exclusively on the proprietary software, systems and investment methodology developed and maintained by Morningstar to create target allocation for individuals who use Target My Retirement. Morningstar acts as an Independent Financial Expert (“IFE”), as that term is described in the U.S. Department of Labor’s Advisory Opinion 2001-09A (“Opinion 2001-09A”). Target My Retirement has been designed to satisfy applicable requirements under the Employee Retirement Income Security Act of 1974 (“ERISA”). Principal Advised Services is not responsible for selecting and monitoring the Plan investments used to build Target My Retirement portfolios or for choosing to designate Target My Retirement as the QDIA. In Plan Advice Principal Advised Services, through our investment advice representatives (“IARs”) that staff our call centers, also offer nondiscretionary investment advice to participants in Plans when the Plan has elected to make Target My Retirement available. The nondiscretionary advice that the IARs will provide is limited to the following: i. Advice about Target My Retirement – We provide Plan participants with advice regarding whether they should enroll in the Managed Account Service or use Point-in-Time Advice. ii. Savings Rates – We provide participants with advice regarding the amount of money they should contribute to their Plans, including savings rate recommendations. iii. Fund-specific recommendations– We provide participants with recommendations regarding the funds they should select from the Plan’s available investment options. A participant receives the ability to view a recommended investment portfolio that includes allocations among all, or a portion of, the Plan’s investment options. The advice described above is informed by factors including a participant’s retirement profile information, situation, objectives, investment experience, the level of engagement the participant plans to have in managing their retirement savings, their outlook on volatility, and whether the participant finds value in professional management. Conflicts of Interest Principal Advised Services earns an advisory fee while a participant is enrolled in the Managed Account Service. When a participant enrolls in the Managed Account Service or is automatically enrolled as part of the Plan’s QDIA, Principal Advised Services earns compensation for providing these services. Principal Advised Services thus has an incentive to encourage Plan sponsors to elect Target My Retirement as a service within the Plan, has an incentive to encourage Plan sponsors to consider the Managed Account Service as the QDIA, and has an incentive to encourage participants to enroll and add more money to Target My Retirement. Some Principal personnel receive incentive compensation for promoting Target My Retirement to Plan sponsors; these personnel are responsible for selling recordkeeping services to retirement Plan sponsors and are eligible to earn incentive compensation based on whether the Plan selects Target My Retirement as a Plan offering. As a result, these personnel are incentivized to suggest that the Plan sponsor select the Target My Retirement service. A Plan can select proprietary investments as part of their lineup. Our affiliates, including Principal Global Investors, LLC, which does business as Principal Asset Management, manage these proprietary investments and can earn increased fund advisory fees if your account includes proprietary investment options. Principal Advised Services seeks to mitigate these conflicts by ensuring that neither it nor its affiliates exercise discretion or have responsibility for the selection or monitoring of the investment options available within Target My Retirement. The Plan sponsor is responsible for selecting the investment options from a selection of both proprietary and non-proprietary investment options available on the recordkeeper platform. Additionally, Morningstar, as the IFE, is responsible for the selection of the Plan investment options recommended through Target My Retirement, rather than Principal Advised Services. Our affiliate, Principal Life Insurance Company, earns revenue for employer-sponsored retirement Plans that it provides recordkeeping 4  Form ADV Part 2A Target My Retirement | Principal Advised Services and other services to by assessing fees that are calculated as a percentage of the Plan’s assets held within participant’s accounts. As a result, if a participant follows our recommendations to contribute more money to their account within the Plan, Principal Life Insurance Company earns additional revenue. This conflict of interest is mitigated by Principal Advised Services having a dedicated supervision team that reviews transactions where a recommendation of Target My Retirement is made to ensure it is in the participant’s best interest. Additionally, our recommendation to use Target My Retirement constitutes a promotional relationship under the SEC’s marketing rule. We will provide required disclosure to participants to whom we recommend Target My Retirement. IARs receive a base salary and benefits. Although IARs do not receive commissions, they are eligible to receive variable compensation in the form of annual bonuses that are directly tied to their success in gathering assets in accounts offered through Principal Financial Group. IARs are eligible to receive an annual bonus, which depends on company and individual performance results. Individual performance measurements for the annual bonus generally include (i) the number of new managed accounts opened (ii) call quality metrics; (iii) call and consultation volume; (iv) adherence to corporate values; and (v) referrals to other parts of the business within Principal Financial Group. A substantial portion of the bonus metrics also depends on the extent to which Plan participants accept staff recommendations. The annual bonus creates conflicts of interest because IARs have an incentive to recommend use of Principal Financial Group accounts when other options may be in a client’s best interest. To mitigate these conflicts of interest, other applicable policies and procedures require IARs to provide recommendations that are in the client’s best interest. Moreover, front-line managers supervise IARs and an independent quality team monitors client calls. In addition, recommendations by IARs are reviewed and analyzed by a risk-based supervision program designed to ensure the recommendation is in the clients’ best interest. Customers, retail clients, prospective retail clients and Plan participants (together “Clients”) are not obligated to implement any recommendations made by Principal Advised Services or maintain an ongoing relationship with Principal Advised Services or its affiliates. As of December 31, 2024, Principal Advised Services managed $887,316,440 of client assets on a discretionary basis. Item 5: Fees and Compensation Principal Advised Services charges an annual fee of up to .50% of the daily value of a participant’s account assets managed by the Managed Account Service. The advisory fee is accrued daily based on the participant’s account balance managed by the Managed Account Service and is deducted monthly in arrears. The advisory fee is on a tiered pricing structure and is negotiable by the Plan sponsor. The negotiated tiered fee will vary depending upon a combination of several variables, including participant account balances, Plan assets under management, Plan demographics, if the Plan chooses to enroll its participants into the service as the QDIA option, include proprietary funds, and other factors. Principal Advised Services may make the service available to participants at no cost during a free trial period, which if applicable will be described in the participants’ Plan documents. Principal Advised Services begins to assess the advisory fee on the date the participant enrolls in the Managed Account Service or upon the expiration of a free trial period. A participant can unenroll from the Managed Account Service online or by calling Principal, and the fee will no longer be accrued. If the Plan sponsor terminates Target My Retirement or the Plan is transitioned to a new recordkeeper, the participants in Managed Account Service will be unenrolled, and the fee will be deducted from the participants’ accounts on a pro-rated basis. When enrolled in the Managed Account Service, participants bear the fees and expenses associated with the underlying funds and investments in the account, in addition to the advisory fee of .50%. Fees and expenses for the investments are described in the respective prospectuses or other offering materials for the investments. Participants should review the prospectuses and other offering materials carefully for information about the fees and expenses of the investment options available within the Plan. Additionally, participants within a Plan pay recordkeeping fees and other Plan-related fees as applicable. For additional information on these recordkeeping fees, please contact your Plan sponsor. There is no additional fee charged by Principal Advised Services for Point-in-Time Advice. However, if the participant later enrolls in the Managed Account Service, the advisory fee described above will be charged upon enrollment. 5  Form ADV Part 2A Target My Retirement | Principal Advised Services Item 6: Performance-Based Fees and Side-By-Side Management Principal Advised Services does not charge performance-based fees (fees calculated based on a percentage gain in the underlying account). Item 7: Types of Clients Principal Advised Services provides services described herein to participants in employer sponsored retirement Plans recordkept by Principal Life Insurance Company, where the Plan sponsor has contractually authorized Principal Advised Services to provide Target My Retirement. There is currently no minimum balance required for Target My Retirement. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Principal Advised Services’ decision to select Morningstar as the IFE was made based on an analysis of Morningstar’s processes and methodologies. Principal Advised Services conducts due diligence and oversight of Morningstar as subadvisor and IFE. Principal Advised Services does not guarantee the performance of the asset allocation portfolios developed by Morningstar. Morningstar provides advice on contribution rate, asset allocation and retirement age based on the individual’s retirement goals using a 70% probability of success. The portfolio provided by Target My Retirement will be the product of a computer program applying portfolio management methodologies developed, maintained and overseen by Morningstar as the IFE. Morningstar has sole control over the development of its model asset allocation portfolios. Principal Advised Services cannot modify the IFE’s model portfolios. Principal Advised Services Governance Committees Principal Advised Services has governance committees appointed by the Principal Advised Services’ Board of Directors to oversee the nondiscretionary and discretionary advisory activities described in this Brochure. The Committees are comprised of investment and risk professionals working for various member companies of Principal Financial Group. Among other responsibilities, the Committees have the responsibility to oversee the formulation and delivery of the advice described herein, including by overseeing the fiduciary requirements, conflicts of interest and conflict mitigation strategies, disclosures regarding advice, policies and procedures, audit and correction issues, and investment methodology used in formulating the advice. To this end, the Committees review and approve the proprietary investment methodology that generates advice about whether a participant should enroll in Target My Retirement, as well as the investment methodology provided by Morningstar that generates advice about savings recommendations and the Point-in-Time fund-specific advice. Material Risks In general, all Client accounts are subject to risks, including the risks discussed below. This Brochure does not include every potential risk associated with the services described herein. Rather, it is a general description of certain risks inherent with the advice described herein. Clients should refer to the agreements and underlying fund prospectuses and disclosure documents relevant to the services described above for additional information. Model Risk The model asset allocation portfolios available in Target My Retirement are based on generally accepted principles of modern portfolio investment theory. However, like all investment activity, models, algorithms and/or calculations (“Models”) come with inherent risks. Models may incorrectly forecast future behavior or produce unexpected results, including losses. The success of using Models depends on numerous factors, including the validity, accuracy and completeness of the Model’s development, implementation and maintenance, 6  Form ADV Part 2A Target My Retirement | Principal Advised Services the Model’s assumptions, factors, algorithms and methodologies, and the accuracy and reliability of the supplied historical or other data. In addition, if incorrect data is entered into a well-designed Model, the resulting information will be incorrect. Investments selected with the use of Models may perform differently than expected as a result of the design of the Model, inputs into the Model, or other factors. Changes to a Model, although subject to compliance controls and testing, may not have the desired effect with respect to an investor’s account. While this risk increases if changes to a Model are insufficiently tested prior to implementation, even extensively tested changes may not produce the desired effect over time. The advice generated from Models is dependent, in part, upon information received from Clients as well as from other third parties and external sources, meaning that the service could be impacted depending on the accuracy of the information provided. Plan Investment Lineup Risk Target My Retirement is limited to the investments available in the retirement Plan. If those funds underperform or carry higher fees, participants bear that risk. Investment Risks Investing in securities, like mutual funds, ETFs or other funds, whether in connection with the advice described above or otherwise, involves risk of loss that Clients should be prepared to bear, including loss of principal. Principal Advised Services does not guarantee the results of any advice or recommendation. In addition, Principal Advised Services does not guarantee that the objectives of the Client will be met. The past performance of investment strategies managed by Principal Advised Services or Morningstar is no guarantee of future results; therefore, a customer should not assume the future performance of an investment strategy will be profitable. Market, interest rate, investment and other related risks may adversely affect the performance of securities held in customer accounts and cause losses in a Client account. Investing can result in losses, including loss of principal. While employing a diversified investment portfolio, including the usage of a variety of investment products representing different asset categories, can mitigate some risks for investors, they cannot and do not prevent all loss. Ultimately, such risks are borne by the individual investor. Below are some of the main risks of investing in mutual funds, ETFs, and other funds. This is not intended to be a complete list. Investing in funds generally. A Client account bears all the risks of the investment strategies employed by the mutual funds and ETFs and other funds held in the Client account, including the risk that the fund will not meet its investment objectives. The funds held in Client accounts may invest in equities, fixed income, and other asset classes; the risks associated with such investments are described below. For the specific risks associated with any particular fund, please refer to its prospectus or other disclosure document. Market Risk. The price of any security or the value of an entire asset class can decline for many reasons, including but not limited to interest rates, regulatory changes, unpredictable market sentiment changes, and political, economic, and social conditions. Global markets are interconnected, and events like hurricanes, floods, earthquakes, forest fires and similar natural disturbances, war, terrorism or threats of terrorism, civil disorder, public health crises, and similar “Act of God” events have led and may in the future lead to increased short-term market volatility and may have adverse long-term and widespread effects on world economies and markets generally. Client Accounts may have exposure to countries and markets impacted by such events, which could result in material losses. Equity Investments. Price changes may occur in the market, or in a country, industry, or sector of the market. In addition, different types of stocks tend to shift in and out of favor depending on market and economic conditions, and the types of stocks in which a fund invests may underperform the market. For example, growth stocks can be more volatile than other types of stocks, and the market can undervalue value stocks for long periods of time. Dividends on common stocks are not fixed but are declared at the discretion of an issuer’s board of directors. There is no guarantee that a company will pay dividends, or that if paid they will remain at current levels or increase over time. Investors holding common stock of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer. Fixed Income Investments. In general, the bond market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) The ability of an issuer of a bond to repay principal prior to a security’s maturity can cause greater price volatility if interest rates change, and, if a bond is prepaid, a bond fund may have to invest the proceeds in securities with lower yields. Fixed income securities also carry inflation risk and credit 7  Form ADV Part 2A Target My Retirement | Principal Advised Services and default risks for both issuers and counterparties. Unlike individual bonds, most bond funds do not have a maturity date, so holding them until maturity to avoid losses caused by price volatility is not possible. In addition, investments in certain bond structures may be less liquid than other investments and therefore may be more difficult to trade effectively. Foreign Investments. Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which may be greater in emerging markets. These risks are particularly significant for funds that focus on a single country, region, or emerging markets. Foreign markets may be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Item 9: Disciplinary Information Neither Principal Advised Services nor any of its officers, directors, employees, or other management persons has been involved in any legal or disciplinary events that would require disclosure in response to this Item. Item 10: Other Financial Industry Activities and Affiliations As a wholly owned subsidiary in the family of entities of Principal Financial Group, Principal Advised Services is part of a diversified, global financial services organization with many types of affiliated financial services providers, including but not limited to broker- dealers, insurance companies and other investment advisers. Certain of Principal Advised Services’ management persons, including its members of the management team, Committee members, and other control persons, also hold positions with one or more affiliated entities. These management persons will have significant other duties for our affiliates and allocate a substantial portion of their time to the management of other affiliated entities of Principal Advised Services. Management persons performing work for Principal Advised Services in addition to work performed for other affiliates are not required to devote all their working time to Principal Advised Services. Conflicts of interest arise from time to time when allocating management time, services, or functions among Principal Advised Services and other affiliates. Principal Advised Services attempts to mitigate such conflicts through its internal controls and by disclosure to Clients. Material Relationships with Related Persons and Potential Conflicts of Interest Principal Advised Services has certain relationships or arrangements with related persons that are material to its investment advisory business. Below is a description of these relationships and some of the conflicts that arise from them. Principal Advised Services mitigates the conflicts of interest discussed below through disclosure in this Brochure and through the implementation, monitoring and review of the policies and procedures that comprise its compliance program. Principal Life Insurance Company is licensed as an insurance company in all 50 states and the District of Columbia. Principal Advised Services has entered into an agreement pursuant to which Principal Life Insurance Company and its global affiliates will furnish certain personnel, services and facilities to Principal Advised Services, and Principal Advised Services will reimburse its affiliates for the costs associated with these services. Principal Life Insurance Company provides recordkeeping services to retirement Plans. The majority of services and programs described here are offered to participants of retirement Plans that use Principal Life Insurance Company as a recordkeeper. Principal Securities Inc. (“PSI”) is an investment adviser and a broker-dealer registered with the SEC, and a FINRA member firm. Principal Advised Services does not conduct any brokerage business with PSI, although PSI has brokerage relationships with retirement Plans recordkept by Principal Financial Group. However, certain supervised persons or associated persons of Principal Advised Services are registered representatives of PSI as a result of other duties they perform. Principal Trust Company, the trade name for Delaware Charter Guarantee & Trust, ("PTC") is a non-deposit trust company chartered in 8  Form ADV Part 2A Target My Retirement | Principal Advised Services the State of Delaware. PTC provides trust and custodial services to certain Plans recordkept by PLIC. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Principal Advised Services has adopted a Code of Ethics (the “Code”). The primary purpose of the Code is to provide policies and procedures consistent with applicable laws and regulations, including Rule 204A-1 under the Advisers Act, to prevent or mitigate conflicts of interests or the appearance of such conflicts. The Code applies to all Supervised Persons of Principal Advised Services including officers, directors, employees and certain non-employees of Principal Advised Services with access to Client and trading information of Principal Advised Services (“Access Persons”) who own or engage in their own personal transactions involving securities. The Code requires all Supervised Persons to adhere to high standards of honest and ethical conduct and the interests of our advisory Clients to always be placed first. Supervised Persons are required to certify upon association/employment and annually thereafter that they have read, understood, and complied with the Code. An Access Person must certify they have complied with the requirements to disclose covered accounts, reportable securities and pre-cleared transactions as required by the Code, when applicable. Access Persons are permitted to personally buy and sell securities of issuers that Principal Advised Services also trades for its Clients, so long as those buy and sell transactions are conducted in accordance with the Code. As such, there are procedures in place to mitigate potential conflicts of interest between the personal securities transactions of the Access Persons and the securities transactions that Principal Advised Services does for Client accounts. The compliance area of Principal Advised Services monitors personal trading. All Access Persons are required to obtain pre-clearance approval to buy and sell any offerings that are exempt from registration under the Securities Act of 1933 pursuant to Regulation D (“private placements”) and are required to report their securities transactions on an ongoing basis through an online monitoring system. There is also a quarterly review of reportable transactions, as well as annual certification of accounts and holdings by Access Persons. Clients and prospective Clients of Principal Advised Services can request and obtain a full copy of the Code by contacting an IAR or the Compliance Department at 866-412-0770. Please refer to our Code for a detailed overview of provisions. Participation or Interest in Customer Transactions and Other Conflicts of Interest Conflicts of interest or potential conflicts of interest refers to activities or relationships in which the interests of Principal Advised Services and its affiliates compete with the interests of Clients. Members of the Principal Advised Services management team, Committees and Board will meet on an as needed basis to identify and discuss any actual or potential conflicts of interest. Additionally, such members will review risk controls, policies, and procedures to identify any necessary controls to mitigate or eliminate any actual or potential conflicts of interest. Recommendations or Investments in Securities that Principal Advised Services or its Related Persons may also Purchase and Sell As a wholly-owned subsidiary of Principal Financial Group, Principal Advised Services is part of a diverse family of financial services companies that offers Clients a wide range of financial products and services. Principal Advised Services’ affiliates at times gives investment advice and/or acts in the performance of their duties in a manner that differs from or is inconsistent with the advice given for Client accounts described in this Brochure. In addition, Principal Advised Services’ recommendations described above will differ from its affiliates’ recommendations or guidance. Affiliated Mutual Funds and other Funds If Principal Advised Services selects or recommends affiliated mutual funds or other funds, then its affiliates, including Principal Asset Management, will, in the aggregate, receive more compensation when Client assets are invested in affiliated funds than they would receive if the Client instead invested in unaffiliated funds. This creates a financial incentive for Principal Advised Services to choose or recommend affiliated funds over non-affiliated funds. We mitigate this conflict of interest by disclosing it to Clients, and in the case of Target My Retirement, by using third party investment methodology to power fund-specific investment recommendations in accordance 9  Form ADV Part 2A Target My Retirement | Principal Advised Services with Opinion 2001-09A. Retention of Affiliated and Unaffiliated Service Providers In addition to retaining its affiliates to provide certain services, Principal Advised Services also retains unaffiliated service providers to provide various other services. A service provider will provide services to Principal Advised Services while also providing services to affiliates of Principal Advised Services and will negotiate rates in the context of the overall relationship. Alternatively, Principal Advised Services will be unable to obtain the same fee rates from a given service provider that its affiliates negotiated, and Principal Advised Services will not know about these lower negotiated rates. Conflicts of Interest Created by Trading Model Portfolios Our affiliates benefit if your account includes proprietary investment options. A Plan can include proprietary investments that are managed or sponsored by a Principal Advised Services affiliate, such as mutual funds or collective investment trusts (CITs). When a proprietary investment option is in a Plan lineup, Principal Advised Services’ affiliates receive compensation for services they provide. Principal Advised Services mitigates the conflict by ensuring that neither its affiliates exercise discretion or have responsibility for the selection or monitoring of the investment options available within Target My Retirement. Instead, the Plan sponsor is responsible for selecting the investment options available in the Plan. Item 12: Brokerage Practices Principal Advised Services does not have discretion to select brokerage arrangements for the Target My Retirement Services. The Plan Sponsor instructs Principal Advised Services to utilize the brokerage arrangement for the Plan as authorized by the Plan Sponsor as part of the Plan’s recordkeeping arrangement with PLIC and its affiliates. Principal Advised Services provides some of the services described herein within retirement Plans recordkept by Principal Financial Group. As part of the recordkeeping arrangement with Principal Financial Group, retirement Plan sponsors instruct Principal Financial Group about how to execute trades in Plan accounts, and entities within Principal Financial Group are selected for this purpose. Principal Advised Services does not select or recommend the manner in which Plan brokerage functions take place, and some of the services described herein are delivered without regard to the brokerage arrangements selected by the Plan sponsor. Principal Advised Services does not receive research or other soft dollar benefits from broker-dealers that place mutual fund transactions. Item 13: Review of Accounts Accounts in the Managed Advice Service are evaluated to be rebalanced or reallocated on a periodic basis (approximately quarterly) according to the methodology that Principal Advised Services receives from Morningstar. Participants are encouraged to review personal information to ensure that it is accurate and consistent with their goals, as changes to this information could impact the Managed Account Service’s asset allocation and how an account is invested. Principal Advised Services does not automatically update or monitor the nondiscretionary advice offered through Point-in-Time Advice. If participants would like an updated recommendation for any reason, they must reengage with the Point-In-Time Advice service and they are solely responsible for reviewing and updating their individual financial information, for tracking their account and the market to be aware of changes that may impact their management of their account. Principal Advised Services has practices to periodically confirm that its investment methodology remains appropriate and accurate. Supervision of Advice Principal Advised Services’ Board of Directors has established a committee structure to provide governance over advisory activities. At least annually, Principal Advised Services will review the Morningstar methodologies used to power Target My Retirement to ensure 10  Form ADV Part 2A Target My Retirement | Principal Advised Services they are consistent with advisory best practices, and they meet the terms of the agreement between Principal Advised Services and Morningstar. Item 14: Client Referrals and Other Compensation Principal Advised Services has entered into and is currently a party to referral agreements whereby we receive referral fees as a promoter in accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any corresponding state securities law requirements. In order to make referrals to unaffiliated registered investment advisers, Plan sponsors must agree to add this feature to the Plan. Principal Advised Services will refer Plan participants, as appropriate, to affiliated and unaffiliated registered investment advisers that are able to provide comprehensive wealth management services. The referral fee is a percentage of the investment advisory fees received by the registered investment adviser and is paid to Principal Advised Services when a referred Plan participant becomes a new Client. Item 15: Custody Principal Advised Services does not hold physical custody of any Target My Retirement funds. However, its affiliate Principal Trust Company is the trustee and qualified custodian for the retirement Plans whose participants receive advice through the services described in this Brochure. Principal Advised Services also deducts advisory fees directly from a participant’s account through its recordkeeping affiliate Principal Life Insurance Corporation. PAS has taken the position that it has custody under the Custody Rule, as a result of the affiliated trustee and qualified custodian, and is subject to an annual surprise custody audit. Item 16: Investment Discretion Principal Advised Services relies on Morningstar as an IFE for Target My Retirement. Principal Advised Services implements the recommendations of the IFE and has limited discretionary authority as it relates to changing any transactions associated with composing or rebalancing a participant’s account in connection with the portfolio recommendations of the IFE in the Managed Account Service. Principal Advised Services does not have discretionary authority of the Point-in-Time asset allocation recommendations. Item 17: Voting Client Securities Principal Advised Services does not accept authority to vote proxies on investment funds held in participant accounts. If a security held in Plan account files a proxy statement, the Plan sponsor or participant may vote the proxy, depending on Plan procedures. Item 18: Financial Information Principal Advised Services does not have any adverse financial condition that is reasonably likely to impair Principal Advised Services’ ability to continuously meet its contractual commitments. Principal Advised Services has not been the subject of a bankruptcy proceeding. 11