Siebert Advisornxt, Llc.

Siebert AdvisorNxt, LLC Wrap Fee Brochure Form ADV – Part 2A CRD # 288572 (212) 644-2400 300 Vesey Street, Suite 501 New York, NY 10282 212-644-2400 www.siebertnxt.com September 22, 2026 This brochure provides information about the qualifications and business practices of Siebert AdvisorNXT, LLC ("Siebert.NXT"). If you have any questions about the contents of this brochure, please contact customer service at (212) 644-2400. 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 Siebert.NXT on the SEC’s website at www.adviserinfo.sec.gov. Siebert AdvisorNXT, LLC is required to be registered as an Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Page 1 of 22  Item 2 – Material Changes There were no material changes to Siebert AdvisorNXT, LLC ("Siebert.NXT") since the filing of our last brochure. Item 3 - Table of Contents ITEM 1 COVER PAGE ................................................................................................................................................ ..… 1 ITEM 2 MATERIAL CHANGES .......................................................................................................................................... 2 ITEM 3 TABLE OF CONTENTS.......................................................................................................................................... 2 ITEM 4 SERVICES, FEES AND COMPENSATION ............................................................................................................... 3 ITEM 5 TYPES OF CLIENTS ........................................................................................................................................... 10 ITEM 6 METHODS OF ANALYSIS, INVESTMENT STRATEGIES, RISK OF LOSS .................................................................. 11 ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ........................................................................ 17 ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS .............................................................................................. 18 ITEM 9 ADDITIONAL INFORMATION ............................................................................................................................. 18 Page 2 of 22  Item 4 - Services, Fees, and Compensation Services Siebert AdvisorNXT, LLC ("Siebert.NXT") is an SEC registered investment advisor with its headquarters in New York which began conducting business in 2017. The firm provides clients with investment strategies for all market conditions through various distribution channels. As a firm, Siebert.NXT has several different distinct lines of services. Under the Siebert umbrella, there is the AdvisorNXT web-based advisory program(“AdvisorNXT”), a third- party investment Manager, and Investment Supervisory Services. Clients can engage Siebert.NXT to manage all or a portion of their assets on a discretionary or non- discretionary basis. With regard to portfolio management services, Siebert offers its primary services pursuant to several types of investment strategies: fundamental and technical analysis (as described further in Item 6). Siebert primarily provides its services to individuals. Siebert offers to its clients a number of asset management programs (“Managed Programs”) consisting of asset allocation, flexible asset management and focused strategies where Financial Advisors will assist each client in reviewing information about the programs, completing a client questionnaire to determine the client’s risk tolerance, financial situation and investment objectives, and selecting an investment strategy. Siebert contracts with and selects other investment advisors to act as either the portfolio manager or sub-advisor on behalf of its clients. Siebert may have representatives act as portfolio managers as well. Siebert (as further discussed in Item 6) primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), individual securities, and Independent Managers, in accordance with the investment objectives of the client. Siebert also provides advice about any type of investment held in clients’ portfolios. Siebert tailors its services to the individual needs of clients, in accordance with the fiduciary standards and the clients’ best interests. Siebert consults with clients initially and has periodic follow-up contact (generally no less than annually) to determine and/or update risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Clients are advised to notify Siebert if there are changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon Siebert’s management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in Siebert’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. It is the clients’ ongoing responsibility to timely communicate with the Advisor, any changes to their financial situation or status, which may affect the appropriateness of the client’s particular portfolio. Siebert will devote its best efforts with respect to its management of its client accounts. AdvisorNXT The AdvisorNXT platform provides clients with a web-based, cost-efficient, competitively priced, easy to use automated wealth management solution intended to maximize portfolio returns based on a clients’ specific risk tolerance. Upon signing up for the AdvisorNXT platform, clients will be provided with a risk tolerance questionnaire that will help create ideal portfolios for their specific investing needs. Our Premier Plan is our comprehensive plan, offering a dedicated wealth manager who will work with clients on a regular basis to address specific needs, and will also offer in-depth advice of services and products offered outside of AdvisorNXT. See section “General AdvisorNxt Management Fee Program” for an in- depth description of our services. Page 3 of 22  The AdvisorNXT Platform utilizes Nobel Prize winning "Modern Portfolio Theory" techniques to create optimal portfolios for each client. Modern Portfolio Theory seeks to optimize expected portfolio returns for specific levels of risk. The technique is referred to as Mean Variance Optimization (MVO) and it requires a series of highly complicated calculations in which all possible combinations of the potential asset classes are evaluated to determine the optimal blend of allocations for each individual client. AdvisorNXT selects low-cost, well-managed exchange traded funds (ETFs) and exchange traded notes (ETNs) that represent the asset classes that we believe will provide our clients the necessary risk-adjusted exposure given current market conditions. In order to determine a client’s risk tolerance, a prospective client answers a series of objective questions posed in the form of an interactive interview. Once a client’s risk tolerance is determined, the AdvisorNXT algorithm will utilize Modern Portfolio Theory to create an optimized allocation across a diverse selection of asset classes, thus tailoring a portfolio to a client’s specific investment objectives and risk tolerance. The AdvisorNXT program will continuously monitor client accounts and periodically adjust portfolios to address changes in market and economic conditions. Envestnet Siebert offers its clients access to investment managers and advisory services of Envestnet Asset Management, Inc. Envestnet is registered with the SEC as an investment advisor and provides investment advisory services, technology services, and products to our advisory clients. Upon contracting to an Investment Strategy Proposal, clients grant full discretionary authority to Envestnet to determine the securities to be bought and sold, and the amount and time of those transactions. When creating a proposal for a client, Siebert uses Envestnet’s Asset Managers and clients grant full trading discretion to the money manager. Upon beginning an advisory relationship and/or with subsequent amendments to Envestnet’s Brochure, you will also receive Envestnet’s updated Brochure. While the portfolio managers offered through Envestnet’s Asset Managers may act on a discretionary basis, clients may at any time place restrictions on certain types of investments, certain asset managers, or other restrictions. Siebert may, at its own discretion, terminate an advisory relationship if it determines that a clients’ restrictions are not feasible through the advisory platform and/or prohibitive based on the services offered. FMAX Platform The FMAX Platform provides access to a wide range of investment strategies ("Strategies") provided by professional investment managers ("Investment Managers"), including FIWA ("Fidelity Institutional Wealth Adviser LLC"). Investment Managers may be affiliated or unaffiliated with FIWA or the Intermediary. FIWA has contracted with Investment Managers to provide these Strategies to the Intermediary for use with Your Program Assets. The FMAX Platform also provides access to a wide range of actively managed, passively managed, and liquid alternative mutual funds and ETPs (mutual funds and ETPs, when discussed together, are hereinafter referred to as "Funds") that are managed by the Investment Managers. Covered Call Transition Strategy The Covered Call Transition Strategy is designed for investors seeking a systematic approach to selling equity holdings in a legacy portfolio that no longer aligns with their current investment objectives. We offer the strategy through First Trust Advisor LP. A legacy portfolio may result from an inheritance, a shift in investment strategy, or price appreciation over time. This strategy provides a disciplined framework for liquidating existing equity positions at a price above the current market value while generating additional income through call option premiums. Investors can customize key parameters, including income targets, call-strike prices, and transition timelines. By selling call options on existing equity holdings, investors receive premium income, participate in potential price appreciation up to the call strike price, and continue to collect any dividends. Page 4 of 22  The call premium serves as a source of income and a potential buffer against stock price declines. Clients that embrace this strategy will be enabling the portfolio manager (First Trust Advisor LP) to act on a discretionary basis. Given the fact that this strategy is somewhat more sophisticated, complex, and utilizes derivatives in the form of options; the strategy is only available to clients that demonstrate the ability to incur larger than typical risks and possess significant investment knowledge that enables them to understand the offering. Fees and Compensation Our annual fees for Investment Supervisory Services are based upon a percentage of assets under management and generally range from .25% to 2.5%. Fees are based on total assets under management, which include cash balances. licensed as insurance agents or brokers. These individuals are able to implement Limited Negotiability of Advisory Fees: Siebert.NXT has established the aforementioned fee schedule(s). We retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, and reports, among other factors. The specific annual fee schedule is identified in the Investment Management Agreement (IMA) between the adviser and each client. Investment Advisory Representatives ("IARs") may, in their separate capacity, be licensed as registered representatives of Muriel Siebert & Co., LLC an affiliated broker-dealer and/or investment recommendations for clients for separate and typical compensation (i.e., commissions, 12b-1 fees or other sales- related forms of compensation). This presents a conflict of interest to the extent that these individuals recommend that a client invest in a security which results in a commission being paid to the individuals. Siebert.NXT does not charge advisory fees in addition to commissions or mark-ups when one of its IARs sells securities products through Muriel Siebert & Co., LLC. Clients are not under any obligation to engage these individuals when considering implementation of advisory recommendations and clients have the option to purchase investment products that our IARs recommend through other brokers or agents that are not affiliated with us. The implementation of any or all recommendations is solely at the discretion of the client. The annual fee includes all brokerage commissions, transaction fees, and other related costs and expenses except those inherent in a particular investment vehicle. The annual investment advisory fee is prorated and charged quarterly, in advance. Depending on the vendor, the calculation may be based on the average daily balance of the previous quarter, or the calculation may be based on the balance on the last day in the quarter. Calculations may include cash balances. AdvisorNXT may change the fee at any time by giving 30 days’ prior written notice. , based upon the total value of the assets under management as of the last day of the previous quarter, including cash balances. AdvisorNXT may change the fee at any time by giving 30 days’ prior written notice. Additional Fees and Expenses The advisory fees may not cover fees and charges in connection with debit balances; margin interest, odd-lot differentials, IRA fees, transfer taxes, exchange fees, wire transfers, extensions, non-sufficient funds, mailgrams, legal transfers, bank wires, postage, costs associated with exchanging foreign currencies, and SEC fees or other fees or taxes required by law. The Firm may engage in relationships with sub-advisers under which the Firm may receive fees. To mitigate potential conflicts of interest, the Firm will seek to waive any fees that may otherwise be passed on to customers, so that customers are not charged twice for the same services. AdvisorNXT offers you a dedicated Investment Advisor for support and guidance with your investments. General AdvisorNXT Management Fee Program Page 5 of 22  The AdvisorNXT program is a wrap fee program sponsored by Siebert. This portion of the Wrap Fee Brochure describes the business of Siebert as it relates to clients receiving services through the AdvisorNXT Program. Certain sections also describe the activities of the Firm’s Supervised Persons, which refer to any officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or other persons who provide investment advice on behalf of AdvisorNXT. The Program includes discretionary investment advice offered by AdvisorNXT through its Premier platform. AdvisorNXT Premier offers access to an assigned, dedicated, qualified Investment Advisor Representative who will interact with the client on a regular basis and will be responsible for managing clients’ investment needs. The fee for Premier Service is negotiated between the client and adviser and will fall between .25% and 2.50%. The annual fee includes all brokerage commissions, transaction fees, and other related costs and expenses except those inherent in a particular investment vehicle. However, they may not cover fees and charges in connection with debit balances; margin interest, odd-lot differentials, IRA fees, transfer taxes, exchange fees, wire transfers, extensions, non-sufficient funds, mailgrams, legal transfers, bank wires, postage, costs associated with exchanging foreign currencies, and SEC fees or other fees or taxes required by law. Though the firm attempts to waive most of these charges, there could be occasions where they are charged. The annual investment advisory fee is prorated and charged quarterly, in advance, based upon the total of the assets under management as of the last day of the previous quarter, including cash balances. AdvisorNXT may change the fee at any time by giving 30 days’ prior written notice. Fees for Management during Partial Quarters of Service Investment Advisory Fees for the initial period or the first quarter of service are calculated on a pro rata basis from the inception date of the account to the end of the first quarter. The Agreement between the Firm and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. The Firm’s fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. Fees Charged by Financial Institutions The Firm generally recommends that clients utilize the brokerage and clearing services of either National Financial Services LLC (“NFS”) or Muriel Siebert & Co., LLC for investment management accounts. The Firm may only implement its investment management recommendations after the client has arranged for and furnished all information and authorization regarding accounts with appropriate financial institutions. Financial institutions include, but are not limited to, NFS or any other broker dealer recommended by Siebert, broker-dealer directed by the client, trust companies, banks, etc. (collectively referred to herein as the “Financial Institutions”). Siebert.NXT and/or its advisers may be compensated or receive incentives from our clearing firms for assets under management, which may pose a conflict of interest. This type of compensation may provide an incentive to recommend investment products based on compensation received rather than clients’ needs. However, the Firm has a stringent review process to ensure that client needs are the priority in transactions and that the clients’ best interests are considered when making any recommendations. Siebert.NXT or its affiliates may receive compensation in connection with the purchase and/or ongoing maintenance of positions in certain mutual funds in your account. This compensation may take the form of the receipt of 12b-1 fees or other revenue sharing payments. Such fees and revenue would be paid to Muriel Siebert & Co., LLC. 12b-1 fees are considered to be an operational expense and as such is included in a funds expense ratio. It is generally between 0.25 and 1% of a fund’s net assets. For additional information on mutual fund payments and compensation practices, review the applicable prospectus or offering statements. Such fees may create a conflict of interest because many mutual funds offer a variety of share classes, including some that pay 12b-1 fees and others that do not. When Page 6 of 22  there is a lower cost share class available that does not charge a 12b-1 fee or charges a lower 12b-1 fee it may be in the best interest for the client to invest in the lower cost alternative share class so as to not reduce investment returns. The Siebert.NXT platform does not participate in any 12b-1 fees or any revenue sharing arrangements. Siebert also offers its clients access to investment managers and advisory services through Envestnet, a Sub-Advisor. Envestnet has developed a method of screening and selecting mutual funds by performance and risk characteristics, asset class, minimum fund size, inception date, manager tenure, load fees and security holdings. Envestnet will pass to Siebert all 12b-1 fees or other revenue sharing that it may receive. Brokerage Fees and Commissions As described above, clients do not pay brokerage commissions or other fees to their Custodian in connection with the AdvisorNXT Program. The Custodian may, however, receive other revenues in connection with the Wealth Management Program. Brokerage arrangements are further described below. In addition, you may incur charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, step-out fees, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap fee you are charged by the Firm. Account Additions and Withdrawals Clients make additions to and withdrawals from their account at any time, subject to the Firm’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to AdvisorNXT, subject to the usual and customary securities settlement procedures. However, AdvisorNXT designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a client’s investment objectives. AdvisorNXT may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fess assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. Envestnet Siebert offers wrap fee programs through Envestnet. There are no differences in how we manage the wrap fee services and other accounts. Siebert may receive a portion of the wrap fee for our services. Compensation Siebert’s standard advisory fees are negotiated at the time of account opening. Siebert’s management fees, inclusive of platform and advisor fees, and typically will not exceed 3% of assets under management. When an Envestnet advisor is selected, Siebert receives a portion of the fee charged to the client while Envestnet receives a platform and advisory fee. All fees are negotiated at the time of the contract. The fee will be stated in the client’s agreement. Fees are payable quarterly, on the first business day of the quarter. Lower fees for comparable services may be available from other sources. Forms of Payment Client authorizes Advisor to bill the Custodian and authorizes the Custodian to pay Advisor directly the fees described above. The Custodian has agreed to send to Client at least quarterly a statement indicating all amounts disbursed from the Account, including the amount of fees paid directly to Advisor. Page 7 of 22  Other Fees and Expenses Siebert may charge other fees for services not included in the advisory relationship such as wire fees, transfer fees, and other administrative fees, as described in more detail throughout this brochure. What is a “Wrap Fee” Program? A wrap fee program allows our clients to pay a specified fee for investment advisory services and the execution of transactions. The advisory services include portfolio management, and the fee is not based directly upon transactions in the account. The fee is bundled with the Firm’s costs for executing transactions in the account(s). This results in a higher advisory fee to clients. We do not charge our clients higher advisory fees based on their trading activity, but clients should be aware that we may have an incentive to limit our trading activities in account(s) because we are charged for executed trades. By participating in a wrap fee program, clients may end up paying more or less than they would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to them by the executing broker. Portfolio Management For services provided by Siebert, Investment Advisory Fees are on a negotiated basis and are paid quarterly in advance on the last day of the previous quarter end pursuant to the terms of the Investment Advisory Agreement. Investment Advisory Fees are based on the market value of the assets under management at the end of each calendar quarter and the fees are negotiated with the client. Lower fees for comparable services are available from other sources. The Investment Advisory Fee schedule is the starting point for the client to negotiate from and typically is as follows: 2.0% on the first $500,000 1.50% on the next $500,000 1.25% on the next $1,000,000 1.00% on the next $3,000,000 0.75% on assets in excess of $5,000,000. Investment Advisory Fees are negotiated with the Client The Fee Schedule above is the starting point of the negotiation. As such, Siebert negotiates fees with the client(s) and may charge a lesser or greater management fee than is what is listed in the Fee Schedule immediately above. Clients provide written authorization either as part of the Investment Advisory Agreement, or separately, permitting Siebert, the independent manager or third-party manager provider or their custodian to deduct Siebert and client’s manager’s fees directly from the client’s account and remit to the respective parties. Investment Advisory Fees can also be paid by check. The amount due is calculated by applying the quarterly rate to the total assets under management with Siebert at the end of the prior quarter. The Client’s fees will take into consideration the aggregate assets under management with the advisor. Any Investment Advisory Fee deducted from the clients’ account will appear on the clients’ account statement from NFS, Muriel Siebert & Co., LLC or other custodian. In addition, at the client’s request, Siebert will provide the client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. It is the responsibility of the client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Fees for Management during Partial Quarters of Service Page 8 of 22  Investment Advisory Fees for the initial period or the first quarter of service are calculated on a pro rata basis from the inception date of the account after the inception of a quarter, the fee payable with respect to such assets may be adjusted on a pro rata basis for deposits and/or withdrawals occurring within such quarter and will be calculated in accordance with the advisory agreement based on the days remaining in the quarter. The agreement between Siebert and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. Siebert’s fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. Clients may make additions to and withdrawals from their account on notice to Siebert subject to the usual and customary securities settlement procedures, and subject to Siebert’s right to terminate the account. Additions may be in cash or securities provided that Siebert reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Siebert designs certain of its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Siebert may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. Siebert prohibits clients from self-directing trading in their managed accounts. Fees Charged by Financial Institutions As further discussed in response to Item 9 below, Siebert generally recommends that clients utilize the brokerage and clearing services of National Financial Services LLC (“NFS”) or Muriel Siebert & Co., LLC for investment management accounts. Siebert may only implement its investment management recommendations after the client has arranged for and furnished Siebert with all information and authorization regarding accounts with appropriate financial institutions. Financial institutions include, but are not limited to, NFS, Muriel Siebert & Co., LLC, or any other broker dealer recommended by Siebert, broker dealer directed by the client, trust companies, banks, etc. (collectively referred to herein as the “Financial Institutions”). Clients may incur certain charges imposed by the Financial Institutions and other third parties such as fees charged by Independent Managers, custodial fees, charges imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfers and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee programs, clients may incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to Siebert’s fee. In addition to the transactional charges described above, clients may also pay the following separately incurred expenses, which we do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). Clients should review the ADV brochures of any third-party managers for details about any additional fees they charge. Performance-Based Fees and Side-By-Side Management Siebert does not have any performance-based fee arrangements. “Side by Side Management” refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time manages other accounts for which fees are assessed on a performance fee basis. Because Siebert has no performance-based fee accounts, it has no side-by-side management. Page 9 of 22  Item 5 - Types of Clients AdvisorNXT The Firm generally provides investment advice to individuals, high net worth individuals, families, trusts, corporations and business entities. Siebert generally imposes no minimum account size. Envestnet, FMAX, & Independent Managers Siebert provides advisory services to individuals, high net worth individuals, charitable organizations, corporations, trusts and business entities. When providing managed investment advisory account services, the fee and minimum account size is established by the Independent Third-Party Manager selected through the Envestnet Platform. Certain independent managers may impose more restrictive account requirements and varying bill practices than Siebert, and the firm does not have control over these requirements. In such instances, Siebert may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 6 - Methods of Analysis, Investment Strategies, Risk of Loss AdvisorNXT AdvisorNXT acts as the sponsor and sole portfolio manager of the AdvisorNXT Program. Clients’ investment portfolios are managed directly by AdvisorNXT on a discretionary basis. As AdvisorNXT is the sole portfolio manager, a conflict of interest exists because AdvisorNXT receives the entire management fee and therefore has an incentive to manage the client’s entire portfolio rather than utilize the services of one or more sub-advisors. AdvisorNXT however, believes it can provide overall portfolio management services at a lower price than if it were to utilize the services of one or more sub-advisors. As described above, AdvisorNXT develops optimized portfolios using Modern Portfolio Theory that are used as the basis for implementing a client’s investment plan and in accordance with the client’s risk tolerance. The portfolios include investment in exchange traded funds and exchange traded notes. The accounts of Siebert.NXT are supervised by a qualified individual who is a designated supervisory principal of the Firm. These reviews include oversight of investment management, operational policies and procedures, and an overall review of advisory operations. Clients may impose reasonable restrictions or mandates on the management of their accounts if we determine, in our sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to the Firm’s management efforts. Envestnet & Independent Managers Upon contracting to an investment strategy proposal that includes account management through Envestnet, clients grant full discretionary authority to Envestnet to determine the securities to be bought and sold, and the amount and time of those transactions. Page 10 of 22  To ensure that we are at all times and in all circumstances acting strictly in the best interests of our clients, and to the highest fiduciary standards, our policy requires that, if we allow a Siebert representative to act with discretion, he or she may under no circumstances purchase securities for their own or related accounts within sixty business days before or after recommending to, or purchasing or selling for, the same security or related security (i.e., convertible bond, option, preferred shares) to any client. A Siebert Investment Advisor Representative can act in the capacity of a portfolio manager. Additional determinations as to securities to be bought or sold, and amount of securities to be bought or sold, whether by the account advisor or by a money manager to whom the advisor has referred the account, are required to be in accordance with the client’s stated investment objectives and profile. The determinations will be made only in the expectation of furthering the Investment Strategy agreed upon in writing by the client at the outset of the Advisory relationship, or as subsequently modified by the client. Siebert recommends managed account services and Money Managers to advisory clients. These outside managers are registered brokers, and due diligence has been exercised by the sponsor or by Siebert as the advisory firm. A recommended Manager is subject to review and approval by the client. At no time and under no circumstances is the client under any obligation to have any requirement to accept a recommended program or manager. The selection and evaluation of advisory firms by Siebert encompasses several factors. The most significant include the range and quality of managers available, technical support, level of due diligence performed and made known to Siebert, reasonableness of fees, and a satisfactory commitment to safeguarding the privacy of our clients. Siebert may employ various investment evaluation strategies to select Managers and/or sub- advisors. Siebert provides clients with portfolios from one sub-advisor: Brinker Capital, Inc. Siebert does not plan to add more accounts to this sub-advisor. When considering a new Independent Manager and/or evaluating an existing Manager or sub- advisor, the methods of analysis utilized will be quantitative and qualitative in nature and may vary by each strategy and manager for funds managed. Siebert typically seeks investment managers that it believes will deliver attractive risk adjusted returns over the investment horizon based on a quantitative and qualitative assessment of the manager’s track record, investment strategy, and trading and investing methodology. Siebert may perform qualitative peer analysis comparisons of each manager and also perform quantitative analysis including optimization analysis to build a portfolio of various managers and instruments. Qualitative analysis of Managers and strategies are inherently subjective. There is no guarantee that the advisor would be correct in assessing the attributes of a manager or strategy going forward. Qualitative analysis is largely dependent on past results and assumes that past results and relationships (i.e. correlations between managers, etc.) are indicative of future relationships. This would be the case if a manager changes their investment philosophy over time. Siebert generally seeks diversification in the types of securities managers selected for investment. Certain investments may be illiquid and/or not have a ready market to sell. Please refer to the Form ADV of the Independent Managers for additional information. All clients should be aware that investing involves certain risks, including: Risk of Loss: Past performance is not indicative of future results. Therefore, current and prospective clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, bonds, and pooled investment vehicles) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss including loss of original principal. We do not represent to any client, either directly or indirectly, any level of performance or any representation that Page 11 of 22  our professional services will not result in a loss of the Client’s invested assets. We do our very best as an investment advisor to manage risk exposures and to prevent losses; however, losses cannot be prevented in all cases. Below are certain additional risks associated when investing in securities through our investment management program(s). Risks Associated with Certain Investments Used in the Products: It is important to remember that all investments carry at least some degree of risk. Risk may include loss of some, or even all, of your investment. No particular type of investment, or approach to investing, is guaranteed to perform well, and there may be other investment vehicles, portfolio managers or approaches not offered by Siebert that may perform as well or better. You should consider these factors carefully before deciding to invest and be prepared to bear losses. Stocks generally fluctuate in value more than bonds and may decline significantly over short time periods. There is the chance that stock prices overall will decline because stock markets tend to move in cycles, with periods of rising and falling prices. The value of a stock may decline due to general weakness in the stock market or because of factors that affect a company in a particular industry. Management Risk: Siebert investment products are subject to management risk because each account is an actively managed portfolio. Market Risk: Profitability of a portion of Siebert’s recommendations may depend to a great extent upon correctly assessing the future course of price movements of stocks. There can be no assurance that Siebert will be able to predict those price movements accurately. The prices of the securities and securities products in which Siebert may invest and strategies each may recommend may decline for a number of reasons including in response to economic developments, factors relating to the company, and market activity. Adjustable Rate and Floating Rate Securities Risks: Although adjustable and floating rate debt securities tend to be less volatile than fixed-rate debt securities, they nevertheless fluctuate in value. Alternative Investments and Derivatives: Certain mutual funds used in products may invest in alternative investment strategies or derivatives that are often more volatile than other investments and may magnify the vehicle’s gains and losses. A derivative is a security or contract (futures, options, etc.) the value of which fluctuates with the value of another security (i.e., its value is “derived” from the value of another). An investment vehicle that uses derivatives could be negatively affected if the change in market value of its securities fails to correspond as expected to the underlying securities. Alternative investment products are not for everyone and entail risks that are different from more traditional investments. Alternative investment strategies are intended for sophisticated investors and involve a high degree of risk, including, among other things, the risks inherent in investing in securities and derivatives, using leverage, and engaging in short sales. An investment in an alternative investment product or strategy may be considered speculative and should not constitute a complete investment program. Diversification and strategic asset allocation do not assure a profit or protect against loss in declining markets. The potential for a commodity investment vehicle to use derivative instruments, such as futures, options, and swap agreements, to achieve its investment objectives may create additional risks that would not be present in the underlying securities themselves, thus raising the potential for greater investment loss. Concentration Risk: Portfolios that invest a significant portion of assets in a small or limited number of securities, a single specific or closely related sectors, industries, a specific region or country, may involve greater risks, including greater potential for volatility, than more diversified portfolios. The value of these holdings will vary considerably in response to changes in the market value of the securities that represent these sectors, industries, or regions. Covered Calls: Mutual funds that engage in selling (or writing) of covered calls may involve a high degree of risk and may not be suitable for all investors. For a call option that is sold (written), if that option is exercised, the upside potential is limited to the premium received plus the difference between its stock price and the stock purchase price. If the option is not exercised and expires out-of-the-money and with no value, the upside potential is any gain in Page 12 of 22  share value plus the premium received. On the downside, limited protection is provided by the premium received from the call’s sale. The loss potential may be substantial and is limited only by the stock declining to zero. Investors should read and understand the risks associated with options prior to engaging in any covered call strategy. These risks are more fully described in the booklet entitled “The Characteristics & Risks of Standardized Options,” which can be accessed at www.optionsclearing.com. Credit Risk: The issuers of the bonds and other debt securities held in products offered through Siebert may not be able to make interest or principal payments. Currency Risk: If invested in non-U.S. securities, Siebert products are subject to the risk that foreign currencies will decline in value relative to the U.S. dollar, or, in the case of hedging positions, that the U.S. dollar will decline in value relative to the currency being hedged. Exchange-Traded Notes: Exchange-traded notes are a type of senior, unsecured, unsubordinated debt security of the issuing company. This type of debt security differs from other types of bonds and notes because ETN returns are generally based upon the performance of a market index minus applicable fees, no periodic coupon payments are distributed, and no principal protection exists. Similar to ETFs, ETNs are generally traded on a securities exchange. Investors can also hold the debt security until maturity. At that time, the issuer is obligated to give the investor a cash amount that would be equal to the principal amount times the applicable index factor less investor fees. The index factor on any given day is a mathematical equation equal to the closing value of the underlying index on that day divided by the initial index level. ETNs are subject to credit risk and liquidity risk that impact the price received upon disposition of the notes. Additional risks of investing in ETNs include limited portfolio diversification, price fluctuations, issuer default, uncertain principal repayment, and uncertain federal income tax treatment. The performance of the ETNs may vary from the actual performance of the underlying index and the performance of the underlying index components. By investing in ETNs, the owner does not have certain rights that investors in the underlying index or the underlying index components may have, such as stock voting rights. Foreign Securities Risks: Siebert clients may invest a significant portion of assets in securities of foreign issuers denominated in U.S. dollars, including issuers in emerging markets. Foreign economies may differ from domestic companies in the same industry. Foreign economies may differ from domestic companies in the same industry. Investment in emerging markets involves additional risks, including less social, political and economic stability, smaller securities markets involve additional risks, including less social, political and economic stability, smaller securities markets and lower trading volume, restrictive national policies and less developed legal structures. Foreign Securities and Emerging Markets Risk: The value of foreign investments offered through Siebert may be adversely affected by changes in the foreign country’s exchange rates, political and social instability, changes in economic or taxation policies, decreased liquidity and increased volatility. Foreign companies may be subject to less regulation than U.S. companies. Investment in emerging markets involves additional risks, including less social, political and economic stability, smaller securities markets and lower trading volume, restrictive national policies and less developed legal structures. General Risk of Loss: Investing in securities involves the risk of loss. Clients should be prepared to bear such losses. Gold: Approved Siebert clients may invest in ETFs that invest in gold bullion. Several factors affect the price of gold including the global supply and demand; global or regional political, economic or financial events and situations; investors’ expectations with respect to the rate of inflation; currency exchange rates and interest rates. There is no assurance that gold will maintain its long-term value in terms of purchasing power in the future. The price of gold has fluctuated widely over the past several years and may experience significant volatility. Government-Sponsored Entities Risk: Approved Siebert clients may invest in securities issued or guaranteed by government-sponsored entities, including GNMA, FNMA and FHLMC. However, these securities may not be guaranteed or insured by the U.S. Government and may only be supported by the credit of the issuing agency. Page 13 of 22  Interest Rate Risk: In general, the value of bonds and other debt securities falls when interest rates rise. Longer- term obligations are usually more sensitive to interest rate changes than shorter-term obligations. Liquidity Risk: Low or lack of trading volume may make it difficult to sell securities held in the PIPs product at quoted market prices. Long/Short Positions: Investment vehicles, such as mutual funds and ETFs, used in the Strategies may employ the use of long and short positions, which may involve risks different from those normally associated with other types of investment vehicles. It is possible that the fund’s long positions will decline in value at the same time that the value of the securities sold short increases, thus raising the potential for greater investment loss. Market neutral investing, in using long and short positions, provides no guarantee that it will be successful in limiting the fund’s exposure to domestic stock market movements, capitalization, sector swings or other risk factors. Investment in a strategy involved in long and short selling may have higher portfolio turnover rates, which may result in additional tax consequences. Short selling involves certain risks, including additional costs associated covering short positions and a possibility of unlimited loss on certain short sale positions. Mutual Funds and ETFs: An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event, they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholder fees (e.g., sales loads, purchase fees, redemption fees). The per-share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges are transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for index-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Portfolio Turnover Risk: A high portfolio turnover rate (100% or more) has the potential to result in the realization and distribution to shareholders of higher capital gains, which may subject you to a higher tax liability. A high portfolio turnover rate also leads to higher transaction costs. REITs: Issuer risk investments in REITs are subject to many of the risks associated with direct real estate ownership and, as such, may be adversely affected by declines in real estate values and general and local economic conditions. Risks Associated with High Yield Securities: Approved Siebert clients may invest in high yield securities. Securities with ratings lower than BBB or Baa are known as “high yield” securities (sometimes referred to as “junk bonds”). High yield securities provide the potential for greater income and opportunity for gains than higher rated securities but entail greater risk of loss of principal. Risks Associated with Inflation and Deflation: Inflation risk is the risk that the rising cost of living may erode the purchasing power of an investment over time. Deflation risk is the risk that prices throughout the economy decline over time – the opposite of inflation. Page 14 of 22  Risks Associated with Mortgage-Backed Securities: These include Market Risk, Interest Rate Risk, Credit Risk, Prepayment Risk as well as the risk that the structure of certain mortgage- backed securities may make their reaction to interest rates and other factors difficult to predict, making their prices very volatile. In particular, the recent events related to the U.S. housing market have had a severe negative impact on the value of some mortgage-backed securities and resulted in an increased risk associated with investments in the securities. Small- and/or Mid-Cap Issuer Risk: Small and midsize companies carry additional risks because the operating histories of these companies tend to be more limited, their earnings and revenues less predictable (and some companies may be experiencing significant losses), and their share prices more volatile than those of larger, more established companies, which can adversely affect the pricing of these securities. These companies may have limited product lines, markets or financial resources, or may depend on a limited management group. Some investments will rise, and fall based on investor perception rather than economic factors. Other investments are made in anticipation of future products, services or events whose delay or cancellation could cause the stock price to drop. Use of Independent Managers: Siebert may recommend the use of Independent Managers for certain clients, but such recommendations rely, to a great extent, on the Independent Manager(s) ability to successfully implement their investment strategy. In addition, Siebert does not have the ability to supervise the Independent Managers on a day-to-day basis. Material Risks: Investing in securities involves the risks of loss of principal as well as opportunity cost in other investments. Clients should ensure that they can bear these risks prior to investing with an investment advisor representative and understand their particular risks based on the proposal that will be provided at account opening. As with all forms of analysis, technical and fundamental analyses provided may have different interpretations and estimates used in preparation. Specific risks include fund-specific risks, risks of lack of diversification, and market risk. Clients should fully understand their proposal and review its appropriateness to their particular risk profile prior to entering into any agreement with Siebert. Security Specific Risk: Siebert does not promote any specific security type to advised clients. Securities selected for investment will depend on a variety of factors, including, among others, the client’s unique needs, objectives, financial status, as well as market conditions. Selections are made in accordance with the specific plan chosen by the client and verified by contract. The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in any or all of the strategies managed by Siebert. Prospective clients should read this entire Form ADV and all accompanying materials provided by Siebert before deciding whether to invest with us. In addition, as our investment philosophy develops and changes over time, an investment with Siebert may be subject to additional and different risk factors. Siebert will promptly amend this Brochure if and when any information regarding its investment risks becomes materially inaccurate. Voting of Client Securities Siebert reserves the authority to vote clients’ securities (i.e., proxies) on their behalf. Clients generally receive proxies directly from their custodian and may contact Siebert with any questions by calling the number on the cover of this Wrap Fee Brochure. Page 15 of 22  Item 7 - Client Information Provided to Portfolio Managers AdvisorNXT, as the portfolio manager for the Program, encourages clients to promptly notify the Firm if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. When utilizing the Envestnet Platform and Independent Managers, all information that is disclosed to Siebert gets passed through to the Third-Party Independent Manager, who has full discretionary authority. Item 8 - Client Contact with Portfolio Managers AdvisorNXT as portfolio manager communicates with clients in the Premier services as needed through a designated investment advisor representative to ensure your most current investment goals and objectives are understood and reflected in your portfolio. In most cases, we will communicate such information as part of our regular investment management meetings. Clients of the AdvisorNXT Personal Program are not offered the opportunity to interact directly with a designated Representative. If utilizing a Third-Party Manager through the Envestnet Platform, the client will have an assigned Siebert investment representative who they will interact with. The Siebert representative will in turn deal with the Third-Party Manager on the client’s behalf. Item 9 - Additional Information The Custodian and Brokers We Use The Firm’s Agreement and/or the separate agreement with any Financial Institution may authorize Siebert through such Financial Institution to debit the client’s account for the amount of Siebert’s fee and to directly remit that management fee to Siebert in accordance with applicable custody rules. In order to use our services, you must establish a custodial account with Muriel Siebert & Co., LLC or NFS. The Advisor has not and will not seek to add or change a custodian without the clients’ prior approval. You will generally receive custodian account statements about portfolio holdings at least quarterly directly from the custodian that maintains your funds and securities. You are encouraged to carefully review the custodial account statements you receive from the custodian and promptly report any errors or omissions to the custodian at the number listed on the account statement and to Siebert. You may contact Siebert Client Services by calling (212) 644- 2400 during regular business hours. It is Siebert’s policy that it does not advise, initiate or take any other action on your behalf relating to securities held in accounts managed by Siebert in any legal proceeding (including, without limitation, class actions, class action settlements and bankruptcies). Siebert may not file proofs of claim relating to securities held in your account and does not notify you or your custodian of class action settlements or bankruptcies relating in any way to such account. You should consult with your custodian and other service providers to ensure such coverage. Your Custody and Brokerage Costs. Siebert.NXT is a wrap fee program. As such, AdvisorNXT does not charge a commission. This creates an inherent conflict of interest for the Firm because the Firm incurs transaction fees in the purchase and sale of Page 16 of 22  securities, incentivizing us to limit the amount of transactions we enter into without charging commission. However, as a fiduciary, the Firm is obligated and dedicated to act to the highest fiduciary standards and in the client’s best interest, regardless of the cost to the Firm. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, if any, execution capability, commission rates, and responsiveness. Siebert seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Siebert periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. The client may not direct Siebert in writing to use a particular Financial Institution to execute some or all transactions for the client. Transactions for each client generally will be affected independently, unless Siebert decides to purchase or sell the same securities for several clients at approximately the same time. Siebert may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among Siebert’s client’s differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will generally be averaged as to price and allocated among Siebert’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that Siebert determines to aggregate client orders for the purchase or sale of securities, including securities in which Siebert’s Supervised Persons may invest, Siebert generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Siebert does not receive any additional compensation or remuneration as a result of the aggregation. In the event that Siebert determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, AdvisorNXT may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Disciplinary Information Siebert is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of management. Siebert does not have any disciplinary information to disclose at this time. Additional information about Siebert.NXT is available on the SEC’s website at www.adviserinfo.sec.gov. Other Financial Activities and Affiliations Siebert is required to disclose any relationship or arrangement that is material to its advisory business or to its clients with certain related persons. Siebert has disclosed such information below. Siebert is not a registered broker dealer, but its management persons and staff are registered as either Registered Representatives, Principals and/or Officers Page 17 of 22  with one or more of its affiliate broker dealers as listed below. Siebert is not a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing. Affiliates of Siebert may refer Consultants, Co-Sponsors, or Sub-Advisors to Siebert.NXT. The firm shall make an independent determination as to whether to do business with such entities. Affiliates of Siebert may also have business arrangements with Consultants, Co-Sponsors, Custodians or Sub-Advisors that may indirectly benefit from such entities’ business with Siebert. Siebert does not receive any additional compensation from third party advisors. Muriel Siebert & Co. is an affiliated broker dealer of the publicly held corporation Siebert Financial Corp., which is also the parent company of Siebert.NXT. Financial Industry Affiliations Muriel Siebert & Co. LLC (CRD #5376) is an affiliate broker dealer that has been registered since August 8, 1969. Siebert.NXT executes transactions through Muriel Siebert & Co., LLC under a wrap fee structure. No conflict of interest exists because the broker dealer is not charging any related fees. Peter Sosnowski is Sr. Vice President, Retail Division, at Muriel Siebert & Co., LLC, the affiliated broker dealer of the public holding company Siebert Financial Corporation. Siebert has Management, Financial Advisors, Supervised Persons and Staff that are Registered Representatives, Staff and Management of Muriel Siebert & Co. LLC. Both Siebert and Muriel Siebert & Co., LLC are wholly owned subsidiaries of Siebert Financial Corporation. Barbara Villella is Chief Compliance Officer and AMLCO of both Muriel Siebert & Co., LLC and Siebert.NXT. Siebert Advisor NXT is also affiliated with Park Wilshire Companies, Inc. through ownership. Siebert.NXT has no business interaction with either entity. Siebert Financial Corporation is a public holding company traded on NASDAQ under the symbol SIEB. Material conflicts of interest related to compensation may exist. To remedy the potential conflicts, Peter Sosnowski and Muriel Siebert & Co., LLC do not receive financial compensation based upon the AdvisorNXT business. Custodians The Firm contracts with two custodians, NFS and Muriel Siebert & Co., LLC. NFS is not an affiliate of Siebert. NFS custodies client assets and performs administrative account services, including issuing statements to the clients. Peter Sosnowski is affiliated with our broker-dealer, as noted above. Mark P. Malek, the CIO and Member of the Firm’s Investment Committee may receive a portion of the fees based upon the assets under management. Siebert Officers, Financial Adviser, Supervised Persons, Staff and/or family member(s) may invest with Siebert and may have their personal accounts at Muriel Siebert & Co., LLC, affiliate broker dealer. Though dual relationships may present a potential conflict of interest, Siebert employees are required to put the interest of all clients first. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading The Firm has adopted its Investment Advisory Compliance Program (the “Program”), pursuant to Rule 206(4)-7 under the Investment Advisors Act of 1940 (“Advisors Act”). Part of that program includes the adoption of written policies and procedures, which are incorporated within Siebert’s Compliance Manual. Page 18 of 22  Code of Ethics and Personal Trading The Firm has adopted a Code of Ethics (“Code”) and provides a copy to any clients and prospective clients upon request. The Code sets out our standard of conduct of investment advisory personnel. The Firm’s employees are required to abide by the Code of Ethics and Siebert’s overall Compliance Program, which is amended periodically to reflect additional policies and/or changes in regulations. The Firm expects each of its employees, financial advisors and management (collectively referred to as, “Employees”) to conduct themselves with integrity, honesty and professionalism. Prohibitions to certain practices such as hot issues and insider trading, protection of material nonpublic information and procedures for monitoring personal securities trading are addressed in the Code of Ethics. Equity and option orders are processed through order management systems. Trades are reviewed by a designated registered representative including, among other important items, adherence to order- handling rules, and to detect prohibited trading practices including trading ahead, painting the tape, acting in concert, and trade shredding. The Compliance Department and supervisory principals review all employee and related trades and account activity. Our market making desk is physically isolated from the source of retail orders. We internalize a portion of our equity order flow, and when acting as principal on such transactions we may realize 100% of any profit or loss generated. Traders on the market making desk have no access to retail client account information, advance knowledge of orders accepted by sales representatives or the unsolicited order desk and receive orders without identifying account information. Siebert employees and related persons generally may have accounts, only through Siebert, with investment managers that Siebert recommends to clients as part of its advisory program. This means that Siebert employees or related persons may buy or sell securities that clients also own. Investment decisions by the independent investment managers for Siebert employees and related persons are without foreknowledge of the account ownership. The Firm and persons associated with the Firm (“Associated Persons”) are permitted to buy or sell securities that it also recommends to clients consistent with Siebert’s policies and procedures. The Firm’s Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material nonpublic information by Siebert or any of its associated persons. The Code of Ethics also requires that certain of the Firm’s personnel (called “Access Persons”) report their personal securities holdings and transactions and are prohibited from participating in initial public offerings of equity or equity related securities unless otherwise approved by the Compliance Department and/or the Investment Committee. Under certain circumstances, exceptions may be made to the policies stated herein. In order to monitor personal securities trading, Employees are required to follow reporting procedures including arrangement for the Compliance Department to receive duplicate monthly confirmations or account statements, which are reviewed by Siebert. The Firm provides each Employee with a copy of the Code of Ethics and any amendments thereto and obtains written acknowledgement of receipt of the Code of Ethics from each of the Employees on an annual basis. Violations of the Code of Ethics are required to be reported promptly to Siebert’s Chief Compliance Officer. The Firm (and its officers and employees) and certain Affiliates (and their respective officers and employees) may recommend to their respective clients’ investment vehicles in which Siebert, or such Affiliate has a financial interest by virtue of management fees associated with such investments. Certain control individuals and/or access persons may, subject to applicable compliance policies, invest in products alongside outside investors. The conflicts inherent in such an investment are mitigated in part due to the fact that investors are affected in proportion to their investment, including the control individuals. Typically, outside investors may gain comfort by the fact that a control person is also invested and as such is also affected by the gains and losses of such investment. Page 19 of 22  These rules and/or restrictions are designed to protect the Firm’s Clients. Officers and Employees are required to put the interest of the Clients first in all dealings relating to the Client and their investments. A copy of Siebert’s Code of Ethics will be made available to any client or prospective client upon request. Privacy Policy The Firm protects your personal information and has adopted a privacy policy. A copy of the Siebert privacy policy is provided to clients when the account is established, whether there is a change to the privacy policy, on an annual basis and upon request. The privacy policy can also be viewed on our website at www.siebert.com/disclosures. Business Continuity The Firm has adopted a business continuity plan which was developed by its affiliate broker dealer Muriel Siebert & Co., LLC. Siebert’s strategy is to maintain critical functions in the event of circumstances, which impact our physical plants, applications, data centers or networks. Siebert, through its affiliate has engaged in planning and process development to reduce risk in this area. You may request a copy of the business continuity statement by calling customer service at (212) 644-2400 Risk Management Review The accounts of Siebert.NXT are supervised by a qualified individual who is a designated supervisory principal of the Firm. Siebert conducts ongoing reviews of all managed investment advisory accounts. The designated principal is instructed to scrutinize account activity and status for (i) investment integrity, specifically defined as adherence to the client’s stated investment objective, (ii) performance, encompassing the success of the manager in achieving those objectives; (iii) value, a determination that the cost to the client on an advisory level is appropriate to the level of service received and activity generated, and that there is no indication that the client would be better served through a traditional non-advisory account, and that the account is not neglected by the Siebert advisor upon receipt of fees and assignment of the account to a money management plan. Risk management reviews by designated principles include daily reviews to measure drift/risk, weekly reviews measuring portfolio risk versus stated investment objectives, monthly reviews of funds, quarterly reviews of fees, as well as other routine reviews. Regulatory Best Interest Regulation Best Interest (Reg BI) requires broker-dealers to act in the best interest of their clients when making recommendations, while Registered Investment Advisers (RIAs) are held to a fiduciary standard, meaning they must always act in their client's best interest, encompassing both care and loyalty. Siebert AdvisorNxt Investment Advisors are also dually registered with our broker-dealer affiliate, Muriel Siebert LLC, which may potentially create a conflict of interest while servicing customers who maintain accounts with both entities. To manage these potential conflicts, activity in these accounts is routinely reviewed to ensure that it aligns with fiduciary standards and the clients’ best interest and not based on the fees or commissions received. Account Reviews Siebert monitors its clients’ investment management portfolios as part of an ongoing process. All investment advisory clients are encouraged to discuss their needs, goals and objectives with the firm and to keep Siebert informed of any changes thereto. The firm contacts ongoing investment advisory clients at least annually to review its previous services and recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. If a Third-Party Investment Manager is used, quarterly performance reviews are generated and will be available to corresponding clients. Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular monthly or Page 20 of 22  quarterly account statements directly from the broker dealer or custodian for the client accounts. Siebert may, from time to time, elect to provide clients with written quarterly performance reports generally sourced from or through the custodian. Such quarterly performance reports would be in addition to the custodian’s monthly or quarterly account statements. If there are any discrepancies between the quarterly performance reports and the custodian’s statements, clients should rely on the custodian’s statement, and any such discrepancies should be promptly reported to Siebert Client Service by calling (212) 644-2400 during regular business hours. Siebert may review accounts more frequently than the periodic reviews described in this Brochure. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. While there are no restrictions on a client’s ability to contact and consult with the Independent Manager personnel, it is generally preferred that it is accomplished through, or together with, the Siebert adviser. Margin and Advisory account considerations At Siebert.NXT, certain advisory programs may be eligible for margin lending purposes. Advisory accounts include discretionary and non-discretionary investment advisory programs for which you may be charged a fee based on the account value. Before using margin in conjunction with advisory accounts you should consider and be aware that: The cost of margin can exceed the returns on your account. • • All the general risks of margin also exist. • • Using margin to purchase additional securities in advisory programs will increase your asset-based fee. Fees are based on the market value of the securities in the advisory program and not on the net equity after consideration of the margin debit. In addition, you will be charged margin interest on the debit balance in your account. The increased asset-based fee that you pay may provide an incentive for your Financial Advisor to recommend the use of margin. Financial Advisors are compensated on asset-based fees and will benefit when you use margin in lieu of liquidating assets in advisory programs, which may create a conflict of interest. The following example illustrates the effect of margin on your asset-based fee: • Your account is valued at $100,000 and your asset-based fee is 2%. If you do not use margin to purchase securities, your fee will be $2,000 annually. If you elect to use margin to purchase additional securities valued at $50,000 so that your account has total securities valued at $150,000, your fee will be $3,000 annually even though the net account value remains at $100,000. Margin interest will also be assessed on your debit balance. Advisory programs are not designed for excessively traded or inactive accounts and may not be suitable for all investors. Please carefully review the Siebert.NXT advisory disclosure document for a full description of our services. For more information, see the Siebert Website. How your Financial Advisor and Siebert Advisor NXT Generally, the custodian of your assets is compensated for margin loans. The interest rate is subject to change without notice. Although Siebert Advisor NXT Advisors will not receive interest based on your outstanding balance, or debit, of your margin loan, we reserve the right to change compensation plans in the future without any prior notice to our clients. Further, our affiliated broker-dealer receives interest rate mark-ups when Siebert recommends margin loans in advisory accounts, which can create a potential conflict of interest. Also, it can create an additional conflict of interest for Siebert to recommend margin loans because management fees are based on the total account value, including securities purchased on margin, as opposed to the net equity in the account. Financial Advisors may receive different compensation on different products. This creates an incentive for Financial Page 21 of 22  Advisors to recommend other similar products. Talk to your Financial Advisor about what other similar products may be available to you. Siebert Advisor NXT Advisors and your Financial Advisor may be compensated for certain securities and investment advisory programs collateralizing your margin debit. Industry practices may provide your Financial Advisor with an incentive to recommend the transfer of your account to a new firm. Before transferring your margin account, please review your options, including portability of assets, termination charges, fees, rates, and product offerings carefully to ensure that they are consistent with your investment objectives and needs. Account Statements and General Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the broker dealer or custodian for their accounts. Clients may also receive reports from Siebert that includes relevant account and/or market-related information such as an inventory of account holdings and account performance on a monthly basis or as otherwise agreed upon with the client. Clients should compare the account statements they receive from their custodian with any supplemental reports they receive from Siebert. Unfunded Account Termination If your account has a zero balance for more than six months, Siebert may terminate your advisory agreement. Your underlying brokerage account, however, will remain open, unless terminated by the custodian. Once an advisory account has been terminated, Siebert will not be held responsible for account trading delays and Siebert will not provide any communications to you or your Registered Investment Advisor. New account paperwork and/or other procedures for reactivating the account may be required. Client Referrals and Other Compensation The Firm does not use client brokerage to reward brokers for client referrals. Siebert may receive referrals from its affiliate broker dealer, but no compensation is paid for such referrals. Siebert Financial has developed a relationship with two credit unions affiliated with first responders located in the state of New York. Advisor NXT is a fully owned subsidiary of Siebert Financial. We hope these relationships with the credit unions will help our RIA develop new accounts. Both credit unions will be compensated through a revenue sharing arrangement if these revenues are realized in the future. Assets Under Management As of December 2025, the Firm had approximately $391 million in assets under management. Page 22 of 22