Summit Financial, LLC

Investment Advisory Disclosure Brochure March 16, 2026 4 Campus Drive Parsippany, NJ 07054 (973) 285-3600 www.SummitFinancial.com This Form ADV 2A ("Disclosure Brochure") provides information about the qualifications and business practices of Summit Financial, LLC. If you have any questions about the contents of this brochure, please contact us at (973) 285-3600. 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 Summit Financial, LLC is available on the SEC's website at www.adviserinfo.sec.gov. Summit Financial, LLC is acting as SEC registered investment adviser under Section 203(g) of the Investment Advisers Act of 1940. Registration does not imply a certain level of skill or training.  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Item 2. Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Financial Advisor Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor's business practices and conflicts of interest. The Financial Advisor Brochure Supplement provides information about the Advisory Persons of Summit Financial, LLC. Summit Financial, LLC believes that communication and transparency are the foundation of its relationship with Clients and will continually strive to provide its Clients with complete and accurate information at all times. Summit Financial encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us. Material Changes Item 4 has been updated with additional information about the different cost structures with different Qualified Custodians, and the potential conflicts the different cost structures create. Also, details about a new program called APM Plus have been added, along with other information about a potential conflict of interest created by recommendations of non-purpose loans. Also, information about incentives to use Summit’s investment strategies or approved third-party managed solutions platforms has been provided. Item 5 contains additional information about fees and other charges, including Summit’s Program Fee and the fee for using the Pontera platform which creates an incentive for Summit to recommend the Pontera platform over other platforms. Item 14 includes information about incentives from Summit’s receipt of non-cash benefits, such as research materials and analytical tools. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 299322. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (973) 285-3600. Page 2 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Item 3. Table of Contents Item 1 Cover Page ...................................................................................................................... 1 Item 2 Material Changes ........................................................................................................... 2 Item 3 Table of Contents ........................................................................................................... 3 Item 4 Advisory Business ........................................................................................................... 4 Item 5 Fees and Compensation……………….........................................................................16 Item 6 Performance-Based Fees and Side-By-Side Management ........................................ 22 Item 7 Types of Clients ............................................................................................................ 23 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................. 23 Item 9 Disciplinary Information ............................................................................................. 28 Item 10 Other Financial Industry Activities and Affiliations ................................................. 28 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................................................................... 32 Item 12 Brokerage Practices ..................................................................................................... 33 Item 13 Review of Accounts ...................................................................................................... 33 Item 14 Client Referrals and Other Compensation ................................................................ 34 Item 15 Custody ......................................................................................................................... 37 Item 16 Investment Discretion .................................................................................................. 37 Item 17 Voting Client Securities ............................................................................................... 37 Item 18 Financial Information .................................................................................................. 38 Page 3 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Item 4. Advisory Business Summit Financial, LLC, a Delaware limited liability company (hereinafter referred to as the "Advisor", "Summit" or "Summit Financial") is a successor to Summit Equities, Inc.'s registration under Section 203(g) of the Investment Advisers Act of 1940 (the "Advisers Act"). Established in 2018, Summit has succeeded from the advisory businesses of Summit Equities, Inc. ("SE") which had been providing investment advisory and financial planning services since 1991. Summit is wholly owned by Summit Financial Holdings, LLC ("SFH") which is owned by Stanley Gregor and Merchant Wealth Management Holdings 3, LLC (“MWMH”). MWMH is wholly owned by Merchant Wealth Partners, LLC, a Company managed by MWP Advisory, LLC, a registered investment advisor, which is wholly owned by Merchant Investment Management, LLC. Summit offers investment advisory services to individuals, high net worth individuals, corporations and/or business entities, pension and profit-sharing plans, and charitable organizations (each referred to as a "Client" or collectively as "Clients"). Summit serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Summit's Clients do not all use the same qualified custodian. Custodians for Summit include National Financial Services LLC ("NFS"), an affiliate of Fidelity Brokerage Services, LLC ("FBS"), Schwab Advisor Services LLC (“Schwab”), Goldman Sachs, SEI, and Pershing LLC (together “Qualified Custodians”), which provide brokerage services in connection with Client accounts. All clients will complete documentation provided by the Qualified Custodian of their choice at account opening and may have also been notified of their selected Qualified Custodian via the Advisory Program Schedule (“APS”) attached or incorporated by reference to their Investment Management Agreement ("IMA"). Summit has different cost structures established with each Qualified Custodian and therefore benefits differently depending on which Qualified Custodian is selected. Additional costs related to ticket charges from certain Qualified Custodians are passed on to advisors as well, creating an incentive to avoid trading certain securities which may incur those costs. Please see Item 5, Fees and Compensation, below for additional information. Please contact your Financial Advisor or Summit at research@sfr1.com for additional information regarding custodians. Each advisory relationship at Summit is managed by one or more Financial Advisors, acting in the capacity of an investment adviser representative registered with Summit (hereinafter referred to as "Financial Advisor(s)" or "IAR(s)"). The Financial Advisor serves as the primary point of contact between Summit and the Client. The Financial Advisor collects financial information from the Client and based on the Client needs, recommends specific advisory services or programs that would seek to meet their investment objectives. Some Financial Advisors choose to incorporate more of Summit's resources in their provision of advisory services to their Clients than others do, such as consultations with internal Summit specialists. Some of Summit’s Financial Advisors are also associated with certain unaffiliated broker-dealers such Page 4 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 as Purshe Kaplan Sterling Investments ("PKS")1, APW Capital, Inc. ("APW") and Private Client Services ("PCS") (collectively herein referred to as "Unaffiliated Broker Dealers"). These Unaffiliated Broker Dealers are registered with the SEC as a broker-dealer and are members of FINRA and SIPC. Financial Advisors who are associated with Unaffiliated Broker Dealers can provide brokerage services in the capacity of a Registered Representative ("RR") of that broker-dealer. All brokerage products offered by the Financial Advisor are provided in their capacity as an RR through their broker-dealer, not through Summit or its affiliates. The Financial Advisors who provide (i) investment advisory services, including asset management and financial planning services, through Summit or its affiliated firms, (ii) insurance through Summit Risk Management, LLC ("SRM"), and (iii) brokerage services through PKS or any other unaffiliated broker dealer, are independent contractors or employees of each of these companies. In addition, certain Financial Advisors that are registered with Summit are employees of affiliated or unaffiliated entities. Some Financial Advisors have other material business interests as well, as described in their Form ADV Part 2B Brochure Supplements ("Financial Advisor Brochure Supplement"). SRM is an affiliate of Summit. Please see Item 10 – Other Financial Industry Activities and Affiliations which contains more details about SRM. Some of our Financial Advisors operate their business under a "doing business as" ("DBA") firm. The investment advisory and financial planning products and services offered through their DBAs are provided through Summit. Other business lines such as brokerage and insurance services and products, provided through their DBA, are provided through other unaffiliated and affiliated firms. For more information about a Financial Advisor or their DBA, please refer to the particular Financial Advisor’s Brochure Supplement. Each Financial Advisor is compensated by Summit for providing investment advisory and related services. The amount of this compensation varies depending on which advisory service or program the Client selects and may be more than what the Financial Advisor would receive if the Client selected a different advisory service or program provided by Summit. Accordingly, Financial Advisors have a financial incentive to recommend one advisory service or program over another to maximize their compensation. This Form ADV Part 2A Disclosure Brochure describes the investment advisory services and programs offered by Summit. Wrap fee programs offered by Summit are described in detail in another brochure, Summit's Wrap Fee Program Brochure, which contains the information required by Part 2A, Appendix 1 of Form ADV. Types of Advisory Services Summit offers several different asset management programs for its advisory Clients as well as financial planning. From time to time, individual Financial Advisors offer custom consulting or other services. In such event, the details will be disclosed in the specific agreements with the Client. 1 SE assisted the Financial Advisors who wished to continue to remain registered representatives of a broker-dealer to register with Purshe Kaplan Sterling Investments a broker dealer and member of FINRA and SIPC ("PKS"). PKS is not affiliated with SE or its successors. If the Financial Advisor continues to offer brokerage products to Clients, it will not be through Summit or any of its affiliates but will be through PKS, or other unaffiliated broker dealers as appropriate. PKS, PCS, and APW, through a referral agreement, pay a referral fee to a broker dealer that is owned by Summit Financial Holdings, LLC (LS Securities, LLC) for the brokerage business conducted by the Financial Advisors at PKS, PCS, and APW. Other unaffiliated broker-dealers do not pay similar referral fees. Page 5 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 For the assets in its asset management programs, Summit provides continuous and regular supervisory or management services (as defined by the SEC) based on the Client's individual goals, objectives, time horizon, risk tolerance, liquidity needs, investment assets and income ("financial circumstances") utilizing the investment strategy selected by the Client. Financial Advisors obtain a financial profile for each Client to aid in the construction of a portfolio that matches the Client's specific situation and needs. Many Clients maintain "household" relationships, in which multiple accounts for an individual or members of a family are managed jointly to maximize efficiencies. (The term "Client" includes such households, for purposes of this brochure.) For all of the different types of asset management programs, the Financial Advisor will assist Clients in assessing their goals, risk tolerance, income and tax situation and selecting an investment strategy and asset allocation that is appropriate for the Client's specific circumstances. However, Summit and its Financial Advisors do not provide tax advice to Clients. Summit, through its Financial Advisors, is available to Clients on an ongoing basis to discuss Client financial circumstances, the selected portfolio and the securities therein or to process instructions from Clients concerning advisory assets. Summit or a third-party manager as applicable, will exercise discretion in connection with certain advisory programs as described herein, or pursuant to an investment advisory agreement the Client signs with Summit. By signing Summit's Discretionary Investment Management Agreement, Clients appoint Summit and the selected Summit Financial Advisor to provide investment advisory and investment management services on a discretionary basis for assets in the Client's designated accounts which may include all accounts in the Client's household. Additional information regarding discretionary services can be found in Summit's Wrap Fee Program Brochure. In connection with non-discretionary services or programs, it is up to the Client to decide whether to accept or reject Summit's recommendations. Summit's securities recommendations seek to be consistent with a Client's financial circumstances and any reasonable guidelines or restrictions provided by a Client. Unless otherwise instructed by the Client, all dividends and other distributions will be reinvested in Client accounts. The investment strategies used by Summit vary by Client and are based on the Clients' individual circumstances. Clients are advised to notify Summit promptly if there are changes in their financial situation, investment objectives or if they wish to impose any reasonable restrictions upon Summit's investment management services. Clients can engage Summit to manage all or a portion of their assets on a discretionary or non-discretionary basis, by selecting one or more advisory programs as set forth in their IMAs with Summit. As applicable, Clients are typically required to enter into additional written agreements with the Qualified Custodian for the accounts, third-party investment managers, platform managers, insurance companies or other parties that are not affiliated with Summit. All investments have risk and there is no guarantee that utilizing the asset management or financial planning services of Summit or its Financial Advisors will produce favorable results. 1. Summit Managed Portfolios Summit Managed Portfolios ("Managed Portfolios") are custom designed portfolios constructed by Page 6 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Summit's Investment Management Committee ("IMC"), which includes the Chief Investment Officer ("CIO") and members of the Investment Management Department. The IMC meets regularly to oversee the Managed Portfolios. The IMC also conducts quarterly meetings with the Investment Committee, an advisory group of Financial Advisors, to discuss changes to the Managed Portfolios as well as other investment topics. Summit, acting through the Chief Investment Officer, has discretionary authority over the assets managed under the Managed Portfolios program. The IMC determines the asset allocation, the securities to be bought or sold, the amount of securities to be bought or sold and the timing of the purchases and sales of the securities. Given the long-term nature of many Managed Portfolios strategies, many Managed Portfolios accounts may have little or no activity during a given period. With the exception of the Tax-Deferred Strategies Portfolios ("TDS"), the Managed Portfolios are part of the wrap fee program.2 The TDS program includes managed portfolios that target a specific asset class, market segment or investment strategy or offer various mixes of these components. Each portfolio has a strategic allocation designed to overweight market segments seeking to outperform over the long term and to control exposures to investment risks. Portfolios with a range of investment objectives and potential levels of risk and return are available. These portfolios are only available on the Nationwide Monument Advisor tax-deferred variable annuity platform. The specific strategies offered as TDS are detailed in the Summit Managed Portfolio Brochure which is provided to Clients prior to investing in this advisory program. 2. Strategic Asset Allocation ("SAA") The SAA program enables Financial Advisors to custom design portfolios for Clients, taking into account each Client's circumstances. The Financial Advisor does not have discretion over the assets and must get approval from Clients before entering any trades. SAA accounts primarily include assets for which regular and continuous supervision or management services are provided but from time to time, they hold specific investments for which the Financial Advisor provides only consultative and administrative services, including periodic monitoring, reporting and/or servicing.3 Although most SAA accounts are primarily allocated among mutual funds and ETFs, some Financial Advisors recommend that their Clients also hold individual positions in stocks, bonds, traded and non- traded REITs, hedge funds (including funds of funds), unit investment trusts ("UITs") or other securities. As of December 1, 2022, all alternative investment purchases will occur in SAA accounts. Mutual funds, UITs and ETFs often provide diversification but may be concentrated in a particular asset class or investment style. The risk in these investments is determined by the risk in underlying holdings (e.g., a stock mutual fund's risk is determined by the risk of the stocks in the fund). Further, some of the selected securities may be less liquid than those utilized in the Managed Portfolios. The Financial Advisors are invited to consult with members of the IMC regarding particular securities or when constructing portfolios, but they are not required to, and some choose to rely solely on their own due diligence regarding the securities recommended. Clients should speak to their Financial Advisors to understand how their Financial Advisor determines which securities to recommend. Given the long- term nature of many SAA strategies, many SAA accounts have little or no activity during a given For additional information about the Managed Portfolios that are part of Summit's Managed Portfolios wrap fee For certain assets, such as those invested in hedge funds and non-traded REITS, or those managed by third parties 2 program, please see Summit's Wrap Fee Program Brochure. 3 who have a direct relationship with the Client, Summit and the Financial Advisor provide ongoing advice and monitoring rather than what the SEC refers to as "continuous and regular supervisory services." Page 7 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 period. If you have any questions, please speak with your Financial Advisor or contact research@sfr1.com. Assets held in connection with the SAA program are custodied at a Qualified Custodian or elsewhere as selected by the Client, and when custodied at a Qualified Custodian, they are part of Summit's Wrap Fee Programs. Please take note that SAA accounts at certain Qualified Custodians have been grandfathered in from previous programs as non-wrap accounts and are not part of Summit's Wrap Fee Programs. Additional information regarding SAAs that are part of Summit's Wrap Fee Program can be found in Summit's Wrap Fee Program Brochure. Clients can refer to their APS document, IMA or contact their Financial Advisor to determine if their SAA account is a Wrap or Non-Wrap account. Within SEI Managed Account Solutions ("SEI MAS") and SEI Mutual Fund Portfolio ("SEI MF") accounts, a Financial Advisor can direct, on a non-discretionary basis, some or all of the Client's assets into non-SEI investments to customize the portfolio based on the Client's needs and circumstances ("Wealth Manager-Directed Non-Discretionary"). Summit treats assets held as part of Wealth Manager-Directed Non-Discretionary (but not other assets held in connection with the SEI MAS and SEI MF accounts) as part of a SAA program. The Wealth Manager-Directed Non-Discretionary assets are primarily allocated among mutual funds and ETFs; however, they may also hold other types of investments, if recommended by the Financial Advisor. When Financial Advisors recommend these other investments in connection with Wealth Manager-Directed Non-Discretionary, Clients incur additional charges. 3. Advisor as Portfolio Manager ("APM") / Flexible Managed Accounts ("FMA") The APM and FMA programs are similar to the SAA program except that the Financial Advisor has discretion to place trades without contacting the Client for approval. The APM and FMA programs are the same. The FMA program name was changed to APM in 2021; however, both FMA and APM accounts can still be opened. Direct investments, such as non-traded REITs and hedge funds, are generally not included in APMs or FMAs. The Financial Advisor reviews the Client's financial circumstances and exercises discretion to determine the securities to be bought or sold in the Client's account, the amount of securities to be bought or sold and the timing of the purchases and sales of the securities. The securities used in these accounts generally include mutual funds, ETFs, UITs, equities, and fixed income. Mutual funds, UITs and ETFs often provide diversification but may be concentrated in a particular asset class or investment style. The risk in these investments is determined by the risk in underlying holdings (e.g., a stock mutual fund's risk is determined by the risk of the stocks in the fund). The Financial Advisors are invited to consult with members of the IMC regarding particular securities or when constructing portfolios, but they are not required to, and some choose to rely solely on their own due diligence regarding the securities recommended. Some Financial Advisors select securities that are less liquid than those utilized by the IMC in connection with the Managed Portfolios. Clients should speak to their Financial Advisor to understand how their Financial Advisor determines which securities to buy and sell. In certain limited instances, a client will be given authorization to trade securities in their own account. Given the long-term nature of many APM/FMA strategies, an APM or FMA account may have little or no activity during a given period. If there are few trades made in a Client's APM/FMA account, then a Page 8 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 wrap fee program such as APM or FMA will not be the most cost-effective option for the Client as compared to non-wrap programs. Some Financial Advisors are more tactical and may trade more often to manage risk and/or seek opportunities. There are tax implications to more active approaches and there is no guarantee that these strategies will provide greater returns or lower risk. Clients should discuss the approach with their Financial Advisor. For more information on these fees and the APM/FMA Program or if you have any questions, please contact with your Financial Advisor or email research@sfr1.com. Assets held in connection with the APM or FMA program may be custodied at a Qualified Custodian or elsewhere as selected by the Client, and when custodied at one of the Qualified Custodians, they are part of Summit's Wrap Fee Programs. Additional information regarding APMs or FMAs that are custodied at one of the Qualified Custodians can be found in Summit's Wrap Fee Program Brochure. Clients can refer to their APS, IMA or contact their Financial Advisor to confirm whether their account is a Wrap or Non-Wrap account. Within SEI MAS and SEI MF accounts, an IAR can direct, on a discretionary basis, some or all of the Client's assets into non-SEI investments to customize the portfolio based on the Client's needs and circumstances ("Wealth Manager-Directed Discretionary"). Summit treats assets held as part of Wealth Manager-Directed Discretionary (but not other assets held in connection with the SEI MAS and SEI MF accounts) as part of an FMA program. The Wealth Manager-Directed Discretionary assets are primarily allocated among mutual funds and ETFs; however, they may also hold other types of investments, if recommended by the Financial Advisor. When Financial Advisors recommend these other investments in connection with Wealth Manager-Directed Discretionary, Clients incur additional charges. 4. APM Plus The APM Plus program represents a partnered approach between the Advisor, Financial Advisor and Summit’s investment team to implement strategies best aligned with the client’s objectives and overall risk tolerance. The Financial Advisor will consult with the Summit investment team for investment decisions and trades will be implemented by the Summit Trading Group. Based on the needs of the client, Accounts can be allocated to a variety of strategies including but not limited to: model portfolios consisting primarily of commingled funds (ex. ETFs, Mutual Funds), separately managed accounts of individual stocks and/or bonds, select alternative investments and third-party managers. Accounts can incorporate tactical or dynamic changes based upon the opportunity set but also incorporating the tax status of the account. Tax capabilities and or strategies may also be employed for suitable accounts at additional expense; these can include direct indexing, tax loss harvesting (TLH), tax optimization, and intelligent tax transition. Because these strategies may involve more frequent portfolio changes, the Advisor utilizes no transaction fee (“NTF”) mutual fund share classes in order to implement the strategy in a sustainable and efficient manner, reduce transaction costs associated with trading, and maintain accessible investment minimums. The use of NTF funds may result in clients bearing higher internal fund expenses than other available share classes or investment options, and lower transaction expenses to the Advisor. The Advisor, as a fiduciary, determines that the use of such funds are in the client’s best interest when consistent with the overall design of the strategy, the client’s objectives, and the efficient Page 9 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 implementation of the strategy. These strategies may also be implemented within unified managed accounts (“UMAs”), which can include strategies managed by third-party managers, as determined in coordination with the Advisor, Financial Advisor and the Summit investment team. Your Summit Financial Advisor will provide regular and continuous review of your assets in the Investment Program and may recommend periodic rebalancing. If Summit terminates third party manager relationship, it will promptly notify the Account holder to discuss reallocation of the assets. 5. Third Party Managers ("TPM") and Platforms In the TPM program, the Financial Advisor reviews the Client's financial circumstances and recommends an unaffiliated third-party investment manager to manage the Client's assets. Some of the TPMs are sub-advisers under agreements with Summit and others will have separate advisory agreements directly with the Client. Some of the third-party managers operate on separate platforms. TPMs and Platforms each have their own fees charged to clients which are different than the fees charged by Summit. For additional information about Summit's sub-advisory stock portfolios with Seeds, Parametric and AllianceBernstein or the Municipal Bond Program, a TPM program under which AllianceBernstein serves as sub-adviser and pursues a municipal bond strategy, please see Summit's Wrap Fee Program Brochure. The Advisor provides investment advisory services through its investment advisory platform, which includes the recommendation and ongoing monitoring of third-party investment advisers and portfolio managers. For clients who select a TPM and enter into a separate investment management agreement with that manager, the agreement will detail the applicable advisory fee for portfolio management services. The Advisor does not have discretionary authority over client accounts managed by TPMs unless otherwise agreed in writing. The Advisor's services with respect to these accounts include investment strategy review, manager selection, suitability analysis, and ongoing monitoring to ensure continued alignment with client objectives. The Advisor’s reported assets under management include assets for which the Advisor provides ongoing investment advisory services, including manager selection, suitability analysis, and continuous monitoring. Please also see Item 5, Item 10, and Item 14 for more information about Third-Party Managers. In some cases, Summit acts as a solicitor on behalf of the TPM. TPMs actively manage the assets on a continuous basis and have discretion to buy, sell and trade stocks, bonds, mutual funds and/or other securities in accordance with the program selected by the Client. Depending on the TPM, the Financial Advisor will provide either consultative or continuous and regular supervisory services to assets in TPM programs and may recommend periodic rebalancing among the TPM's offerings. Clients are advised to review the investment advisory brochure for any recommended TPM and the Advisory Program Schedule for details including fees charged by the TPM that are separate from fees charged by Summit. In some cases, the Financial Advisor can create custom allocations on a TPM's platform. If you have questions about a particular TPM or program, please ask your Financial Advisor or contact research@sfr1.com. Some of the TPM programs constitute "wrap programs." For example, the SEI MAS program is a wrap program sponsored by SEI that utilizes third party managers and/or mutual fund models. The Page 10 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 investment advisory brochure for the specific TPM will indicate if its program is a wrap program and contain important disclosures about the program. Clients are encouraged to read those brochures and follow up with their Financial Advisor if they have any questions. Summit and SEI have entered into an arrangement where SEI will compensate Summit for providing administrative and marketing services on behalf of SEI. The compensation for these services are paid based on the fees SEI collects from Summit clients as of October 2023. This arrangement poses a conflict of interest since the more assets Summit places with SEI, the more compensation Summit receives, thus providing Summit with incentive to recommend SEI to its clients. If you have any questions related to this arrangement or would like to understand how this affects you, please contact your Financial Advisor. Certain TPM accounts are part of Summit's Wrap Fee Program. Please see Summit's Wrap Fee Program Brochure for information about TPM accounts that are wrap, including the nature of the advisory services provided, fees and expenses, and discussion of relevant conflicts of interest. Client can reference their APS document, IMA or contact their Financial Advisor to determine if their TPM account is a Wrap or Non-Wrap account. 6. SEI Mutual Fund Portfolios The SEI Mutual Fund Portfolios program (which is separate and distinct from the SEI MAS program) enables Financial Advisors to design portfolios for Clients, taking into account the Client's financial circumstances, and uses actively managed SEI mutual fund asset allocation portfolios to help meet Client investment objectives. The Financial Advisor and Client decide whether to subject the accounts to automatic quarterly rebalancing so the allocation selected by the Client remains consistent over time. The Financial Advisor provides ongoing advice and monitoring and does not have discretion over the assets and must get approval from the Client before entering any trades (except for automatic rebalancing or Wealth Manager-Directed Discretionary, if selected). Given the long-term nature of most of the strategies, a SEI MF account may have little or no activity during a given period. Assets in the program are custodied at SEI, which is unaffiliated with Summit. As permitted by SEI, other assets may be held in the accounts, as well. As stated previously, SEI and Summit Financial have entered into an arrangement that poses a conflict of interest. Please see above for additional information. 7. Outside Investment Monitoring In some cases, Clients ask their Financial Advisors to oversee assets managed by other advisers, assets at brokers, or alternative investments such as hedge funds. Often, these are assets held in retirement plans. In these cases, the Financial Advisor provides ongoing consultative services which take into account the Client's financial circumstances. Services include periodic investment monitoring, reporting and/or servicing to the Client. In connection with this service, the Financial Advisors typically do not have the ability to direct the trades, which must occur through the broker of record. Page 11 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 8. Alternative Investments Held Directly ("AID") The AID Program enables your Financial Advisor to recommend Alternative Investments based on your needs and circumstances. These are held directly at the issuer, not at one of Summit's Qualified Custodians, but may be shown on your custodian statement. You must approve each recommended transaction. All assets are subject to regular and continuous supervision or management. Liquidity, custody and other features of Alternative Investments are detailed in the offering documents that you sign with the issuer, platform manager or other third party. Certain AID accounts are part of Summit's Wrap Fee Programs. Please see Summit's Wrap Brochure for information about AID accounts that are wrap, including the nature of the advisory services provided, fees and expenses, and discussion of relevant conflicts of interest. Clients can reference their APS document, IMA or contact their Financial Advisor to determine if their AID account is a Wrap or Non-Wrap account. 9. Retirement Plan Advisory Services Summit provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a "Plan") and the company (the "Plan Sponsor"). The Advisor's retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. In addition, Plan Sponsors may engage Summit to serve as a 3(38) Fiduciary to their plan and assume investment discretion over the Plan. In such instances, the Plan Sponsor shall authorize this discretion to select and implement the Plan investment options. Summit may provide the following retirement plan advisory services: • Vendor Analysis • Employee Enrollment and Education Tracking • Investment Policy Statement ("IPS") Support • Investment Management • Performance Reports • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance • Benchmarking Services Summit may provide investment advisory services on behalf of the Plan and Plan Sponsor, which may be in either a 3(21) or 3(38) context depending on whether or not it is also providing discretionary investment management over the Plan assets. For 3(38) services, Summit shall have the discretion to select the investments for the Plan and/or make investment decisions on behalf of Plan Participants. In addition, we use Pontera Solutions, LLC, a third-party platform, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to have direct access to Client accounts without Client log-in credentials to affect trades. We are not affiliated with the platform. However, we do charge fees as outlined in the Fees and Compensation section below. Because Pontera provides access to certain held-away accounts that we may not otherwise be able to manage, both the application of Summit’s advisory fee to a broader asset base and the additional fees paid by the Client outlined in the Fees and Compensation section below present a potential conflict of interest. This is mitigated by the fact that any recommendation to use the platform is based solely on what we believe to be in the Client’s best interest. Page 12 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 To use Pontera, a link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, your Wealth Manager will review the current account allocations. When deemed necessary, your Wealth Manager will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to coordinate investment allocation with the client's overall portfolio objectives utilizing investment choices available within the Client's benefit plan. Client account(s) will be reviewed at least annually and allocation changes will be made as deemed necessary. 10. Financial Planning Financial planning is designed seeking to meet the Client's financial goals, needs and objectives. The scope of the financial plan varies depending on the Client and typically involves some combination of a review of the Client's current financial situation, including estate planning, insurance planning, education planning, retirement planning, business succession planning and portfolio analysis. Summit does not typically advise on business value analysis, and/or business liquidations, or property and casualty insurance, but these components can be referred out to third parties. The financial planning team includes income tax and estate specialists, insurance specialists and/or members of the IMC. Although some members of the Summit financial planning team are admitted attorneys and/or CPAs, they act in a non-representative capacity. Neither they, nor any Summit entity, provides tax, accounting or legal advice to Clients. Clients should make all decisions regarding the tax and legal implications of their investments and plans with their independent tax or legal advisors. Following delivery of the financial planning services, which may or may not include a written financial plan, the investment advisory relationship terminates for Clients who have engaged Summit as investment adviser for the limited purpose of providing financial planning services. Clients are free to implement none, some or all of the recommendations and may do so through Summit and its affiliates or through other providers of such services. Charges may be lower or higher if the plans are implemented away from Summit and its affiliates. If additional services are selected by the Client, they will be covered under separate agreement(s). Financial planning services will include various recommendations and planning strategies, depending on the nature of the financial planning services selected. These may include recommendations to allocate your assets among generic product or account types or they may include more specific recommendations. Implementation of financial planning recommendations is your responsibility. The actions necessary to implement a financial planning recommendation and the costs of doing so are not included in the financial planning fee. As noted above, many Financial Advisors are also RRs of unaffiliated broker-dealers that are not affiliated with Summit and are also insurance agents of SRM. In the Financial Advisor's capacity as an RR and/or an insurance agent, he or she is authorized to provide securities brokerage services and/or sell insurance. In those capacities, and separate from the financial planning services, the Financial Advisor may help you implement one or more financial planning recommendations included with the financial planning services. If you accept the Financial Advisor's offer to assist with implementation of the financial plan, the Financial Advisor may make additional recommendations to invest in specific products or accounts or to purchase additional investment advisory services, but any such recommendations will be limited to Page 13 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 those products, accounts and services that the Financial Advisor is authorized to offer. You are under no obligation to engage the Financial Advisor to implement the financial plan, or to purchase any investment or insurance product or obtain an advisory service from the Financial Advisor to implement the recommendations made in your financial plan. In circumstances where the Financial Advisor recommends specific investments and/or otherwise is involved in implementing the plan, the opportunity for the Financial Advisor and Summit, SRM or LS Securities, LLC to receive additional compensation as a result of such recommendations creates a conflict between your interests and those of the Financial Advisor and Summit. For more information about LS Securities, LLC, please see Item 10. In addition, if you separately purchase a product or service recommended by the Financial Advisor to implement a financial planning recommendation, you generally will be charged commissions or fees in connection with those transactions and services that are separate from and in addition to the fees charged by Summit for financial planning services. The obligations of SRM when it is acting as an insurance agency, as well as the obligations of PKS when it is acting as a broker-dealer, differ from Summit's obligations to you when Summit is acting as an investment adviser. Similarly, your Financial Advisor's obligations when acting as an insurance agent for you or providing securities brokerage services to you differ from his/her obligations to you when acting as a Financial Advisor. Client or Summit may terminate an advisory program at any time by providing notice of such election to the other party. Refunds for financial plans are addressed in Item 5 below. In addition to these core investment advisory services and platforms (i.e., Managed Portfolios, SAA, APM, FMA, TPMs, SEI MF, Outside Investment Monitoring accounts and Financial Planning), Clients and Financial Advisors may negotiate other types of services for a retainer, flat fee or otherwise. These arrangements will be documented separately with the Client, the Financial Advisor and Summit. All investments have risk and there is no guarantee that utilizing the financial planning, asset management and/or advisory consulting services of Summit or its Financial Advisors will produce favorable results. 11. Variable Annuity Contracts Summit offers Client's access to variable annuity products. Variable annuity contracts facilitate long-term investment on a tax-deferred basis. A variety of investments options with different objectives, strategies and expenses are generally available. Add on features with a death benefit or living benefit may also be available, sometimes for an additional cost. Any obligations of the contract are subject to the claims-paying ability of the issuing insurance company. Contract values may be invested in the fixed account of the issuing insurance company or in sub-account investment funds. Investment funds may be affiliated funds or managed by third-party sub-advisors. The issuing insurance company is responsible for selecting the available investment funds which may include asset allocation fund of funds that are diversified across multiple asset classes and underlying funds. Clients should discuss fees related to Variable Annuity products with their Financial Advisor to see if there are alternative channels that would have lower fees. Page 14 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Other Aspects of Asset Management In its provision of investment advice and asset management, Summit utilizes various types of investments including but not limited to mutual funds, ETFs, equities, UITs, fixed income, hedge funds, traded and non-traded REITs, and insurance products such as variable life insurance and variable annuities. Summit offers the same suite of services to all of its Clients. However, each Financial Advisor determines, based on his or her own analysis, management style and preferences, in conjunction with each Client's specific profile and financial circumstances, which services and products to recommend and whether to recommend Summit's wrap fee programs or Summit's non-wrap advisory programs. Clients may impose reasonable restrictions on Summit regarding investing in certain securities or types of securities in accordance with their values or beliefs (or based on their employer or regulatory restrictions). However, if the restrictions prevent Summit or the TPM, as applicable, from properly servicing the Client account, or if the restrictions would require Summit to deviate from its standard platform of services, Summit reserves the right to end the relationship. The Advisor does not offer formal family office services, but when it refers to “family office” services it provides, it generally means a combination of services tailored to high-net-worth families, such as: • Wealth Management Services: Customized investment planning, asset allocation, and portfolio management • Asset Allocation and Rebalancing: Account monitoring based on market conditions and client- specific changes. • Financial Planning & Consulting on topics such as cash flow management and tax filings. • Business Planning for financial and tax matters • Retirement Plan Advisory: Fiduciary services for company retirement plans under ERISA. • Use of Sub-Advisers: Engagement of third-party managers for specialized advisory services. The Advisor views client relationships holistically and may recommend a combination of tailored services to meet the needs of high-net-worth families, which could include but not be limited to the above. Certain services are provided separately and in the event there are additional charges for these services, clients will enter into a separate agreement. As noted above, Financial Advisors act as portfolio managers in connection with the SAA, FMA and APM programs that may or may not be custodied at one of the Qualified Custodians. Certain conflicts arise in connection with these related persons acting as portfolio managers in these programs. In particular, the advisory fee paid by Clients differs depending on the specific service they select and often varies from Client to Client. Clients should be aware that Financial Advisors, therefore, have an incentive to recommend the programs or services in which they receive more of the advisory fee. Summit is aware of the conflicts of interest created by the variability in advisory fee compensation and has adopted practices to supervise recommendations of programs and services. Financial Advisors acting as portfolio managers in connection with the SAA, FMA and APM programs have to conduct their own due diligence of securities and allocations they recommend and select under these programs, while they do not have to conduct the same degree securities-level due diligence in connection with the other programs. Because the SAA, FMA and APM programs involve this additional effort by Financial Advisors, Financial Advisors may be disincentivized from recommending Page 15 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 these programs to Clients. Summit is aware of the conflicts of interest created by variability of the role the Financial Advisor plays in connection with the different programs and has adopted practices to supervise program recommendations. In certain limited instances, the client will be given authorization to trade securities in their own account. If there is little or no trading activity in the account, a Client may pay more in advisory fees than commission charges if the assets were in a non-managed program. Assets Under Management As of December 31, 2025, Summit provided advisory services to Clients with respect to $22,470,472,144 of their assets, approximately $12,240,875,462 of which is on a discretionary basis. (Note that Summit does have limited discretion with respect to the remaining assets to sell securities if there is insufficient cash in an account to pay the fees.) This includes assets for which regular and continuous supervision and management are provided as well as assets for which other consultative services, including periodic monitoring, managing, supervising, reporting and/or servicing. Non-Purpose Loans and Lines of Credit The Advisor may introduce certain Clients to a non-purpose loan or line of credit program made available through a bank or lending affiliate associated with the Client’s qualified custodian (the “Lending Program”). In such instances, eligible assets held in the Client’s Account[s] may be pledged as collateral for the non-purpose loan or line of credit. A recommendation to utilize a Lending Program presents a conflict of interest because the Advisor will generally continue to receive investment advisory fees on the assets pledged as collateral, as assets will not leave the Client's Account[s]. Clients are not obligated to engage the Advisor in connection with any Lending Program and may obtain similar lending arrangements through other lenders or through the custodian directly. For additional information regarding risks associated with non-purpose loans and lines of credit, including risks of forced liquidation and market-related declines in collateral value, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. Item 5. Fees and Compensation Investment Services Fees When a Client engages Summit to provide investment management services, Summit charges an annual advisory fee and in wrap accounts, a program fee. Clients in the SEI programs, the Envestnet program, or the AssetMark/Genworth program do not pay the program fee to Summit, and only pay an advisory fee to Summit. Both the advisory fee and the program fee are negotiable. For additional information regarding the negotiability of these fees, please contact your Financial Advisor or Summit at research@sfr1.com. Advisory Fee Financial Advisors set their own advisory fees and/or flat fees for their services, as long as the maximum advisory fees do not exceed those on the advisory fee schedule, below. Financial Advisors consider various factors in determining what advisory fee to charge, which may include the nature and Page 16 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 size of the overall Client relationship with the Financial Advisor and/or the type of advisory products or services likely to be provided through the Financial Advisor. As discussed below, Clients with assets with TPMs or in Outside Investment Monitoring programs typically pay fees directly to other parties as well as to Summit. Since Summit began providing these services, it has had other legacy advisory fee schedules in effect, which may be higher than described below. As new advisory fee and program schedules are put into effect, they are made applicable only to new Clients and fees to existing Clients are not affected. Therefore, some existing Clients pay different advisory fees than shown below. The maximum advisory fee for the programs is 1.50%, exclusive of the program fee, sub- advisory fees, third-party manager fees, platform fees, and fees not covered by a Wrap Program that are charged by the Qualified Custodian. Summit's advisory fees for all programs are included in the written Investment Management Agreement between Summit and the Client. As noted above, advisory fees are negotiable at the sole discretion of Summit. Summit may also charge an upfront "portfolio design fee" for the initial allocation, which amount is not included in the annual maximum. If such fees are charged, they will be noted on a written agreement with the Client. Moreover, since Financial Advisors can negotiate their own fee arrangements, some Clients pay flat rates for services rather than asset-based charges, which are deducted differently. Pontera Fee In the Pontera program, there is an additional charge of 30 bps to Clients; 25 bps is paid to Pontera for use of the Pontera platform and a 5 bps fee is paid to Summit for its administrative services charge. The compensation creates an incentive for Summit to recommend the Pontera platform over other platforms. For information regarding the fees charged in connection with Summit's wrap fee programs, please see Summit's Wrap Fee Program Brochure. Summit Program Fee As noted above, persons who participate in any of the programs described in Summit's Wrap Fee Program Brochure also pay an annual program fee (“Program Fee”). Some clients who move their accounts to Summit from another firm will pay different fees than clients who open new accounts at Summit. The Program Fee includes for all accounts an annual Account Maintenance charge of $120 per year billed monthly or quarterly depending on the billing frequency of the account. Therefore, there is a benefit to Summit to opening more accounts, but the portfolio construction and design, including how many accounts are appropriate, is the responsibility of the IAR, who does not participate in the Account Maintenance fee payments. There is also a benefit to Summit for advisors selecting programs that have a higher Program Fee. Beginning in 2026, certain Financial Advisors will share in Program Fees as additional compensation or credits against expenses. In addition, certain Financial Advisors will receive a higher multiple if they sell part or all of their Advisor Revenue to Summit or an affiliate or receive a forgivable loan to join Summit from another firm based on a higher amount of assets in the Managed Portfolios or TPM programs. These programs have higher Program Fees than the APM program, which creates an Page 17 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 incentive for Advisors to recommend the programs with the higher Program Fee. If you have any questions regarding the Program Fee or incentives, please ask your Financial Advisor. Financial Advisors who enroll clients in APM programs are billed for ticket charges, except at Goldman Sachs, because Goldman charges an asset-based fee regardless of ticket charges. This creates a conflict because IARs that do more trading or have higher ticket charges are incented to select Goldman Sachs, compared with other Qualified Custodians. Goldman also charges Summit an asset- based fee instead of ticket charges like other Qualified Custodians do. Therefore, since the asset-based fee can be a higher or lower cost to Summit, lower operational costs incentivize use of Goldman by Summit’s Advisors, depending on a Client’s account holdings and trading frequency. For APM program assets custodied at Goldman Sachs, Program Fees for clients are not discounted based on asset size. In addition, since Summit pays Goldman an asset-based fee, the Program Fee for APM accounts is not discounted. Although part of the SAA, APM or FMA program, assets in Wealth Manager-Directed Non- Discretionary or Wealth Manager-Directed Discretionary programs are not subject to Summit's Program Fee. Additional Fees for TDS Managed Portfolios Clients invested in the TDS Managed Portfolios are also charged a monthly platform fee of $20/month by the custodian, Nationwide Mutual Insurance Company ("Nationwide"). In addition, a "Low Cost Fund Platform Fee" up to 0.35% annually on the contract value invested in certain underlying investments will be charged by Nationwide. Please see Nationwide's prospectus and Statement of Additional Information for the variable annuity used in connection with the TDS Managed Portfolios for more information. These documents can be provided by the Client's Financial Advisor. Additional Fees for SAA, FMA and APM Assets that are not part of Summit's Wrap Program For details regarding any additional fees, including, but not limited to, trading commissions and service fees, charged by the broker-dealer executing trades in these SAA, FMA and APM programs, Clients should reference the broker-dealer's fee schedule, which Clients can obtain from their Financial Advisor or the broker-dealer. Additional Envestnet Fees In addition to the advisory fee noted above, for Envestnet, Clients are charged a "Custody Fee" designed to cover the cost of brokerage in the Client's account, as well as a "Sponsor Fee." Additional information can be found in the Envestnet Direct Program Fees schedule provided to Clients. Payment of Advisory Fees and Program Fees Summit's advisory fees for the TDS Managed Portfolios are deducted from a bill-to account or billed directly by Nationwide. They are assessed either quarterly in advance based on quarter-end values, or quarterly in arrears, based on average daily balance. For SAAs, APMs and FMAs that are not custodied at one of the Qualified Custodians, Summit Page 18 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 typically calculates and deducts the advisory fees and Program Fees directly from the Client's custodial account quarterly in advance based on the average daily value of the assets under management during the immediately preceding quarter. In some instances, during a transition of assets to Summit under the same Custodian, there is a delay at the Custodian in providing valuation information needed to properly obtain the daily value of your accounts to determine the appropriate billing for those days in which there is a delay. In an effort to avoid disrupting the billing process, if we are missing no more than three (3) days, we will use the daily average balance of the Client’s account on the information we do have, to determine the value of the account to bill for the days where such information was delayed. This may result in a slightly higher or lower value of the average daily balance had all the values been available. For SEI programs, program and management fees are calculated daily and payable in arrears net of any income, withholding or other taxes. Summit's fee is calculated and paid monthly, in arrears, based on the month end balance of the account. For Envestnet programs, Clients should review their Statement of Investment Selection for information regarding billing terms. For Outside Investment Monitoring Accounts, advisory fees and Program Fees can be charged however determined by the Client. Some outside investment advisers deduct Summit's advisory fees and Program Fees; other Clients designate a bill-to account. For Retirement Plan Advisory services, advisory fees are charged pursuant to the terms of the agreement. Fees may be negotiable depending on the size and complexity of the Plan. Summit does not require or solicit Clients to prepay fees of more than $1,200, six months or more in advance. For information regarding how to obtain a refund of a pre-paid fee if the IMA is terminated before the end of the billing period, and how any refund will be determined, please refer to your IMA or speak to your Financial Advisor. Clients who engage a Third-Party Manager pay an advisory fee to that manager, typically calculated as a percentage of assets under management. Clients are advised to review the investment advisory brochures and applications/ contracts/agreements with the TPMs and/or sponsors of the investments for complete information on how fees are charged by such parties because their processes for charging fees may change from time to time. Moreover, since Financial Advisors can negotiate their own fee arrangements, some Clients pay flat rates for services rather than asset-based charges, which are deducted differently. Summit receives a portion of the advisory fee paid to certain Third-Party Managers pursuant to platform services agreements. This compensation paid to the Advisor is paid by the Third-Party Manager from its advisory fee and is not an additional fee charged directly to the client. Because Summit receives a portion of the Third-Party Manager's fee, the Advisor has a financial incentive to recommend or retain Third Party Managers that participate in these arrangements or that pay higher platform services fees. This presents a conflict of interest. The amount of platform services compensation received by Summit varies among Third Party Managers and is based on a percentage of assets managed by the Third-Party Manager for Summit’s clients. Summit addresses this conflict by selecting and monitoring Third-Party Managers based on a variety Page 19 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 of qualitative and quantitative factors, including investment strategy, performance, risk management, and client objectives, and not solely on compensation arrangements. Summit’s reported assets under management include assets for which it provides ongoing investment advisory services, including manager selection, suitability analysis, and continuous monitoring. Clients should be aware that the advisory fees charged by Third-Party Managers participating in Summit’s platform services arrangements are higher than those charged by similar managers who do not participate in such arrangements, or higher than if Summit were to provide advisory services without a Third-Party Manager. Clients are not required to select any Third-Party Manager made available through Summit’s platform and may request information regarding alternative investment management options. For the APM Programs, certain Financial Advisors will be charged trading costs to reimburse Summit for trading costs in the APM Program, and therefore have an incentive to limit trading in certain securities or avoid using those securities which would incur trading costs. Please speak to your Financial Advisor for information about any of these incentives. Fees for Financial Planning Services Summit's financial planning fees are negotiable and are generally determined based on the nature and extent of the services being provided, the complexity of the Client's circumstances, as well as the other aspects of the Client's current and historical relationship with the Financial Advisor. All fees are agreed upon prior to entering into an Agreement with any Client. Fees are payable by check in advance and may change depending on whether or not new complexities present themselves. Summit does not require or solicit Clients to prepay fees of more than $1,200, six months or more in advance. Any changes made to a financial planning fee will be discussed with Clients in advance, and a new agreement will be signed to reflect the changes. The fees for financial planning have generally ranged from $2,000 to $25,000, depending upon the complexity of the Client situation. The fees charged to a Client for preparation of financial planning services are paid to Summit and a portion of the fees is paid to the Financial Advisor. If a Financial Advisor discusses matters relating to planning with a Client's tax or legal consultants per the Client's request, the Client may be charged a separate fee by those consultants. There is no minimum dollar value of assets or other conditions required of a Client to receive these services. In the event the Client is not satisfied, the Client may request a fee refund and any unearned portion will be refunded. Other types of fees and expenses Unless otherwise noted on the IMA, Clients are responsible for paying all applicable third-party fees (including, but not limited to, wire fees, foreign transaction fees, margin interest, liquidation fees, ACAT fees, regulatory fees, state-specific taxes and fees, and execution costs charged by broker- dealers and/or the other Qualified Custodians for execution), which are separate and distinct from the fees and expenses charged by Summit. A schedule of such charges for accounts custodied at a Qualified Custodian is provided to Clients at account inception or at any time by the Financial Advisor. Pursuant to certain sub-advisory and client agreements, securities in Client accounts may be liquidated by a subadvisor in their sole discretion, to cover unpaid fees. The Custodians for the SAAs, FMAs, APMs, TPMs and sponsors for other investments (such as hedge funds, REITs, variable annuities, etc.) impose other charges. As noted throughout, Clients are Page 20 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 encouraged to review all documentation provided by those TPMs and sponsors for full and current details regarding their practices. When SEI is used as the Qualified Custodian for the SAA, FMA or APM Wealth Manager-Directed accounts within the two SEI programs, Clients will incur transaction charges. Each case will vary so please contact compliance@sfr1.com or your Financial Advisor if you have any questions. Additionally, all pooled investment vehicles, including mutual funds, ETFs, REITs, hedge funds, and UITs, as well as variable annuities and variable life insurance, have their own internal operating fees and expenses that Clients must pay. These fees and expenses are disclosed in each security's offering documents and vary considerably. These fees and expenses often include operating expenses, management fees, redemption fees, 12b-1 fees, distributor fees, offering fees, administrative fees, concessions and other fees and expenses and increase the expense ratio of the investment. These fees are in addition to the fees charged by Summit. If Clients transfer in B or C share classes of mutual funds and if such shares are liquidated after being transferred to Summit, those shares will incur contingent deferred sales charges (CDSC) from the mutual fund company if they are within the CDSC holding period. Many direct investments are alternative investments which often incur higher costs than many traditional securities such as equities, mutual funds and ETFs. Some, such as hedge funds and private equity funds, also charge incentive or performance fees. Variable annuities and variable life insurance also charge mortality and expense charges, administrative charges, sub-account investment management fees and other applicable fees associated with sub-account options. Summit encourages all Clients to closely review the offering documents for all such investments with their Financial Advisors and to consider the aggregate costs. Additionally, certain Qualified Custodians, including Schwab and Fidelity based on certain criteria, have eliminated commissions for online trades of equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to the Qualified Custodian. We encourage you to review your Qualified Custodian’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. The final decision to custody assets with any of our Qualified Custodians is at the discretion of the Summit client. To see what you would pay for transactions in a non-wrap account, please request the Qualified Custodian’s most recent pricing schedule from your IAR. Outside Compensation for the Sale of Securities to Clients Summit endeavors to use the lowest cost mutual fund share class available to the Client. Many mutual fund companies have offered newer, lower-cost share classes in recent years that are available to fee- paying advisory Clients. Summit periodically reviews its holdings in order to convert higher cost shares to lower cost shares, if available, and endeavors to offer Clients the lowest eligible share class. Even so, Summit cannot ensure that all Clients will hold the lowest cost shares at any given time. Further, some TPMs are more careful about utilizing the lowest cost share class than others. Tactical ETF and Mutual Fund Programs Page 21 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Tactical Model Portfolios provide third-party professionally managed investment allocations which change with the investment markets and economic conditions. The third party sub-advisor is responsible for the day-to-day investment decisions of the Tactical Model Portfolio, including trading frequency and share-class selection. Portfolios often include proprietary funds (both mutual funds and ETFs) where the Subadvisor is earning a fee on allocated solutions. Funds from other providers other than the Subadvisor also are often incorporated for enhanced diversification. Due to the frequency of portfolio changes, no transaction fee (NTF) mutual fund share classes are often employed to alleviate trading costs and maintain accessible portfolio minimums. These models can be employed within unified managed accounts (UMA) which may include strategies from other sub-advisors, determined by the advisor. Although this structure presents potential conflicts related to NTF mutual funds which are often not the least expensive share class, these are mitigated because trading activity reflects the sub-advisor’s investment signals and implementation process, rather than transactions initiated by the Advisor to minimize its own costs. The Advisor periodically reviews the reasonableness of the strategy to ensure it continues to meet the Client’s needs and objectives. Clients who prefer to avoid strategies that utilize higher-expense share classes may request alternative approaches or strategies. As part of financial planning, a Financial Advisor may recommend changes to a Client's insurance coverage. If Clients request their Financial Advisor to assist them in implementing the recommendations in financial planning, the Financial Advisors, in their capacity as insurance agents, may suggest insurance products, which will generate commissions to them. Most of Summit's Financial Advisors have the ability to place insurance as brokers through many insurance companies, including American International Group, Guardian, Lincoln National, MetLife, New York Life, Penn Mutual, Principal, Prudential and William Penn and/or as agents or brokers of Mass Mutual. The Financial Advisors often access these insurance products through SRM, which operates as a Mass Mutual General Agency, or through unaffiliated agencies, including ASH Brokerage and Stonegate Brokerage, among others. Even though the insurance products are typically not included in an advisory program, Clients are advised that some of these insurance carriers pay allowances and benefits to some of the agents and brokers (which include trips, training support, educational conferences among other benefits), which vary considerably from year to year. Mass Mutual regularly supplements these benefits by paying SRM and the Financial Advisors (who are insurance agents) additional allowances and benefits (including subsidies on health insurance and retirement contributions). All of these allowances and benefits are customary in the industry and are in addition to the commissions generated on insurance sales and are based on the volume of business they conduct on an annual basis. These payments are significant to the revenue of the Summit affiliates and to the Financial Advisors. Although this arrangement creates a conflict of interest and incentivizes Financial Advisors to recommend that Clients use Mass Mutual or other insurance carriers which provide higher compensation, Financial Advisors who sell insurance recommend insurance carriers based on what they believe is appropriate for the Client. Summit's Director of Insurance also monitors insurance recommendations to mitigate these conflicts. Item 6. Performance-Based Fees and Side-By-Side Management Not applicable. Neither Summit nor any of its supervised persons accept performance-based fees. Page 22 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Item 7. Types of Clients Summit primarily provides investment advice and/or management supervisory services to the following types of Clients: Individuals and personal trusts • • High Net Worth Individuals • Corporations and/or Business Entities • Pension & Profit Sharing Plans • Charitable Organizations Minimum Account Size The minimum account size for TDS Managed Portfolios is $100,000, which can be waived at Summit's discretion. There is no minimum account size associated with the SAA, APM or FMA programs. Some TPMs have minimums of $25,000 to $1,000,000. Any minimum account size is outlined in the IMA entered into by the Client. Exceptions to minimum account size requirements may be negotiated. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis As discussed in Item 4, Summit and its IARs primarily recommend or select investments in ETFs and mutual funds in the SAA, APM, FMA and Managed Portfolios programs. They also recommend certain outside managers in the TPM program. The analysis for these securities and managers is conducted in the following way. Managed Portfolios and Certain TPMs – Members of the IMC conduct due diligence on securities, investment managers and strategies for the Managed Portfolios and certain TPMs. While various sources of information may be used, the IMC's principal sources of information include fund databases; (ii) financial publications; (iii) management interviews and contacts; (iv) industry trade association statistics; (v) government data; (vi) capital markets data; and (vii) third party research materials that analyze the overall investing landscape as well as specific market sectors and strategies. As appropriate, the IMC also reviews materials supplied by the investment managers including annual reports, factsheets, presentations, fund prospectus/offering memorandum, performance and related investment data, if available. When reviewing the investment strategy and process, performance, risk management and expenses of a prospective investment manager, the IMC evaluates some or all of the following items, among others: • Are the assets under management large enough to efficiently manage a diversified • • • • portfolio but small enough to navigate supply constrained market sectors; Is there a stable investment team with the experience and depth required by the investment strategy; Is there consistency of the investment objective and the strategy followed; Is there a clearly defined investment style and management process; Is there a well-designed benchmark index (e.g., universe of securities, weighting methodology); Page 23 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 • Does the organization have a disciplined management of risk exposures (e.g., market, • interest rate, credit, inflation, currency, liquidity); Is there attractive absolute and risk-adjusted performance, consistent with return and risk objectives. A track record from a different but similar investment vehicle may be used to evaluate performance; • Are volatility and returns during market drawdowns consistent with risk exposures; • Are there positive or neutral supply/demand trends and investor sentiment; • Are the investment characteristics (e.g., geography, industry sectors, valuation, capitalization range, credit quality) consistent with the investment mandate; • Are the types of securities that may be held in the portfolio sufficiently liquid and well understood (i.e., in line with the specific mandate); • Are the costs, including management fees, operating expenses, sales fees and • administrative expenses, marketing expenses, etc., reasonable (i.e., moderate or low for the specific mandate); and Is the product structure attractive and what are the potential tax implications. SAA, APM, FMA and SEI Mutual Fund Portfolios – Given the number of IARs providing advice at Summit, the methods of analysis, investment strategies and investment selections will vary based upon the individual Financial Advisor providing the advice. As noted in Item 4, in the SAA, APM, FMA and SEI Mutual Fund Portfolios programs, Financial Advisors are not limited to using securities that have been reviewed by the IMC. Financial Advisors may conduct their own research and due diligence when making a securities recommendation. Several tools available to Financial Advisors include (i) Morningstar; (ii) Fi360; (iii) Bloomberg; (iv) financial publications; and (v) other sources to construct portfolios and research track records and fundamentals regarding the particular securities recommended. Summit also uses third-party artificial intelligence solutions to support investment research, portfolio analysis, and risk monitoring. These tools are used solely as decision-support resources and do not independently make investment decisions or execute trades. All recommendations and investment decisions are subject to human review and approval. Investment Strategies Certain strategies and securities pose risks to Clients, as detailed below. ETFs: Shares in an ETF can be traded throughout the day on an exchange and are bought and sold at a market price that may differ from Net Asset Value (NAV). When conducting due diligence on ETFs, members of the IMC review additional data on liquidity and trading costs, often including: • Tracking error versus the benchmark index (for passive ETFs); • Premium/discount between the market price of the shares and NAV; • Bid/ask spread; and • Trading volume. Active Strategies: Active investment strategies (including open-end mutual funds and certain TPMs) seek to outperform a benchmark by selecting a portfolio of securities that differs from the benchmark portfolio. Active strategies involve manager risk and are typically more expensive than passive strategies that track benchmark indices. When conducting due diligence on active strategies, members Page 24 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 of the IMC typically participate in a conference call, on-site meeting and/or meeting in Summit's offices with a member of the investment strategy's portfolio management team. Factors evaluated by members of the IMC during the due diligence process include: • Understanding the investment guidelines and discretion given to the investment team; • Understanding the current risk/reward environment for taking on active risk exposures; • Reviewing performance versus a universe of similar strategies; • Considering investment techniques that may be used (e.g., leverage, derivatives, shorting); • Reviewing whether return premium compensates for active portfolio management and trading expenses. The IMC looks at the experience and track record of the manager of each mutual fund and ETF as well as certain TPMs in an attempt to determine if that manager has demonstrated reasonable results and an ability to invest over a period of time and in different economic conditions. The IMC also monitors these mutual funds, ETFs and TPMs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund, ETF or TPM analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as the IMC does not control the underlying investments in a mutual fund, ETF or TPM, managers of different funds held by the Client may purchase the same security, increasing the risk to the Client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the mutual fund, ETF or TPM, which could make the holding(s) less suitable for the Client's portfolio. Investment Platform Due Diligence -TPMs: Summit and its Financial Advisors also recommend some investment platforms that provide integrated portfolio management, administration and reporting. These investment platforms typically offer asset allocation portfolios designed to meet different investment objectives and a broad array of separately managed accounts (SMAs) and investment funds. These platforms are supported by investment specialists in asset allocation, portfolio construction and manager due diligence as well as technology platforms that facilitates custody, trading, tax management and reporting. While members of the IMC conduct due diligence on the investment platforms to validate their business models, ability to identify and access attractive investment managers to the platform and the costs of the platform compared to direct investments, the IMC typically does not conduct diligence on the actual TPMs offered on the platform. When conducting due diligence on investment platforms, members of the IMC typically participate in a conference call, on-site meeting and/or meeting in Summit's offices with a member of the management team. The investment platforms offer a wide spectrum of investments with different asset classes, strategies and risk exposures. Depending on the TPM's internal due diligence processes, the IMC often relies heavily on the due diligence performed by the investment platforms and often conducts additional screening on the TPM's available investments to identify strategies that are suitable for a particular Client's objectives, risk tolerance and other preferences. Alternative Investment Strategies Alternative Investments – including non-traded REITs, Private Equity, Private Credit, Hedge funds and funds of hedge funds will be offered through a Summit advisory program such as SAA or APM. Page 25 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Alternatives, in most cases, have limited liquidity with no available market price or are valued infrequently. Some programs have very long holding periods (10 plus years) with no liquidity for the entire period. Certain Alternative Investments may use leverage, options or derivatives which may increase the risk. Each program has its own characteristics and risks spelled out in an offering memorandum or prospectus. When conducting due diligence on Alternative Investments, many items are examined including all legal documents, financial statements, and depending on the type of investment may include: • Sponsor/advisor track record managing the particular investment or similar investments. • Conflicts of interest that may arise from the relationship between the sponsor, the partnership or other partnerships being managed. Investment opportunity (e.g., supply/demand trends, valuation of private vs. public markets) Investment limits of individual investments in the portfolio (use of leverage and derivatives) • Other investments controlled by the sponsor that may compete for new acquisitions • Pace of capital raising and expected timeframe until the offering is closed to new investments; • The background of the management team managing the portfolio • • Diversification and quality of the portfolio • • Reasonableness of achieving investment objectives • Offering, operational and liquidation fees are not excessive and are competitive with evolving industry practices. If the investment has been reviewed by an independent Due-Diligence Service, the Investment Team will review their reports as additional support. Investment Platform Due Diligence—Alternative Investments: Summit and its Financial Advisors also recommend investment platforms that provide access to alternative strategies such as hedge funds. These platforms are supported by a deep bench of alternative investment specialists that conduct due diligence encompassing the investment and operational risks of the investment funds available on the platform. In some cases, these efforts are outsourced by the platforms to third parties. This independent due diligence bolsters the efforts of the IMC. These platforms provide access to alternative investments that are sometimes only directly available to large institutional investors and utilize technology that facilitates investment execution and reporting. Members of the IMC conduct due diligence on alternative investment platforms to validate their business model, ability to access attractive hedge funds to the platform and the costs of the platforms compared to direct investment. This review covers platform documents, the due diligence reports provided by the platform, fund performance and investment terms such as fees and liquidity. When conducting due diligence on alternative investment platforms, members of the IMC typically participate in a conference call, on- site meeting and/or meeting in Summit's offices with a member of the management team. The IMC may select a small group of investment funds with specific characteristics from the larger universe of funds available on the platform. General Risks Although the IMC and Financial Advisors consider many risks before recommending a security or investment manager to Clients (or investing on their behalf), there are a myriad of circumstances that may cause investments to lose value. Their assessment of any investment manager or security's likely future performance is inherently a prediction and it is subject to uncertainty and risk that the outlook might prove wrong. An outcome contrary to what the IMC or Financial Advisor anticipated may arise Page 26 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 from a number of factors, such as: an erroneous assessment of the value offered by the investment manager/security, a change in strategy by the selected manager, market changes, unanticipated changes to interest rates or the tax code, among others. Summit's IMC and Financial Advisors invest in and recommend securities they believe to be appropriate for the Client based on an understanding of the Client's investment objectives and risk tolerance. Summarized below are relevant risks broadly relating to the types of securities Summit primarily invests in for Client assets; however, securities may be subject to additional risks specific to that security or issuer. Clients are strongly encouraged to review the prospectus disclosures and offering documents relating to the securities held in their portfolios if they have any questions, as these documents discuss in more detail the risks relating to the particular investment. Additional information regarding the general characteristics and risks relating to the types of securities that Summit primarily recommends for Client assets are explained in Summit's "Product Risk Disclosure" document posted on Summit's website at www.SummitFinancial.com. Clients with additional questions regarding a particular security should contact their Financial Advisor. If there is little or no trading activity in the account, a Client will pay more in advisory fees than commission charges than if the account was a brokerage account. Specific Risks Clients participating in the Managed Portfolios program should understand the underlying holdings within the Managed Portfolio (mutual funds and ETFs) involve risk and the potential of loss. Money markets used in Managed Portfolios are generally considered low risk but are not guaranteed and may be subject to loss and or change in market value. Mutual funds and ETFs often provide diversification but may be concentrated in a particular asset category or class within a category. Investments in funds impose risk due to exposure to economic forces or factors for which the future is uncertain. Some of these are unique to individual funds, but many are common to many funds. A fund's risk depends on how closely its return is coupled with given indexes, the riskiness of each index and how closely the indexes tend to move together. The level of overall investment market diversification will vary depending on the Managed Portfolio(s) used as well as the underlying exposures of the underlying funds. The risk in a Managed Portfolio or collection of Managed Portfolios is a function of the underlying asset classes utilized. Further, all investment strategies involve risk and the investment performance and success of any strategy cannot be predicted or guaranteed. Past performance should not be used to forecast future results. Hedge funds are speculative in nature and may use leverage or other aggressive investment practices. As a result, Client returns may be highly volatile, and Clients may lose all or a portion of the investment in the fund. Clients who invest in commodities (through hedge funds that specialize in this asset class) should know that commodities are subject to world events, limited liquidity, shifting market preferences, trade signal disruption, supply/demand imbalances, currency movement and many other things that cannot be successfully predicted, but do have a significant impact on future results. The use of artificial intelligence-based solutions may rely on historical data, assumptions, or third- party inputs that are incomplete, outdated, inaccurate, or misleading, and may not fully reflect current market conditions or issuer-specific developments. In addition, such tools may incorporate modeling Page 27 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 limitations, simplified assumptions, or unintended biases and may fail to anticipate unusual or rapidly changing market events, which could result in underperformance or losses. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a Client, should be prepared to bear. This list of risks is not exhaustive. When Clients invest in mutual funds, ETFs, UITs and newly issued municipal bonds, for example, they receive prospectuses and official statements which identify the risk factors associated with those securities and issuers. Clients are encouraged to review such disclosure documents. Similarly, Clients are encouraged to review the offerings documents for private investments and the investment advisory brochures for all TPMs for additional risk disclosures. Please contact your Financial Advisor or research@sfr1.com if you have questions about your investments. Item 9. Disciplinary Information Not applicable. Summit has no legal or disciplinary events to disclose. Item 10. Other Financial Industry Activities and Affiliations LS Securities, LLC ("LSS") – LSS is a limited purpose broker dealer owned by SFH. LSS does not provide brokerage or other services to any retail customers and has no direct relationship with any of Summit's Clients. PKS, PCS, and APW, who are unaffiliated broker-dealers, pay a referral fee to LSS on the brokerage business that Summit's Financial Advisors conduct in their capacity as RRs of these unaffiliated broker dealers, and some of that brokerage business may be with persons who are also Summit Clients. Other unaffiliated broker-dealers do not pay similar referral fees. This means that even though Summit is not involved in the brokerage activity conducted at PKS, PCS, and APW, even if conducted with Summit Clients, Summit's parent company will profit by the Financial Advisor's brokerage activity. Please contact your Financial Advisor if you have any questions. Summit Risk Management, LLC – SRM is a Delaware limited liability company and is licensed to sell non-securities insurance products and earns commissions or remuneration on such products. No variable insurance products are sold through SRM. Many of the Clients of SRM are also Clients of Summit. Most persons associated with Summit are also associated with SRM. Most Summit Financial Advisors are insurance brokers or agents under an SRM agency relationship. Merchant Wealth Management Holdings 3, LLC – Merchant Wealth Management Holdings 3, LLC ("Merchant Wealth"), an entity wholly owned by Merchant Wealth Partners, LLC ("MWP"), owns a controlling interest in the Advisor. Merchant Wealth is wholly owned by MWP, a Company managed by MWP Advisory, LLC, a registered investment advisor, which is wholly owned by Merchant Page 28 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Investment Management, LLC (“Merchant Investment”). Merchant Investment, through MWP, has ownership interests in various companies that provide investment and other consulting services to financial firms, including investment advisors ("Investment Solutions"). The Advisor is provided access to use these Investment Solutions, where the Advisor may utilize the Investment Solutions pursuant to an engagement that the Advisor enters into directly with the third party providing the Investment Solution. These Investment Solutions may include, but are not limited to, third party money managers, private investments, pooled investment vehicles, or other investment products for which a commission is earned. Engagement of and with these Investment Solutions poses a potential conflict of interest due to the minority ownership interest that Merchant Investment's or MWP's various subsidiaries own in the third parties providing these Investment Solutions. Through these ownership interests in the third parties that provide these Investment Solutions, Merchant Investment or MWP will benefit from additional revenue that is generated when the Advisor engages any of these third party service providers. Accordingly, the Advisor has an incentive to engage one or more of these Investment Solutions. In an effort to ensure these conflicts of interest are addressed, the Advisor has implemented a risk control and disclosure framework, the objective of which is for the Advisor to select Investment Solutions that are in the best interest of the Client. Although Merchant Wealth has a controlling interest in the Advisor, the Advisor operates as a Fiduciary and seeks to ensure Client’s interests are met and will ensure appropriate disclosure of all relevant conflicts of interest and disclose how such conflicts are mitigated. Merchant offers opportunities for qualified Summit clients to invest in Merchant both directly and indirectly. While Summit does not receive any additional compensation for these investments, the offering does create a conflict of interest since Summit will benefit directly and indirectly from these investments through its affiliation with Merchant. Sextant Securities, LLC – Summit Financial, in which Merchant Wealth has an indirect minority, non- controlling ownership interest, may engage Sextant Securities, LLC ("Sextant"), an affiliated Broker- Dealer owned by Merchant Investment, to access certain investment products, which may include, but not be limited to, private equity funds, open-ended and close-ended mutual funds, and other products for which Sextant earns a commission if they are sold (herein "Security Offering"). As a result of Merchant Investment's ownership of Sextant, Merchant Investment may benefit from revenue and/or placement fees received by Sextant if a Financial Advisor invests any Client funds into a Security Offering. Accordingly, Summit has an incentive to have Financial Advisors invest Client funds into a Security Offering. In addition, there is no requirement for a Financial Advisor to recommend to a Client a Security Offering offered through Sextant. Prior to recommending a Security Offering, the Financial Advisor will conduct appropriate due diligence to ensure that any recommendation to invest Clients funds into a Security Offering aligns with the Client's investment needs and objectives. In addition, the Financial Advisor will provide additional disclosure information to each Client, which will include relevant details regarding material financial interests and compensation surrounding the Security Offering. Maxim Income Opportunity Fund I, II, III, and IV L.P. – Summit may recommend that Clients invest into the Maxim Income Opportunity Fund I, II, III, and IV L.P. (herein "Maxim"), a Security Offering of Sextant. Individual owners of Merchant Wealth, in their separate capacity, have material ownership interests in Maxim. As a result, these individuals stand to benefit financially from additional investments made into Maxim and from returns generated by Maxim. These individual owners of Maxim, who also have an indirect ownership interest in Summit, would benefit financially in their Page 29 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 individual capacity if Summit invests Client funds into Maxim. Notwithstanding this conflict of interest, Summit and its Financial Advisors will only invest Clients in Maxim if it is suitable for the Client's investment objectives. Lastly, there is no requirement for Summit to recommend Maxim to Clients, nor are Clients obligated to invest into Maxim. Treville Capital Management Certain individuals of Merchant Investment are each affiliated with GPS Investment Partners ("GPS"), which, either individually or via affiliated entities of GPS, is an investor in both Merchant and the parent company of Treville Capital Management (“Treville”). Each, either individually or via affiliated entities, individually may also be investors in funds managed by Treville. Additionally, certain funds and accounts managed by Treville are invested in Merchant. The affiliations above create a conflict of interest as GPS and Treville directly and/or indirectly benefits from any fees generated due to an investment in any of Treville’s products. In addition, certain owners of Merchant are also board members of Treville. Prior to recommending an investment in an offering by Treville, your Summit Financial Advisor has conducted the appropriate due diligence to determine that such investment aligns with your investment needs, risk tolerance and investment objectives. However, it is your choice as to whether you invest based upon such a recommendation and in light of the conflicts raised in this disclosure statement. Redwood Real Estate Income Fund Summit may recommend that Clients invest in the Redwood Real Estate Income Fund (herein "Redwood Fund"), a fund managed by Redwood Investment Management, LLC (herein "Redwood"), in which Merchant Wealth Partners holds an indirect, non-controlling minority stake in Redwood. In addition, Redwood Fund may invest in loan opportunities that are originated by Maxim Capital Fund (herein "Maxim Capital"), an affiliated entity of Maxim, where individual owners of Merchant Wealth hold a material ownership interest. This poses a conflict of interest due to the minority interests Merchant holds in both Summit and Redwood. As a result, your Financial Advisor has an incentive to invest client assets into the Redwood Fund. The Redwood Fund's investment objective is to provide current income and preserve shareholders' capital. The Fund seeks to achieve its investment objective by investing in U.S. commercial real-estate income investments. These investments may include but are not limited to senior mortgage loans, second lien mortgages, also known as junior or sub-ordinated debt, mezzanine loans, and participation interests in such mortgages or debt. The Fund will also invest up to 20% of its net assets in short- duration fixed income instruments. The Fund is an appropriate investment only for those investors who do not require a liquid investment. Prior to the recommendation of Redwood Fund, your Financial Advisor conducts the appropriate due diligence to ensure that any recommendation to a Client to invest in Redwood Fund aligns with the Client's investment needs and objectives. In addition, the Financial Advisor will provide the Client with the necessary disclosures and offering documents of Redwood Fund so that the Client can carefully review the risks, fees and other important information related to the fund. Neither Summit nor its Financial Advisors will receive any additional compensation for investing Client assets into Redwood Fund. In addition, there is no requirement for the Financial Advisor to recommend Redwood Fund to a Client, nor are Clients obligated to invest in Redwood Fund. Page 30 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Third-Party Managers Summit has entered into platform services agreement with certain independent third-party investment advisors and portfolio managers pursuant to which the Summit provides due diligence, manager selection and monitoring, operational and administrative support, billing, coordination, technology access and related platform services. In connection with these arrangements, Summit receives compensation from the Third-Party Managers based on assets managed for its clients. Waterfall Bank Stan Gregor, Chief Executive Officer of Summit Financial, also serves as a board member of Waterfall Bank. Neither the Advisor, any advisory affiliate, nor Mr. Gregor receives any compensation or other benefit in connection with this arrangement. Clients of the Advisor are not required to engage Waterfall Bank for banking services. Relationships or Arrangements with Related Persons As detailed in Item 5 above, in their capacities as insurance brokers or insurance agents, Summit's Financial Advisors receive fees, commissions and other remuneration from non-Clients including insurance companies for their insurance activities. Some of that insurance activity generates revenue to SRM as well. Financial Advisors who are registered with PKS or other broker-dealers, will offer brokerage products, for which such Financial Advisors will receive compensation, in their capacity as RRs of the broker dealers. As noted above, LSS will receive a referral for such business through PKS or other unaffiliated broker dealers. Your Financial Advisor's obligations to you when selling insurance or securities differs from his or her obligations to you when he or she is acting as a Financial Advisor through Summit and except as noted herein, Summit does not supervise those activities. You are under no obligation, however, to purchase any other products or services from your Financial Advisor. SummitVantage™ SummitVantage is a brand slogan only used for marketing purposes to identify the services offered by the Summit affiliated firms. It is not an operating entity and offers no products or services. SummitVantage is used in the recruitment and retention of financial advisors. Selection of Other Investment Advisers As noted in Item 4 – Advisory Business, Summit may recommend TPMs as providers of investment management services for Clients. Summit's fee is typically added to the fee charged by the TPM. This relationship and the fees are described in the IMA, and in some programs, an additional agreement between the Client and the TPM. This practice creates a conflict of interest in that the Financial Advisor has an incentive to direct Clients to those managers who provide Summit with a larger fee split. Some TPM programs provide higher payouts to the Financial Advisors than Summit's other advisory programs, but the amount of compensation will depend on the fee agreement negotiated with the Client. Summit may recommend Piton Investment Management, LP ("Piton") as a TPM. Piton is a SEC- registered investment advisor focusing on fixed income investment management services to Page 31 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 institutions and high net worth individuals. Individual owners of Merchant Wealth, in their separate capacity, have ownership interests in Piton. As a result, these individuals stand to benefit financially from additional investments placed with Piton. These individual owners of Piton, who also have an indirect ownership interest in Summit, would benefit financially in their individual capacity if Summit invests Client funds into Piton. Notwithstanding this conflict of interest, Summit and its IARs will only invest Clients with Piton if it is suitable and in accordance with the Client's investment objectives. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Summit believes it owes Clients the highest level of trust and fair dealing. As part of its fiduciary duty, Summit endeavors to put the interests of its Clients ahead of the interests of the firm and its personnel. Summit has adopted a Code of Ethics that emphasizes the high standards of conduct the firm seeks to observe. Summit personnel are required to conduct themselves with integrity at all times and follow the principles and policies detailed in our Code of Ethics. Summit's Code of Ethics attempts to address specific conflicts of interest it has identified or that could likely arise. Summit personnel are required to follow guidelines in areas such as prohibitions on insider trading, personal securities transactions, conflicts of interest, gifts, confidentiality and privacy, compliance procedures, certification of compliance, training, record keeping and adherence to applicable securities laws. Clients may request a copy of Summit's Code of Ethics by contacting (973) 285-3600 or by emailing compliance@sfr1.com. Personal Trading Practices Summit supervised persons are not permitted to acquire beneficial ownership of any securities in an initial public offering (IPO) or purchase any private placements without the prior written approval of Summit's Chief Compliance Officer. Summit does not require pre-clearance for personal securities transactions other than IPOs or private placements. Summit does not hold or trade securities for its own accounts, although from time to time, Financial Advisors of Summit may trade in securities for their own accounts that they also buy or recommend to Clients, and they also may trade in different securities that they do not feel are appropriate for certain Clients (including related securities, such as warrants or options). The conflict presented in this practice could lead to a Financial Advisor purchasing or selling a security in advance of a Client and/or receiving a better price. Summit monitors such transactions to look for potential conflicts of interest and to reasonably ensure that representatives of Summit transact Client business before their own when the same securities are being bought or sold at or around the same time. Summit executives are expected to invest in a Merchant offering that will also be offered to Clients that are "qualified purchasers". For the executives that participate in the Merchant offering, there will be compliance procedures in place to ensure that any transactions related to such investments are not in conflict with the positions taken on behalf of the Client. These procedures are to mitigate any potential conflicts. Page 32 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Item 12. Brokerage Practices Soft Dollar Arrangements Summit does not engage in soft dollar arrangements. Trade Aggregation Transactions for each Client in the TDS Managed Portfolios and the SAA, APM and FMA programs will be effected independently and are not "batched". For trade aggregation practices in connection with TPM programs, Clients should refer to the investment management agreements they enter into with the TPMs, as well as the disclosure brochures for the TPMs. Best Execution Summit maintains a fiduciary duty to seek the best execution pricing available for Client transactions. While best execution is difficult to define and challenging to measure, there is some consensus that it does not solely mean the achievement of the best price on a given transaction. Rather, it is a collective consideration of factors concerning the trade in question. Such factors include the security being traded, the price of the trade, the speed of the execution, apparent conditions in the market and the specific needs of the Client. Additionally, for certain Clients, the availability of short interest rebates or similar credits may reduce overall costs and improve net results for Clients, providing an economic benefit to the Client. Summit's primary objective when placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as price, size of order, difficulty of execution and broker skill. Based on these criteria, the firm may not necessarily pay the lowest commission or commission equivalent, as specific transactions can involve specialized services on the part of the broker. Brokerage for Client Referrals Summit has an incentive for Financial Advisors to select PKS as the broker-dealer to conduct brokerage business in furtherance of a financial plan or otherwise, as LSS will receive a referral fee on such brokerage business. In addition, as stated earlier, most Financial Advisors are also RRs of PKS, an unaffiliated broker dealer, and when acting in their capacity as RRs they will receive compensation for securities brokerage services conducted at PKS. Selection of Brokers Clients in Summit's wrap programs must execute transactions through FBS. For additional information, please see Summit's Wrap Fee Program Brochure. For some TPM programs, the executing broker is affiliated with the custodian of the assets. For additional information, please refer to the brochure of the TPM. Item 13. Review of Accounts Page 33 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 The Managed Portfolios are reviewed on a continuous basis by the IMC. SAAs, APMs, FMAs, TPMs, SEI MAS and SEI MF (and Wealth Manager-Directed assets within the SEI programs) are reviewed on a continuous and regular basis by the Financial Advisor providing supervisory services to the account. The Outside Investment Monitoring accounts may be reviewed on a regular or on a periodic basis – as determined by the Client and Financial Advisor at inception of the relationship. Additional reviews are triggered by material market, economic, or political events, or by changes in Client's financial situations, such as retirement, change in employment or marital status, physical move, inheritance or other life events. Each Client will receive written statements from the Custodian that detail the Client's positions and activity. Many Financial Advisors also provide their Clients with periodic performance reports, which may show performance across multiple accounts within a household. Clients are advised to always compare those reports to the statements provided by the qualified Custodians, which are the official records of the accounts. Item 14. Client Referrals and Other Compensation Economic Benefits Provided by Third Parties for Advice Rendered to Clients Summit and its Financial Advisors receive economic benefits from third parties in a number of ways. Please see Item 5 – Fees and Compensation for additional details. Generally, Financial Advisors are compensated through Summit on a percentage of the advisory fee charged to the Clients' accounts (often referred to as a "grid" or "net" payout). The payout percentage varies based upon the advisory program, service or TPM selected. Moreover, Financial Advisors with higher total revenue generally receive higher "grid" payouts. Most of the revenue paid to Summit from Clients are also split with the Financial Advisors. Additionally, if Financial Advisors recommend insurance in connection with financial planning service to Clients many of the Financial Advisors receive significant allowances from Mass Mutual or other insurance companies, as discussed in Item 5 – Fees and Compensation and in the Financial Advisor Brochure Supplements. SRM receives allowances as well. This variability in Summit's practices with respect to retention of advisory fees creates an incentive to Financial Advisors to steer Clients to programs or services that generate higher revenue to them, although Summit believes the Financial Advisors focus on each Client's specific needs in recommending an advisory program, combination of programs or service. Certain Financial Advisors receive other types of support from SEI and insurance companies. Payments from insurance companies are made to Financial Advisors in their capacity as securities or insurance brokers or as insurance agents and are routed through Summit or an affiliate. These payments frequently include reimbursement for marketing costs (such as paying for Client meetings or mailing expenses). These tend to be modest and are often a few hundred dollars. These third-party firms may also pay for travel and attendance at due diligence meetings, conferences, Client relationship building events and other events that benefit the Financial Advisor financially and educate them about the sponsors' products, services and support. These types of reimbursements are intended to result in the Financial Advisor's promotion of their investment products and create an incentive for the Financial Advisors, often acting as RR or insurance brokers/agents, to steer Clients to invest with sponsors who deliver these economic benefits. All of these payments and reimbursements are customary in the industry and are in addition to the commissions generated on insurance sales. Clients are not required to purchase products recommended or offered by our insurance brokers or agents. Page 34 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Summit also has agreements whereby it receives promoter or service fees for referring Clients' assets to be managed by certain TPMs. The Financial Advisors typically provide advisory services in connection with those assets as well. For additional information and disclosures about promoter or service arrangements, please see the written disclosure document you will receive in connection with any referral to a TPM for which a solicitation fee is earned, as well as your investment management agreement with any TPM to whom you are referred. Certain service providers including subadvisors and TPMs that provide services to Summit's clients, have a revenue fee share or service arrangement with Summit. This causes Summit to have a conflict of interest as it has incentive to recommend these service providers over others where they do not have this incentive. Please contact your Financial Advisor to find out if your service provider has this arrangement with Summit. The Advisor receives ongoing compensation from certain Third-Party Managers in connection with client participation in the Advisor’s investment advisory platform. This compensation is based on a portion of the advisory fees paid to the Third-Party Managers and represents an economic benefit to the Advisor that is not paid directly by clients. This arrangement creates a conflict of interest because the Advisor has a financial incentive to recommend Third-Party Managers that participate in the platform or that pay higher fees. The Advisor seeks to mitigate this conflict by evaluation and selecting Third-Party Managers based on investment merit and client suitability, and not solely on compensation arrangements. Summit or its affiliated firms and certain Financial Advisors will receive referral payments from banks and other financial institutions as applicable for referring Summit Clients to use their products and services. This includes bank loans, asset backed securities loans, financial and other such type loans, etc. These payments may be in the form of a one-time payment or ongoing trails. Summit and the Financial Advisor will not receive any such payments for Clients that are considered ERISA Plans or prohibited under ERISA laws. Summit does not supervise or review any such referrals by the Financial Advisor. Summit is not responsible for any such recommendations. The Financial Advisor is acting outside of advisory duties and responsibilities that are overseen by Summit. These referral payments create a conflict of interest because your Financial Advisor may direct you to one firm over another in order to receive such payments. Summit mitigates this conflict on such recommendations and referrals by disclosure in this brochure. Summit receives certain non-cash benefits from Hamilton Lane Advisors, LLC (“HLA”), including complimentary subscriptions to research materials, industry data, and analytical tools for use by Summit’s IMC. Summit’s eligibility for these benefits is based on the aggregate amount of client assets maintained with HLA, which creates an incentive for Summit to maintain assets with HLA. Summit mitigates this conflict by using these resources solely to support the IMC’s investment analysis and oversight. None of the Summit Financial Advisors receives these benefits separately, and there is no requirement that they place client assets with HLA. Recommendations to allocate client assets to HLA are made based on each Financial Advisor’s independent assessment of the client’s objectives and circumstances, and Summit’s fiduciary obligation to act in the client’s best interest. Summit may recommend or require that clients establish brokerage accounts with certain Qualified Custodians, including Schwab Advisor Services division of Charles Schwab & Co., Inc. (hereinafter Page 35 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 "Schwab"), which are registered broker-dealers, members SIPC, to maintain custody of clients' assets and to effect trades for their accounts. The final decision to custody assets with Schwab or other Qualified Custodians is at the discretion of the Summit client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Summit is independently owned and operated and not affiliated with Schwab or any of the Qualified Custodians. Schwab, or other Qualified Custodians as applicable, provide Summit with access to its institutional trading and custody services, which are typically not available to their retail investors. These services generally are available to independent Financial Advisors on an unsolicited basis, at no charge. Schwab, or the other Qualified Custodian as applicable, services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab, and other Qualified Custodians as applicable, also make available to Summit, and certain affiliated firms, other products and services that benefit Summit or its affiliates but may not benefit its clients' accounts. These benefits may include national, regional or Summit specific educational events organized and/or sponsored by Schwab or the other Qualified Custodians. Other potential benefits if applicable include occasional business entertainment of personnel of Summit by Schwab or the qualified custodian personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Summit in managing and administering clients' accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of Summit's fees from its clients' accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of Summit's accounts, including accounts not maintained at the qualified custodian. Schwab, or the Qualified Custodians if applicable, also make available to Summit other services intended to help Summit manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab, or other Qualified Custodians if applicable, make available, arrange and/or pay vendors for these types of services rendered to Summit by independent third parties. Schwab Advisor Services and the other qualified custodians may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to Summit. While, as a fiduciary, Summit endeavors to act in its clients' best interests, Summit recommendation/requirement that clients maintain their assets in accounts at Schwab or another qualified custodian may be based in part on the benefit to Summit of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab or the qualified custodians, which creates a potential conflict of interest. As noted above, Summit's parent company receives an economic benefit through LSS for brokerage business that the Financial Advisors conduct in their capacity as RRs of PKS, PCS, and APW. Page 36 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Compensation to Non-Advisory Personnel for Client Referrals Summit compensates third parties, including individuals and entities not affiliated with our firm, for client referrals (“Promoters”). These referral arrangements are designed to introduce prospective clients to our advisory services and may include cash payments or other forms of economic benefit. Each Promoter or referring party is required to provide the prospective client with a separate written disclosure statement that outlines: • The nature of the relationship between the solicitor and our firm, • Whether the promoter received any compensation (direct or indirect, cash or non-cash) for the testimonial or endorsement. • Any potential conflicts of interest that may arise from the referral. These arrangements are made in accordance with Rule 206(4)-1 and applicable state regulations. Clients are not obligated to accept services from Summit as a result of a referral by a Promoter. Item 15. Custody The SEC defines custody as holding Client funds or securities, directly or indirectly, or having the authority to obtain possession of them. Summit is deemed to have custody over Client assets because, among other things, the Clients' authorization in the IMA directs Custodians to accept all instructions from Summit related to such assets. Because it has custody, Summit is obligated to adhere to additional safeguards which include reasonably ensuring Client assets are maintained with a "qualified Custodian" (a legal term by the SEC), notifying the Clients of the name and address of the qualified Custodian (if Summit opens the account), having a reasonable belief the qualified Custodian sends statements no less than quarterly and engaging an independent public accountant to examine those assets on a surprise basis every year. The accountant performing the "surprise" examination will contact some of Summit's Clients to confirm their holdings with those listed on the records of the Advisor. Summit urges Clients to compare the account statements they receive from their Custodian with any performance report or statements Summit or its service providers may create for them. Item 16. Investment Discretion Summit, acting through the CIO, has discretionary authority over the accounts invested in the Managed Portfolios Program. The CIO and the Investment Committee determine the securities to be bought or sold, the amount of securities to be bought or sold and the timing of the purchases and sales of the securities. In FMAs and APMs, including the SEI Wealth Manager Directed accounts, the Financial Advisor exercises discretion and determines the securities to be bought or sold, the amount of securities to be bought or sold and the timing of the purchases and sales of the securities. The exercise of discretion is noted in the investment management agreements and/or the Advisory Program Schedule documents as appropriate, which are signed by the Clients. Item 17. Voting Client Securities Page 37 of 38  Summit's Investment Advisory Disclosure Brochure March 16, 2026 Summit will not request or accept voting authority for Clients. Clients will receive proxies directly from the issuer of the security or the Custodian. Clients should direct all proxy questions to the issuer of the security. Item 18. Financial Information Summit does not require or solicit Clients to prepay fees of more than $1,200, six months or more in advance. Page 38 of 38 

er Page Wrap Fee Program Brochure March 16, 2026 4 Campus Drive Parsippany, NJ 07054 (973) 285-3600 www.SummitFinancial.com This wrap fee program brochure provides information about the qualifications and business practices of Summit Financial, LLC. If you have any questions about the contents of this brochure, please contact us at (973) 285-3600. 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 Summit Financial, LLC is available on the SEC's website at www.adviserinfo.sec.gov. Summit Financial, LLC is acting as SEC registered investment adviser under Section 203(g) of the Investment Advisers Act of 1940. Registration does not imply a certain level of skill or training.  Summit Wrap Fee Program Brochure March 16, 2026 Item 2. Material Changes The Wrap Fee Brochure provides information about a variety of topics relating to an Advisor's business practices and conflicts of interest. In particular, this Wrap Fee Brochure discusses wrap fee programs offered by Summit. Material Changes The following are the material changes since Summit Financial LLC’s last annual update, dated March 31, 2025. Item 4 has been updated with additional information about the different cost structures with different Qualified Custodians, and the potential conflicts the different cost structures create. Also, details about a new program called APM Plus have been added, along with other information about a potential conflict of interest created by recommendations of non-purpose loans. Information about incentives to use Summit’s investment strategies or approved third-party managed solutions platforms has also been provided in Item 4, along with additional information about fees and other charges, including Summit’s Program Fee and the fee for using the Pontera platform which creates an incentive for Summit to recommend the Pontera platform over other platforms. Future Changes From time to time, we may amend this Wrap Fee Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Wrap Fee Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Summit Financial. At any time, you may view this Wrap Fee Brochure and the current Investment Advisory Disclosure Brochure on-line at the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 299322. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (973) 285-3600. Page 2 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Item 3. Table of Contents Item 1. Cover Page…………………………………………………………………………………. 1 Item 2. Material Changes………………………………………………………………………….. 2 Item 3. Table of Contents………………………………………………………………………….. 3 Item 4. Services, Fees and Compensation………………………………………………………… 4 Item 5. Account Requirements and Types of Clients……………………………………………21 Item 6. Portfolio Manager Selection and Evaluation……………………………………………22 Item 7. Client Information Provided to Portfolio Managers……………………………………29 Item 8. Client Contact with Portfolio Managers………………………………………………... 29 Item 9. Additional Information…………………………………………………………………...30 Page 3 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Item 4. Services, Fees and Compensation About Summit Financial, LLC Summit Financial, LLC ("Summit," "Summit Financial," or the “Advisor”), a Delaware limited liability company is a successor to Summit Equities, Inc.'s registration under Section 203(g) of the Investment Advisers Act of 1940 ("Advisers Act"). Established in 2018, Summit Financial has succeeded from the advisory businesses of Summit Equities, Inc. ("SE"), which had been providing investment advisory and financial planning services since 1991. Summit is wholly owned by Summit Financial Holdings, LLC ("SFH") which is owned by Stanley Gregor and Merchant Wealth Management Holdings 3, LLC (“MWMH”). MWMH is wholly owned by Merchant Wealth Partners, LLC, a Company managed by MWP Advisory, LLC, a registered investment advisor, which is wholly owned by Merchant Investment Management, LLC. Summit offers investment advisory services to individuals, high net worth individuals, corporations and/or business entities, pension and profit-sharing plans, and charitable organizations (each referred to as a "Client" or collectively as "Clients"). Summit serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, Summit upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Summit's Clients do not all use the same qualified custodian. Custodians for Summit include National Financial Services LLC (“NFS”), an affiliate of Fidelity Brokerage Services, LLC ("FBS"), Schwab Advisor Services LLC (“Schwab”). Goldman Sachs, SEI, and Pershing LLC (together “Qualified Custodians”) which provide brokerage services in connection with Client accounts. All clients will complete documentation provided by the Qualified Custodian of their choice at account opening and may have also been notified of their selected Qualified Custodian via the Advisory Program Schedule (“APS”) attached or incorporated by reference to their Investment Management Agreement ("IMA"). Summit has different cost structures established with each Qualified Custodian and therefore benefits differently depending on which Qualified Custodian is selected. Additional costs related to ticket charges from certain Qualified Custodians are passed on to advisors as well, creating an incentive to avoid trading certain securities which may incur those costs. Please see below for additional information. Please contact your Financial Advisor or Summit at research@sfr1.com for additional information regarding custodians. Each advisory relationship at Summit is managed by one or more financial advisors registered with Summit as an investment adviser representative (hereinafter referred to as "IAR(s)" or "Financial Advisor(s)"). The Financial Advisor serves as the primary point of contact between Summit and the Client. The Financial Advisor collects financial information from the Client and based on the Client needs recommends specific advisory services or programs to Client. Some Financial Advisors choose to incorporate more of Summit's resources in their provision of advisory services to their Clients than others do, such as consultations with internal Summit specialists. Page 4 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Some of the Financial Advisors are also associated with unaffiliated broker-dealers Purshe Kaplan Sterling Investments ("PKS")1, Aurora Private Wealth Inc. ("Aurora") and Private Client Services ("PCS") (collectively herein referred to as "Unaffiliated Broker Dealers"). These Unaffiliated Broker Dealers are registered with the SEC as a broker-dealer and are members of FINRA and SIPC. Financial Advisors who are associated with Unaffiliated Broker Dealers can provide brokerage services in the capacity of a Registered Representative ("RR") of that broker-dealer. All brokerage products offered by the Financial Advisor are provided in their capacity as an RR through their broker-dealer, not through Summit or its affiliates. The Financial Advisors who provide (i) investment advisory services, including asset management and financial planning services, through Summit (ii) insurance through Summit Risk Management, LLC ("SRM"), and (iii) brokerage services through an Unaffiliated Broker Dealer are independent contractors or employees of each of these companies. In addition, certain Financial Advisors that are registered with Summit are employees of affiliated or unaffiliated entities. Some Financial Advisors have other material business interests as well, as described in their Form ADV Part 2B Brochure Supplement ("Financial Advisor Brochure Supplement.") SRM is an affiliate of Summit and Item 9 - Additional Information contains more details about SRM. Some of our Financial Advisors operate their business under a "doing business as" ("DBA") firm. The investment advisory and financial planning products and services offered through their DBAs are provided through Summit. Other business lines such as brokerage and insurance services and products, provided through their DBA, are provided through other unaffiliated and affiliated firms. For more information about a Financial Advisor or their DBA, please refer to the particular Financial Advisor's Brochure Supplement. A Financial Advisor with Clients in the Program(s) is compensated by Summit for providing investment advisory and related services. The amount of this compensation varies and may be more than what the Financial Advisor would receive if paid separately for investment advice and such other services. Accordingly, Financial Advisors have a financial incentive to recommend a Program over other investment advisory services provided by Summit. For additional information regarding this conflict, please speak with your Financial Advisor and also see Item 6, Portfolio Manager Selection and Evaluation, Related Persons & Supervised Persons. This Wrap Fee Program Brochure describes the Programs offered by Summit to existing and new clients. Other advisory services offered by Summit are described in another brochure, Summit's Investment Advisory Brochure, which contains the information required by Part 2A of Form ADV. Types of Advisory Services Summit offers several different asset management programs (each a "Program") to its advisory Clients. For the assets in its Programs, Summit provides continuous and regular supervisory or management services (as defined by the SEC) based on the Client's individual goals, objectives, time horizon, risk tolerance, liquidity needs, investment assets and income ("financial circumstances") utilizing the 1 SE assisted the Financial Advisors who wished to continue to remain registered representatives of a broker-dealer to register with Purshe Kaplan Sterling Investments a broker dealer and member of FINRA and SIPC ("PKS"). PKS is not affiliated with SE or its successors. If the Financial Advisor continues to offer brokerage products to Clients, it will not be through Summit or any of its affiliates but will be through PKS, or other unaffiliated broker dealers as appropriate. PKS, PCS, and Aurora, through a referral agreement, pay a referral fee to a broker dealer that is owned by Summit Financial Holdings, LLC (LS Securities, LLC) for the brokerage business conducted by the Financial Advisors at PKS, PCS, and Aurora. Other unaffiliated broker dealers do not pay similar referral fees. Page 5 of 37  Summit Wrap Fee Program Brochure March 16, 2026 investment strategy selected by the Client. Financial Advisors obtain a financial profile for each Client to aid in the construction of a portfolio that matches the Client's specific situation and needs. Many Clients maintain "household" relationships, in which multiple accounts for an individual or members of a family are managed jointly to maximize efficiencies. Please note, the term "Client" used herein includes such households and their account(s) are referred to as "Account(s)". For all of the different types of asset management programs, the Financial Advisor will assist Clients in assessing their goals, risk tolerance, income and tax situation and selecting an investment strategy and asset allocation that is appropriate for the Client's specific circumstances. However, Summit and its Financial Advisors do not provide tax advice to Clients. Summit, through its Financial Advisors, is available to Clients on an ongoing basis to discuss Client financial circumstances, the selected portfolio and the securities therein or to process instructions from Clients concerning advisory assets. Summit or a sub-adviser as applicable will exercise discretion in connection with certain Programs, as described below and in the Investment Management Agreement ("IMA") between Summit and the Client. In connection with the non-discretionary services or program, it is up to the Client to decide whether to accept or reject Summit's recommendations. Summit's securities recommendations seek to be consistent with a Client's financial circumstances and any reasonable guidelines or restrictions provided by a Client. A Client may choose to give full discretion to Summit and their Financial Advisor to manage a portion or all of their assets. By signing the Discretionary Investment Management Agreement, Client appoints Summit and the selected Summit Financial Advisor to provide investment advisory and investment management services on a discretionary basis for assets in the Client's designated accounts which may include all accounts in the Client's household. Summit shall have the power and authority to supervise and direct on a discretionary basis the investments of and for the Account(s) of the Client. The Client grants Summit ongoing and continuous discretionary authority to execute its investment recommendations in accordance with the objectives of the Client as communicated to Summit and/or the Financial Advisor, without the Client's prior approval of each specific transaction or investment. Under this authority, the Client shall allow Summit to purchase and sell securities and instruments in the Account(s), arrange for delivery and payment in connection with the foregoing, select and retain sub-advisors, deduct fees from the Account(s) of the Client, and act on behalf of the Client in all matters necessary or incidental to the handling of the Account(s), including monitoring certain assets. Summit does not vote proxies on issues held in the Account(s). All transactions in the Client Account(s) shall be made in accordance with the directions and preferences provided to Summit by the Client and include all Accounts designated under one household unless otherwise requested by Client. The Client will execute all required forms related to Summit's trading authority as required by each Qualified Custodian. By entering into the aforementioned Discretionary Investment Management Agreement, Client understands and acknowledges that certain Assets in the Account(s) may be invested in strategies or portfolios managed by Summit wherein Summit and/or the Financial Advisor collects additional fees, which creates a conflict of interest. Summit is aware of this conflict of interest created by providing Summit and the Financial Advisor full discretion and has adopted practices to supervise the services provided for discretionary accounts. Client should review these conflicts with their Financial Advisor. Page 6 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Unless otherwise instructed by the Client, all dividends and other distributions will be reinvested in Client accounts. The investment strategies used by Summit vary by Client, as they are based on their individual circumstances. Clients are advised to notify Summit promptly if there are changes in their financial situation, investment objectives or if they wish to impose any reasonable restrictions upon Summit's investment management services. Clients can engage Summit to manage all or a portion of their assets on a discretionary or non-discretionary basis, by designating one or more advisory programs in connection with their IMA with Summit. Some parties that are not affiliated with Summit, such as FBS, require Clients to enter into additional written contracts directly with such party for the services they provide. All investments have risk and there is no guarantee that utilizing the asset management services of Summit or its Financial Advisors will produce favorable results. 1. Summit Managed Portfolios Summit Managed Portfolios ("Managed Portfolios") are custom designed portfolios constructed by Summit's Investment Management Committee ("IMC"), which includes the Chief Investment Officer ("CIO") and members of the Investment Management Department. The IMC meets regularly to oversee the Managed Portfolios. The IMC also conducts quarterly meetings with the Investment Committee, an advisory group of Financial Advisors, to discuss changes to the Managed Portfolios as well as other investment topics. Summit, acting through the Chief Investment Officer, has discretionary authority over the accounts managed under the Managed Portfolios program. The IMC determines the asset allocation, the securities to be bought or sold, the amount of securities to be bought or sold and the timing of the purchases and sales of the securities. Given the long-term nature of many Managed Portfolios strategies, many Managed Portfolios accounts may have little or no activity during a given period. Summit currently offers a variety of Managed Portfolios2 through its wrap program, some of which are broad, internally diversified Managed Portfolios, while others target a specific industry or market, or a combination of target industry and/or market exposures. The Managed Portfolios primarily use mutual funds and exchange traded funds (ETFs) to achieve various mixes of domestic equities, international equities, fixed income, real asset alternatives and hedging strategies. The Managed Portfolios are generally designed to be tax efficient and are more strategic in nature than tactical. Although Summit has full discretion over all assets managed under the Managed Portfolios Program, it is not uncommon for accounts in the Program to have few or no trades between annual rebalancing. Clients should consider this in deciding whether Managed Portfolios is an appropriate choice for them, in light of the fact that (i) brokerage is included within the cost of the Program and (ii) Clients pay the same wrap fee regardless of the number of transactions. If there are few trades made in a Client's account, then a wrap fee program such as Managed Portfolios would not be a more cost effective option for the Client as compared to non-wrap programs (although Summit does not offer these services as a non-wrap option). 2 In addition to the Managed Portfolios operated as wrap programs, Summit manages additional Managed Portfolios that do not constitute wrap programs. Those non-wrap model portfolios are addressed in Summit's Form ADV Part 2A Firm Brochure. Page 7 of 37  Summit Wrap Fee Program Brochure March 16, 2026 If you have any questions, please speak with your Financial Advisor or contact research@sfr1.com. All of the securities held within Managed Portfolios have daily liquidity. Each Financial Advisor works with the Client to develop an allocation strategy best suited to the Client's financial needs and circumstances. Financial Advisors often recommend multiple Managed Portfolios to achieve the Client's goals. Each Managed Portfolio is allocated similarly, but not necessarily identically, for all Clients whose accounts are managed in accordance with that Managed Portfolio and annual rebalancing is done, as necessary, to drive each Managed Portfolio account to desired weightings, as the portfolio may deviate from the target over time. A Client will have an account for the securities underlying each Managed Portfolio, but many Clients have multiple accounts, each of which is allocated in accordance with a different Managed Portfolio to achieve their recommended allocations. Occasionally, a Client requests and Summit permits non-Managed Portfolio securities positions to be maintained in a Managed Portfolio account. This includes, but is not limited to, tax loss harvesting strategies where certain depreciated investments can be sold in an effort to realize a tax loss to offset capital gains and be temporarily replaced by other investments that are not substantially identical (as defined by the IRS) but are otherwise highly correlated. 2. Strategic Asset Allocation ("SAA") The SAA program enables Financial Advisors to custom design portfolios for Clients, taking into account the Client's financial circumstances. The Financial Advisor does not have discretion over the assets and must get approval from the Client before entering any trades. SAA accounts primarily include assets for which regular and continuous supervision or management services are provided but from time to time, they hold specific investments for which the Financial Advisor provides only consultative and administrative services, including periodic monitoring, reporting and/or servicing.3 Although most SAA accounts are primarily allocated among mutual funds and ETFs, some Financial Advisors recommend that their Clients also hold individual positions in stocks, bonds, traded and non- traded REITs, hedge funds (including funds of funds), unit investment trusts ("UITs") or other securities. Mutual funds, UITs and ETFs often provide diversification but may be concentrated in a particular asset class or investment style. The risk in these investments is determined by the risk in underlying holdings (e.g., a stock mutual fund's risk is determined by the risk of the stocks in the fund). Further, some of the selected securities may be less liquid than those utilized in the Managed Portfolios. The Financial Advisors are invited to consult with members of the IMC regarding particular securities but they are not required to, and some choose to rely solely on their own due diligence regarding the securities or third party managers ("TPMs"). Clients should speak to their Financial Advisor to understand how their Financial Advisor determines which securities to recommend. Given the long-term nature of many strategies used in the SAA, SAA accounts may have little to no activity during a given period. If there are few trades made in a Client's SAA account, then a wrap fee program such as SAA will not be the most cost-effective option for the Client as compared to non-wrap programs. If you have any questions, please speak with your Financial Advisor or contact research@sfr1.com. For certain assets, such as those invested in hedge funds and non-traded REITS, or those managed by third parties 3 who have a direct relationship with the Client, Summit and the Financial Advisor provide ongoing advice and monitoring rather than what the SEC refers to as "continuous and regular supervisory services." Page 8 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Most assets held in connection with the SAA program are custodied at Qualified Custodians, but the assets can also be held at an issuer, hedge fund, etc. If alternative non-traded investments (such as non- traded REITs or hedge funds) are linked to a Qualified Custodian account, the assets may be identified on the custodial statement but the actual securities are often held with and valued by the sponsor of the security. The custodial statements may not segregate these positions separately from securities that are held within the account although they do note that non-traded REITs are "Based on an Independent Appraisal," and hedge funds are "Based on Program Management's Unconfirmed Estimate of Net Asset," or a similar notation is provided. As of December 1, 2022, all alternative investment purchases occur in SAA accounts. Assets held in connection with the SAA program are custodied at a Qualified Custodian or elsewhere as selected by the Client. If the assets are custodied at a Qualified Custodian, they are part of Summit's Wrap Fee Programs. Please take note that SAA accounts at certain Qualified Custodians have been grandfathered in from previous programs as non-wrap accounts and therefore are not part of Summit's Wrap Fee Programs. Please see Summit's Form ADV Part 2A Firm Brochure for information about SAAs that are non-wrap, including the nature of the advisory services provided, fees and expenses, and discussion of relevant conflicts of interest. Clients can refer to their APS document, IMA or contact their Financial Advisor to determine if their SAA account is a Wrap or Non-Wrap account. 3. Advisor as Portfolio Manager ("APM") / Flexible Managed Accounts ("FMA") The APM and FMA programs are similar to the SAA program except that the Financial Advisor has discretion to place trades without contacting the Client for approval. The APM and FMA programs are the same. The FMA program name was updated to APM in 2021; however, both FMA and APM accounts can still be opened. Direct investments, such as non-traded REITs and hedge funds, are generally not included in APMs or FMAs. The Financial Advisor reviews the Client's financial circumstances and exercises discretion to determine the securities to be bought or sold in the Client's account, the amount of securities to be bought or sold and the timing of the purchases and sales of the securities. The securities used in these accounts generally include mutual funds, ETFs, UITs, equities, and fixed income. Mutual funds, UITs and ETFs often provide diversification but may be concentrated in a particular asset class or investment style. The risk in these investments is determined by the risk in underlying holdings (e.g., a stock mutual fund's risk is determined by the risk of the stocks in the fund). The Financial Advisors are invited to consult with members of the IMC regarding particular securities or when constructing portfolios, but they are not required to, and some choose to rely solely on their own due diligence regarding the securities recommended. Some Financial Advisors select securities that are less liquid than those utilized by the IMC in connection with the Managed Portfolios. Certain Financial Advisors use option strategies and ETFs for hedging including inverse ETFs. In addition, some Financial Advisors have created their own portfolios that they manage within an APM/FMA account. Clients should speak to their Financial Advisor to understand how their Financial Advisor determines which securities to buy and sell. In certain limited instances, a client will be given authorization to trade securities in their own account. Given the long-term nature of many APM/FMA strategies, an APM or FMA account may have little or no activity during a given period. If there are few trades made in a Client's APM/FMA account, then a wrap fee program such as APM/FMA will not be the most cost-effective option for the Client as Page 9 of 37  Summit Wrap Fee Program Brochure March 16, 2026 compared to non-wrap programs. Some Financial Advisors are more tactical and may trade more often to manage risk and/or seek opportunities. There are tax implications to more active approaches and there is no guarantee that these strategies will provide greater returns or lower risk. Clients should discuss the approach with their Financial Advisor. For more information on these fees and the APM/ FMA Program or if you have any questions, please contact with your Financial Advisor or email research@sfr1.com. Assets held in connection with the APM/FMA programs may be custodied at a Qualified Custodian or elsewhere and are part of Summit's wrap fee programs. Certain APM and FMA accounts at Qualified Custodians have been grandfathered in from previous programs as non-wrap accounts and are not part of Summit's Wrap Fee Programs. Please see Summit's Form ADV Part 2A Firm Brochure for information about APMs and FMAs that are non-wrap, including the nature of the advisory services provided, fees and expenses, and discussion of relevant conflicts of interest. Clients can refer to their APS, IMA or contact their Financial Advisor to determine if their APM or FMA account is a Wrap or Non-Wrap account. 4. APM Plus The APM Plus program represents a partnered approach between the Advisor, Financial Advisor and Summit’s investment team to implement strategies best aligned with the client’s objectives and overall risk tolerance. The Financial Advisor will consult with the Summit investment team for investment decisions and trades will be implemented by the Summit Trading Group. Based on the needs of the client, Accounts can be allocated to a variety of strategies including but not limited to: model portfolios consisting primarily of commingled funds (ex. ETFs, Mutual Funds), separately managed accounts of individual stocks and/or bonds, select alternative investments and third-party managers. Accounts can incorporate tactical or dynamic changes based upon the opportunity set but also incorporating the tax status of the account. Tax capabilities and or strategies may also be employed for suitable accounts at additional expense; these can include direct indexing, tax loss harvesting (TLH), tax optimization, and intelligent tax transition. Because these strategies may involve more frequent portfolio changes, the Advisor utilizes no transaction fee (“NTF”) mutual fund share classes in order to implement the strategy in a sustainable and efficient manner, reduce transaction costs associated with trading, and maintain accessible investment minimums. The use of NTF funds may result in clients bearing higher internal fund expenses than other available share classes or investment options, and lower transaction expenses to the Advisor. The Advisor, as a fiduciary, determines that the use of such funds are in the client’s best interest when consistent with the overall design of the strategy, the client’s objectives, and the efficient implementation of the strategy. These strategies may also be implemented within unified managed accounts (“UMAs”), which can include strategies managed by third-party managers, as determined in coordination with the Advisor, Financial Advisor and the Summit investment team. Your Summit Financial Advisor will provide regular and continuous review of your assets in the Investment Program and may recommend periodic rebalancing. If Summit terminates third party manager relationship, it will promptly notify the Account holder to discuss reallocation of the assets. Page 10 of 37  Summit Wrap Fee Program Brochure March 16, 2026 5. Sub-advisory Accounts Summit also provides access to third party sub-advisors that provide discretionary asset management services to Summit Clients. These sub-advisors offer portfolios with a range of investment strategies and objectives, including equity, fixed income, cash and alternative strategies such as options overlay and tax management. These sub-advisors actively manage Client assets and have discretion to buy and sell investments without first receiving client authorization. Clients should consult with their tax professionals for tax advice related to the tax strategies. The Financial Advisor provides continuous and regular review of the assets in these portfolios and may recommend periodic rebalancing. Clients utilizing sub-advisors are advised to review the sub-advisor investment advisory brochures and disclosures carefully. For additional information regarding the sub-advisor managing your assets including a description of their strategies, fees and billing terms, please review the sub-advisor's ADV, your Summit APS, or the Program Disclosure for accounts that have authorized full discretion to their Financial Advisor. If you have questions about any subadvisor to your accounts, please speak with your Financial Advisor or contact research@sfr1.com. Tactical ETF and Mutual Fund Programs Tactical Model Portfolios provide third-party professionally managed investment allocations which change with the investment markets and economic conditions. The third party sub-advisor is responsible for the day-to-day investment decisions of the Tactical Model Portfolio, including trading frequency and share-class selection. Portfolios often include proprietary funds (both mutual funds and ETFs) where the Subadvisor is earning a fee on allocated solutions. Funds from other providers other than the Subadvisor also are often incorporated for enhanced diversification. Due to the frequency of portfolio changes, no transaction fee (NTF) mutual fund share classes are often employed to alleviate trading costs and maintain accessible portfolio minimums. These models can be employed within unified managed accounts (UMA) which may include strategies from other sub-advisors, determined by the advisor. Although this structure presents potential conflicts related to NTF mutual funds which are often not the least expensive share class, these are mitigated because trading activity reflects the sub-advisor’s investment signals and implementation process, rather than transactions initiated by the Advisor to minimize its own costs. The Advisor periodically reviews the reasonableness of the strategy to ensure it continues to meet the Client’s needs and objectives. Clients who prefer to avoid strategies that utilize higher-expense share classes may request alternative approaches or strategies. Affiliated Third Party Manager Seeds Investor LLC ("Seeds") was founded by two Financial Advisors of Summit. Seeds is a SEC- registered investment advisor that provides strategies for Summit clients. Summit is a minority owner of Seeds and engages Seeds to provide sub-advisory services to its advisory clients. This affiliation creates a conflict of interest, as Summit has an incentive to use and recommend the Seeds platform. The Financial Advisor founders of Seeds also have a conflict of interest due to their IAR positions at Summit and ownership in Seeds. Please request the related Financial Advisor's Part 2B brochure for the conflicts and the steps taken by Summit to mitigate the conflicts if you are interested in using Seeds Page 11 of 37  Summit Wrap Fee Program Brochure March 16, 2026 as a subadvisor. Please see Summit fees related to Seeds herein and please see the Seeds ADV for additional details related to fees and costs. 6. Third Party Manager – Atria Investments, LLC ("Atria"), also conducting business as Adhesion Wealth Advisor Solutions, Inc. ("Adhesion") Adhesion offers investment services on a discretionary basis selected by the clients in the program which may include the selection of a Model Portfolio or Model Allocation, requests for specific actions to be taken in the account, account investing parameters and restrictions, and enrollment in Tax Overlay Portfolio Management (Tax OPM) services. A model portfolio is a recommended set of security purchases or sales via a weighted list comprised of individual securities. A model allocation is an asset allocation in the form of a weighted list of asset classes, a set of Model Portfolios, individual mutual funds and/or ETFs selected for the asset classes, and parameters meant to guide the ongoing implementation of the asset allocation. Tax OPM services seek to minimize negative tax consequences of portfolio management. Your Financial Advisor provides continuous and regular review of the assets in the Adhesion program and may recommend periodic rebalancing. Clients utilizing this strategy are advised to review Atria Investments, LLC's ("Atria") investment advisory brochures. For further detail related to this program, Client should review Atria's ADV 2A and related documents, and any applicable third party subadvisor's ADV and related documents. For any questions on this program, please contact your Financial Advisor or email research@sfr1.com. Certain Adhesion accounts have been grandfathered in from previous programs as non-wrap accounts and are therefore not a part of Summit's Wrap Fee Programs. Please see Summit's Form ADV Part 2A Firm Brochure for information about Adhesion accounts that are non-wrap, including the nature of the advisory services provided, fees and expenses, and discussion of relevant conflicts of interest. Clients can refer to their Advisory Program Schedule document, IMA or contact their Financial Advisor to determine if their Adhesion account is a Wrap or Non-Wrap account. 7. Alternative Investments Held Directly ("AID") The AID Program enables your Financial Advisor to recommend Alternative Investments based on your needs and circumstances. These are held directly at the issuer, not at one of Summit's Qualified Custodians, but may be shown on your custodian statement. You must approve each recommended transaction. All assets are subject to regular and continuous supervision or management. Liquidity, custody and other features of Alternative Investment are detailed in the offering documents that you sign with the issuer, platform manager or other third party. Certain AID accounts have been grandfathered in from previous programs as non-wrap accounts and are not part of Summit's Wrap Fee Programs. Please see Summit's Form ADV Part 2A Firm Brochure for information about AID accounts that are non-wrap, including the nature of the advisory services provided, fees and expenses, and discussion of relevant conflicts of interest. can refer to their Advisory Program Schedule document, IMA or contact their Financial Advisor to determine if their AID account is a Wrap or Non-Wrap account. 8. Meeder Investment Management Programs On or about April 2024, as part of a joint venture transaction between Meeder Asset Management Inc. Page 12 of 37  Summit Wrap Fee Program Brochure March 16, 2026 and Summit's affiliated firm, SUMDR Merchant LLC, Summit Financial, LLC will assume the retail investment advisory business of Meeder Asset Management Inc. ("MAM"). The MAM financial advisors will become investment advisor representatives (IARs) of Summit. MAM and MAM's affiliate, Meeder Advisory Services, Inc. ("MAS") will provide sub-advisor services for some of those accounts where MAM and MAS manage and trade on the accounts in the Meeder Programs at Summit. For other accounts, MAS will perform "strategist services" to the accounts that are managed and traded by Summit in the Meeder Investment Management Programs at Summit Financial. MAS will offer a series of portfolios on the Summit platform which will be available based on the client's investment objectives. Please contact your Summit Wealth Manager if you have any questions regarding your account. Other Aspects of Asset Management In its provision of investment advice and asset management, Summit utilizes various types of securities including, but not limited to, mutual funds, ETFs, equities, UITs, fixed income, hedge funds, private placements, traded and non-traded REITs and insurance products such as variable life insurance and variable annuities. Summit offers the same suite of services to all of its Clients. However, each Financial Advisor determines, based on his/her own analysis, management style and preferences, in conjunction with each Client's specific profile and financial circumstances, which services and products to recommend, and whether to recommend the Programs or Summit's non-wrap advisory programs. Clients may impose reasonable restrictions on Summit regarding investing in certain securities or types of securities in accordance with their values or beliefs (or based on their employer or regulatory restrictions). However, if the restrictions prevent Summit from properly servicing the Client's account, or if the restrictions would require Summit to deviate from its standard platform of services, particularly with respect to the Managed Portfolios, Summit reserves the right to end the relationship. When Summit refers to “family office” services, it generally means a combination of services tailored to high-net-worth families, such as: • Wealth Management Services: Customized investment planning, asset allocation, and portfolio management • Asset Allocation and Rebalancing: Account monitoring based on market conditions and client- specific changes. • Financial Planning & Consulting on topics such as cash flow management and tax filings. • Business Planning for financial and tax matters • Retirement Plan Advisory: Fiduciary services for company retirement plans under ERISA. • Use of Sub-Advisers: Engagement of third-party managers for specialized advisory services. The Firm views client relationships holistically and may recommend a combination of tailored services to meet the needs of high-net-worth families, which could include but not be limited to the above. Certain services are provided separately and in the event there are additional charges for these services, clients will enter into a separate agreement. Page 13 of 37  Summit Wrap Fee Program Brochure March 16, 2026 As Summit absorbs certain transaction costs in wrap fee accounts, Summit may have a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. Summit does not charge its clients higher advisory fees based on their trading activity, but clients should be aware that it has an incentive to limit its trading activities in the clients' account(s) because it is charged for executed trades. Non-Purpose Loans and Lines of Credit The Advisor may introduce certain Clients to a non-purpose loan or line of credit program made available through a bank or lending affiliate associated with the Client’s qualified custodian (the “Lending Program”). In such instances, eligible assets held in the Client’s Account[s] may be pledged as collateral for the non-purpose loan or line of credit. A recommendation to utilize a Lending Program presents a conflict of interest because the Advisor will generally continue to receive investment advisory fees on the assets pledged as collateral, as assets will not leave the Client's Account[s]. Clients are not obligated to engage the Advisor in connection with any Lending Program and may obtain similar lending arrangements through other lenders or through the custodian directly. For additional information regarding risks associated with non-purpose loans and lines of credit, including risks of forced liquidation and market-related declines in collateral value, please see Item 6 – Portfolio Manager Selection and Evaluation. Administrative, Execution and Clearance Services Clients participating in the asset management programs are required to enter into an agreement with a Qualified Custodian to open a brokerage account that will hold the assets of the Client's portfolio. For the Summit Wrap Fee accounts, with the exception of some fixed income trades in the SAA, FMA and APM Programs, and the fixed income trades in the Municipal Bond Program (further information about all such programs in this regard is provided below), all orders for the purchase or sale of securities in Client portfolios will be cleared by the Qualified Custodian. Summit periodically evaluates the execution services of Qualified Custodians to determine the extent to which Clients receive best execution and price improvement and to review that such services remain competitive and are in the best interest of the firm's Clients. Summit does not receive any investment research and/or services in connection with directing orders to any Qualified Custodians. Some Financial Advisors route fixed income order flow to prime brokers in connection with the SAA, FMA and APM programs. These practices are subject to certain conflicts of interest which are discussed in further detail below. Summit typically aggregates Clients' purchase and sale orders for securities held (or to be held) in the Managed Portfolios Program and then transmits "batched" orders in an effort to reduce market impact and to obtain best execution. When an order is so aggregated, the actual prices applicable to the aggregated transaction will be averaged and the account and each other account participating in the aggregated transaction shall be treated as having purchased or sold its portion of the securities at such average price. Where the batched order is not filled in its entirety, Clients will be deemed to have purchased or sold a proportionate share of the securities involved unless otherwise warranted by particular circumstances, such as residual position size. In some cases, aggregating orders adversely affects the size of the position obtainable, and in some cases, Clients would receive better price execution if they did not participate in a batched order. Certain Financial Advisors aggregate or batch Page 14 of 37  Summit Wrap Fee Program Brochure March 16, 2026 trades in the SAA, FMA or APM Programs. Clients should contact their Financial Advisor with any questions about batched orders. It should be noted that Summit has an incentive to direct Clients to select certain Qualified Custodians to provide brokerage and clearing services and custody for their Accounts. Based on the amount of assets placed with some Qualified Custodians, Summit receives transition and/or support services payments from the Qualified Custodian as an incentive to place more assets with them. Summit also has different financial arrangements, including higher or lower costs, with each Qualified Custodian. In addition, pursuant to a transaction-based fee schedule with Summit, some Qualified Custodians also offer to waive commissions. This waiver applies to transaction fee-based accounts only. Commission free trading applies on domestic stocks and ETFs, bond transactions entered directly through Fidelity's bond trading system, domestic options and transaction fee mutual funds in accounts with assets under management over $1 million or that have been set up for full eDelivery. (Clients do not pay ticket charges on transactions and the cost of their brokerage is included in the wrap fee for the Program they select.) Clients should be aware that Summit will not reduce the wrap fee for any Program by the value of the waiver. Based on these waivers, Summit is incentivized to focus on portfolios of ETFs and stocks, as well as No Transaction Fee ("NTF") mutual funds and enter bond trades directly through Fidelity's bond trading system instead of other mutual funds and securities that Summit is charged a transaction fee. Many funds charge additional transaction costs or have higher custodial charges for transactions for which the customer would not be receiving the recommended share class for. Summit's IMC manages this conflict by selecting the lowest cost share class for all mutual funds. For Financial Advisor managed accounts, Financial Advisors have the ability to recommend the lowest cost share class or ETFs and are not disincentivized from these recommendations. After the expiration of this NTF waiver period, Summit will have an incentive to minimize Clients' overall trade volume in all securities because it will be responsible for paying the ticket charges incurred in connection with all trades placed with and executed through the participating Qualified Custodians. Summit has an incentive not to recommend certain types of securities because of the higher ticket charges that would be incurred. For example, Summit will not be charged in connection with Client orders in certain funds affiliated with the Qualified Custodian that participate in their No Transaction Fee ("NTF") program but will be charged for the purchase of shares in no-load or load-waived, non- affiliated mutual funds that do not participate in the NTF program, and charged an additional fee for purchases of shares in the non-NTF mutual funds that do not pay a servicing fee to the Qualified Custodian (including both asset based or position based servicing fees) for such fund or share class ("Non-Participating CUSIPs"). This pricing structure creates a conflict of interest and provides Summit with an incentive to recommend the Qualified Custodian's affiliated funds and NTF program funds over other mutual funds. In addition, Summit will be charged transaction charges per trade with respect to exchange traded funds ("ETFs") other than iShares ETFs and certain affiliated ETFs; this creates a similar conflict of interest and provides Summit with an incentive to recommend iShare ETFs and the Qualified Custodian's affiliated ETFs over other ETFs. Summit is also charged various fees in connection with trades in individual equities, options and fixed income securities (such as municipal bonds and corporate bonds), including trade away fees in connection with individual equities and fixed income securities; this creates a conflict of interest and provides Summit with an incentive to recommend investments that do not charge these fees over individual equities, options and fixed income securities, and also an incentive to direct trades in individual equities and fixed income Page 15 of 37  Summit Wrap Fee Program Brochure March 16, 2026 securities to the Qualified Custodian rather than other brokers who may provide better execution services to Clients. The trade-away and other various fees charged in connection with fixed income securities create a conflict specific to the SAA, FMA, APM, and Municipal Bond Programs. In particular, some Financial Advisors managing SAA, FMA, and APM accounts direct their individual fixed income trades to prime brokers rather than the Qualified Custodian, which would cause Summit to incur the trade-away fee for each such fixed income transaction. Because of the additional expenses Summit incurs in connection with the fixed income trades in the SAA, FMA, APM, and Municipal Bond Programs, Summit has an incentive to recommend other Programs over the SAA, FMA, APM and Municipal Bond Programs for Clients who invest in fixed income securities. However, Summit believes this conflict is significantly mitigated by, among other things, the fact that the Financial Advisors who recommend a Program, do not absorb these charges directly and are thus not influenced by these additional costs. Summit is aware of the foregoing conflicts of interest created by the Transaction-Based Fee Schedule and has adopted practices to monitor (i) recommendations and advice provided by its supervised persons for suitability; (ii) the amount of trading in Client accounts to assess consistency with Client investment profiles, and (iii) the quality of execution received from the Qualified Custodians with respect to individual equity and fixed income trades to assess Client trades directed to the Qualified Custodian receive best execution. Further, Summit negotiated the rates in the Transaction-Based Fee Schedule so that the costs for trades are lowest on the investment products used most frequently by Summit and its Financial Advisors, which mitigates the conflict. With limited exceptions, equities, options and fixed income securities (other than in some sub-advisory accounts) represent a small percentage of assets in the Programs. The costs of the execution services provided by the Qualified Custodian for the custody, clearance and administrative services provided by them are included in the total fee for each Program, as described below and in the Advisory Program Schedules incorporated into the Client's IMA. Additionally, certain Qualified Custodians, including Schwab and Fidelity based on certain criteria, have eliminated commissions for online trades of equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to the Qualified Custodian. We encourage you to review your Qualified Custodian’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. The final decision to custody assets with any of our Qualified Custodians is at the discretion of the Summit client. To see what you would pay for transactions in a non-wrap account, please request the Qualified Custodian’s most recent pricing schedule from your IAR. Wrap Fees When a Client decides to participate in any of the programs described above, Summit charges a wrap fee, which consists of an annual advisory fee and an annual program fee. The wrap fee includes the costs of investment advisory, execution, clearance and administrative services provided by Summit, the custodians, broker of record on the account and any prime brokers under the Programs (exclusive of certain third-party fees for optional services which are separate and distinct from the fees and expenses charged by Summit and are further described below). Both the advisory fee and the program fee are Page 16 of 37  Summit Wrap Fee Program Brochure March 16, 2026 negotiable. Some clients who move their accounts to Summit from another firm will pay different fees than clients who open new accounts at Summit. In some instances during a transition of assets to Summit under the same Custodian, there is a delay at the Custodian in providing valuation information needed to properly obtain the daily value of your accounts to determine the appropriate billing for those days in which there is a delay. In an effort to avoid disrupting the billing process, if we are missing no more than three (3) days, we will use the daily average balance of the Client’s account on the information we do have, to determine the value of the account to bill for the days where such information was delayed. This may result in a slightly higher or lower value of the average daily balance had all the values been available. For additional information regarding the negotiability of these fees, please contact your Financial Advisor or Summit at research@sfr1.com. Advisory Fee Financial Advisors set the annual advisory fee component of the wrap fee for the Programs, so long as the maximum advisory fee does not exceed the limits of the advisory fee schedule below. Financial Advisors consider various factors in determining what level of advisory fee to charge, which may include the nature and size of the overall Client relationship with the Financial Advisor, the size of the Program account, and/or the type of advisory products or services likely to be provided through Summit and its affiliates. Part of the advisory fee is paid to the Financial Advisors as compensation for the services they provide under the Programs. Since Summit began providing investment management services, it has had other legacy advisory fee schedules in effect, which were generally higher than described below. As new advisory fee schedules are put into effect, they are made applicable only to new Clients, and fees to existing Clients are not affected. Therefore, some existing Clients pay different advisory fees than shown below. The maximum advisory fee for the Programs is 1.50%, exclusive of the program fee, sub- advisory fees, third-party manager fees, platform fees, and fees not covered by a Wrap Program that are charged by the Qualified Custodian. The advisory fees charged for assets in the Programs are included in the written IMA between Summit and the Client. As noted above, certain components of the wrap fee are negotiable at the sole discretion of the Financial Advisor. In accounts that do not pay program fees, Summit retains 10-15% of the advisory fee component. The Financial Advisor does not receive additional compensation for his/her role as the portfolio manager in connection with the SAA, FMA or APM Programs. Pontera Fee In the Pontera program, there is an additional charge of 30 bps to Clients; 25 bps is paid to Pontera for use of the Pontera platform and a 5 bps fee is paid to Summit for our administrative services charge. The compensation creates an incentive for Summit to recommend the Pontera platform over other platforms. More information about Pontera is available in Summit's Form ADV Part 2A Firm Brochure. Page 17 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Summit Program Fee As noted above, persons who participate in any of the programs described in this Brochure also pay an annual program fee (“Program Fee”). Some clients who move their accounts to Summit from another firm will pay different fees than clients who open new accounts at Summit. The Program Fee includes for all accounts an annual Account Maintenance charge of $120 per year billed monthly or quarterly depending on the billing frequency of the account. Therefore, there is a benefit to Summit to opening more accounts, but the portfolio construction and design, including how many accounts are appropriate, is the responsibility of the IAR, who does not participate in the Account Maintenance fee payments. There is also a benefit to Summit for advisors selecting programs that have a higher Program Fee. Beginning in 2026, certain Financial Advisors will share in Program Fees as additional compensation or credits against expenses. In addition, certain Financial Advisors will receive a higher multiple if they sell part or all of their Advisor Revenue to Summit or an affiliate, or receive a forgivable loan to join Summit from another firm based on a higher amount of assets in the Managed Portfolios or TPM programs. These programs have higher program fees than the APM program, which creates an incentive for Advisors to recommend the programs with the higher Program Fee. If you have any questions regarding the Program Fee or incentives, please ask your Financial Advisor. Financial Advisors who enroll clients in APM programs are billed for ticket charges, except at Goldman Sachs, because Goldman charges an asset-based fee regardless of ticket charges. This creates a conflict because IARs that do more trading or have higher ticket charges are incented to select Goldman Sachs, compared with other Qualified Custodians. Goldman also charges Summit an asset- based fee instead of ticket charges like other Qualified Custodians do. Therefore, since the asset-based fee can be a higher or lower cost to Summit, lower operational costs incentivize use of Goldman by Summit’s Advisors, depending on a Client’s account holdings and trading frequency. For APM program assets custodied at Goldman Sachs, Program fees for clients are not discounted based on asset size. In addition, since Summit pays Goldman an asset-based fee, the Program Fee for APM accounts is not discounted. Household Size Up to $3,000,000 $3,000,001 - $5,000,000 $5,000,001+ Annual Program Fee 0.15% 0.125% 0.10% Due to the additional requirements and services provided by the Financial Advisor, accounts in the FMA and APM programs will use less resources from Summit's Investment Management Team, thus have lower fees than certain other Summit account programs. The annual Program Fee for these programs is based on the aggregate value of the household subject to Summit's program fee per the schedule below and an annual Account Maintenance charge of $120 per year billed monthly. Page 18 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Household Size Annual Program Fee* Up to $3,000,000 $3,000,001-$5,000,000 $5,000,001+ 0.08% 0.06% 0.05% *For FMA and APM accounts custodied at Goldman Sachs, Summit's program fee will be 0.08% for all accounts regardless of household size and an annual account maintenance charge of $120 per year billed monthly. For the Adhesion program, Summit's annual program fee will be 0.08% for all accounts regardless of household size and an annual account maintenance charge of $120 per year billed monthly. The annual Program Fee is assessed at the household level, meaning that the relevant fee percentage from the table above is applied to the aggregate value of the assets subject to the annual Program Fee for an individual or members of a family. The total fees charged under any Program may be higher than what another investment adviser would charge for a similar combination of services, or what would be charged by Summit or another investment adviser if the investment advisory and brokerage services were provided separately. The relative cost of each Program is affected by such factors as the administrative costs associated with the Programs, the fees charged when investment adviser and brokerage services are purchased separately, the size of the Client's account, and the level of trading activity in the Client's account. For the APM Programs, certain Financial Advisors will be charged trading costs to reimburse Summit for trading costs in the APM Program, and therefore have an incentive to limit trading in certain securities or avoid using those securities which would incur trading costs. Please speak to your Financial Advisor for information about any of these incentives. Payment of Wrap Fees Pursuant to the IMA signed by Clients, the Qualified Custodian is authorized to deduct the applicable advisory and program fee on a monthly basis in the month the services are provided. The advisory fee and the program fee are calculated by multiplying the average daily account value of the prior month by the annual fee, divided by 365, multiplied by the number of actual days in the month. For example, the January fees are based on the average daily balance of a Client's account in December. Unless otherwise agreed to by the Client, Summit calculates the average daily account balance based on all days within the period, including weekends and market holidays, which means that Friday valuations account for 3/7th of the average. This applies to all of the Programs custodied at NFS or one of the other Qualified Custodians. These fees will appear as management fees on the monthly statements issued by the custodian. Most investments are valued daily or monthly, some quarterly. For non-marketable securities, Summit will use third party or sponsor provided values. If no value is available, Summit will use the cost until a better valuation is available. Some accounts, which have been open for a long time, prepay fees. Some clients will have advisory fees deducted from accounts quarterly in arrears. Advisory fees and program fees for the previous calendar quarter are calculated based on a percentage of the client's asset value at the end of the most recent calendar quarter. Page 19 of 37  Summit Wrap Fee Program Brochure March 16, 2026 If you have questions about your particular fees, please speak with your Financial Advisor. Please note, Summit does not require or solicit Clients to prepay fees of more than $1,200, six months or more in advance. For information regarding how to obtain a refund of a pre-paid fee if the IMA is terminated before the end of the billing period, and how any refund will be determined, please refer to your IMA or speak with your Financial Advisor. Some Clients with accounts designate a bill-to account from which the custodian is directed to deduct the wrap fees. These arrangements are approved by the owners of the managed account and the bill-to account, in the event the account registration is not identical. When wrap fees are not paid from an account for which the services are provided, the performance of that account will not be net of fees. Clients who engage a Third-Party Manager pay an advisory fee to that manager, typically calculated as a percentage of assets under management. Clients are advised to review the investment advisory brochures and applications/ contracts/agreements with the TPMs and/or sponsors of the investments for complete information on how fees are charged by such parties because their processes for charging fees may change from time to time. Moreover, since Financial Advisors can negotiate their own fee arrangements, some Clients pay flat rates for services rather than asset based charges, which are deducted differently. Summit receives a portion of the advisory fee paid to certain Third-Party Managers pursuant to platform services agreements. This compensation paid to the Firm is paid by the Third-Party Manager from its advisory fee and is not an additional fee charged directly to the client. Because Summit receives a portion of the Third-Party Manager's fee, the Firm has a financial incentive to recommend or retain Third Party Managers that participate in these arrangements or that pay higher platform services fees. This presents a conflict of interest. The amount of platform services compensation received by Summit varies among Third Party Managers and is based on a percentage of assets managed by the Third-Party Manager for Summit’s clients. Summit addresses this conflict by selecting and monitoring Third-Party Managers based on a variety of qualitative and quantitative factors, including investment strategy, performance, risk management, and client objectives, and not solely on compensation arrangements. Summit’s reported assets under management include assets for which it provides ongoing investment advisory services, including manager selection, suitability analysis, and continuous monitoring. Clients should be aware that the advisory fees charged by Third-Party Managers participating in Summit’s platform services arrangements is higher than those charged by similar managers who do not participate in such arrangements, or higher than if Summit were to provide advisory services without a Third-Party Manager. Clients are not required to select any Third-Party Manager made available through Summit’s platform and may request information regarding alternative investment management options. Other Types of Fees and Expenses Unless otherwise noted on the IMA, Clients are responsible for paying all applicable third-party fees (including, but not limited to, wire fees, foreign transaction fees, margin interest, liquidation fees, ACAT fees, regulatory fees, state-specific taxes and fees, and execution costs charged by broker- Page 20 of 37  Summit Wrap Fee Program Brochure March 16, 2026 dealers and/or the other Qualified Custodians for execution), which are separate and distinct from the fees and expenses charged by Summit. A schedule of such charges for accounts custodied at a Qualified Custodian is provided to Clients at account inception or at any time by the Financial Advisor. Pursuant to certain sub-advisory and client agreements, securities in Client accounts may be liquidated by a subadvisor in their sole discretion, to cover unpaid fees. Certain investments such as hedge funds and non-traded REITs impose other charges. Clients are encouraged to review all documentation provided by those managers and issuers for details regarding their practices. Additionally, all pooled investment vehicles, including mutual funds, ETFs, REITs, UITs and hedge funds have their own internal operating fees and expenses that Clients must pay. These fees and expenses are disclosed in each security's offering documents and vary considerably. These fees and expenses often include operating expenses, management fees, redemption fees, 12b-1 fees, administrative fees, concessions and other fees and expenses and increase the expense ratio of the security. These fees are in addition to the fees charged by Summit. If Clients transfer in particular share classes of mutual funds, and if such shares are liquidated after being transferred to Summit, those shares will incur Contingent Deferred Sales Charges (CDSC) from the mutual fund company if they are within the CDSC holding period. Many direct investments are alternative investments, which often incur higher costs than many traditional securities such as equities, mutual funds and ETFs. Some securities, such as hedge funds and private equity funds, also charge incentive or performance fees. Summit encourages all Clients to closely review the offering documents for all such investments with their Financial Advisors and to consider the aggregate costs. Clients should contact their Financial Advisor or research@sfr1.com with any questions about particular products. Summit endeavors to use the lowest cost share class available to the Client. Many mutual fund companies have offered newer, lower-cost share classes in recent years that are available to fee-paying advisory Clients. Summit periodically reviews its holdings in order to convert higher cost shares to lower cost shares, if available, and endeavors to offer Clients the lowest eligible share class. Even so, Summit cannot ensure that all Clients will hold the lowest cost shares at any given time. Summit does not participate in any revenue sharing arrangements. The Municipal Bond Program does not utilize mutual funds. As noted, if there is little or no trading activity in an account, the program fee will cost more than the commission charges the Client would have incurred if the account were a non-managed account. Item 5. Account Requirements and Types of Clients. Summit primarily provides investment advice and/or management supervisory services to the following types of Clients: Individuals and personal trusts • Pension & Profit Sharing Plans • Charitable Organizations • • High Net Worth Individuals • Corporations and/or Business Entities Page 21 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Minimum Account Size There is no minimum account size associated with the SAA, FMA and APM Programs. The Managed Portfolios have minimum account sizes ranging from $5,000 to $100,000, which can be waived at Summit's sole discretion. Any minimum account size is outlined in the IMA entered into by the Client. Exceptions to minimum account size requirements may be negotiated. Item 6. Portfolio Manager Selection and Evaluation Selection and Review of Portfolio Managers Portfolio manager selection and review processes with respect to each Program are as follows: Managed Portfolios. As noted above, Managed Portfolios are custom designed portfolios constructed by Summit's IMC, which is comprised of the Chief Investment Officer and members of the Investment Management Department. The IMC is the only portfolio manager for the Managed Portfolios, and as a result, Summit and its Financial Advisors do not undertake a portfolio manager selection or recommendation process in connection with this Program. However, Summit does undertake a consistent process to review and oversee the ongoing performance of the IMC to assess whether the Managed Portfolios are being managed in accordance with Client expectations and investment objectives. In particular, on at least a quarterly basis, the IMC conducts meetings with the Investment Committee, a group of Financial Advisors who provide advisory services to a significant cross-section of Summit's Client base. During these quarterly meetings, the IMC informs the Investment Committee of any changes to the Model Portfolios, and the Investment Committee provides feedback to the IMC, which can include any notable concerns communicated by Clients regarding the Managed Portfolios of which the Investment Committee members become aware. In addition, on a monthly basis the IMC will calculate the performance of each Managed Portfolio for internal purposes and benchmark that performance against an appropriate index and then presents that information to the Investment Committee during each quarterly meeting for its review. The Investment Committee assesses the performance as compared to the benchmarks and offers suggestions on the development of new strategies to better meet Client needs. The performance data underlying these internal calculations are based on information provided by Morningstar, a third-party vendor and data provider. Performance calculations prepared by the IMC are not made available to Clients and the IMC does not prepare performance presentations regarding the Managed Portfolios that can be presented to current or prospective Clients. However, Clients can request information regarding the performance of their accounts at any time from their Financial Advisors. SAA, FMA and APM Programs. If a Client participates in the SAA, FMA or APM Programs, his/her Financial Advisor(s) will act as the Account's portfolio manager. The Client's Financial Advisor is the only portfolio manager for the SAA, FMA and APM Programs, and as a result, Summit does not undertake a portfolio manager selection or recommendation process. However, Summit does have a process to supervise the portfolio management services Financial Advisors provide in connection with these Programs. On an annual basis, Financial Advisors acting as portfolio managers in connection with the SAA, FMA and APM programs must complete an annual review form that, among other things, Page 22 of 37  Summit Wrap Fee Program Brochure March 16, 2026 requires Financial Advisors to (i) provide information regarding the nature of any due diligence they performed in connection with investments they recommended to or selected for Clients; (ii) review all share classes held by their Clients and note if there are lower cost shares available for each mutual fund, UIT, REIT or any other pooled investment vehicle in each Client portfolio; (iii) explain whether the current portfolio composition and prior year's trading activity met the Client's needs, his/her risk tolerance and investment objectives, including the Financial Advisor's rationale for the number of trades placed in each account, as well as a discussion of the value of such trades relative to each account and the portfolio as a whole and the performance of the portfolio; (iv) report the nature and content of any communication with the Client regarding how the current portfolio composition and prior year activity addressed the Client's needs (including liquidity), risk tolerance and investment objectives; and (v) assess and explain whether the Financial Advisor recommends changes to the portfolio to meet the needs of the Client and if so, what they are. A member of Summit's compliance team tests a sample of the submitted forms and follows up with Financial Advisors as appropriate to assess that Client needs in connection with their SAA, FMA and APM accounts are being met. Summit does not calculate the performance of the Financial Advisors who provide portfolio management services in connection with the SAA, FMA and APM Programs. However, Clients can request information regarding the performance of their accounts at any time from their Financial Advisors. The data underlying the performance information relating to traded investments and mutual funds is provided by Morningstar, a third-party vendor and data provider, and data relating to non-traded investments is provided by the sponsors of those investments. Neither Summit nor Financial Advisors prepare actual performance presentations regarding the SAAs, FMAs or APM that can be presented to prospective Clients. However, upon request, and as part of analyzing the Client's risk profile, a Client and a Financial Advisor can review theoretical performance in the event of the realization of certain risks. These theoretical presentations are generated by non-proprietary software, and Clients should carefully review the disclosures that are provided in connection with them. Related Persons & Supervised Persons Managed Portfolios are custom designed portfolios constructed by Summit's IMC, and Financial Advisors act as portfolio managers in connection with the SAA, FMA and APM Programs. Certain conflicts arise in connection with these related persons acting as portfolio managers in these Programs. In particular, the maximum advisory fee paid by Clients differs depending on the specific program or service they select and often varies from Client to Client. Moreover, in connection with accounts in which Clients do not pay a program fee to Summit (except AssetMark and Envestnet accounts) and, with certain limited exceptions, accounts in the SEI programs, Summit retains a portion of the advisory fee before applying the Financial Advisor's grid to calculate the Financial Advisor's compensation. In connection with accounts that do pay a program fee to Summit, the AssetMark accounts, Envestnet accounts, and, in certain limited cases, SEI accounts, Summit retains no portion of the advisory fee before applying the Financial Advisor's grid to calculate the Financial Advisor's compensation and the Financial Advisor's compensation is based on the entire advisory fee. Clients should be aware that Financial Advisors, therefore, have an incentive to recommend the programs or services in which they charge a higher advisory fee, or the programs or services in which they keep more of the advisory fee. Summit is aware of the conflicts of interest created by the variability in advisory fee compensation across programs and services and has adopted practices to supervise recommendations of programs and services. Financial Advisors act as portfolio managers in connection with the SAA, FMA and APM Programs and have to conduct their own due diligence of securities and/or allocations they recommend and select Page 23 of 37  Summit Wrap Fee Program Brochure March 16, 2026 under these Programs, while they do not have to conduct securities-specific due diligence in connection with the other programs. Because the SAA, FMA and APM Programs involve this additional effort and workload, your Financial Advisors may not recommend these programs to his/her Clients. Conversely, the maximum advisory fee is higher for SAA, FMA and APM accounts, which incentivizes Financial Advisors to recommend these Programs. Summit is aware of the conflicts of interest created by variability of the role the Financial Advisor plays in connection with the different Programs and has adopted practices to supervise recommendations of Programs. Advisory Services Provided in Connection with Managed Portfolios, SAAs and FMAs Summit's IMC and its Financial Advisors are supervised persons of Summit and provide portfolio management services in connection with Managed Portfolios and SAA, FMA and APM accounts, respectively. For information about the advisory services provided in connection with Managed Portfolios, SAA, FMA and APM accounts, please see Item 4 above regarding Services, Fees and Compensation. Tailored Investment Advice As described in Item 4 above regarding Services, Fees and Compensation, Summit offers the same suite of services to all of its Clients. However, each Financial Advisor determines, based on his/her own analysis, management style and preferences, in conjunction with each Client's specific profile and financial circumstances, which services and products to recommend and whether to recommend the Programs or Summit's non-wrap advisory programs. Clients may impose reasonable restrictions on Summit regarding investing in certain securities or types of securities in accordance with their values or beliefs (or based on their employer or regulatory restrictions). However, if the restrictions prevent Summit from properly servicing the Client's account, or if the restrictions would require Summit to deviate from its standard platform of services, particularly with respect to the Managed Portfolios, Summit reserves the right to end the relationship. Summit also uses third-party artificial intelligence solutions to support investment research, portfolio analysis, and risk monitoring. These tools are used solely as decision-support resources and do not independently make investment decisions or execute trades. All recommendations and investment decisions are subject to human review and approval. Performance-Based Fees and Side-by-Side Management Summit does not assess performance-based fees or other fees based on a share of capital gains on or capital appreciation of assets of a Client. Methods of Analysis As discussed in Item 4, Summit and its Financial Advisors primarily recommend or select investments in ETFs and mutual funds in the Managed Portfolio, SAA, FMA, and APM Programs. They also recommend sub-advisors and portfolio managers. The analysis for these securities and managers is conducted in the following way. Managed Portfolios and Sub-advisors - Members of the IMC conduct due diligence on securities, investment managers and strategies for Managed Portfolios and sub-advisors. While various sources of Page 24 of 37  Summit Wrap Fee Program Brochure March 16, 2026 information may be used, the IMC's principal sources of information include: (i) fund databases; (ii) financial publications; (iii) management interviews and contacts; (iv) industry trade association statistics; (v) government data; (vi) capital markets data; and (vii) third party research materials that analyze the overall investing landscape as well as specific market sectors and strategies. As appropriate, the IMC also reviews materials supplied by the investment managers including annual reports, factsheets, presentations, fund prospectus/offering memorandum, performance and related investment data, if available. When reviewing the investment strategy and process, performance, risk management and expenses of a prospective manager, the IMC evaluates some or all of the following items, among others: • Are the assets under management large enough to efficiently manage a diversified portfolio but • small enough to navigate supply constrained market sectors; Is there a stable investment team with the experience and depth required by the investment strategy; Is there consistency of the investment objective and the strategy followed; Is there a clearly defined investment style and management process; Is there a well-designed benchmark index (e.g., universe of securities, weighting methodology); • • • • Does the organization have a disciplined management of risk exposures (e.g., market, interest • rate, credit, inflation, currency, liquidity); Is there attractive absolute and risk-adjusted performance, consistent with return and risk objectives. A track record from a different but similar investment vehicle may be used to evaluate performance; • Are volatility and returns during market drawdowns consistent with risk exposures; • Are there positive or neutral supply/demand trends and investor sentiment; • Are the investment characteristics (e.g., geography, industry sectors, valuation, capitalization range, credit quality) consistent with the investment mandate; • Are the types of securities that may be held in the portfolio sufficiently liquid and well understood (i.e., in line with the specific mandate); • Are the costs, including management fees, operating expenses, sales fees and administrative expenses, marketing expenses, etc., reasonable (i.e., moderate or low for the specific mandate); Is the product structure attractive and what are the potential tax implications. • SAA/FMA/APM – Given the number of Financial Advisors providing advice at Summit, the methods of analysis, investment strategies and investment selections will vary based upon the individual Financial Advisor providing the advice. As noted in Item 4, in the SAA, FMA and APM Programs, Financial Advisors are not limited to using securities that have been reviewed by the IMC. Financial Advisors may conduct their own research and due diligence when making a securities recommendation. Several tools available to Financial Advisors include: (i) Morningstar; (ii) Fi360; (iii) Bloomberg; (iv) financial publications; and (v) other sources to construct portfolios and research track records and fundamentals regarding the particular securities recommended. Investment Strategies Certain strategies and securities pose risks to Clients, as detailed below. Page 25 of 37  Summit Wrap Fee Program Brochure March 16, 2026 ETFs: Shares in an ETF can be traded throughout the day on an exchange and are bought and sold at a market price that may differ from Net Asset Value (NAV). When conducting due diligence on ETFs, members of the IMC review additional data on liquidity and trading costs, often including: • Tracking error versus the benchmark index (for passive ETFs); • Premium/discount between the market price of the shares and NAV; • Bid/ask spread; • Trading volume. Active Strategies: Active investment strategies (including open-end mutual funds and certain TPMs) seek to outperform a benchmark by selecting a portfolio of securities that differs from the benchmark portfolio. Active strategies involve manager risk and are typically more expensive than passive strategies that track benchmark indices. When conducting due diligence on active strategies, members of the IMC typically participate in a conference call, on-site meeting and/or meeting in Summit's offices with a member of the investment strategy's portfolio management team. Factors evaluated by members of the IMC during the due diligence process include: • Understanding the investment guidelines and discretion given to the investment team; • Understanding the current risk/reward environment for taking on active risk exposures; • Reviewing performance versus a universe of similar strategies; • Considering investment techniques that may be used (e.g., leverage, derivatives, shorting); • Reviewing whether return premium compensates for active portfolio management and trading expenses. The IMC looks at the experience and track record of the manager of each mutual fund and ETF as well as certain TPMs in an attempt to determine if that manager has demonstrated reasonable results and an ability to invest over a period of time and in different economic conditions. The IMC also monitors these mutual funds, ETFs and TPMs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund, ETF or TPM analysis is that, as with all securities, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as the IMC does not control the underlying investments in a mutual fund, ETF or TPM, managers of different funds held by the Client may purchase the same security, increasing the risk to the Client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the mutual fund, ETF or TPM which could make the holding(s) less suitable for the Client's portfolio. Alternative Investment Strategies Alternative Investments – including non-traded REITs, Private Equity, Private Credit, Hedge funds and funds of hedge funds will be offered through a Summit advisory Program such as SAA or APM. Alternatives, in most cases, have limited liquidity with no available market price or are valued infrequently. Some programs have very long holding periods (10 plus years) with no liquidity for the entire period. Certain Alternative Investments may use leverage, options or derivatives which may increase the risk. Each program has its own characteristics and risks spelled out in an offering memorandum or prospectus. When conducting due diligence on Alternative Investments, many items are examined including all legal documents, financial statements, and depending on the type of investment may include: Page 26 of 37  Summit Wrap Fee Program Brochure March 16, 2026 • Sponsor/advisor track record managing the particular investment or similar investments. • Conflicts of interest that may arise from the relationship between the sponsor, the partnership or other partnerships being managed. Investment opportunity (e.g., supply/demand trends, valuation of private vs. public markets) Investment limits of individual investments in the portfolio (use of leverage and derivatives) • Other investments controlled by the sponsor that may compete for new acquisitions • Pace of capital raising and expected timeframe until the offering is closed to new investments; • The background of the management team managing the portfolio • • Diversification and quality of the portfolio • • Reasonableness of achieving investment objectives • Offering, operational and liquidation fees are not excessive and are competitive with evolving industry practices. If the investment has been reviewed by an independent Due-Diligence Service, the Investment Team will review their reports as additional support. Investment Platform Due Diligence—Alternative Investments: Summit and its Financial Advisors also recommend investment platforms that provide access to alternative strategies such as hedge funds. These platforms are supported by a deep bench of alternative investment specialists that conduct due diligence encompassing the investment and operational risks of the investment funds available on the platform. In some cases, these efforts are outsourced by the platforms to third parties. This independent due diligence bolsters the efforts of the IMC. These platforms provide access to alternative investments that are sometimes only directly available to large institutional investors and utilize technology that facilitates investment execution and reporting. Members of the IMC conduct due diligence on alternative investment platforms to validate their business model, ability to access attractive hedge funds to the platform, and the costs of the platforms compared to direct investment. This review covers platform documents, the due diligence reports provided by the platform, fund performance and investment terms such as fees and liquidity. When conducting due diligence on alternative investment platforms, members of the IMC typically participate in conference calls, on-site meeting and/or meeting in Summit's offices with a member of the management team. The IMC may select a small group of investment funds with specific characteristics from the larger universe of funds available on the platform. General Risks Although the IMC and Financial Advisors consider many risks before recommending a security or investment manager to Clients (or investing on their behalf), there are a myriad of circumstances that may cause investments to lose value. Their assessment of any investment manager or security's likely future performance is inherently a prediction and it is subject to uncertainty and risk that the outlook might prove wrong. An outcome contrary to what the IMC or Financial Advisor anticipated may arise from a number of factors, such as: an erroneous assessment of the value offered by the investment manager/security, a change in strategy by the selected manager, market changes, unanticipated changes to interest rates or the tax code, among others. Summit's IMC and Financial Advisors invest in and recommend securities they believe to be appropriate for the Client based on an understanding of the Client's investment objectives and risk Page 27 of 37  Summit Wrap Fee Program Brochure March 16, 2026 tolerance. Summarized below are relevant risks broadly relating to the types of securities Summit primarily invests in for Client accounts; however, securities may be subject to additional risks specific to that security or issuer. Clients are strongly encouraged to review the prospectus disclosures and offering documents relating to the securities held in their portfolios if they have any questions, as these documents discuss in more detail the risks relating to the particular investment. Additional information regarding the general characteristics and risks relating to the types of securities that Summit primarily invests in for Client accounts are explained in Summit's "Product Risk Disclosure" document posted on Summit's website at www.summitfinancial.com. Clients with additional questions regarding a particular security should contact their Financial Advisor. Specific Risks Clients participating in the Managed Portfolios should understand the underlying holdings within the Managed Portfolios (mutual funds and ETFs) involve risk and the potential of loss. Money markets used in Managed Portfolios are generally considered low risk but are not guaranteed and may be subject to loss and or change in market value. Mutual funds and ETFs often provide diversification but may be concentrated in a particular asset category or class within a category. Investments in funds impose risk due to exposure to economic forces or factors for which the future is uncertain. Some of these are unique to individual funds, but many are common to many funds. A fund's risk depends on how closely its return is coupled with given indexes, the riskiness of each index and how closely the indexes tend to move together. The level of overall investment market diversification will vary depending on the Managed Portfolio(s) used as well as the underlying exposures of the underlying funds. The risk in a Managed Portfolio or collection of Managed Portfolios is a function of the underlying asset classes utilized and the particular weighting of the Managed Portfolios if more than one is used to meet the portfolio design. Further, all investment strategies involve risk and the investment performance and success of any strategy cannot be predicted or guaranteed. Past performance should not be used to forecast future results. Hedge funds are speculative in nature and may use leverage or other aggressive investment practices. As a result, Client returns may be highly volatile, and Clients may lose all or a portion of the investment in the fund. Clients who invest in commodities (through hedge funds that specialize in this asset class) should know that commodities are subject to world events, limited liquidity, shifting market preferences, trade signal disruption, supply/demand imbalances, currency movement and many other things that cannot be successfully predicted, but do have a significant impact on future results. The use of artificial intelligence-based solutions may rely on historical data, assumptions, or third- party inputs that are incomplete, outdated, inaccurate, or misleading, and may not fully reflect current market conditions or issuer-specific developments. In addition, such tools may incorporate modeling limitations, simplified assumptions, or unintended biases and may fail to anticipate unusual or rapidly changing market events, which could result in underperformance or losses. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest Page 28 of 37  Summit Wrap Fee Program Brochure March 16, 2026 rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a Client, should be prepared to bear. This list of risks is not exhaustive. When Clients invest in mutual funds, ETFs, UITs and newly issued municipal bonds, for example, they receive prospectuses and official statements which identify the risk factors associated with those securities and issuers. Clients are encouraged to review such disclosure documents. Similarly, Clients are encouraged to review the offerings documents for private investments and the investment advisory brochures for all TPMs for additional risk disclosures. Please contact your Financial Advisor or research@sfr1.com if you have questions about your investments. Voting Client Securities Summit will not request or accept voting authority for Clients. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Summit also will not be responsible for taking action or rendering any advice with respect to securities held in Program accounts which become subject to legal notices or proceedings, including bankruptcy proceedings. Item 7. Client Information Provided to Portfolio Managers Client information, including their financial circumstances, is collected and continually maintained by Financial Advisors. Furthermore, on an annual basis, Summit requires Financial Advisors complete an annual review for each Client, pursuant to which the Financial Advisors report whether there have been any changes to each Client's investment profile, and if there has been such a change, further requires the Financial Advisors to report the changes to Summit's Operations Department. For the SAA, FMA, and APM Programs, the Financial Advisors serve as the portfolio managers and Clients can thus communicate any changes to their investment profiles at any time. Client investment profile information is not communicated to the IMC, which serves as the portfolio manager in connection with Managed Portfolios, but as noted above, Financial Advisors collect and continually maintain information about Clients and update it as necessary in connection with their participation in Managed Portfolios. Finally, in connection with the Municipal Bond Program, AB asks Summit and its Financial Advisors to obtain and continually update information from Clients that is material to the construction and maintenance of the Client's portfolio, such as existing municipal bond holdings at the inception of an account, state of residence, and cash flow needs. Item 8. Client Contact with Portfolio Managers Summit does not place any restrictions on Clients' ability to contact and consult with their Financial Advisors. Further, the members of the IMC are available to talk to Clients. Sub-advisors are generally not available to speak to Summit's Clients, but Financial Advisors can communicate information to the sub-advisor upon Client request. Page 29 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Item 9. Additional Information Disciplinary Information Not applicable. Summit has no legal or disciplinary events to disclose. Other Financial Industry Activities and Affiliations Summit is registered with the Securities Exchange Commission (SEC) as an investment adviser. As noted herein, most Summit Financial Advisors are also registered representatives of Unaffiliated Broker-Dealers, which are members of FINRA and SIPC. Summit is also associated with other affiliates that have overlapping employees and/or Clients and which may receive fees, commissions or other remuneration from non-Clients as a result of a sale or product or service by the affiliate to the Client. Neither Summit nor the Financial Advisors in their capacity as an IAR will act as a broker in connection with the Programs. LS Securities, LLC ("LSS") – LSS is a limited purpose broker dealer owned by SFH. LSS does not provide brokerage or other services to any retail customers and has no direct relationship with any of Summit's Clients. PKS, PCS, and Aurora, who are unaffiliated broker-dealers, pay a referral fee to LSS on the brokerage business that Summit's Financial Advisors conduct in their capacity as RRs of these unaffiliated broker dealers, and some of that brokerage business may be with persons who are also Summit Clients. Other unaffiliated broker-dealers do not pay similar referral fees. This means that even though Summit is not involved in the brokerage activity conducted at PKS, PCS, and Aurora, even if conducted with Summit Clients, Summit's parent company will profit by the Financial Advisor's brokerage activity. Please contact your Financial Advisor if you have any questions. Summit Risk Management, LLC – SRM is a Delaware limited liability company and is licensed to sell non-securities insurance products and earns commissions or remuneration on such products. No variable insurance products are sold through SRM. Many of the Clients of SRM are also Clients of Summit. Most persons associated with Summit are also associated with SRM. Most Summit Financial Advisors are insurance brokers or agents under an SRM agency relationship. Merchant Wealth Management Holdings, LLC - Merchant Wealth Management Holdings 3, LLC – Merchant Wealth Management Holdings 3, LLC ("Merchant Wealth"), an entity wholly owned by Merchant Wealth Partners, LLC ("MWP"), owns a controlling interest in the Advisor. Merchant Wealth is wholly owned by MWP, a Company managed by MWP Advisory, LLC, a registered investment advisor, which is wholly owned by Merchant Investment Management, LLC (“Merchant Investment”). Merchant Investment, through MWP, has ownership interests in various companies that provide investment and other consulting services to financial firms, including investment advisors ("Investment Solutions"). The Advisor is provided access to use these Investment Solutions, where the Advisor may utilize the Investment Solutions pursuant to an engagement that the Advisor enters into directly with the third party providing the Investment Solution. These Investment Solutions may include, but are not limited to, third party money managers, private investments, pooled investment vehicles, or other investment products for which a commission is earned. Engagement of and with these Investment Solutions poses a potential conflict of interest due to the minority ownership interest that Merchant Investment's or MWP's various subsidiaries own in the third parties providing these Investment Solutions. Through these ownership interests in the third parties that provide these Investment Solutions, Merchant Investment or MWP will benefit from additional revenue that is Page 30 of 37  Summit Wrap Fee Program Brochure March 16, 2026 generated when the Advisor engages any of these third party service providers. Accordingly, the Advisor has an incentive to engage one or more of these Investment Solutions. In an effort to ensure these conflicts of interest are addressed, the Advisor has implemented a risk control and disclosure framework, the objective of which is for the Financial Advisor to select Investment Solutions that are in the best interest of the Client. Although Merchant Wealth has a controlling interest in the Advisor, the Advisor operates as a Fiduciary and seeks to ensure Client’s interests are met and will ensure appropriate disclosure of all relevant conflicts of interest and disclose how such conflicts are mitigated. Merchant offers opportunities for qualified Summit clients to invest in Merchant both directly and indirectly. While Summit does not receive any additional compensation for these investments, the offering does create a conflict of interest since Summit will benefit directly and indirectly from these investments through its affiliation with Merchant. Sextant Securities, LLC - The Advisor, in which Merchant Wealth has an indirect minority, non- controlling ownership interest, may engage Sextant Securities, LLC ("Sextant"), an affiliated Broker- Dealer owned by Merchant Investment, to access certain investment products, which may include, but not be limited to, private equity funds, open-ended and close-ended mutual funds, and other products for which Sextant earns a commission if they are sold (herein "Security Offering"). As a result of Merchant Investment's ownership of Sextant, Merchant Investment may benefit from revenue and/or placement fees received by Sextant if the Advisor invests any Client funds into a Security Offering. Accordingly, the Advisor may have an incentive to invest Client funds into a Security Offering. In addition, there is no requirement for the Advisor to recommend to a Client a Security Offering offered through Sextant. Prior to recommending a Security Offering, the Advisor will conduct appropriate due diligence to ensure that any recommendation to invest Clients funds into a Security Offering aligns with the Client's investment needs and objectives. In addition, the Advisor will provide additional disclosure information to each Client, which will include relevant details regarding material financial interests and compensation surrounding the Security Offering. Maxim Income Opportunity Fund I, II, III, and IV L.P. - Summit may recommend that Clients invest into the Maxim Income Opportunity Fund I, II, III, and IV L.P. (herein "Maxim"), a Security Offering of Sextant. Individual owners of Merchant Wealth, in their separate capacity, have material ownership interests in Maxim. As a result, these individuals stand to benefit financially from additional investments made into Maxim and from returns generated by Maxim. These individual owners of Maxim, who also have an indirect ownership interest in Summit, would benefit financially in their individual capacity if Summit invests Client funds into Maxim. Notwithstanding this conflict of interest, Summit and its Financial Advisors will only invest Clients in Maxim if it is suitable for the Client's investment objectives. Lastly, there is no requirement for Summit to recommend Maxim to Clients, nor are Clients obligated to invest into Maxim. Treville Capital Management Certain individuals of Merchant Investment are each affiliated with GPS Investment Partners ("GPS"), which, either individually or via affiliated entities of GPS, is an investor in both Merchant and the parent company of Treville Capital Management ("Treville"). Each, either individually or via affiliated entities, individually may also be investors in funds managed by Treville. Additionally, Page 31 of 37  Summit Wrap Fee Program Brochure March 16, 2026 certain funds and accounts managed by Treville are invested in Merchant. The affiliations above create a conflict of interest as GPS and Treville directly and/or indirectly benefit from any fees generated due to an investment in any of Treville's products. In addition, certain owners of Merchant are also board members of Treville. Prior to recommending an investment in an offering by Treville, your Summit financial advisor has conducted the appropriate due diligence to determine that such investment aligns with your investment needs, risk tolerance and investment objectives. However, it is your choice as to whether you invest based upon such recommendation and in light of the conflicts raised in this disclosure statement. Redwood Real Estate Income Fund Summit may recommend that Clients invest in the Redwood Real Estate Income Fund (herein "Redwood Fund"), a fund managed by Redwood Investment Management, LLC (herein "Redwood"), in which Merchant Wealth Partners holds an indirect, non-controlling minority stake in Redwood. In addition, Redwood Fund may invest in loan opportunities that are originated by Maxim Capital Fund (herein "Maxim Capital"), an affiliated entity of Maxim, where individual owners of Merchant Wealth hold a material ownership interest. This poses a conflict of interest due to the minority interests Merchant holds in both Summit and Redwood. As a result, your Financial Advisor has an incentive to invest client assets into the Redwood Fund. The Redwood Fund's investment objective is to provide current income and preserve shareholders' capital. The Fund seeks to achieve its investment objective by investing in U.S. commercial real-estate income investments. These investments may include but are not limited to senior mortgage loans, second lien mortgages, also known as junior or sub-ordinated debt, mezzanine loans, and participation interests in such mortgages or debt. The Fund will also invest up to 20% of its net assets in short- duration fixed income instruments. The Fund is an appropriate investment only for those investors who do not require a liquid investment. Prior to the recommendation of Redwood Fund, your Financial Advisor conducts the appropriate due diligence to ensure that any recommendation to a Client to invest in Redwood Fund aligns with the Client's investment needs and objectives. In addition, the Financial Advisor will provide the Client with the necessary disclosures and offering documents of Redwood Fund so that the Client can carefully review the risks, fees and other important information related to the fund. Neither Summit nor its Financial Advisors will receive any additional compensation for investing Client assets into Redwood Fund. In addition, there is no requirement for the Financial Advisor to recommend Redwood Fund to a Client, nor are Clients obligated to invest in Redwood Fund. Third-Party Managers Summit has entered into platform services agreement with certain independent third-party investment advisors and portfolio managers pursuant to which the Summit provides due diligence, manager selection and monitoring, operational and administrative support, billing, coordination, technology access and related platform services. In connection with these arrangements, Summit receives compensation from the Third-Party Managers based on assets managed for its clients. Waterfall Bank Stan Gregor, Chief Executive Officer of Summit Financial, also serves as a board member of Waterfall Page 32 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Bank. Neither the Advisor, any advisory affiliate, nor Mr. Gregor receives any compensation or other benefit in connection with this arrangement. Clients of the Advisor are not required to engage Waterfall Bank for banking services. Relationships or Arrangements with Related Persons As detailed above, in their capacities as insurance brokers or insurance agents, Summit's Financial Advisors receive fees, commissions and other remuneration from non-Clients including insurance companies for their insurance activities. Some of that insurance activity generates revenue to SRM as well. Financial Advisors who are registered representatives of PKS or other unaffiliated broker dealers will offer brokerage products for which they will receive compensation in their capacity as RRs of the broker dealer. As noted above, LSS will receive a referral for such business through PKS or other unaffiliated broker dealers. The Client's Financial Advisor's obligations to Client when selling insurance or securities differs from his or her obligations when acting as a Financial Advisor through Summit, and except as noted herein, Summit does not supervise those activities. Clients are under no obligation, however, to purchase any other products or services from Financial Advisor. SummitVantage™ SummitVantage is used for marketing purposes to identify the services offered by the Summit affiliated firms. It does not offer products or services. SummitVantage is used in the recruitment and retention of investment advisor representatives. Selection of Other Investment Advisers Summit may recommend third party managers and sub-advisors to Clients. This relationship and the fees are in the IMA and in some programs, an additional agreement between the Client and the TPM. This practice creates a conflict of interest in that the Financial Advisor has an incentive to direct Clients to those managers who provide Summit with a larger fee split. Some TPM programs provide higher payouts to the Financial Advisors than Summit's other advisory programs, but the amount of compensation will depend on the fee agreement negotiated with the Client. Summit may recommend Piton Investment Management, LP ("Piton") as a TPM. Piton is a SEC- registered investment advisor focusing on fixed income investment management services to institutions and high net worth individuals. Individual owners of Merchant Wealth, in their separate capacity, have ownership interests in Piton. As a result, these individual owners of Piton, who also have an indirect ownership interest in Summit, would benefit financially in their individual capacity if Summit invests Client funds into Piton. Notwithstanding this conflict of interest, Summit and its Financial Advisors will only invest Clients with Piton if it is suitable and in accordance with the Client's investment objectives. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Summit believes it owes Clients the highest level of trust and fair dealing. As part of its fiduciary duty, Summit endeavors to put the interests of its Clients ahead of the interests of the firm and its personnel. Summit has adopted a Code of Ethics that emphasizes the high standards of conduct the firm seeks to observe. Summit personnel are required to conduct themselves with integrity at all times and follow the principles and policies detailed in our Code of Ethics. Page 33 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Summit's Code of Ethics attempts to address specific conflicts of interest it has identified or that could likely arise. Summit personnel are required to follow guidelines in areas such as prohibitions on insider trading, personal securities transactions, conflicts of interest, gifts, confidentiality and privacy, compliance procedures, certification of compliance, training, record keeping and adherence to applicable securities laws. Clients may request a copy of Summit's Code of Ethics by contacting (973) 285-3600 or by emailing compliance@sfr1.com. Personal Trading Practices Summit's associated persons are not permitted to acquire beneficial ownership of any securities in an initial public offering (IPO) or purchase any private placements without the prior written approval of Summit's Chief Compliance Officer. Summit does not require pre-clearance for personal securities transactions other than IPOs or private placements. Summit does not hold or trade securities for its own accounts, although from time to time, Financial Advisors of Summit may trade in securities for their own accounts that they also buy or recommend to Clients, and they also may trade in different securities that they do not feel are appropriate for certain Clients (including related securities, such as warrants or options). The conflict presented in this practice could lead to a Financial Advisor purchasing or selling a security in advance of a Client and/or receiving a better price. Summit monitors such transactions to look for potential conflicts of interest and to reasonably confirm that representatives of Summit transact Client business before their own when the same securities are being bought or sold at or around the same time. Review of Accounts The Financial Advisors review all of the accounts in the Programs on a continuous and regular basis. The Managed Portfolios are also reviewed on a continuous basis by the IMC. Additional reviews are triggered by material market, economic, or political events, or by changes in Client's financial situations, such as retirement, change in employment or marital status, physical move, inheritance or other life events. Each Client will receive written reports from the custodian that detail the Client's positions and activity. Many Financial Advisors also provide their Clients with periodic performance reports, which show performance across multiple accounts within a household. Clients are advised to always compare those reports to the ones provided by the Qualified Custodians, which are the official records of the accounts. Client Referrals and Other Compensation – Economic Benefits Provided by Third Parties for Advice Rendered to Clients Summit and its Financial Advisors receive economic benefits from third parties in a number of ways. Many of those are addressed in Item 4, above. Financial Advisors are compensated through Summit by sharing a percentage of the advisory fee component charged to the Clients' accounts (often referred to as a "grid" or "net" payout). The payout Page 34 of 37  Summit Wrap Fee Program Brochure March 16, 2026 percentage varies based upon the advisory program or TPM selected. Moreover, Financial Advisors with higher total revenue generally receive higher "grid" payouts. Additionally, if Financial Advisors recommend insurance in connection with financial planning service to Clients (which are separate from the Programs), Summit affiliates and many Financial Advisors receive significant allowances from Mass Mutual or other insurance companies, as discussed in Item 5 – Fees and Compensation of Summit's Form ADV Part 2A Firm Brochure and in the Financial Advisor Brochure Supplement. Summit does not retain any portion of the advisory fee component of the wrap fee before applying the Financial Advisor's grid except as noted above for legacy accounts to calculate the Financial Advisor's compensation. However, in connection with accounts in which Clients do not pay a program fee to Summit, which are not wrap programs, (except AssetMark and Envestnet accounts), and, with certain limited exceptions, accounts in the SEI programs, Summit retains a portion of the advisory fee before applying the Financial Advisor's grid to calculate the Financial Advisor's compensation. In connection with accounts that do pay a program fee to Summit, the AssetMark accounts, Envestnet accounts, and, in certain limited cases, SEI accounts, Summit retains no portion of the advisory fee before applying the Financial Advisor's grid to calculate the Financial Advisor's compensation and the Financial Advisor's compensation is based on the entire advisory fee. This variability in Summit's practices with respect to retention of advisory fees creates an incentive to Financial Advisors to steer Clients to programs or services that generate higher revenue to them, although Summit believes the Financial Advisors focus on each Client's specific needs in recommending an advisory program, combination of programs or service. Moreover, as noted above, Summit has adopted practices to supervise recommendations of programs and services. Certain service providers that provide services to Summit's Clients, such as SEI (for additional information see Summit's ADV 2A), have a revenue fee share or service arrangement with Summit. This causes Summit to have a conflict of interest as it has incentive to recommend these service providers over others where they do not have this revenue share incentive. Please contact your financial advisor to find out if your service provider has this arrangement with Summit. Summit or its affiliated firms and certain Financial Advisors will receive referral payments from banks and other financial institutions as applicable for referring Summit Clients to use their products and services. This includes bank loans, asset backed securities loans, financial and other such type loans, etc. These payments would be in the form of a one-time payment or ongoing trails. Summit and the Financial Advisor will not receive any such payments for Clients that are considered ERISA Plans or prohibited under ERISA law. Summit does not supervise or review any such referrals by the Financial Advisor. Summit is not responsible for any such recommendations. Advisor is acting outside of advisory duties and responsibilities that are overseen by Summit. These referral payments create a conflict of interest because your Financial Advisor may direct you to one firm over another in order to receive such payments. Summit mitigates this conflict on such recommendations and referrals by disclosure in this brochure. Summit may recommend or require that clients establish brokerage accounts with certain Qualified Custodians, including Schwab Advisor Services division of Charles Schwab & Co., Inc. (hereinafter "Schwab"), which are registered broker-dealers, members SIPC, to maintain custody of clients' assets and to effect trades for their accounts. The final decision to custody assets with Schwab or other Qualified Custodians is at the discretion of the Client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Summit is independently owned and operated and not affiliated with Schwab or any Page 35 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Qualified Custodians. Schwab, or other Qualified Custodians as applicable, provide Summit with access to its institutional trading and custody services, which are typically not available to their retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. Schwab, or the other Qualified Custodian as applicable, services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab, and other Qualified Custodians as applicable, also make available to Summit and its affiliates other products and services that benefit Summit or its affiliates but may not benefit its clients' accounts. These benefits may include national, regional or Summit specific educational events organized and/or sponsored by Schwab or the other Qualified Custodians. Other potential benefits if applicable include occasional business entertainment of personnel of Summit by Schwab or the qualified custodian personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Summit in managing and administering clients' accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of Summit's fees from its clients' accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of Summit's accounts, including accounts not maintained at the Qualified Custodian. Schwab, or the Qualified Custodians if applicable, also make available to Summit other services intended to help Summit manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab, or other Qualified Custodians if applicable, make available, arrange and/or pay vendors for these types of services rendered to Summit by independent third parties. Schwab Advisor Services and the other qualified custodians may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to Summit. While, as a fiduciary, Summit endeavors to act in its clients' best interests, Summit recommendation/requirement that clients maintain their assets in accounts at Schwab or another Qualified Custodian may be based in part on the benefit to Summit of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab or the Qualified Custodians, which creates a potential conflict of interest. As noted herein, Summit's parent company receives an economic benefit through LSS for brokerage business that the Financial Advisors conduct in their capacity as RRs of PKS, PCS or other unaffiliated broker dealers. Page 36 of 37  Summit Wrap Fee Program Brochure March 16, 2026 Compensation to Non-Advisory Personnel for Client Referrals Summit compensates its own Financial Advisors as well as some third parties for Client referrals. Terms of the compensation for third parties are disclosed to the Client at the time of the solicitation and upon request. Financial Information Summit does not require or solicit Clients to prepay fees of more than $1,200, six months or more in advance. Page 37 of 37