Overview
- Headquarters
- Columbus, GA
- Average Client Assets
- $2.6 million
- SEC CRD Number
- 14023
Fee Structure
Primary Fee Schedule (CREATIVE FINANCIAL GROUP ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.50% |
| $250,001 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.00% |
| $1,000,001 | and above | 0.75% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,875 | 1.19% |
| $5 million | $41,875 | 0.84% |
| $10 million | $79,375 | 0.79% |
| $50 million | $379,375 | 0.76% |
| $100 million | $754,375 | 0.75% |
Clients
- HNW Share of Firm Assets
- 58.68%
- Total Client Accounts
- 12,411
- Discretionary Accounts
- 5,799
- Non-Discretionary Accounts
- 6,612
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection, Educational Seminars
Regulatory Filings
Additional Brochure: CREATIVE FINANCIAL GROUP ADV PART 2A (2026-01-28)
View Document Text
Item 1 – Cover Page
A division of Synovus Securities, Inc.
Creative Financial Group
3400 Overton Park Drive SE, Suite 600
Atlanta, GA 30339
(770) 913‐9704
www.cfgltd.com
January 28, 2026
This Brochure provides information about the qualifications and business practices of Creative
Financial Group (“CFG”), a division of Synovus Securities, Inc. If you have any questions about the
contents of this Brochure, please contact Gene Gunderson, Chief Compliance Officer at (706) 644‐
0298 or by email at genegunderson@synovus.com. The information in this Brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
Creative Financial Group is a division of Synovus Securities, Inc. (“SSI”), a registered investment
adviser and registered broker‐dealer with the U.S. Securities and Exchange Commission (“SEC”).
Registration as an Investment Adviser does not imply any level of skill or training. The oral and written
communications of an Adviser provide you with information about which you determine to hire or
retain an Adviser.
This disclosure Brochure describes the business practices of CFG. Advisory services are also offered
directly through other divisions of Synovus Securities, Inc. SSI’s business practices are described in a
separate Brochure, which is available upon request. Additional information about Creative Financial
Group and Synovus Securities, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov.
i
Item 2 – Material Changes
This Brochure dated January 28, 2026, is a revised document prepared according to the SEC’s
requirements and rules. This Item will discuss only specific material changes that are made to the
Brochure and provide clients with a summary of such changes.
Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and
subsequent Brochures within 120 days of the close of our business' fiscal year. We may further provide
other ongoing disclosure information about material changes as necessary. We will further provide you
with a new Brochure as necessary based on changes or new information, at any time, without charge.
This Brochure does not contain any material changes but has been updated since the previous version
filed with the Securities and Exchange Commission dated November 3, 2025, to include refreshed totals
for assets under management.
Effective January 1, 2026, Synovus Securities, Inc. became a wholly owned subsidiary of Pinnacle
Financial Partners, Inc. as a result of a merger between Synovus Financial Corp. and Pinnacle Financial
Partners, Inc.
Our Brochure may be requested by contacting Gene Gunderson, Chief Compliance Officer at (706) 644‐
0298 or genegunderson@synovus.com. It is also available on our web site www.cfgltd.com free of
charge. Clients have the option to electronically receive copies of this Brochure, along with any
subsequent updates. Please contact your Creative Financial Group representative for more information
about electing electronic delivery for future brochures.
ii
Item 3 ‐Table of Contents
Item 1 – Cover Page ....................................................................................................................................... i
Item 2 – Material Changes ........................................................................................................................... ii
Item 3 ‐ Table of Contents .......................................................................................................................... iii
Item 4 – Advisory Business............................................................................................................................ 4
Item 5 – Fees and Compensation ..................................................................................................................6
Item 6 – Performance‐Based Fees and Side‐By‐Side Management ............................................................. 9
Item 7 – Types of Clients............................................................................................................................. 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10
Item 9 – Disciplinary Information................................................................................................................ 11
Item 10 – Other Financial Industry Activities and Affiliations..................................................................... 12
Item 11 – Code of Ethics..............................................................................................................................13
Item 12 – Brokerage Practices..................................................................................................................... 13
Item 13 – Review of Accounts....................................................................................................................... 15
Item 14 – Client Referrals and Other Compensation.................................................................................... 15
Item 15 – Custody........................................................................................................................................ 15
Item 16 – Investment Discretion................................................................................................................. 16
Item 17 – Voting Client Securities… ............................................................................................................. 16
Item 18 – Financial Information…............................................................................................................... 16
Appendix A – Risk Definitions..................................................................................................................... 17
CFG Asset Management Transaction & Miscellaneous Fee and Expenses
Brochure Supplement(s)
iii
Item 4 – Advisory Business
Creative Financial Group was founded in 1988 as an independent registered investment advisor. In
February of 2001, Creative Financial Group (“CFG”) became a subsidiary of Pinnacle Financial Partners,
Inc., a publicly traded company (NYSE: PNFP). As of January 1, 2011, CFG was merged into the
corporate structure of its affiliate, Synovus Securities, Inc. (“SSI”) a dually registered broker‐dealer and
investment adviser. CFG operates as a separate division of SSI, maintains its own office space and
personnel, and offers a different scope of advisory services than SSI’s other divisions.
As of January 1, 2026, CFG’s assets under management were $2,464,934,906 on a discretionary basis,
and $91,452,937 on a non‐discretionary basis.
A. Financial Planning:
CFG offers a comprehensive package of wealth management services to its Clients, or provides
individual service components, such as broad‐based financial planning, investment and asset
management, tax related services, risk management services, or administrative services.
A broad‐based financial planning relationship with emphasis upon the six
steps listed below as the Financial Planning Process. The primary objective of the Financial
Planning services is to construct a comprehensive financial plan that provides sufficient cash
flow to meet the Client’s standard of living throughout their lifetime.
Other objectives include retirement planning, risk management, tax planning, estate planning,
investments, education and special needs planning. The fee CFG charges for preparing a written
financial plan and other financial planning services is based on the complexity involved and skill
required to complete the plan. The Financial Planning Process includes:
1.
Establishing and defining the client‐planner relationship;
2.
Gathering extensive personal and financial client data, including the exploration of
Client’s goals and objectives;
3.
Analyzing and evaluate the Client’s financial status and formulate action
recommendations and plans for Client to progress towards goals and objectives;
4.
Developing and present recommendations to Client in a consultative and interactive
manner towards formal financial plan;
5.
Implementing the financial planning recommendations, including any action plans and
investment plans;
6.
Monitoring the financial planning recommendations, per agreement. The advice and
monitoring arrangement is continuous if the Client elects to engage CFG for regular
review of the plan.
B. Investment and Asset Management:
Typically, a broad‐based written financial plan would include advice on income tax
planning, life and disability insurance planning, estate planning, retirement planning, children’s
education planning, cash flow and investment planning. All these things might not necessarily
involve securities. Broad‐based financial planning comprises the bulk of services provided by
CFG.
Page 4
CFG provides individualized discretionary and non‐
discretionary investment advisory services, including but not limited to utilizing the following
kinds of assets: mutual funds, stocks, bonds, exchange traded funds, index products, and on a
more limited basis, options, private placements, hedge funds, as well as separate accounts, with
services provided internally or through third‐parties. Clients can impose reasonable
restrictions on the management of their account, such as limiting the amount of certain
securities or types of securities in their portfolio. For discretionary accounts, CFG has full
Creative Financial Group Disclosure Brochure
January 28, 2026
ACFG14023V25
discretion to supervise, manage and direct the assets in the Client account; however, CFG
attempts to secure Client approval prior to execution of any transactions.
CFG serves as an overall wealth manager for its Clients. CFG’s Financial Planning services
revolve around setting investment goals and objectives, formulating a comprehensive asset
allocation strategy, selecting investment managers or funds, reporting and meeting periodically,
and making change recommendations as necessary. Many of the actual processes and advisory
services are integrated with the Financial Planning services:
1. Planning: Set investment scope, goals and objectives, and formalize an appropriate asset
allocation strategy.
2. Implementation: Select investment products appropriate for each Client’s investment
goals. Products and services recommended by CFG may be implemented through CFG or
through any other broker, agent or representative chosen by the client. Clients are not
required to implement the Financial Plan through CFG.
3. Monitoring: Portfolio reports are prepared for Clients, usually quarterly. Account
reviews are scheduled, at least annually, to assess asset allocations and discuss any
changes to the Client’s financial situation.
C. Tax‐Related Services:
Unsupervised Assets: Under certain circumstances, a Client may hold securities or other
property in their brokerage account for which CFG does not provide investment advisory
services (“Unsupervised Assets”). An unsupervised asset is not monitored or reviewed by CFG
and is only traded upon instructions from the Client. CFG may request that Clients provide a
list of Unsupervised Assets in writing and may also request any trade instructions are in writing.
Client account statements normally include the Unsupervised Assets, but these assets are not
included in the account fee calculations, do not count towards assets under management, and
CFG will have no duty, responsibility or liability with respect to the Unsupervised Assets and
will not take the Unsupervised Assets into consideration when managing the portion of the
account for which it provides investment advice.
Unsupervised assets are not included in
current investment performance calculations, nor historical performance calculations,
provided that the asset has been designated as unsupervised since the account’s inception. In
cases where an asset is part of the managed portfolio and is later designated as unsupervised,
the historical performance will include that asset’s returns up to the point at which it was
designated as unsupervised.
CFG provides individualized tax‐related services with emphasis upon:
1. Identifying tax‐saving opportunities, primarily through the
financial planning
relationship, including employee benefits, investment planning, gifts and charitable
giving, and estate planning concerns.
2. Preparing periodic tax projections.
3. Preparing tax returns, as described in the Client agreement and/or engagement letter.
4. Considering changes in tax laws, investment products, business relationships, employee
D. Risk Management Services:
benefits plans, and family relationships.
CFG provides individual risk management services with
emphasis upon identifying financial and non‐financial risk‐related alternatives including:
1. Long‐term care;
2. Life insurance;
3. Employee/employer benefits;
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Creative Financial Group Disclosure Brochure
January 28, 2026
4. Disability insurance;
ACFG14023V25
5. Business succession planning; and/or
6. Estate planning.
E. Administrative Services:
CFG, under the broad umbrella of administrative/family office
services, provides management and coordination of the following:
1. Cash flow management, including services with budgeting and financial statement
preparation;
2. Document and Record Management;
3. Coordination of external advisors, including legal, financial, and risk management;
4. Family objectives development, including philanthropy and trust referrals.
Item 5 – Fees and Compensation
Financial Planning Services – Fees and Compensation:
Fees associated with financial planning services vary in conjunction with the complexity of each
individual engagement. Fees for a comprehensive financial plan begin at $2,500/plan. In addition, some
engagements may be agreed upon via an hourly rate approach, ranging from $150/hour to $300/hour
depending upon the level of complexity and/or experience level of the advisor(s) providing the services.
Terms and schedule of payment are agreed upon at time of engagement and can be modified upon
agreement between the Client and CFG. For producing a written financial plan and providing other
financial planning advice, CFG charges fees according to the degree of complexity involved and the skill
required in the formulation of the advice. After initial data gathering, a fee is estimated by CFG and quoted
to the Client for the Client’s agreement. One‐half the agreed upon fee is due immediately upon acceptance
by the Client. The remaining one‐half of the fee is due at completion and delivery of the written financial
plan. The financial planning agreement can be terminated at any time by the Client prior to completion of
the plan. There will be a refund to the Client of fees paid for which services have not been rendered. If a
Client elects an update of a written financial plan, the fee is negotiated and agreed upon in advance of
preparation and delivery of the plan. These fees are payable one‐half upon engagement and one‐half upon
delivery of the updated written financial plan. Termination and refund of unearned fees for written
financial plan updates are handled in the same manner as for the original written financial plan.
If a Client elects a periodic review, the fee is negotiated, agreed upon and paid in advance, and is
refundable on a pro‐rata basis if the Client wishes to terminate the agreement. Incidental investment
analysis is priced at a fee agreed upon with the Client in advance, but due and payable in arrears. There is
Investment and Asset Management Services – Fees and Compensation:
no refund policy for fees paid in arrears.
Fees for investment and asset
management services are billed quarterly in arrears and based upon the market value of assets held in
the Client’s accounts on the last business day of each quarter. Unsupervised assets are not included in the
fee calculations. The fee will be prorated if the contract is made effective or cancelled within a quarter.
Fees are negotiable. While fees to different Clients may vary, all fees are quoted to the Client in advance
and the Client is always free to decline the fee and the service. The actual fee schedule paid by the Client
is noted in each Client’s advisory agreement.
CFG’s basic fee schedule for Investment and Asset Management services is as follows:
First $250,000
Next $250,000
Next $500,000
Over $1,000,000
1.50% annual rate
1.25% annual rate
1.00% annual rate
0.75% annual rate
Page 6
‐
‐
‐
‐
Creative Financial Group Disclosure Brochure
January 28, 2026
ACFG14023V25
Tax‐Related Services – Fees and Compensation
: Fees associated with tax related services vary based
on the complexity of each individual engagement and the skill required in providing tax‐ related services.
Fees for an individual tax return preparation begin at $500/return. In addition, some engagements may
be agreed upon via an hourly rate approach, ranging from $150/hour to $300/hour depending upon level
of complexity and/or experience level of the advisor(s) providing the services. Terms and schedule of
payment are agreed upon at time of engagement and can be modified upon agreement between the Client
and CFG.
In conjunction with its tax‐related service offerings to Clients, CFG utilizes the services of NDTS Books &
Taxes 101, a tax preparation company that is owned and operated by an employee of CFG. CFG provides
Risk Management Services – Fees and Compensation
payment to the tax preparation company for services rendered.
: Risk management or insurance services are
often imbedded with the comprehensive financial planning services and are not billed separately. In
special circumstances, special engagements may be agreed upon via an hourly rate approach, ranging
from $150/hour to $300/hour depending upon level of complexity and/or experience level of the
advisor(s) providing the services. Terms and schedule of payment are agreed upon at the time of
engagement and can be modified upon agreement between the Client and CFG.
Insurance products recommended as part of risk management services may incur additional costs, such
Administrative Services – Fees and Compensation
as commissions, transaction fees, account fees or other expenses.
: Fees associated with administrative services vary
in conjunction with the determination and complexity of each individual relationship. Administrative
services will be coordinated, if applicable, with other services provided by CFG into a comprehensive
wealth management approach. Terms and schedule of payment are agreed upon at time of engagement
and can be modified upon agreement between the Client and CFG.
These services are offered individually and in combination. Additional fees may be incurred from
products, transaction fees, account fees, or services provided by other affiliated or unaffiliated third
General Information Regarding Fees and Compensation:
parties.
While it is the policy of CFG to charge
investment management fees to its Clients in accordance with the fee schedules in effect at the time of
executing the investment management agreement, fees are subject to negotiation and may vary from the
aforementioned schedule to reflect circumstances that may apply to a specific client relationship or
account. Examples of exceptions to standard CFG fee schedule include:
1.
2.
3.
4.
5.
6.
7.
Fee schedules for accounts of employees, family members, or associates of CFG;
Affiliates of CFG, accounts of employees of broker‐dealer or advisory firms with whom CFG
maintains a relationship or agreement;
Long‐standing client relationships;
Anticipated additions to Client’s assets;
Size and scope of the assets under management;
The nature of the financial planning relationship, including potential credits applied for fees; and,
Aggregation of all accounts of one family or household.
Fees are calculated based upon valuations from CFG’s portfolio management system. These valuations
may vary from the custodian statements due to timely recognition of accruals, dividends, minor pricing
differences, corporate actions, other transactions in process, etc. In accordance with CFG’s account house‐
holding policy and upon request from the Client, accounts may be aggregated for purposes of the fee
calculation, with the blended fees applied to the individual accounts pro‐rata.
Page 7
When a third party manager is selected to provide investment advice to the Client, the actual fee schedule
may be higher than what is listed herein. From these fees, CFG at its sole discretion may pay a portion of
Creative Financial Group Disclosure Brochure
the management fee to the third party manager for their services.
January 28, 2026
ACFG14023V25
All fees paid to CFG for investment and asset management services are separate and distinct from the
internal fees and expenses charged by open‐end mutual funds, closed‐end mutual funds, exchange‐traded
funds, unit investment trusts or other investment company securities. Unless otherwise noted, the
standard fees described herein do not include items such as transaction charges, postage and handling
fees for statements and/or trade confirmations, transfer fees, exchange fees, electronic fund and wire
transfer fees, product expense or purchase/sales fees, brokerage account maintenance fees/charges, or
any other charges, taxes or other fees mandated by any federal, state or other applicable law or
otherwise agreed to with the Client. Clients directing CFG to use another broker‐dealer/custodian
will incur fees, transaction costs and expenses established by the firm selected by the Client and to
whom CFG has been directed to use. Neither CFG nor its affiliates has control over the pricing of the
specified broker‐dealer/custodian's fees, transaction costs, or other expenses related to the account
established at said firm. Some of these fees may be paid to CFG. In addition, any out‐of‐pocket expenses,
such as travel expenses, may be invoiced separately. Please refer to Item 12 for more information about
CFG’s brokerage practices.
Many mutual funds are offered with more than one type of fee structure, commonly called “share classes”.
There are several factors to consider when selecting a mutual fund share class. For example it is
important to evaluate whether a share class involves payment of a commission at the time of purchase
(commonly referred to as “front end loads”), at the time of liquidation (“back end loads”), incrementally
while the investor owns the share class (“level loads”) or no commission at all (“no‐loads”). Share classes
also differ in terms of what fees and expenses are deducted from the mutual fund’s pooled investment
assets, since these fees and expenses are often not billed separately to a mutual fund shareholder. While
there a variety of fees investors may encounter when purchasing a mutual fund, common fees/expenses
include management fees paid to the fund’s investment manager, operating expenses used to pay for the
day‐to‐day costs incurred to operate the mutual fund, and distribution fees (known as “12b‐1” fees) used
to promote, advertise, or compensate financial professionals for aiding in sales of a mutual fund. Though
not all mutual fund shares classes include each of the fees/expenses presented here, what remains
consistent is that a mutual fund’s share class with a lower total annual expense as compared to another
share class of the same fund can result in a significant difference in investment returns over time. It is
common for mutual funds to set certain eligibility requirements, such as minimum investment amounts,
for an investor to qualify for purchasing a lower cost share class. Investors can learn more about a
specific mutual fund’s available share classes and the fees, loads, expenses, and eligibility requirements
by reading the fund’s investment prospectus. In addition, we encourage Clients to ask their representative
about the fees and expenses associated with mutual funds currently owned by the Clients or those
presented to them. The programs described in this brochure do not offer, or may not qualify for, all share
classes offered by a fund company. Therefore, it is possible you could invest in a lower costing share class of
the same fund if purchased outside the programs outlined in this brochure, though without the benefit of the
advice and related services we offer through our programs. Despite our reasonable efforts to utilize cost‐
effective share classes, there is no guarantee that a client will always be in the most cost advantageous
share class. Ask your representative about shares classes available to you.
Page 8
With respect to funds that pay 12b‐1 fees, SSI's intent (including that of the CFG division), is to limit the
use of such funds by opting to use a share class of the same fund which does not include 12b‐1 fee
payments wherever possible. However, in cases where we receive 12b‐1 payments from a fund, the Firm
generally will seek to credit the entire 12b‐1 payment to the advisory Client's(s') account holding the
asset which generated the payment from the fund. These credits are intended to but may not guarantee
the same effect as investing into a non‐12b‐1 class. Credits to client accounts generally occur monthly
and represent the total 12b‐1 fee payments credited during the preceding month. Additionally, the Firm
will generally seek to issue a check to the most recent address of record of closed client accounts
representing 12b‐1 payments the Firm received as a result of funds owned during the quarter in which
the account was closed.
Creative Financial Group Disclosure Brochure
SSI’s clearing firm, Fidelity Clearing and Custody Solutions ("FCCS"), sponsors a “No Transaction Fee”
January 28, 2026
ACFG14023V25
program (the “NTF Program”) whereby FCCS does not charge SSI a transaction fee for purchase or
sell orders SSI submits on a Client’s behalf for mutual funds participating in the NTF Program. SSI
benefits from this cost savings, therefore creating a conflict in that SSI may be incented to recommend or
use the mutual funds participating in the NTF Program for advisory client accounts over those mutual
funds which do not participate. However, SSI does not give preference itself, nor does the Firm influence,
recommend, promote, advise or otherwise direct any third party investment adviser, to select mutual
funds participating in the NTF Program over those funds which do not participate.
Advisory Clients may also maintain non‐advisory brokerage accounts. Representatives of CFG are
compensated through commissions assessed on the transactions executed in these accounts or through
some other manner, such as 12b‐1 fees. This creates an incentive for the representative to recommend
investment products based on the compensation received rather than on the Client’s needs. However, all
brokerage services are performed on a non‐discretionary basis; therefore, transactions are approved by
the Client in advance. In addition, advisory fees are not charged on brokerage accounts.
To the extent that a Client invests in new issues of equity or fixed‐income security, SSI will receive a selling
concession or other similar type of compensation, as described in the prospectus or offering document of
the security. This compensation is in addition to the fees paid in conjunction with Investment and Asset
Management services. Clients are not required to implement any investment recommendation through
CFG, SSI or its affiliates. Investment products may be purchased through brokers or representatives that
are not affiliated with CFG. On a limited basis, Clients may direct CFG to utilize a specified Custodian for
custody purposes and for all securities transactions for a specified account. By directing use of a specific
broker‐dealer and/or custodian, a Client may not receive best execution on transactions for such account.
SSI has partnered with Pinnacle Bank, an SSI affiliate and Federal Deposit Insurance Corporation (“FDIC”)
member bank, to offer certain advisory clients the option of sweeping free credit balances within the
investment account to a Pinnacle Bank deposit account chosen as those clients’ core investment vehicle
(the “Bank Sweep Program). SSI receives an annual fee from Pinnacle Bank of $25 to $50 for each account
participating in the Bank Sweep Program. Items 10 and 12 of this Brochure contain additional
information and important disclosures about the Bank Sweep Program.
The CFG Division of SSI charges a transaction fee of $10 for each mutual fund and equity order of 5000
shares or less ($10 plus $0.0125 per share for equity trades of over 5000 shares), up to $50 for options
orders and $15 dollars for fixed income trades. These transaction fees are in addition to asset
management fees assessed to accounts, and thus may create a financial incentive to trade more
frequently within advisory accounts. However, CFG does not recommend or place transactions with the
intent of increasing fee revenue. Rather, transactions within portfolios are recommended and placed with
the Client’s best interest in mind and in accordance with the Client’s expressed investment purpose,
needs, risk appetite, and other factors important to the Client. Further information regarding transaction
fees and other miscellaneous service costs are detailed in CFG’s Asset Management Transaction Fee
Schedule, a copy of which is available free of charge at any time upon request or via CFG’s website
Fee Debiting Authority
www.cfgltd.com.
: Clients may, but are not required to, grant CFG the authority to debit fees
directly from the Clients’ accounts held through FCCS, SSI’s clearing firm. If the Client authorizes CFG to
CFG urges clients to review
debit fees, CFG is deemed to have custody of the Client’s funds. Clients will receive a statement, usually
the information on the statement for accuracy and compare the information to any reports
monthly but no less than quarterly, directly from their account custodian.
received directly from CFG/SSI.
Please refer to Item 15 of this document for additional disclosures
relating to Custody.
Item 6 – Performance‐Based Fees and Side‐By‐Side Management
Page 9
Creative Financial Group does not charge any Clients a performance‐based fee.
Creative Financial Group Disclosure Brochure
January 28, 2026
ACFG14023V25
Item 7 – Types of Clients
Creative Financial Group provides financial planning and asset management services to individuals, high
net worth individuals, estates, corporate pension and profit‐sharing plans, charitable institutions,
foundations, endowments, trust programs, and other corporations or business entities.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Creative Financial Group offers advice on the following types of securities:
1.
Equity securities, including exchange‐listed securities, securities traded over‐the‐counter, and
foreign issues;
2.
Warrants;
3.
Corporate debt securities;
4.
Commercial paper;
5.
Certificates of deposit (CDs);
6.
Municipal securities;
7.
Investment company securities, including, variable life insurance, variable annuities, and mutual
fund shares;
8.
United States government securities;
9.
Options contracts on securities; and Interests in partnerships investing in real estate, oil and gas
interests.
In the event that it is an appropriate investment for the Client, CFG may recommend partnership interests,
such as real estate, commodities, agriculture, citrus crops, cattle, equipment leasing and/or entertainment
investments. CFG may also recommend alternative investments such as hedge funds, private placements,
and tangible assets, such as precious metals, coins, precious stones or stamps. Recommendations of these
asset types are typically associated with very high investment risk and very high volatility.
CFG purchases information from open sources and from industry sources such as Morningstar, Value Line,
and by publications such as Standard & Poor’s Corporation Stock Guide, Barron’s, Wall Street Journal, or
other such publications. In addition, CFG depends upon its contacts and qualified third parties, including
its affiliates, in the investment community with certain technical experts who offer advice on market
timing, cyclical analysis, etc.
CFG utilizes many third‐party resources for investment knowledge, perspective, forecasting, etc., in
personalized investment strategies. CFG may use third party managers for investment guidance and asset
allocation recommendations. If the Client elects to use the services of a third party manager, CFG may pay
a portion of its management fee to the third party manager for their services.
Investing in securities involves risk of loss that Clients should be prepared to bear. CFG uses its best
judgment and good faith efforts in providing advisory services to Clients. CFG cannot warrant or
Not every investment decision or recommendation made by CFG will be profitable. The Client
guarantee any particular level of account performance, or that an account will be profitable over time.
should understand that investments in securities are subject to various market, currency,
inflation, economic, political and business risks. We attempt to minimize these risks by
recommending diversified portfolios constructed to meet the specific goals and objectives of
Clients.
In
such instances, Clients are exposed to unique risks not otherwise inherent to their advisory
From time to time, Clients may pledge assets held in their advisory accounts as collateral for a loan.
accounts and this strategy is not suitable for everyone
Page 10
. Before a Client decides to pledge their
Creative Financial Group Disclosure Brochure
January 28, 2026
ACFG14023V25
•
advisory assets as collateral for a loan, care must be given to consider the following:
•
Changes in market conditions could impact your account at any time and affect the value of the
securities in your account pledged as collateral. Should the value of your assets fall below the
amount of your loan, you may be unable to draw upon your account, pledged securities may need
to be sold for less than the original price you paid, and/or other appropriate steps may need to
be taken to ensure you can still meet your loan obligation to Pinnacle.
•
If you are required to sell some of the pledged securities, any long‐term investment
strategies and goals may be impacted. Therefore, it is important you discuss with your advisory
representative your investment goals, objectives, risk tolerance, strategies and time horizon
concerning any advisory account you pledge as collateral.
•
Should loan repayment terms not be met, the lender may instruct us to sell some or all pledged
securities as payment against the loan. In this instance, you are not able to choose which
securities are liquidated. You would also be responsible for any shortfall in the loan after such
sale. It is essential that you carefully review the provisions outlined in your loan agreement and
the corresponding collateral control agreement, as it contains details such as who has trading
authority, amongst other important information.
•
The CFG division of SSI provides certain tax services to a limited number of Clients with whom
the extent of tax services provided is determined on a case‐by‐case basis. Pledging advisory
account assets as collateral can have tax implications and we encouraged you to discuss those
with your tax professional. CFG does not provide tax advice concerning assets pledged as
collateral unless the Client has specifically engaged CFG to tax advice regarding such matters.
•
SSI is an affiliate of Pinnacle Bank (the “Bank”), and both are subsidiaries of Pinnacle
Financial Partners, Inc. By establishing an investment advisory account used to collateralize a
loan, you will be responsible for paying to SSI any advisory/management fees, and any other fees
as outlined in Item 5 of this Brochure, in addition to paying to the Bank any interest, fees, or other
agreed upon expenses. Your SSI advisory representative may also be a dual employee of the
Bank, and your Bank loan officer may also be an advisory representative of SSI. SSI advisory
representatives and/or the Bank’s loan officers may receive incentive compensation relating to
loans and advisory accounts used as collateral.
There is no guarantee that returns of any advisory account will meet or exceed your loan costs.
Carefully consider the interest rate and repayment terms of the loan before making a final
decision.
We have included in Appendix A of this brochure a list of common risks and their definitions. The list is
not meant to be inclusive of all possible risks but rather to help our Clients better understand that each
investment management program involves certain risks.
Item 9 – Disciplinary Information
Page 11
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of CFG or the integrity of CFG’s management.
The CFG division of Synovus Securities, Inc., does not have any disciplinary disclosure information.
However, in October of 2025, SSI and the Financial Industry Regulatory Authority (FINRA) formalized a
regulatory action known as a Letter of Acceptance, Waiver, and Consent whereby SSI, without admitting
or denying the findings, consented to sanctions and findings by FINRA that, from January 2022 to
September 2025, SSI failed to establish, maintain, and enforce a supervisory system and procedures
reasonably designed to address forgery and falsification of electronic signatures; as a result, FINRA found
that SSI violated FINRA Rules 3110, 4511, and 2010, Section 17 (A) of the Securities Exchange Act of 1934,
and Exchange Act Rule 17A‐3. The Firm agreed to a censure and to a fine of $315,000. Information
Creative Financial Group Disclosure Brochure
January 28, 2026
concerning this matter is also available via www.brokercheck.com and www.adviserinfo.sec.gov by either
ACFG14023V25
searching under the firm name Synovus Securities, Inc., or the firm CRD#14023.
Item 10 – Other Financial Industry Activities and Affiliations
CFG is a division of Synovus Securities, Inc. (“SSI”). SSI is also a broker‐dealer registered with the
Securities and Exchange Commission, FINRA and various state regulatory agencies. In this capacity, SSI is
involved in the sale of various types of securities, such as stock, bonds, and mutual funds. Employees
providing investment advisory services to Clients are also registered representatives and are able to
affect securities transactions on behalf of Clients. Clients may maintain brokerage accounts that are not
advisory accounts. In these accounts, CFG and its representatives are compensated based on commissions
and/or other fees paid by the Client as a result of the purchase or sale of an investment product. This may
represent a conflict of interest when determining recommendations for the Client, as there is an incentive
to recommend investment products based on the compensation received rather than on the Client’s
needs.
Consequently, brokerage services are offered to Clients on a non‐discretionary basis. Brokerage
transactions and sales of any investment products are approved by Clients in advance. Representatives
of CFG do not receive separate commissions on advisory accounts. Likewise, advisory fees are not charged
on non‐advisory brokerage accounts. CFG recognizes that a potential conflict exists when it offers both
brokerage services and investment advisory services to its Clients. CFG requires its representatives, when
offering both types of services, to explain the different services and identify the capacity in which they are
acting when making recommendations.
SSI is a licensed insurance company in all five of the Firm’s footprint states including Georgia, Florida,
Alabama, South Carolina, Tennessee, and various other states outside the company’s brick and mortar
locations in the aforementioned footprint states. Additionally, SSI has affiliations with other insurance
companies in those states. Individuals of SSI may also be licensed insurance agents. To the extent that a
representative of SSI recommends insurance products and services, SSI and/or the representative will
receive commissions on the sale of those products. In some instances, SSI representatives receive a higher
percentage of insurance commissions generated than the percentage they receive from brokerage or
advisory business. These commissions are paid directly from the insurance company underwriting the
insurance policy and are not paid separately by the Client.
CFG is a division of Synovus Securities, Inc. SSI is a wholly owned subsidiary of Pinnacle Financial
Partners, Inc., a publicly traded multi‐billion dollar bank holding company based in Atlanta, Georgia.
Pinnacle Financial Partners, Inc. provides integrated financial services including banking, financial
management, insurance, mortgage, and leasing service. CFG is under common control with the following
entities that have material business arrangements with CFG and/or other divisions of SSI. Certain
employees, directors and members of CFG’s executive management may also serve as employees,
Synovus Trust Company, N.A. (a National Trust Company)
directors and/or executive management of these entities:
33 West 14th Street
Columbus, Georgia 31901
Pinnacle Bank (a Tennessee state chartered bank)
21 Platform Way South, Suite 2300
Nashville, TN 37203
Page 12
SSI utilizes its affiliate, Pinnacle Bank, to provide a bank sweep deposit option (“Bank Sweep Program”)
as the core account investment vehicle for free credit balances in brokerage accounts. This includes
accounts opened as part of CFG’s investment advisory offerings (see Item 5 for a description of the
offerings) with limited exceptions. Specifically, the Bank Sweep Program is not available to ERISA plan
accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase Plans, etc.) or to
Creative Financial Group Disclosure Brochure
individual retirement accounts (e.g. Traditional IRA, Roth IRA, SIMPLE, etc.) managed as part of an
January 28, 2026
ACFG14023V25
investment advisory program. The arrangement between SSI and Pinnacle Bank to deliver a Bank Sweep
Program creates certain conflicts in that both SSI and its affiliates financially benefit from having free
credit balances swept from brokerage accounts to deposit accounts held at Pinnacle Bank. More details
about the Bank Sweep Program, related conflicts of interest, and compensation derived from it are
found under Item 12‐Brokerage Practices.
Robert W. “Buzz” Law, President of the CFG division of Synovus Securities, Inc., is a licensed real estate
broker in the State of Georgia through Austral Realty, an unaffiliated entity.
In conjunction with its tax‐related service offerings to Clients, CFG utilizes the services of NDTS Books &
Taxes 101, a tax preparation company that is owned and operated by an employee of CFG. CFG provides
payment to the tax preparation company for services rendered.
Item 11 – Code of Ethics
Code of Ethics & Personal Trading
CFG’s Code of Ethics (the “Code”) sets forth a professional business standard to guide CFG and its
employees to place the Clients’ interests before its own. No CFG employee shall prefer his or her own
interest to that of the advisory Client. CFG requires its employees to act in accordance with applicable
federal, state and regulatory agency regulations governing investment advisory practices. The standards
of conduct outline our fiduciary responsibilities and the Code includes our policies related to insider
trading, personal securities transactions, privacy of Client information and reporting requirements.
CFG employees may purchase and sell securities for their own accounts that have also been recommended
to Clients. The Code is designed to prevent personal securities transactions and interests of CFG
employees from interfering with making decisions in the best interest of Clients.
Nonetheless, because the Code permits employees to invest in the same securities as Clients, there is a
possibility that employees might benefit from market activity by a Client. Certain security types, such as
Initial Public Offerings and Private Placements, may be prohibited or subject to a pre‐ clearance
requirement. CFG’s associated persons are required to provide a quarterly report to the Firm’s
Compliance Department showing investment transactions in their personal accounts, as well as disclosing
annually all securities held on their behalf. Governing regulations provide that certain securities are
exempt from this reporting requirement based upon the determination such securities would not
pose any material conflicts. These reports are monitored regularly in an effort to reasonably prevent
conflicts of interest between SSI and its Clients.
Clients or prospective Clients may request a copy of the firm's Code of Ethics by contacting SSI’s
Participation or Interest in Client Transactions
Chief Compliance Officer, Gene Gunderson, at 706‐644‐0298.
CFG or its associated persons may engage in principal transactions and/or agency cross transactions,
subject to Section 206(3) of the Investment Advisers Act of 1940. In accordance with the regulation, SSI
will disclose the capacity in which it acted and will obtain client consent from both parties involved in the
transaction prior to the trade settlement date. These disclosures and consents are required to make all
necessary facts known and to alert Clients to SSI’s potential conflicts of interest in a principal, riskless
principal, or agency cross transaction.
Item 12 – Brokerage Practices
CFG does not receive any proprietary or third‐party research in connection with any soft dollar
arrangements. All research is paid for with hard dollars. CFG does not receive client referrals from
unaffiliated broker‐dealers.
Page 13
Many employees of CFG are registered representatives of SSI. SSI is a registered investment adviser,
Creative Financial Group Disclosure Brochure
registered broker‐dealer, and member of FINRA/SIPC. Fidelity Clearing and Custody Solutions (“FCCS”)
January 28, 2026
ACFG14023V25
was selected by SSI to provide custody, clearing and trade execution for SSI Clients. Services provided by
FCCS in this capacity are provided pursuant to a separate agreement between SSI and FCCS. In its capacity
as SSI’s clearing firm, FCCS provides discounted execution costs upon SSI reaching certain transaction
volumes. In addition, SSI receives benefits, not related to execution of transactions, to offset the costs of
certain workstation expenses. SSI is otherwise unaffiliated with FCCS. SSI may also receive additional
compensation directly from FCCS on behalf of the advisory accounts for which they serve as custodian.
FCCS may pay SSI a percentage of the uninvested cash and/or the balance maintained in a money market
sweep vehicle.
CFG requires all client accounts (with very limited exceptions) to be held in custody at FCCS and all
transactions to be executed by FCCS through SSI. This creates a conflict of interest, as SSI is in effect acting
as both broker and adviser on behalf of the client. Not all investment advisers require clients to use a
specific broker‐dealer. This requirement may represent a conflict of interest, as CFG is limited in its ability
to seek out brokers with different pricing structures or broader services, or to receive more favorable
pricing on securities transactions. Therefore, by directing brokerage, Clients may not receive best
execution on transactions though it is SSI’s aim to provide the most cost effective executions based upon
prevailing conditions at the time of trade. On a limited basis, Clients may direct CFG to use a particular
broker‐dealer and/or custodian other than FCCS to execute client transactions and custody client funds
and securities. Clients that choose to designate a particular broker should consider that such designation
may result in certain additional costs or disadvantages to the Client, either because the Client may pay
higher commissions on transactions that might otherwise be attainable, or the Client may receive less
favorable executions.
SSI is dependent upon FCCS, as its clearing firm, for having agreements in place with mutual fund sponsors
in order for SSI’s investment advisory customers to have access to mutual funds. While FCCS has
agreements in place with a large variety of mutual fund sponsors, not all mutual funds are available
through FCCS. Moreover, many mutual funds offer different share classes, often for the same fund,
representing different fee and expense structures paid by shareholders of a fund. Certain classes of shares
may not be available through FCCS and consequently SSI Clients may not have access to a lower costing
share class otherwise available to investors directly from the fund, a different clearing firm, or other
financial intermediary. This limitation could result in SSI Clients purchasing and/or holding a more
expensive share class of a mutual fund thereby reducing the investment returns.
In coordination with FCCS, SSI also offers to CFG brokerage and investment advisory customers'
participation in the Bank Sweep Program as their core investment vehicle, subject to the exclusions noted
under Item 10 of this Brochure. Participants in the program have free credit balances within their
brokerage/investment advisory account automatically swept to an interest bearing bank deposit account
at Pinnacle Bank, a Federal Deposit Insurance Corporation (“FDIC”) member bank that is affiliated with
SSI. Client balances swept into a deposit account at Pinnacle Bank are eligible for FDIC insurance
coverage up to $250,000 per depositor in each insurable capacity. Examples of separate insurable
capacities include the following non‐exhaustive list: individual accounts, joint accounts, certain trust
arrangements, etc. However, a Client’s cash balance in the Bank Sweep Program is subject to aggregation
with other deposit assets the Client has at Pinnacle Bank outside of the Bank Sweep Program. Neither SSI
(inclusive of the CFG division) nor Pinnacle Bank will monitor the aggregate amount of deposits a Client
has with Pinnacle Bank either directly or through participation in the Bank Sweep Program to determine
the extent of deposit insurance coverage available at any time for program participants. Therefore, each
Client participating in Bank Sweep Program is responsible for monitoring the aggregate total of deposited
assets and determining the extent of deposit insurance applicable to the Client’s deposits.
Page 14
Through the Bank Sweep Program arrangement, SSI and its affiliates benefit financially. Pinnacle Bank
earns net income from the difference in interest paid to Bank Sweep Program participants for balances
held in their core investment accounts and income received from new lending or investment activity
derived from the program deposits (referred to as “spread”). As with any depository institution, Pinnacle
Creative Financial Group Disclosure Brochure
Bank’s income increases when the spread between interest paid, and income received widens. Pinnacle
January 28, 2026
ACFG14023V25
Bank has no obligation to base its interest payments to Bank Sweep Program participants on the
profitability of the income generated from the spread. In addition, SSI receives from Pinnacle Bank an
annual fee ranging from $25 to $50 for each account participating in the Bank Sweep Program. Together,
these financial benefits to SSI and its affiliates create a conflict of interest as accounts participating in the
program may be more profitable to Pinnacle Financial Partners, Inc. than those who do not participate.
To address this conflict, Clients may decline participation in the Bank Sweep Program and SSI offers
alternative choices for core investment vehicles for free credit balances. In addition, SSI excludes
eligibility from the Bank Sweep Program any ERISA plan accounts (e.g., 401(k), Pension Plans, Profit
Sharing Plans, and Money Purchase Plans, etc.) or to individual retirement accounts (e.g. Traditional IRA,
Roth IRA, SIMPLE, etc. opened under an investment advisory program. Lastly, at the time of account
opening, or election into the program, Clients seeking participation in the Bank Sweep Program are
provided with important disclosure documents and agreements containing further details. These
documents may be obtained at any time free of charge upon the request of current or prospective Clients.
Accounts are managed on an individual basis. Therefore, with the exception of fixed income transactions,
it is not a customary practice for CFG to aggregate client trades. If CFG finds that aggregating trades is in
the Client’s best interest, CFG will allocate these trades in a manner that is fair and equitable to each
account participating in the trade. To the extent that a Client uses a third party portfolio manager, the
third party portfolio manager may aggregate trades in accordance with their own policies and procedures
which may differ from CFG’s policies and procedures.
Item 13 – Review of Accounts
As described in Item 1, many facets of a Client’s financial situation are reviewed as part of the Financial
Planning services offered to Clients. Thereafter, Clients may request periodic updates to their financial
plan or consultations to discuss changes to their financial situation. The financial planning agreement
may also provide for regular reviews and updates to the plan at regular intervals.
Clients receive account statements and transaction confirmations directly from the account custodian
usually monthly, but not less than quarterly. Quarterly or other periodic reports are sent out to each
investment and asset management Client, unless suppressed at a client’s direction. CFG representatives
meet with Clients periodically (at the Client’s preference) to review investment accounts and ensure
accounts continue to be managed in accordance with the Client’s goals and objectives.
Item 14 – Client Referrals and Other Compensation
CFG and its representatives do not receive any economic benefits from any third parties with respect to
the advisory services offered to Clients. Product sponsors, mutual fund companies or other third parties
may offer CFG representatives invitations to training sessions, due diligence visits or other meeting or
events at the expense of the third party. These invitations are not offered directly as a result of any
amount of business placed with the third party, but the volume of business placed with a particular
sponsor may be indirectly related. CFG does not compensate, either directly or indirectly, any unaffiliated
party for client referrals or solicitations.
Item 15 – Custody
SSI is dually registered as an investment adviser and broker‐dealer. As broker‐dealer SSI has a minimum
net capital requirement of $250,000 and can accept checks made payable to SSI for deposit into Client
accounts. However, all checks and securities are promptly forwarded to our clearing firm, Fidelity
Clearing and Custody Solutions. Because SSI and CFG accept checks in this manner, under SEC rule
206(4)‐2, they are deemed to have custody of investment advisory accounts.
CFG also has custody because investment advisory fees are directly debited from certain Client accounts.
CFG
Debiting of fees is done pursuant to authorization provided by each Client. FCCS, as the account custodian,
Creative Financial Group Disclosure Brochure
Page 15
furnishes account statements usually monthly, but no less than quarterly, directly to the Clients.
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ACFG14023V25
urges Clients to carefully review their statements for accuracy and compare those records to any
report received directly from CFG/SSI.
Reports prepared by SSI may vary from custodial statements
based on accounting procedures, reporting dates, or valuation methodologies of certain securities.
CFG urges Clients to carefully review their statements for
In very limited situations, Clients may direct CFG to manage assets held with custodians other than FCCS
accuracy and compare those records to any report received directly from CFG/SSI.
and with whom CFG is not affiliated.
Reports
prepared by CFG/SSI may vary from custodial statements based on accounting procedures, reporting
dates, or valuation methodologies of certain securities.
Except in limited circumstances, CFG officers and employees are restricted from serving as account
trustees or in similar capacities unless a pre‐existing, personal relationship exists, or with prior consent
of the Chief Compliance Officer. If the relationship is not based on a personal or familial relationship, CFG
and/or its affiliates will engage an independent public accountant to conduct a surprise audit each year.
CFG will ensure that these accounts are maintained with a qualified custodian that will send statements
at least quarterly to the Client (or independent representative of the Client.)
In order to comply with the custody rules, SSI engages an independent public accountant to perform
an internal controls audit on the operations of SSI, its divisions, and certain affiliates and also to conduct
a surprise examination of any accounts over which it is deemed to have custody. Audits are done annually
and a copy of CFG/SSI's most recent Accountant Surprise Examination Report can be obtained free of
charge via www.adviserinfo.sec.gov.
Item 16 – Investment Discretion
CFG manages client portfolios on both a discretionary and non‐discretionary basis. Clients grant CFG
discretion over their account by providing authorization in the investment advisory agreement. This
discretionary authority authorizes CFG to determine the securities to be bought or sold and the amount
of securities to be bought or sold.
Selections of investments follow the parameters determined for the Client as well as any specific
instructions, investment objectives and risk profile associated with each Client.
Item 17 – Voting Client Securities
CFG does not take any action or render any advice on voting proxies. Furthermore, CFG will not advise
or act on a Client’s behalf in any legal proceedings, including bankruptcies or class action lawsuits. Clients
will receive proxies, and any other issuer communication, directly from their account custodian. Clients
may contact CFG with questions relating to the proxy voting process, but CFG does not provide any
recommendations on how to vote any particular issue.
Item 18 – Financial Information
Creative Financial Group is required to provide you with certain financial information or disclosures
about its financial condition. CFG has no financial commitment that impairs its ability to meet contractual
and fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding.
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ACFG14023V25
Appendix A – Risk Definit ions
All investments offer a balance between risk and potential return. Generally speaking, a typical investor
will take on more investment risk in exchange for the opportunity for greater return. The risk definitions
below are intended to assist our clients in understanding the common risks associated in investing. The
terms listed below are not comprehensive to all potential investment risks and may not be applicable for
all investment strategies.
Business Cycle Risk
Call Risk
The risk that cyclical business cycles, with periods of peak performance
followed by a downturn, then a trough of low activity, affect the returns
of an investment, an asset class or an individual company’s profits.
See reinvestment risk. Some corporate, municipal and agency bonds
have a “call provision” entitling their issuers to redeem them at a
specified price on a date prior to maturity. Declining interest rates may
accelerate the redemption of a callable bond, causing an investor’s
principal to be returned sooner than expected. In that scenario, investors
have to reinvest the principal at the lower interest rates than they may
have had prior.
Collateral Account Risk
Commodity Price Risk
A client may enter into a separate agreement with a creditor, bank,
broker/dealer or other financial institution (together, “creditor”) to
pledge securities or assets against a loan or collateral amount. This
agreement grants the creditor a security interest to transfer, sell,
redeem, close, open, trade or otherwise liquidate any assets in the
account (including instructions to transfer assets directly) in the pledged
assets or collateral account. Adverse market conditions can impact the
value of the value of the pledged securities causing the portfolio value to
decline. This may result in the client to pledge additional assets, pay
down the line of credit or the creditor may instruct the adviser and/or
custodian to sell pledged assets, which depending on market conditions
may result in receiving less for the securities than the original purchase
price. Declining market conditions may also limit client’s ability to draw
upon their account. Long‐term investment strategies and goals may be
adversely impacted by the creditor’s actions, as they may instruct the
adviser to sell some or all of the pledged assets as payment against the
loan. In this instance, since the creditor agreement may provide certain
rights, the client may not be able to choose which securities are
liquidated and the client would also be responsible for any loan shortfall
after such sale. There is no guarantee that investment account returns
will meet or exceed loan costs.
The possibility that fluctuations in the price, shortage or overabundance
of material inputs, such as fuel, energy, raw materials, metals,
manpower, etc. will materially impact operating a company, production
of goods/services or reduce the attractiveness or price of an investment.
Composition Risk
Page 17
The possibility that changes in an index, resulting from security
membership, market capitalization and weighting, and investment guide
changes may increase the relative dispersion for a strategy and result in
unexpected performance variance. Security membership, being added,
reduced or weight changed, in an index may result in security prices
Creative Financial Group Disclosure Brochure
changes.
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ACFG14023V25
Consumers Risk
The risk when clients are exposed to unsuitable investments that they
do not fully understand.
Correlation Risk
See Diversification Risk ‐ When portfolio holdings are too highly
correlated with each other, meaning that the move up and down in value
together, there may be insufficient diversification to counter market or
security risks.
Counterparty Risk
Also called default risk. Counterparty risk occurs when one or more
parties to an agreement, such as a bond, defaults and does not fulfill their
contractual obligation, such as payments or principal. For example, a
bond issuer with a lower quality rating may have a higher default risk
and its bonds will need to pay a higher yield than an issuer with a higher
rating.
Credit Rating / Issuer
Quality Risk
Credit rating agencies provide analysis and comparative opinions on the
bond issuer's ability and willingness to meet its financial obligations. For
bond holders, risk occurs when the opinion changes, resulting in a lower
rating, which may decrease the current holding value and may make it
more expensive, in the form of higher interest rates, for the issuer to
raise new debt to meet future obligations. Credit ratings are not
indications of investment merit, but are a significant factor in the
investment decision. Generally, the higher the credit rating, the higher
the bond price relative to the yield rate.
Currency / Foreign
Exchange Risk
Also called foreign exchange risk and implies international investing: the
possibility that the relative change in currency value from one country
to another will reduce the investment value when converted back from
one currency to the other.
Dispersion Risk
The uncertainty risk associated when an investment strategy is not in
accordance with its model, resulting in performance or risk that is less
or greater than expected.
Diversification Risk
Diversification means to reduce risk by investing in a variety of assets,
and generally in assets that do not move up or down in value together
(correlate). There are two forms of diversification risk: A portfolio that
is relatively undiversified, such as having a single security or positively
correlated holdings may be more volatile and value sensitive to the
security’s market actions. A portfolio that is too diversified may result in
a proxy for an index, and not provide acceptable returns relative to the
fees or expenses incurred with a managed account.
Economic Risk
The risk that economic conditions, such as government regulations, tax
policies, political or social instability, workforce, or exchange rates will
negatively affect investments, usually one in a foreign country. Economic
risk is one of the reasons why international investing, especially in
emerging countries, carries more risk than domestic investing.
Expenses and Fees Risk
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Exchange traded funds, like mutual funds, generally incur operating
expenses for management, record‐keeping, custodial services, taxes,
legal, accounting and audit fees, which are taken from the fund's assets
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January 28, 2026
ACFG14023V25
and lower investor return. Different funds may have different expenses
and fees ratios, relative to the fund assets. Therefore, selection of a fund
with higher expenses and fees may have lower performance than a
comparable fund with a lower expense ratio.
Industry Risk
The possibility of investment losses related to a specific industry or
market sector stemming from economic or regulatory change,
instability, volatility or market shift from a particular industry. These
losses may increase in relation to overall portfolio weighting towards
that industry.
Inflation Risk
Inflation causes tomorrow’s dollar to be worth less than today’s.
Inflation reduces the purchasing power of a bond investor’s future
interest payments and principal, collectively known as “cash flows.”
Inflation also leads to higher interest rates, which in turn leads to lower
bond prices.
Interest Rate Risk
The possibility that the value of a security, especially a bond, will reduce
as a resulting from a rise in interest rates.
Inverse Market ETF Risk
Inverse ETFs are designed to replicate the opposite direction of the
matching or indicated index. These ETFs often use a combination of
futures, swaps, short sales, and other derivatives to achieve these
inverse objectives. As complex products, inverse ETFs may not track the
underlying or contra benchmark as expected and are often designed to
achieve their results on a daily basis only. That means over periods
longer than a trading day, the value of these ETFs can and usually do
deviate from the reciprocal performance of the associated index to
which they correlate. Over longer periods of time or in situations of high
volatility, these deviations can be substantial.
Legal Risk
The risk that a legal contract or financial transaction won't be fulfilled
because it breaks a law or there is a regulatory conflict. In addition,
companies involved in legal actions may have to increase cash reserves
for settlement, which may restrict their growth ability, lower their
relative profit or income potential, and be more volatile.
Liquidity Risk
The risk that investors may have difficulty finding a buyer when they want
to sell a security and may be forced to sell at a significant discount to its
expected market value. Liquidity risk is greater for thinly traded securities.
Market Capitalization
Risk
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Creative Financial Group Disclosure Brochure
January 28, 2026
A company's market capitalization, one measure of potential growth, is
the value calculated from the company's shares outstanding multiplied
by the price per share. The basic market cap categories are large‐cap,
mid‐cap and small‐cap. Large‐cap stocks, representing companies over
$10 billion in size, are generally researched and followed more by
analysts or investors. Many large‐cap companies are called “Blue Chips”.
Large‐caps historically experience comparatively slower growth, with
less risk, than smaller‐sized companies. Smaller‐sized companies
typically are not as financially strong but are expected to grow at a faster
rate with greater investment return potential. Smaller‐sized companies
and funds may experience greater up/down price and value volatility.
ACFG14023V25
Within investment guidelines, many strategies, ETFs or mutual funds
focus their funds in investing in specific market cap sized companies.
Market capitalization risk exists when comparative‐sized companies,
such as large, mid‐ or small‐caps as a whole and the ETFs and funds
targeted to the cap, would decline, bringing the associated values down
regardless of the fundamental characteristics or investment potential.
Strategy allocations that over‐ or under‐weight asset classes, including
market caps, may have greater volatility missed return potential, or
relative loss.
Market Risk
Also called systematic or undiversifiable risk: The risk that the stock or
bond market as a whole would decline, bringing the value of individual
securities down with it regardless of their fundamental characteristics
or investment potential.
Model Risk
The possibility that the analysis, investment or allocation decisions for a
strategy model may be unreliable or provide incorrect signals in volatile
market conditions.
Pandemic Risk
Large‐scale outbreaks of infectious disease that can greatly increase
morbidity and mortality over a wide geographic area, crossing
international boundaries, and causing significant economic, social, and
political disruption.
Regulatory Risk
The risk that changes in laws and regulations will impact a security,
business, sector or market. A change in laws or regulations made by the
government or a regulatory body can increase the costs of operating a
business, reduce the attractiveness of investment, and/or change the
competitive landscape.
Reinvestment Risk
Also see inflation risk. Risk occurs, especially in a declining interest rate
environment, when an income producing bond or security is sold or
called and the reinvested funds may yield a lower rate than the original
security. The reinvested assets may provide a lower cash flow than
expected or required to meet the investor’s investment objectives.
Security Selection Risk
The risk that an investor chooses a security that underperforms the
market for reasons that cannot be anticipated. The possibility of
investment losses related to a specific company or security stemming
from economic or regulatory change, business climate, earnings surprise
or legal action relative to a specific company. These losses may increase
in relation to the security's overall portfolio weighting.
Sociopolitical Risk
Tax Risk
The danger that political or cultural changes or instability in a location
or a country could turn against an investment.
For taxable accounts, the possibility that the security holdings, interest,
dividends and timing of the buys/sell transactions will increase one's tax
liability. Tax risk may also occur when investing just prior to dividend or
capital gain activities for ETFs or mutual funds.
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January 28, 2026
ACFG14023V25
Time Horizon Risk
Investment time horizon generally reflects the total length of time the
investor expects to invest before the assets are used for their financial
goal (e.g., retirement income). Because different security types, such as
equities, bonds and cash have different reward and risk characteristics,
a client's time horizon is important in influencing the investment and
strategy decisions. Generally, the shorter the client's time horizon, the
less time available to the client to recover from any incurred losses.
Timing Risk
The risk that an investment performs poorly after its purchase or better
after its sale. This risk may reflect security selection made either too
soon or too late, relative to historical review, and thereby missing profit
opportunities or increasing loss potential.
Tracking Error Risk
Also called active risk. The possibility that a security, such as ETF or
mutual fund, deviates from and does not accurately track its defined
index or benchmark. The fund does not work as effectively as intended,
resulting in unexpected asset allocation and price behavior for the
holding.
Trading Volume Risk
Trading volume occurs as a direct result of supply and demand.
Generally, the greater the trading volume, the more liquid it is and the
spread between buy/sell transactions is smaller. A lightly‐traded
security may have more volatile pricing, be less liquid and have higher
transaction costs due the buy/sell spreads.
Turnover Rate Risk
Turnover rate or ratio reflects the frequency that managers buy or sells
securities within a portfolio. There is no turnover rate that is correct for
all accounts – the rate will vary upon the strategy type, securities held,
or investment conditions. In effect, a high turnover rate may reflect
excessive trading, resulting in potentially higher costs or transaction
expenses, increased capital gains tax liability of the portfolio, and
reduced relative performance. A low turnover rate, again not conclusive,
may reflect low account management activity or decreased available
investment opportunities.
Valuation Risk
Difficulty in pricing/fairly valuing securities that are thinly or
infrequently traded, not readily accessible, illiquid, or of varying quality.
In the absence of accurate security valuation, buy or sell transactions
may be higher or lower than anticipated. Securities that increase or
decrease in price may result in overweight or underweight conditions
relative to a model or benchmark, increasing diversification risk.
Yield Curve Risk
Page 21
The yield curve represents the relationship between rate of return or
interest rates and time to maturity. For bond holders, risk occurs when
bond values decrease, impacting portfolio value, when interest rates go
up or when needed fixed income or cash flow decrease when bond prices
go up. The yield curve will slope, up/down and widen or narrow, in
relationship between short term bond yields and long‐term bond yields
and varying maturities. To compensate for the liquidity risk of tying up
one's money for long periods of time, a typical investor expects a higher
rate of return for a longer time to maturity.
Creative Financial Group Disclosure Brochure
January 28, 2026
ACFG14023V25
Additional Brochure: SYNOVUS SECURITIES, INC. ADV PART 2A (2026-01-28)
View Document Text
It em 1 – Cover Page
Synovus Securities, Inc.
33 W est 14 th Street, 3 rd Floor
Columbus, GA 31901
(706) 649- 2327
January 28, 2026
This Brochure provides information about the qualifications and business practices of Synovus Securities,
Inc. (“SSI”). If you have any questions about the contents of this Brochure, please contact Gene Gunderson,
Chief Compliance Officer at (706) 644-0298 or by email at genegunderson@synovus.com. The information
in this Brochure has not been approved or verified by the United States Securities and Exchange Commission
or by any state securities authority.
Synovus Securities, Inc. is a registered investment adviser. Registration of an investment adviser does not
imply any level of skill or training. The oral and written communications of an Adviser provide you with
information about which you determine to hire or retain an Adviser.
Inc. and Creative Financial Group
is also available on
This disclosure Brochure describes the business practices of Synovus Securities, Inc. SSI also offers advisory
services under a separate division, known as Creative Financial Group (CFG). CFG’s business practices are
described in a separate Brochure, which is available upon request. Additional information about Synovus
Securities,
the SEC’s website at
www.adviserinfo.sec.gov.
Page 1
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
It em 2 – Mat erial Changes
This Brochure dated January 28, 2026, is a revised document prepared according to the Securities and
Exchange Commission's (“SEC) requirements and rules. This Item will discuss only specific material
changes that are made to the Brochure and provide clients with a summary of such changes.
Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and
subsequent Brochures within 120 days of the close of our business' fiscal year. We may further provide
other ongoing disclosure information about material changes as necessary.
We will further provide you with a new Brochure as necessary based on changes or new information, at any
time, without charge.
This Brochure does not contain any material changes but has been updated since the previous version filed
with the Securities and Exchange Commission dated November 3, 2025, to include refreshed totals for assets
under management.
Effective January 1, 2026, Synovus Securities, Inc. became a wholly owned subsidiary of Pinnacle Financial
Partners, Inc. as a result of a merger between Synovus Financial Corp. and Pinnacle Financial Partners, Inc.
Please review these updates, and all sections of this Brochure, carefully before making investment decisions.
We will further provide you with a new Brochure as necessary based on changes or new information, at any
time, without charge. Copies of this Brochure may be requested by contacting Gene Gunderson, Chief
Compliance Officer at (706) 644-0298 or genegunderson@synovus.com. It is also available free of charge
via our website at https://www.synovus.com/about-us/our-companies. Clients have the option to
electronically receive copies of this Brochure, along with any subsequent updates. Please contact your
Financial Advisor for more information about electing electronic delivery for future brochures.
Page 2
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
It em 3 - Table of Content s
It em 1 – Cover Page ...................................................................................................................... 1
It em 2 – Mat erial Changes ............................................................................................................ 2
It em 3 - Table of Content s ............................................................................................................ 3
It em 4 – Advisory Business ........................................................................................................... 4
It em 5 – Fees and Compensat ion .................................................................................................. 8
It em 6 – Performance-Based Fees and Side-By-Side Management .......................................... 14
It em 7 – Types of Client s ............................................................................................................. 14
It em 8 – Methods of Analysis, Invest ment St rat egies and Risk of Loss .................................... 15
It em 9 – Disciplinary Informat ion ............................................................................................... 16
It em 10 – Ot her Financial Indust ry Act ivit ies and Affiliat ions .................................................. 17
It em 11 – Code of Et hics ............................................................................................................. 18
It em 12 – Brokerage Pract ices .................................................................................................... 19
It em 13 – Review of Account s .................................................................................................... 20
It em 14 – Client Referrals and Ot her Compensat ion ................................................................. 21
It em 15 – Cust ody ....................................................................................................................... 22
It em 16 – Invest ment Discret ion ................................................................................................ 22
It em 17 – Vot ing Client Securit ies .............................................................................................. 22
It em 18 – Financial Informat ion .................................................................................................. 23
Brochure Supplement (s)
Page 3
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
It em 4 – Advisory Business
Synovus Securities, Inc., (“SSI”) is a full-service brokerage and investment advisory firm headquartered in
Columbus, Georgia, with offices across Georgia, Alabama, Florida, South Carolina, and Tennessee. SSI is
owned by Pinnacle Financial Partners, Inc. (NYSE: PNFP), a multi-billion dollar publicly traded bank holding
company also based in Atlanta, Georgia. SSI is a registered broker-dealer and registered investment adviser
with the Securities and Exchange Commission, as well as a member of FINRA and various state regulatory
agencies.
As of January 1, 2026, Synovus Securities, Inc.’s assets under management were $4,987,877,578 on a
discretionary basis, and $3,457,205,437 on a non-discretionary basis.
The general investment services offered to clients are outlined in the bullet points below. The specific
details of each investment program (each a “Program” or collectively “Programs”) available to clients are
described later in Item 4 of this Brochure.
•
•
•
•
•
•
•
•
•
•
Collecting detailed information about the client’s current financial situation;
Identifying client’s goals and objectives;
Developing an appropriate asset allocation model;
Providing asset management services, including individually managed accounts;
Offering mutual fund model portfolios;
Selecting money managers;
Evaluating performance and monitoring services;
Periodic rebalancing;
Executing securities transactions; and,
Providing custody of assets through National Financial Services, LLC. (“NFS”).
Where applicable, portfolio managers selected to manage client accounts may buy, sell or otherwise trade
securities of SSI’s parent company, Pinnacle Financial Partners, Inc. , in client accounts. While this may
appear to create a conflict of interest, these decisions are made solely at the discretion of the manager and
are not influenced by SSI or any of its affiliates. SSI does not recommend to advisory clients the purchase or
sale of any stock issued by Pinnacle Financial Partners, Inc.
Each Program may impose account minimums and due to these minimums, adequate diversification may
not be achieved. The number of accounts within any given program varies, including some with a limited
number of investor accounts. More information about each program is available from your Financial
SYNO VUS INVESTMENT STRATEGIES P RO GRAM
Advisor.
Separately Managed Account Program
1
(“SIS Program”) through Envestnet Asset
SSI offers the Synovus Investment Strategies Program
Management, Inc. (“Envestnet”). Envestnet is a registered investment adviser that operates a technology
platform to assist SSI in providing a variety of managed account offerings, recommending asset allocations
or specific investment managers and/or investment products to our clients. Envestnet is not affiliated with
SSI. A complete description of the SIS Program and the services provided by Envestnet are outlined in
Envestnet’s ADV Part 2, which you should read carefully. The following describes SSI’s offerings available
through the SIS Program.
SSI offers a Separately Managed Account Program through our relationship with Envestnet. This
provides our clients with access to more than 1000 investment strategies available from over 100
1 Synovus Managed Accounts Solution Platform (“MAS”) prior to October 3, 2016
Page 4
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
portfolio managers selected by Envestnet through their due diligence and portfolio manager
evaluation processes. The Separately Managed Account Program is designed to provide our clients
the ability to tailor an investment portfolio to their specific financial needs such as diversification or
tax-conscious investing, along with affording clients further customization of their portfolio by
placing reasonable investment restrictions on the types of assets allowed within the account.
Portfolio managers are recommended based on the client’s investment objectives as determined
from the Client Risk Tolerance Questionnaire. Manager changes would be recommended if SSI’s or
Envestnet’s due diligence reviews indicate the portfolio manager is no longer suitable for a
particular investment strategy or if a client’s investment objectives change. The minimum account
value for the Separately Managed Account Program varies based upon the subadviser(s) chosen.
Mutual Fund & ETF Asset Allocation W rap Strategies Program (“Strategist Program”)
SSI offers mutual fund and ETF asset allocation portfolios (“fund portfolios”) via the Envestnet
platform. The Firm offers fund portfolios created by unaffiliated investment advisers who directly
manage the assets or use one or more model portfolios created by one or more independent
investment advisers (collectively “Strategists”). The Strategists available through SSI are first
screened by Envestnet for inclusion on the Envestnet platform. From that pool, SSI then reviews
and approves certain Strategists the Firm then makes available to our customers.
A number of no load/load-waived mutual funds or exchange-traded funds from various fund
families are available within the portfolios. An asset allocation model is selected based on each
client’s risk score as determined by the Client Risk Tolerance Questionnaire (the “RTQ”). The client
may modify the RTQ at any time by completing the requisite documentation with their adviser
representative. After initial fund portfolio selection, the Strategists will make portfolio changes on
a discretionary basis for their respective models as deemed necessary or appropriate to maintain
the agreed upon investment approach.
Advisor Directed Program
SSI, through its licensed advisory representatives, provides asset management services to clients. The
Advisor Directed Accounts are managed on an individualized basis. Clients have the option to assign
investment discretion to SSI and select SSI investment advisory representatives (individually referred to
as “Advisory Representative” and collectively “Advisory Representatives”) whom the firm has approved
to offer discretionary services. Alternatively, clients can elect to have their account managed on a non-
discretionary basis whereby the SSI Advisory Representative provides recommendations to the
client, who has ultimate decision-making authority in determining whether to proceed with any
recommendation. For clients electing to open a discretionary account, SSI, through selected
Advisory Representatives, has full discretion to supervise, manage and direct the assets in the
client’s account within the mandates of the client’s stated investment objectives, tolerance for risk,
time horizon for investing the assets, and other suitability factors (collectively referred to as the
“Client Investment Profile”) provided to SSI by the client during the account opening and/or review
process. Clients participating in either the discretionary or non-discretionary offering are free to
change or update their Client Investment Profiles at any time by contacting the Advisory
Representative assigned to the account and should do so whenever the information previously
provided to SSI is no longer current or accurate. By providing written notice to the Firm, clients may
elect to revoke the discretion granted to SSI and/or the Advisory Representative and opt to have
their Advisor Directed accounts managed a non-discretionary basis. In such cases, the account will
remain non-discretionary unless or until a client elects to grant discretion in writing to SSI and/or
its Advisory Representative.
Page 5
SSI may use professional services of other third parties, including its affiliates, in servicing either
discretionary or non-discretionary Advisor Directed Accounts. Clients working with SSI’s Advisory
Representatives selected to offer discretionary Advisor Directed Accounts are limited to using only
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
those investments approved by SSI’s Investment Policy Committee based upon research and
recommendations made by SSI’s Investment Advisory Group. Investments and any strategy used
are determined based upon the client’s responses and completion of the RTQ. Though not an
exhaustive list, SSI primarily utilizes mutual funds, stocks, bonds, exchange-traded funds, cash or
cash equivalents. On a limited basis, clients participating in the non-discretionary Advisor Directed
Program may also utilize options within their portfolios, subject to additional suitability and
investor experience criteria specific to investing in options. Finally, clients in either discretionary
or non-discretionary offerings have the option to provide specific guidelines or impose reasonable
restrictions on the management of the portfolio. For this reason, each portfolio’s investment results
will differ, including those with similar investment objectives, and clients should not expect the
performance of their portfolios will be identical with another client of SSI. The minimum account
Unified Managed Account Program
value for the Advisor Directed Account Program is $100,000.
Through our relationship with Envestnet, SSI offers the Unified Managed Account (“UMA”) Program,
which allows clients access to multiple investment strategies by using Separate Account Managers,
mutual funds and/or ETFs, Strategists, model providers, and/or models provided by SSI to facilitate
diversification within an individually managed account. The UMA program includes a Synovus-
branded offering called Synovus Choice, offering access to a broad array of asset classes through use
of mutual funds, ETFs, and/or Separate Account Managers. The fees associated with Synovus Choice
are the same as SSI’s other UMA offerings and, importantly, SSI representatives do not receive any
extra financial compensation for recommending the Synovus Choice UMA over any other UMA
program offered by SSI. The SSI Representative will structure the account based upon the client’s
stated goals and objectives as articulated through the RTQ. The minimum account value for the UMA
Program is $100,000.
The SIS Program includes unregistered securities offerings of alternative investments such as private equity,
private debt, and hedge funds. To invest in these offerings, you must meet the definition of an Accredited
Investor or a Qualified Purchaser, depending on the specific offering. An investment in alternative assets
entails a high degree of risk (including the possible loss of a substantial part, or even the entire amount, of
an investment) and no assurance can be given that any alternative investment will achieve its objectives or
that investors will receive a return of their capital. Further, such investments may not be subject to the same
levels of regulatory scrutiny as publicly listed investments, and as a result, investors may have access to
significantly less information than they can access with respect to publicly listed investments. Prospective
investors should also note that investments in the products described typically involve long lockups and do
not provide investors with liquidity. This Brochure is not intended to provide you with a full description of
risks and considerations related to alternative investments offered through the SIS Program; rather, each
alternative investment has its own offering memorandum which contains these and other important details.
Reviewing the offering memorandum is essential before making an investment decision and you are
SSI INDIVIDUALLY M ANAGED ACCO UNT P RO GRAM
strongly encouraged to discuss its contents with your Financial Advisor.
Page 6
SSI provides asset management services to clients and manages each client’s account on an individualized
basis. Accounts may be managed on a discretionary or non-discretionary basis, depending on the needs of
the client. SSI may use professional services of other third parties, including its affiliates, in managing
accounts. Investments are determined based upon the client’s investment objectives, risk tolerance, net
worth, net income and various other suitability factors. Clients may provide specific guidelines or impose
reasonable restrictions on the management of the portfolio. For this reason, performance of portfolios,
including those within the same investment objective, is likely to differ and clients should not expect that
the performance of their portfolios will be identical with another client of SSI. SSI only accepts accounts
that have a minimum asset value of $100,000. However, accounts with a lesser value may be accepted at
Synovus Securities, Inc. Disclosure Brochure
SSI’s discretion.
January 28, 2026 • A14023V37
O UTSIDE M O NEY M ANAGER P RO GRAM
Synovus Securities, Inc. may refer customers to other investment advisers or portfolio managers outside of
the various Programs listed above. SSI recommends the money management services of non-affiliated
companies (“Managers”). Managers are recommended based upon the investment objectives of the client,
but the ultimate decision to hire an outside manager is made by each client. SSI regularly monitors and
reviews the services provided by the Manager and will recommend changes if the Manager is no longer
suitable for a particular investment strategy or if a client’s investment objectives change. Clients
participating in the Outside Money Manager Program complete customer investment profile information
and/or questionnaires designed to identify their investment objectives and risk appetite. In addition to
recommending an outside money manager, SSI representatives can provide ongoing investment advice on
assets held directly through insurance carriers’ variable contracts such as variable annuities. SSI’s
representatives provide advice concerning the allocation of the contract values across sub-account choices,
information pertaining to any contract riders, and guidance on distribution options.
Each Manager imposes account minimums varying from $25,000 to $5,000,000. SSI will recommend
managers for whom the client meets the minimum investment amount. SSI has no ability to waive the
VARIABLE INSURANCE CO NTRACT P RO GRAM
minimum account size imposed by any particular manager.
SSI charges an annual fee of 1.50% for advice related to variable insurance contracts. The firm may agree
to charge less than 1.50% but has set a minimum annual fee of $500. Fees are billed monthly in advance
based upon the prior month’s ending contract value, as calculated by the issuer of the contract. The
minimum contract value for this service is $50,000. While this program intends to use variable insurance
contracts issued without a commission or 12b-1 fees, certain additional contract fees still apply such as
mortality and expense charges, rider fees, contract administration charges, and subaccount investment
management fees. These fees and charges are disclosed in the variable contract’s prospectus, which you
FINANCIAL P LANNING
should read carefully before investing.
In addition to the above Programs,
Synovus Securities, Inc., provides comprehensive, integrated Financial
Planning services intended to address a variety of needs customized for each client situation. The offerings
include:
Asset Allocation Analysis,
Investment Planning,
Retirement and Cash Flow Planning,
Estate and Gift Tax Planning,
Wealth Transfer Planning,
Charitable Gift Planning,
Education Funding,
Income Tax Planning,
Risk Management Analysis,
Personal Insurance Planning, and
Closely Held Business Succession Planning
The fee Synovus Securities, Inc., charges for preparing a written financial plan and other financial planning
services is based on the complexity involved and skill required to complete the plan. The Financial Planning
Process includes:
Page 7
Establishing and defining the client-planner relationship and the scope of the services to be provide
Gathering extensive personal and financial client data, including the exploration of client’s goals and
objectives;
Analyzing and evaluating the client’s current financial status and identifying deficiencies and
opportunities to move the client closer to achieving goals;
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
Developing and presenting recommendations and alternatives to the client in a consultative and
interactive manner, revising as appropriate, to arrive at actionable recommendations;
Assisting the client, to the extent necessary and agreed upon, with the implementation of the
recommendations, including coordinating as needed with the client’s other advisers;
Monitoring the financial planning recommendations, per agreement. Unless otherwise provided in
the engagement agreement, it is the client’s responsibility to contact their Synovus Securities, Inc.
advisor to obtain a determination as to whether it is appropriate or necessary to review the plan or
to enter into a new engagement.
Typically, a comprehensive written financial plan includes recommendations regarding cash flow and debt
management, income tax planning, personal (life, disability and long-term care) insurance planning, estate
planning, charitable gift planning, retirement planning, children’s education funding, cash flow and
investment planning. Not all these areas will necessarily involve securities.
Financial planning information is obtained through personal interview with each client concerning the
client’s current financial status, future goals, and attitudes toward risk. Documents and information
supplied by the client are carefully reviewed. Once the review is complete, a written financial plan is
provided to the client. Alternatively, financial planning clients can elect to participate in the Synovus Asset
Navigator program, a data aggregation services, whereby clients authorize automated access to investment
and financial information for which the client has preauthorized the sharing. The client is under no
obligation to act upon SSI’s recommendations. If the client elects to act on any of the recommendations, the
EDUCATIO NAL O FFERINGS
client is under no obligation to affect the transactions through SSI or any registered person of SSI.
SSI provides general financial and investment educational services to certain ERISA plans. Examples of the
offerings provided include conducting one-on-one or small group educational sessions where the advisory
representative discusses the benefits of participating in company sponsored plans, explaining general
investment concepts such as historical differences in rates of return between various asset classes, and
providing information on assessing one’s own risk tolerance. Services rendered are generic in nature and
do not include specific investment recommendations or advice, nor do they involve SSI taking investment
discretion over plan assets or individual participants’ accounts. Rather, investment decisions and plan
investment options remain the responsibility of the plan participants and/or the plan fiduciary.
Clients receiving educational offerings and services of SSI are under no obligation to open accounts through
SSI nor are they required to implement any action as a result of the information provided or service
rendered.
It em 5 – Fees and Compensat ion
Clients in each Program pay a program fee (“Program Fee”) that includes the fees associated with
management, custodial and brokerage-related expenses for the client’s account, subject to certain
exceptions. Details of these fees are provided by Program in Item 5 of this brochure. Additional costs not
part of the Program Fee include, but are not limited to, transactions executed away from SSI, dealer mark-
ups, electronic fund and wire transfers, market maker spreads, exchange fees, redemption fees, short-term
trading fees imposed by mutual funds or account maintenance fees. In some accounts under SSI’s Outside
Money Manager Program described in Item 4, neither SSI nor the Manager are directed to execute trades
through SSI; consequently, transactions are expected to be executed primarily away from SSI and
accordingly will likely incur additional costs such that the account will not operate as a traditional “wrap”
account. Clients grant SSI the authority to debit Program Fees directly from clients’ accounts. Clients receive
SSI urges clients to review the information on the statement for accuracy
account statements, usually monthly but no less than quarterly, showing the account holdings and
and compare the information to any reports received directly from their SSI representative.
transactions in their account.
Please
Page 8
refer to Item 15 of this document for additional disclosures relating to Custody.
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
If the client does not have a sufficient cash/cash equivalent balance to cover the fee, SSI may liquidate assets to
generate sufficient funds for the fee to be paid. Conversely, a portion of accounts may be maintained in (and
assessed advisory fees on) cash or other cash equivalents. Advisory agreements may be terminated by either
party, without penalty, immediately upon receipt of written notice by the other party. Any such termination will
not affect a party’s status, obligations or liabilities. If an account is terminated and all assets are withdrawn from
the Program prior to the end of a billing period, the client will receive a refund of the Program Fee prorated based
on the number of calendar days left in the billing period. At the time of termination, any unpaid fees will be due.
Clients may receive comparable services from other broker-dealers or investment advisers and pay fees that are
higher or lower than those charged under these Programs. The fees for the various Programs may be more or
less than the client would have paid if the services (account management, custody and brokerage transactions)
were purchased separately outside of the Programs. Therefore, SSI representatives recommending the Programs
may have a financial incentive to recommend these Programs over other services offered by SSI. Not all Program
fees are the same and the fees Synovus receives vary by Program. This creates a financial incentive for SSI
to recommend the advisory Programs for which it receives the most compensation. However, this conflict
is mitigated by working with current and prospective clients to clearly identify each person’s goals,
objectives, financial needs, risk appetite, investment preferences, and other facts unique to the investor.
This fact-finding process is designed to identify the Program (or Programs) we recommend based upon the
investor’s best interest. We further mitigate this conflict by providing transparent fee pricing for each
Program offered, including fees clients pay to Synovus, those paid to third party managers (if any), and to
Envestnet, with whom we have partnered to deliver the technology platform used in managing clients’
accounts. We encourage you to review the various Program offerings described in this brochure and to
compare the fees found in Item 5 of this brochure associated with each Program.
Page 9
Many mutual funds are offered with more than one type of fee structure, commonly called “share classes”. There
are several factors to consider when selecting a mutual fund share class. For example it is important to evaluate
whether a share class involves payment of a commission at the time of purchase (commonly referred to as “front
end loads”), at the time of liquidation (“back end loads”), incrementally while the investor owns the share class
(“level loads”) or no commission at all (“no-loads”). Share classes also differ in terms of what fees and expenses
are deducted from the mutual fund’s pooled investment assets, since these fees and expenses are often not billed
separately to a mutual fund shareholder. While there a variety of fees investors may encounter when purchasing
a mutual fund, common fees/expenses include management fees paid to the fund’s investment manager,
operating expenses used to pay for the day-to-day costs incurred to operate the mutual fund, and distribution
fees (known as “12b-1” fees) used to promote, advertise, or compensate financial professionals for aiding in sales
of a mutual fund. Though not all mutual fund shares classes include each of the fees/expenses presented here,
what remains consistent is that a mutual fund’s share class with a lower total annual expense as compared to
another share class of the same fund can result in a significant difference in investment returns over time. It is
common for mutual funds to set eligibility requirements, such as minimum investment amounts, for an investor
to qualify for purchasing a lower cost share class. Investors can learn more about a specific mutual fund’s
available share classes, their fees, loads, expenses, and eligibility requirements by reading the fund’s investment
prospectus. In addition, we encourage clients to ask their representative about the fees and expenses associated
with mutual funds currently owned by the clients or those presented to them. The programs described in this
brochure do not offer, or may not qualify for, all share classes offered by a fund company. Therefore, it is possible
you could invest in a lower costing share class of the same fund if purchased outside the programs outlined in
this brochure, though without the benefit of the advice and related services we offer through our programs.
Despite SSI’s reasonable efforts to utilize cost-effective share classes, there is no guarantee that a client will
always be in the most cost advantageous share class. Ask your representative about shares classes available
With respect to funds that pay 12b-1 fees, SSI’s intent is to limit the use of such funds by opting to
to you.
use a share class of the same fund which does not include 12b-1 fee payments wherever possible. However,
in cases where SSI receives 12b-1 payments from a fund, the Firm generally will seek to credit the entire
12b-1 payment to the advisory client(s) account holding the asset which generated the payment from the
fund. These credits are intended to but may not guarantee the same effect as investing into a non-12b-1
Synovus Securities, Inc. Disclosure Brochure
class. Credits to client accounts generally occur monthly and represent the total 12b-1 fee payments credited
January 28, 2026 • A14023V37
during the preceding month. Additionally, SSI will generally seek to issue a check to the most recent address
of record of closed client accounts representing 12b-1 payments the Firm received as a result of funds
owned during the quarter in which the account was closed.
SSI’s clearing firm, NFS, sponsors a “No Transaction Fee” program (the “NTF Program”) whereby NFS does
not charge SSI a transaction fee for purchase or sell orders SSI submits on a client’s behalf for mutual funds
participating in the NTF Program. SSI benefits from this cost savings, therefore creating a conflict in that
SSI may be incented to recommend or use the mutual funds participating in the NTF Program for advisory
client accounts over those mutual funds which do not participate. Those funds that do not participate in the
NTF Program may include lower cost share classes. Upon a client’s request, SSI will provide at no cost a list
of any NTF eligible mutual funds held within the account and will make a representative available to the
client to answer any questions related to the share class selected along with any other share classes available
from the same fund. Information for contacting SSI is provided on the first page of this Brochure.
In conjunction with offering the Synovus Choice UMA, SSI receives access to Envestnet Fiduciary Solutions
Program (“EFS”) free of charge. The EFS Program provides SSI additional access to research, watch lists,
alerts, Large Case Support, Overlay Services and other Envestnet investment-related intellectual capital.
Without offering the Synovus Choice UMA, SSI would have to pay Envestnet for access to the EFS Program.
This creates the potential for a conflict of interest because without offering the Synovus Choice UMA, SSI
would incur extra cost for the research content available from the EFS Program. To mitigate potential
conflicts, SSI’s cost-free access to the EFS Program is not contingent upon any minimum asset values in the
Synovus Choice UMA program, nor are there any requirements to offer certain Separate Account Managers,
mutual funds, ETFs, or any other products—including those proprietary to Envestnet or its affiliates.
Furthermore, clients in the Synovus Choice UMA do not pay additional fees as compared to any other of SSI’s
UMA offerings, nor do SSI representatives receive more compensation for asset within the Synovus Choice
UMA over assets in SSI’s other UMA offerings. SSI’s access to the EFS Program content is intended to benefit
the Firm’s customers by providing SSI associated persons additional research and investment information
used in the management of client assets.
To the extent that a client of the SIS Advisor Directed or the SSI Individually Managed Account Program
invests in new issues of an equity or fixed-income security purchased in their account, SSI will receive a
selling concession, or other similar type of compensation, as described in the prospectus or offering
document of the security. SSI receives this compensation in addition to the Program Fee received for
investment advisory services. You have the option to restrict the purchase of new issues in your account or
to revoke at any time previous authorization granted to purchase them.
SSI’s advisory clients may also maintain non-advisory SSI brokerage accounts. Representatives of SSI are
compensated through commissions assessed on the transactions executed in these accounts or through
some other manner, such as 12b-1 fees. This creates an incentive for the representative to recommend
investment products based on the compensation received rather than on the client’s needs. However, SSI’s
brokerage services are generally performed on a non-discretionary basis; therefore, except in rare instances
whereby a customer has granted an SSI representative written discretionary authority, transactions are
approved by the client in advance and clients receive trade confirmations inclusive of the commissions
charged. Moreover, clients are provided a copy of SSI’s brokerage account commissions schedule at the time
of account opening. Additional copies of the brokerage commissions schedule are available free of charge
upon request by contacting your account representative or the SSI home office by calling 706-649-2327. In
addition, advisory fees are not charged on such brokerage accounts. To address this conflict, an SSI
Designated Principal reviews each new brokerage and advisory account for appropriateness based upon the
expressed needs of the client.
Page 10
While it is the policy of SSI to charge investment management fees to its clients in accordance with the fee
schedules in effect at the time of executing the investment management agreement, fees are subject to negotiation
and reflect circumstances that may apply to a specific client relationship or account. Thus, fees paid by clients do
Synovus Securities, Inc. Disclosure Brochure
vary from the program schedules described later in this section, and it is possible clients with similar asset levels
January 28, 2026 • A14023V37
to have differing fee schedules and pay different fees, even within the same program. The fees specific to each
client account are detailed in that account’s advisory contract.
If a client and the firm agree to a flat fee arrangement instead of the tiered program schedules described later in
this Brochure, the client may pay more fees than if the relevant program’s tiered fee schedule had been used. This
scenario is more likely to occur when the client’s account asset value crosses one or more of the program
schedule’s fee discount tiers. The potential for a flat fee arrangement causing a client to pay more in fees versus
the program’s standard tiered schedule creates a conflict whereby the firm and/or its representatives could be
incented to recommend a flat fee schedule in order to receive more compensation. To mitigate this conflict, SSI
and its representatives are bound to act solely in the client’s best interest including when advising on fee
arrangements. Moreover, SSI has implemented procedures at account opening and throughout the account’s
lifecycle to assess (and remediate as deemed prudent) the impact a negotiated flat fee schedule will have, or has
had, on a client’s fees. Clients can qualify for SSI advisory fee discounts by combining household balances of
related accounts within Synovus’s investment advisory offerings. This is accomplished by notifying your
Financial Advisor of any accounts sharing the same residential address for which you want to link for fee
billing purposes (“household discounts”). Accounts qualifying for household discounts can be added to, or
removed from, the linked group at your direction. SSI has determined to offer employees, associated persons
and their immediate family fee discounts resulting in lower fees than those published in this brochure. SSI
reserves the right to amend or terminate this program at its discretion.
SSI has partnered with Pinnacle Bank, an SSI affiliate and Federal Deposit Insurance Corporation (“FDIC”)
member bank, to offer certain advisory clients the option of sweeping free credit balances within the
investment account to a Pinnacle Bank deposit account chosen as those clients’ core investment vehicle (the
“Bank Sweep Program). SSI receives an annual fee from Pinnacle Bank of $25 to $50 for each account
participating in the Bank Sweep Program. Items 10 and 12 beginning on pages 17 and 19, respectively, of
this Brochure contain additional information and important disclosures about the Bank Sweep Program.
Standard Program Fee Schedules
SSI SYNO VUS INVESTMENT STRATEGIES
Clients’ payments for advisory services contain three general components: (a) fees paid to SSI for
investment advice and related services; (b) fees paid to the subadviser(s) managing the portfolio; (c) fees
paid to Envestnet for use of their technology platform and administration of client accounts. The total cost
to a client is the combination of these fee components and the following shows the maximum costs
associated with each program offered.
Separately Managed Account (SMA) Program
SYNO VUS INVESTMENT STRATEGIES SMA P RO GRAM
Synovus Investment Strategies SMA program fees are billed monthly in advance based on the prior month’s
ending market value. The annual rates are shown in the table that follows:
Amount paid to SSI
Amount paid to subadviser(s)*
Amount paid to Envestnet
Varies by subadviser chosen
1.40%
1.30%
1.20%
1.10%
0.13% to 1.02%
0.13% to 1.02%
0.13% to 1.02%
0.13% to 1.02%
0.17%
0.17%
0.17%
0.17%
Asset Range
first $500,000
next $500,000
next $1,000,000
Account Minimum†
Amount over $2,000,000
*The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but
not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI
does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the
specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment.
Page 11
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
SSI has compensation arrangements in place that provide more compensation to the Advisor than the amount paid to SSI listed above.
The additional compensation will be paid by SSI. These compensation arrangements will not increase the amount paid by the client to
SSI.
† The minimums may be waived at the sole discretion of SSI and/or the program’s money manager
Advisor Directed Program & Mutual Fund/ ETF Asset Allocation Wrap Strategies Program (“Strategist”)
SYNO VUS INVESTMENT STRATEGIES-STRATEGIC ALLO CATIO N P RO GRAM
Synovus Investment Strategies Strategist program fees are billed monthly in advance based on the prior
month’s ending market value. The annual rates are shown in the table that follows:
Amount paid to SSI
Amount paid to subadviser(s)*
Amount paid to Envestnet
Asset Range
First $500,000
Next $500,000
Next $1,000,000
Account Minimum†
Amount over $2,000,000
1.26%
1.16%
1.06%
0.96%
0.00% to 0.18%
0.00% to 0.18%
0.00% to 0.18%
$50,000
0.00% to 0.18%
0.13%
0.13%
0.13%
0.13%
SYNO VUS INVESTMENT STRATEGIES-TACTICAL ALLO CATIO N P RO GRAM
$50,000
Asset Range
First $500,000
Next $500,000
Next $1,000,000
Account Minimum†
Amount over $2,000,000
Amount paid to SSI
1.30%
1.20%
1.10%
1.00%
Amount paid to subadviser(s)*
0.25% to 0.35%
0.23% to 0.30%
0.20% to 0.25%
0.15% to 0.25%
Amount paid to Envestnet
0.13%
0.13%
0.13%
0.13%
SYNO VUS INVESTMENT STRATEGIES-FO UNDATIO NS
Asset Range
First $500,000
Next $1,500,000
Account Minimum†
Amount over $2,000,000
Amount paid to subadviser
0.10%
0.10%
$15,000
0.10%
Amount paid to Envestnet
0.10%
0.10%
0.10%
Amount paid to SSI
1.15%
1.05%
0.95%
SYNO VUS INVESTMENT STRATEGIES-ADVISO R DIRECTED P RO GRAM
‡
Amount paid to SSI
Amount paid to Envestnet
1.46%
1.36%
1.26%
$100,000
1.16%
0.08%
0.08%
0.08%
0.08%
Asset Range
first $500,000
next $500,000
next $1,000,000
Account Minimum†
Amount over $2,000,000
*The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not
limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does
not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific
subadvisory fees, are provided to clients no later than at the time of each account’s establishment.
In addition to the amount paid to SSI for advisory services, clients also pay to SSI the portfolio construction fee which is reflected in the column titled
Amount paid to SSI. This fee is like the amount paid by clients utilizing subadvisers to construct and manage portfolios. As a result, the portion of a
‡
client’s total fee paid to, and retained by SSI, is more than other Strategist programs since SSI does not have to pay a portion of the client fees to
another subadviser. This presents a potential conflict of interest whereby the Advisor Directed Program is recommended over the other Wrap
Strategist Allocation Programs. However, clients using the Advisor Directed Program may find their overall cost to be less than other Strategist
programs depending on the management fee charged by the subadviser. Moreover, SSI does not receive additional compensation (e.g., revenue
sharing) from the fund companies utilized within the Advisory Directed Program models.
† The minimums may be waived at the sole discretion of SSI and/or the program’s money manager.
Page 12
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
Unified Managed Account Program
SYNO VUS INVESTMENT STRATEGIES-UMA P RO GRAM
Synovus Investment Strategies UMA program fees are billed monthly in advance based on the prior month’s
ending market value. The annual rates are shown in the table that follows:
Amount paid to SSI
1.40%
1.30%
1.20%
1.10%
Amount paid to subadviser(s)*
0.15% to 0.67%
0.15% to 0.67%
0.15% to 0.67%
$100,000
0.15% to 0.67%
Amount paid to Envestnet
0.12%
0.12%
0.12%
0.12%
Asset Range
First $500,000
Next $500,000
Next $1,000,000
Account Minimum†
Amount above $2,000,000
*The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but
not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI
does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the
specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment.
SSI has compensation arrangements in place that provide more compensation to the Advisor than the amount paid to SSI listed above.
The additional compensation will be paid by SSI. These compensation arrangements will not increase the amount paid by the client to
SSI. † The minimums may be waived at the sole discretion of SSI and/or the program’s money manager
SSI INDIVIDUALLY M ANAGED ACCO UNT AND O UTSIDE M O NEY M ANAGER P RO GRAMS
Depending on the money manager, fees are either billed monthly or quarterly in advance based on the prior
INDIVIDUALLY M ANAGED ACCO UNTS AND O UTSIDE M O NEY M ANAGER
month's/quarter’s ending market value. The annual rates are shown in the table that follows:
P RO GRAM
Asset Range
Amount paid to SSI
Amount paid to subadviser(s)*
Varies by subadviser chosen
1.40%
1.30%
1.20%
1.10%
0.30% to 1.00%
0.30% to 1.00%
0.30% to 1.00%
0.30% to 1.00%
Amount paid for
technology platform
None
None
None
None
first $500,000
next $500,000
next $1,000,000
Account Minimum†
Amount over $2,000,000
*The subadvisers used in the Separately Managed Account Program charge varying fees as represented above. The fees’ variance is impacted by a
variety of factors such as, but not limited to, portfolio objective, securities used within the portfolio, and sectors or geographic region represented in the
portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total amount a client will pay for their investment advisory account,
inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment.
†The minimums may be waived at the sole discretion of SSI and/or the money manager.
FINANCIAL PLANNING SERVICES
Fees associated with financial planning services vary in conjunction with the complexity of each individual
engagement. Standard fees for a comprehensive financial plan begin at $1,500 per plan. In addition, some
engagements are based upon an hourly rate, ranging from $150 per hour to $300 per hour depending upon
the level of complexity and/or experience level of the advisor(s) providing the services. Terms and schedule
of payment are agreed upon at time of engagement, and can be modified upon agreement between the client
and Synovus Securities, Inc.
Page 13
For producing a written financial plan and providing other financial planning advice, Synovus Securities,
Inc., charges fees according to the degree of complexity involved and the skill required in the formulation of
the advice. After initial data gathering, a fee is estimated by Synovus Securities, Inc., and quoted to the client
for the client’s agreement. One-half the agreed upon fee (or, in the case of an hourly rate engagement, one-
half of the estimated project fee) is due upon acceptance by the client. The remaining fee is due at
completion and delivery of the written financial plan. The financial planning agreement can be terminated
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
in writing at any time by the client prior to completion of the plan. There will be a refund to the client of
fees paid for which services have not been rendered. Alternatively, SSI and/or its representatives may elect
to provide a financial plan at no cost.
If a client elects an update of a written financial plan, the fee, if any, is negotiated and agreed upon in advance
of preparation and delivery of the plan. One-half of the agreed upon engagement fees are due at inception
and one-half upon delivery of the updated written financial plan. Termination and refund of unearned fees
for written financial plan updates are handled in the same manner as for the original written financial plan.
If a client elects a periodic review, any fee is negotiated, agreed upon and paid in advance, and is refundable
on a pro-rata basis if the client wishes to terminate the agreement. Incidental investment analysis is priced
at a fee agreed upon with the client in advance, but due and payable in arrears. There is no refund policy
for fees paid in arrears.
Financial planning fees are subject to negotiation and vary from the pricing above to reflect circumstances
that apply to a specific client relationship. Examples of exceptions to the standard Synovus Securities, Inc.,
fee schedule include:
a) Accounts of employees, family members, or associates of Synovus Securities, Inc., or its
affiliated companies;
b) Long-standing client relationships;
c) Size and scope of investment advisory or brokerage relationships;
d) Anticipated additions to client’s investment advisory accounts;
e) Aggregation of family or household accounts.
Insurance or investment products implemented as part of a financial planning process may incur additional
costs, such as commissions. Additionally, SSI may receive additional compensation from one or more of its
insurance partners upon meeting a pre-determined level of commissions. However, financial planning
clients are under no obligation to purchase insurance or investment products, or otherwise implement the
recommendations provided as a result of a completed plan.
Synovus Securities, Inc. does not provide accounting or legal advice. Fees paid by the client to accountants,
attorneys or other advisors for advice or work done in connection with the financial planning or investment
advisory process are in addition to financial planning or investment advisory fees.
EDUCATIO NAL O FFERINGS
For rendering general investment and financial educational services to ERISA plans and/or participants, SSI
charges a fee that is negotiated on a plan-by-plan basis. Fee options vary but include charging a fee based
upon the total assets in a plan, a set fee based upon the number of participants, or a combination of both.
Fees charged for such services are agreed upon in writing with the plan sponsor/plan fiduciary in advance
of the services commencing.
It em 6 – Performance-Based Fees and Side-By-Side Management
Synovus Securities, Inc. does not charge any clients a performance-based fee.
It em 7 – Types of Client s
SSI generally provides services to individuals, high net worth individuals, banks or thrift institutions,
pension and profit-sharing plans, corporations, and trusts, estates and charitable organizations.
Page 14
Each investment Program offered by SSI imposes an account minimum to be eligible for the Program. SSI,
in its sole discretion, may waive the minimum asset size for any of its investment Programs. However, to
the extent that the client doesn’t meet the minimums imposed by a portfolio manager or program sponsor,
Synovus Securities, Inc. Disclosure Brochure
SSI may not have the ability to waive those requirements.
January 28, 2026 • A14023V37
SSI provides offerings to investors seeking to roll over balances held in employer-sponsored retirement
plans (often referred to as a “rollover”). Individuals with investments in a former employer’s retirement
plan generally have five options for those assets: (1) Leave the investments in that plan, (2) roll the assets
into his/her new employer’s plan, (3) rollover the money to an Individual Retirement Account, (4) liquidate
the investments and cash out the money, or (5) some combination of the previous four options. Each option
presents different considerations—including tax implications— and no one solution is right for every
investor. We encourage you to talk with your adviser about these options and to consult with a tax
professional regarding the potential impacts each of the options may have to your specific situation. SSI
has an economic incentive to recommend a rollover because assets rolled into one of our advisory programs
will generate investment management fees. In discussing and evaluating your options, it is important you
know you are under no obligation to rollover assets to us.
Information about minimum account size requirements for each Program can be found in Item 4 of this
Brochure.
It em 8 – Methods of Analysis, Invest ment St rat egies and Risk of Loss
SSI offers advisory services through the Programs described in Item 4 of this Brochure. The Programs
involve the selection of investment models or separate account managers based on the assessment of each
client’s investment goals and objectives.
SSI has implemented a due diligence process to review various facets of the manager’s business, such as
investment style, performance, portfolio management, trading and operations, and compliance. With
respect to the Synovus Investment Solutions Program (“SIS”), SSI employs use of both internal and external
resources as part of the due diligence process. Envestnet, as part of the services they perform for SSI,
conduct reviews of prospective and current money managers approved for inclusion on the SIS platform.
SSI leverages the research and assessment Envestnet performs of third-party money managers for the
following offerings available through the SIS platform: (1) Separately Managed Accounts, (2) Mutual Fund
Wrap Strategies, and (3) Unified Managed Accounts. Details concerning these program offerings are found
under Item 4 of this brochure.
SSI’s Investment Advisory Group researches and evaluates prospective and current money managers
and/or investment model providers utilized via the SIS program, primarily in connection with the Advisor
Directed Model offering, as described in Section 4 of this brochure. Information, reviews and
recommendations prepared by SSI’s Investment Advisory Group are supplied to SSI’s Due Diligence
Committee, who has final authority to add or remove a money manager or investment model provider from
the Firm’s offerings. The composition and asset allocation of each client portfolio may differ depending on
a variety of factors, including client specific investment goals, risk tolerance, and overall economic and
market conditions. While not the primary focus of the SSI Investment Advisory Group, team personnel may
from time to time also perform due diligence reviews of other SIS platform money managers previously
reviewed by Envestnet to gain additional perspective and information in support of SSI’s general oversight
efforts of the Firm’s selected advisory partners.
To the extent SSI representatives are selecting securities for investments in client portfolios, SSI uses an
asset allocation strategy, or another strategy based upon specific goals and objectives identified and agreed
to by the client to guide investment decisions.
Page 15
Investing in securities involves risk of loss that clients should be prepared to bear. SSI uses its best judgment
and good faith efforts in providing advisory services to clients. SSI cannot warrant or guarantee any
particular level of account performance, or that an account will be profitable over time. Not every
investment decision or recommendation made by SSI, or a Program manager will be profitable. Investments
in securities are subject to various market, currency, inflation, economic, political and business risks. We
attempt to minimize these risks by recommending diversified portfolios constructed to meet the specific
goals and objectives of clients. We have included with this brochure and Appendix describing risks inherent
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
with investing; please note while the list covers many of the common risks an investor may encounter it is
not meant to be exhaustive.
In such instances, clients are exposed to unique risks not otherwise inherent
From time to time, clients may elect to use margin lending or pledge assets held in their advisory accounts
this strategy is not suitable for everyone
to their advisory accounts and
as collateral for a loan.
. Before a client decides to use
margin lending or pledge their advisory assets as collateral for a loan, care must be given to consider the
•
following:
•
Changes in market conditions could impact your account at any time and affect the value of the
securities in your account to establish and maintain margin or pledged as collateral. Should the
value of your assets fall below the amount of your loan or margin maintenance requirement, you
may be unable to draw upon your account, pledged securities may need to be sold for less than the
original price you paid, and/or other appropriate steps may need to be taken to ensure you can still
meet your obligation to your margin lender (NFS) or Pinnacle.
•
If you are required to sell some of the margined or pledged securities, any long-term investment
strategies and goals may be impacted. Therefore, it is important you discuss with your advisory
representative your investment goals, objectives, risk tolerance, strategies and time horizon
concerning any advisory account in which you employ margin or pledge as collateral.
.
•
Should loan repayment terms not be met, the lender may instruct us to sell some or all margined or
pledged securities as payment against the loan. In this instance, you are not able to choose which
securities are liquidated. You would also be responsible for any shortfall in the loan after such sale.
It is essential that you carefully review the provisions outlined in your loan agreement and the
corresponding collateral control agreement, as it contains details such as who has trading authority,
amongst other important information
•
SSI is not a tax advisor. We encouraged you to discuss with your tax professionals the implications
of using margin or pledging securities as collateral.
•
SSI is an affiliate of Pinnacle Bank (the “Bank”), and both are subsidiaries of Pinnacle Financial
Partners, Inc. By establishing an investment advisory account used to collateralize a loan, you will
be responsible for paying to SSI any advisory/management fees, and any other fees as outlined in
Item 5 of this Brochure, in addition to paying to the Bank any interest, fees, or other agreed upon
expenses. Your SSI advisory representative may also be a dual employee of the Bank, and your Bank
loan officer may also be an advisory representative of SSI. SSI advisory representatives and/or the
Bank’s loan officers may receive incentive compensation relating to loans and advisory accounts
used as collateral.
There is no guarantee that returns of any advisory account will meet or exceed your loan costs.
Carefully consider the interest rate and repayment terms of the loan before making a final decision.
We have included in Appendix A of this brochure a list of common risks and their definitions. The list is not
meant to be exhaustive of all risks but rather to help our clients better understand each investment
management program involves certain risks. Additional information specific to the risks associated with
each program can be found by reading the investment manager’s ADV Part 2a. For example, risks specific
to clients in the SIS program should refer to the Envestnet ADV Part 2a.
It em 9 – Disciplinary Informat ion
Page 16
Synovus Securities, Inc. is required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of SSI or the integrity of SSI’s management. In October of 2025,
the Firm and the Financial Industry Regulatory Authority (FINRA) formalized a regulatory action known as
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
a Letter of Acceptance, Waiver, and Consent whereby SSI, without admitting or denying the findings,
consented to sanctions and findings by FINRA that, from January 2022 to September 2025, SSI failed to
establish, maintain, and enforce a supervisory system and procedures reasonably designed to address
forgery and falsification of electronic signatures; as a result, FINRA found that SSI violated FINRA Rules
3110, 4511, and 2010, Section 17 (A) of the Securities Exchange Act of 1934, and Exchange Act Rule 17A-3.
The Firm agreed to a censure and to a fine of $315,000. Information concerning this matter is also available
via www.brokercheck.com and www.adviserinfo.sec.gov by either searching under the firm name Synovus
Securities, Inc., or the firm CRD#14023.
It em 10 – Ot her Financial Indust ry Act ivit ies and Affiliat ions
SSI is also a broker-dealer registered with the Securities and Exchange Commission, FINRA and various state
regulatory agencies. In this capacity, SSI is involved in the sale of various types of securities, such as stock,
bonds, and mutual funds. Employees providing investment advisory services to clients are also registered
representatives and are able to affect securities transactions on behalf of clients. Clients may maintain SSI
brokerage accounts that are not advisory accounts. In these accounts, SSI representatives are compensated
based on commissions or other fees paid by the client as a result of the purchase or sale of an investment
product. This may represent a conflict of interest when determining recommendations for the client, as
there is an incentive to recommend investment products based on the compensation received rather than
on the client’s needs.
Consequently, brokerage services are generally offered to clients on a non-discretionary basis. Except in
rare instances whereby a customer has granted an SSI representative written discretionary authority,
Brokerage transactions and sales of any investment products are approved by clients in advance.
Representatives of SSI do not receive separate commissions on advisory accounts. Likewise, advisory fees
are not charged on non-advisory brokerage accounts. SSI recognizes that a potential conflict exists when
SSI offers both brokerage services and investment advisory services to its clients. SSI requires its
representatives, when offering both types of services, to explain the different services and identify the
capacity in which they are acting when making recommendations.
SSI is a licensed insurance company in all five of the Firm’s footprint states including Georgia, Florida,
Alabama, South Carolina, Tennessee and various other states outside the company’s brick and mortar
locations in the aforementioned footprint states. Additionally, SSI has affiliations with other insurance
companies in those states. Individuals of SSI may also be licensed insurance agents. To the extent that a
representative of SSI recommends insurance products and services, SSI and/or the representative will
receive commissions on the sale of those products. These commissions are paid directly from the insurance
company underwriting the insurance policy and are not paid separately by the client. In addition, SSI may
receive additional compensation from one or more of its insurance partners upon meeting a pre-determined
level of business production with the carrier(s).
SSI also offers investment advisory services under a separate division, known as Creative Financial Group
(“CFG”). Advisory services offered through CFG are substantially different from the services offered through
SSI’s Retail advisory program. CFG’s business practices are described in a separate Brochure, which is
available upon request.
SSI is a wholly owned subsidiary of Pinnacle Financial Partners, Inc. a publicly traded financial services
company and a registered bank holding company headquartered in Atlanta, Georgia. Pinnacle provides
integrated financial services including commercial and retail banking, financial management, insurance and
mortgage services to its customers through Pinnacle Bank.
SSI is under common control with the following entities that have material business arrangements with SSI.
Certain employees, directors and members of SSI’s executive management may also serve as employees,
directors and/or executive management of these entities:
Page 17
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
Synovus Trust Company, N.A. (a National Trust Company)
33 West 14 th Street
Columbus, Georgia 31901
Pinnacle Bank (a Tennessee state-chartered bank)
21 Platform Way South, Suite 2300
Nashville, TN 37203
In limited circumstances, advisory clients may utilize the custody services of Synovus Trust Company. These
arrangements are usually initiated by the trust company. As a general practice, SSI does not refer advisory
clients to Synovus Trust Company for custody services. In the normal course of its business, SSI
representatives may refer clients that are in need of Trust services to Synovus Trust Company. SSI is
compensated for such referrals and such compensation is shared with the representative. Neither SSI nor
its representatives provide additional advisory services to the client.
SSI utilizes its affiliate, Pinnacle Bank, to provide a bank sweep deposit option (“Bank Sweep Program”) as
the core account investment vehicle for free credit balances in brokerage accounts. This includes accounts
opened as part of SSI’s investment advisory wrap programs (see Item 5 for a description SSI’s wrap
programs) with limited exceptions. Specifically, the Bank Sweep Program is not available to ERISA plan
accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase Plans, etc.) or foreign
domiciled accounts. The arrangement between SSI and Pinnacle Bank to deliver a Bank Sweep Program
creates certain conflicts in that both SSI and its affiliates financially benefit from having free credit balances
swept from brokerage accounts to deposit accounts held at Pinnacle Bank. More details about the Bank
Sweep Program, related conflicts of interest, and compensation derived from it are found under Item 12-
Brokerage Practices.
It em 11 – Code of Et hics
Code of Ethics
SSI’s Code of Ethics (the “Code”) sets forth a professional business standard to guide SSI and its employees
to place our clients’ interests before our own. No SSI associated person shall prefer his or her own interest
to that of the advisory client. SSI requires its associated persons to act in accordance with applicable federal,
state and regulatory agency regulations governing investment advisory practices. The standards of conduct
outline our fiduciary responsibilities and the Code includes our policies related to insider trading, personal
securities transactions, privacy of client information and reporting requirements.
SSI’s employees may purchase and sell securities for their own accounts that have also been recommended
to clients. The Code is designed to prevent personal securities transactions and interests of SSI employees
from interfering with making decisions in the best interest of clients. Nonetheless, because the Code permits
employees to invest in the same securities as clients, there is a possibility that employees might benefit from
market activity by a client. Certain security types, such as Initial Public Offerings and Private Placements,
may be prohibited or subject to a pre-clearance requirement. SSI’s associated persons are required to
provide a quarterly report to the Firm’s Compliance Department showing investment transactions in their
personal accounts, as well as disclosing annually all securities held on their behalf. Governing regulations
provide that certain securities are exempt from this reporting requirement based upon the determination
such securities would not pose any material conflicts. These reports are monitored regularly in an effort to
reasonably prevent conflicts of interest between SSI and its clients.
Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting SSI’s Chief
Compliance Officer, Gene Gunderson, at 706-644-0298.
Participation or Interest in Client Transactions
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SSI or its associated persons may engage in principal transactions and/or agency cross transactions, subject
Synovus Securities, Inc. Disclosure Brochure
to Section 206(3) of the Investment Advisers Act of 1940. In accordance with the regulation, SSI will disclose
January 28, 2026 • A14023V37
the capacity in which it acted and will obtain client consent from both parties involved in the transaction
prior to the trade settlement date. These disclosures and consents are required to make all necessary facts
known and to alert clients to SSI’s potential conflicts of interest in a principal, riskless principal, or agency
cross transaction.
It em 12 – Brokerage Pract ices
SSI does not receive any proprietary or third-party research in connection with any soft dollar
arrangements. All research is paid for with hard dollars. However, to the extent a client selects a third-party
manager to manage their account, the third party manager may use client commission to purchase research
or brokerage products and services in accordance with that third party manager’s own policies and
procedures.
Employees providing investment advisory services to clients are registered representatives and are able to
affect securities transactions as instructed by clients. National Financial Services, LLC. (“NFS”), member
FINRA and SIPC, was selected by SSI to provide custody, clearing and trade execution for SSI clients. Services
provided by NFS in this capacity are rendered pursuant to a separate agreement between SSI and NFS. In
its capacity as SSI’s clearing firm, NFS provides discounted execution costs upon SSI reaching certain
transaction volumes. Execution discounts received, if any, are retained by SSI. In addition, SSI receives
benefits, not related to execution of transactions, to offset the costs of certain workstation expenses. SSI is
otherwise unaffiliated with NFS.
SSI requires all client accounts, with very limited exceptions, to be custodied at NFS and all transactions to
be executed by NFS through SSI. This creates a conflict of interest, as SSI is in effect acting as both broker
and adviser on behalf of the client. Not all investment advisers require clients to use a specific broker-dealer.
This direction to itself may represent a conflict of interest, as SSI is limited in its ability to seek out brokers
with different pricing structures or broader services, or to receive more favorable pricing on securities
transactions. Therefore, by directing brokerage, clients may not receive best execution on transactions
though it is SSI’s aim to provide the most cost effective executions based upon prevailing conditions at the
time of trade. In some accounts under SSI’s Outside Money Manager Program, neither SSI nor the manager
is directed to execute transactions through SSI/NFS. Consequently, transactions are expected to be executed
primarily away from SSI and accordingly are likely to incur additional costs such that the account will not
operate as traditional “wrap” account. In such case, the third-party manager is responsible for obtaining
best execution under their current policies and procedures.
SSI is dependent upon NFS, as its clearing firm, for having agreements in place with mutual fund sponsors
in order for SSI’s investment advisory customers to have access to mutual funds. While NFS has agreements
in place with a large number of mutual fund sponsors, not all mutual funds are available through NFS.
Moreover, many mutual funds offer different share classes, often for the same fund, representing different
fee and expense structures paid by shareholders of a fund. Certain classes of shares may not be available
through NFS. Consequently, SSI clients may not have access to a lower costing share class that may be
otherwise available to investors directly from the fund, a different clearing firm, or other financial
intermediaries. This limitation could result in SSI clients purchasing and/or holding a more expensive share
class of a mutual fund thereby reducing the investment returns. SSI may also receive additional
compensation directly from NFS on behalf of the advisory accounts for which they serve as custodian. NFS
may pay SSI a percentage of the uninvested cash and/or the balance maintained in a money market sweep
vehicle.
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As part of its relationship with NFS, SSI’s clients have access to margin lending financed through NFS. Clients
must apply and qualify for this additional service. Use of margin introduces additional risks and it not a
strategy suitable for everyone. These special risks are covered in more detail under Item 8 of this brochure.
Moreover, clients electing the use of margin will be subject to interest charges on any amount borrowed.
The interest paid by the investor is in addition to the asset management fees paid. SSI receives from NFS a
Synovus Securities, Inc. Disclosure Brochure
portion of the margin interest paid by investors. This creates a conflict of interest whereby SSI receives an
January 28, 2026 • A14023V37
economic benefit from both margin interest and the asset management fees charged. SSI mitigates this
conflict by limiting the use of margin within advisory accounts to only a select number of overlay programs
that employ the use of option securities and further limits the availability of such programs to investors
meeting eligibility requirements such as a high liquid net worth and investible assets. Margin borrowing is
not allowed in advisory accounts outside of these select overlay programs.
In coordination with NFS, SSI also offers to brokerage and investment advisory customers the participation
in the Bank Sweep Program as their core investment vehicle, subject to the exclusions noted under Item 10
of this Brochure. Participants in the program have free credit balances within their brokerage/investment
advisory account automatically swept to an interest bearing bank deposit account at Pinnacle Bank, a
Federal Deposit Insurance Corporation (“FDIC”) member bank and SSI affiliate. Client balances swept into
a deposit account at Pinnacle Bank are eligible for FDIC insurance coverage up to $250,000 per depositor in
each insurable capacity. Examples of separate insurable capacities include the following non-exhaustive
list: individual accounts, joint accounts, certain trust arrangements, etc. However, a client’s cash balance in
the Bank Sweep Program is subject to aggregation with other deposit assets the client has at Pinnacle Bank
outside of the Bank Sweep Program. Neither SSI nor Pinnacle Bank will monitor the aggregate amount of
deposits a client has with Pinnacle Bank either directly or through participation in the Bank Sweep Program
to determine the extent of deposit insurance coverage available at any time for program participants.
Therefore, each client participating in the Bank Sweep Program is responsible for monitoring the aggregate
total of deposited assets and determining the extent of deposit insurance applicable to the client’s deposits.
Through the Bank Sweep Program arrangement, SSI and its affiliates benefit financially. Pinnacle Bank
earns net income from the difference in interest paid to the Bank Sweep Program participants for balances
held in their core investment accounts and income received from new lending or investment activity derived
from the program deposits (referred to as “spread”). As with any depository institution, Pinnacle Bank’s
income increases when the spread between interest paid, and income received widens. Pinnacle Bank has
no obligation to base its interest payments to the Bank Sweep Program participants on the profitability of
the income generated from the spread. In addition, SSI receives from Pinnacle Bank an annual fee ranging
from $25 to $50 for each account participating in the Bank Sweep Program. Together, these financial
benefits to SSI and its affiliates create a conflict of interest as accounts participating in the program may be
more profitable to Pinnacle Financial Partners, Inc. than those who do not participate. To address this
conflict, clients may decline participation in the Bank Sweep Program and SSI offers alternative choices for
core investment vehicles for free credit balances. In addition, SSI excludes eligibility from the Bank Sweep
Program any ERISA plan accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase
Plans, etc.) and any foreign domiciled account. Lastly, at the time of account opening, or election into the
program, clients eligible for participation in the Bank Sweep Program are provided with important
disclosure documents and agreements containing further details. These documents may be obtained at any
time free of charge upon the request of current or prospective clients.
With very limited exemptions, third party managers are instructed to execute SSI client trades with NFS,
subject to their fiduciary duty to seek best execution for client trades. Managers have the authority to
execute transactions with another broker or dealer if the manager believes it is in the best interests of the
client to do so.
SSI does not typically aggregate trades for multiple clients, unless trading for clients invested in the same
investment strategy. However, SSI and third-party managers are permitted to aggregate trades according
to their trading policies and procedures. SSI believes aggregating trades will allow the managers to achieve
more favorable pricing and/or better execution at the time of the trade, as well as supporting equitable
prices allocations across client accounts.
It em 13 – Review of Account s
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New accounts are reviewed by an SSI Designated Principal to ensure all information is in order and
Synovus Securities, Inc. Disclosure Brochure
documentation is complete. SSI representatives provide a regular review of client accounts, the frequency
January 28, 2026 • A14023V37
of which is determined based upon the client’s preferences and expectations. Nonetheless, SSI
representatives are expected to initiate contact with clients at least annually in order to confirm the
accuracy of information regarding the client’s financial situation and the investment objective(s) of an
account.
Clients receive account statements and transaction confirmations directly from the account custodian
usually monthly, but not less than quarterly. Clients may request quarterly reports from SSI providing such
information as asset allocation and account performance data. Depending on the Program selected,
performance information is prepared by the individual managers and may not be calculated on a uniform
and consistent basis.
It em 14 – Client Referrals and Ot her Compensat ion
SSI and its representatives do not receive any economic benefits from any third party with respect to the
advisory services offered to clients other than the fees described in this Brochure. Product sponsors, mutual
fund companies or other third parties may offer SSI representatives invitations to training sessions, due
diligence visits or other meetings or events at the expense of the third party. These invitations are not
offered directly as a result of any amount of business placed with the third party, but the volume of business
placed with a particular sponsor may be indirectly related.
SSI entered into a promotional agreement (the “agreement”) with GLOBALT, an unaffiliated investment
adviser, on a limited basis. Pursuant to this agreement, representatives of SSI can refer clients directly to
GLOBALT and receive a referral fee. The fee paid to SSI by GLOBALT is a percentage of the advisory fee
GLOBALT collects from the referred client. The client does not pay a higher fee as a result of the referral;
rather, GLOBALT shares with SSI a percentage of the fee they receive from the client. The client enters into
an investment advisory agreement directly with GLOBALT. SSI or its representative provides no additional
advisory services to the client.
SSI has entered into promotional agreements with various unaffiliated third-party professionals such as
attorneys, certified public accountants, or investment advisers (collectively “promotors”). The promotors
can refer clients to SSI and receive a referral fee. SSI pays a percentage of its fees collected from advisory
clients to the promotor who originated the client referral. The client does not pay a higher fee as a result of
the referral, however. The client enters into an investment advisory agreement directly with SSI. Any other
financial services provided by these promotors to clients are separate from their promotional arrangement
with SSI, and neither SSI nor its representatives make any claim or warranty regarding such services. The
promotors have a financial incentive to promote the advisory services provided by SSI, creating a conflict of
interest whereby the advisory services SSI provides are recommended over those offered by other
investment advisers. Investors should independently evaluate the advisory offerings of competing firms
before engaging SSI as a result of a promotor’s recommendation.
Pinnacle Bank makes investment products available to its customers, including the advisory services offered
by SSI and revenues generated and/or expenses occurred may be shared between the affiliated companies.
Nevertheless, SSI’s advisory clients do not pay a higher fee as a result of these revenue sharing or expense
arrangements. Conversely, SSI representatives may refer clients to Pinnacle Bank for banking services.
Pinnacle Bank may, at its discretion, pay an incentive to SSI and/or its representatives for referrals made
for banking services. Notwithstanding referral incentive programs, if any, sponsored by Pinnacle Bank, SSI
customers are under no obligation to utilize Pinnacle Bank for any banking services, and the establishment
of an advisory relationship with SSI is not contingent upon a client opening or maintaining a banking
relationship with Pinnacle Bank.
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In the normal course of its business, SSI representatives may refer clients that are in need of Trust services
to Synovus Trust Company. SSI is compensated for such referrals and a portion of the compensation is
shared with the SSI representative. SSI or its representative provides no additional advisory services to the
client.
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
It em 15 – Cust ody
SSI is dually registered as an investment adviser and broker-dealer. As broker-dealer SSI has a minimum
net capital requirement of $250,000 and can accept checks made payable to SSI for deposit into client
accounts. However, all checks and securities are promptly forwarded to our clearing firm, NFS. Because SSI
accepts checks in this manner, under SEC rule 206(4)-2, SSI is deemed to have custody of its investment
advisory accounts.
SSI also has custody because investment advisory fees are directly debited from client accounts. Debiting of
fees is done pursuant to authorization provided by each client. NFS, as the account custodian, furnishes
account statements, usually monthly but no less than quarterly, directly to the clients. SSI urges clients to
carefully review their statements for accuracy and compare those records to any report received directly
from SSI. Reports prepared by SSI and/or its sub-advisors may vary from custodial statements based on
accounting procedures, reporting dates, or valuation methodologies of certain securities.
In very limited situations, clients may hold advisory accounts with Synovus Trust Company, an affiliate of
SSI.
In order to comply with the custody rules, SSI engages an independent public accountant to perform an
internal controls audit on the operations of SSI, its divisions, and certain affiliates and also to conduct a
surprise examination of any accounts over which it is deemed to have custody. Audits are done annually.
It em 16 – Invest ment Discret ion
Depending on the investment Program selected, SSI manages client portfolios on both a discretionary and
non-discretionary basis. When appropriate, clients grant SSI discretion over their account by providing
written authorization. Only certain representatives are permitted to act on a discretionary basis, and an SSI
Designated Principal is required to review and approve each discretionary account. Discretionary authority
authorizes the Firm, in its sole discretion and at Client’s risk, to determine the securities to be bought or sold
and the amount of securities to be bought or sold. Further details concerning SSI’s programs concerning
investment discretionary authority are described in Item 4 of this brochure. In some cases, investment
discretion is delegated to a third-party manager. Selection of investments follows the parameters
determined for the client as well as any specific instructions, investment objectives and risk profile
associated with each client.
The investment discretion granted to SSI by its clients does not include discretionary authorization over
disbursements from a client’s account. Irrespective of a client’s authorization of investment discretion to
SSI, clients retain control over disbursements from their accounts; SSI and its associated persons process
disbursements from client accounts only after receiving client instructions deemed in good order pursuant
to the Firm’s policies and procedures.
It em 17 – Vot ing Client Securit ies
Synovus Securities, Inc. does not take any action or render any advice on voting proxies. Furthermore, SSI
will not advise or act on a client’s behalf in any legal proceedings, including bankruptcies or class action
lawsuits. Clients will receive proxies, and any other issuer communication, directly from their account
custodian. Clients may contact SSI with questions relating to the proxy voting process, but SSI does not
provide any recommendations on how to vote any particular issue. If a client uses a third-party manager as
described in Item 4, the third-party manager, at its discretion, may accept responsibility for voting proxies
on the client’s behalf. Any delegation of voting authority to a third-party manager will be outlined in the
investment advisory agreement.
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Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
It em 18 – Financial Informat ion
Synovus Securities, Inc. is required to provide you with certain financial information or disclosures about
its financial condition. SSI has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.
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Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
Appendix A – Risk Definit ions
All investments offer a balance between risk and potential return. Generally speaking, a typical investor will
take on more investment risk in exchange for the opportunity for greater return. The risk definitions below
are intended to assist our clients in understanding the common risks associated in investing. The terms
listed below are not comprehensive to all potential investment risks and may not be applicable for all
investment strategies.
Business Cycle Risk
Call Risk
The risk that cyclical business cycles, with periods of peak performance
followed by a downturn, then a trough of low activity, affect the returns of an
investment, an asset class or an individual company’s profits.
See reinvestment risk. Some corporate, municipal and agency bonds have a
“call provision” entitling their issuers to redeem them at a specified price on a
date prior to maturity. Declining interest rates may accelerate the redemption
of a callable bond, causing an investor’s principal to be returned sooner than
expected. In that scenario, investors have to reinvest the principal at the lower
interest rates than they may have had prior.
Collateral Account Risk
A client may enter into a separate agreement with a creditor, bank,
broker/dealer or other financial institution (together, “creditor”) to pledge
securities or assets against a loan or collateral amount. This agreement grants
the creditor a security interest to transfer, sell, redeem, close, open, trade or
otherwise liquidate any assets in the account (including instructions to
transfer assets directly) in the pledged assets or collateral account. Adverse
market conditions can impact the value of the value of the pledged securities
causing the portfolio value to decline. This may result in the client to pledge
additional assets, pay down the line of credit or the creditor may instruct the
adviser and/or custodian to sell pledged assets, which depending on market
conditions may result in receiving less for the securities than the original
purchase price. Declining market conditions may also limit client’s ability to
draw upon their account. Long-term investment strategies and goals may be
adversely impacted by the creditor’s actions, as they may instruct the adviser
to sell some or all of the pledged assets as payment against the loan. In this
instance, since the creditor agreement may provide certain rights, the client
may not be able to choose which securities are liquidated and the client would
also be responsible for any loan shortfall after such sale. There is no guarantee
that investment account returns will meet or exceed loan costs.
Commodity Price Risk
Composition Risk
Consumers Risk
The possibility that fluctuations in the price, shortage or overabundance of
material inputs, such as fuel, energy, raw materials, metals, manpower, etc.
will materially impact operating a company, production of goods/services or
reduce the attractiveness or price of an investment.
The possibility that changes in an index, resulting from security membership,
market capitalization and weighting, and investment guide changes may
increase the relative dispersion for a strategy and result in unexpected
performance variance. Security membership, being added, reduced or weight
changed, in an index may result in security prices changes.
The risk when clients are exposed to unsuitable investments that they do not
fully understand.
Correlation Risk
See Diversification Risk - When portfolio holdings are too highly correlated
with each other, meaning that the move up and down in value together, there
may be insufficient diversification to counter market or security risks.
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January 28, 2026 • A14023V37
Counterparty Risk
Also called default risk. Counterparty risk occurs when one or more parties to
an agreement, such as a bond, defaults and does not fulfill their contractual
obligation, such as payments or principal. For example, a bond issuer with a
lower quality rating may have a higher default risk and its bonds will need to
pay a higher yield than an issuer with a higher rating.
Credit Rating / Issuer
Quality Risk
Credit rating agencies provide analysis and comparative opinions on the bond
issuer's ability and willingness to meet its financial obligations. For bond
holders, risk occurs when the opinion changes, resulting in a lower rating,
which may decrease the current holding value and may make it more
expensive, in the form of higher interest rates, for the issuer to raise new debt
to meet future obligations. Credit ratings are not indications of investment
merit but are a significant factor in the investment decision. Generally, the
higher the credit rating, the higher the bond price relative to the yield rate.
Currency / Foreign
Exchange Risk
Also called foreign exchange risk and implies international investing: the
possibility that the relative change in currency value from one country to
another will reduce the investment value when converted back from one
currency to the other.
Dispersion Risk
The uncertainty risk associated when an investment strategy is not in
accordance with its model, resulting in performance or risk that is less or
greater than expected.
Diversification Risk
Diversification means to reduce risk by investing in a variety of assets, and
generally in assets that do not move up or down in value together (correlate).
There are two forms of diversification risk: A portfolio that is relatively
undiversified, such as having a single security or positively correlated holdings
may be more volatile and value sensitive to the security’s market actions. A
portfolio that is too diversified may result in a proxy for an index, and not
provide acceptable returns relative to the fees or expenses incurred with a
managed account.
Economic Risk
The risk that economic conditions, such as government regulations, tax
policies, political or social instability, workforce, or exchange rates will
negatively affect investments, usually one in a foreign country. Economic risk
is one of the reasons why international investing, especially in emerging
countries, carries more risk than domestic investing.
Expenses and Fees
Risk
Exchange traded funds, like mutual funds, generally incur operating expenses
for management, record-keeping, custodial services, taxes, legal, accounting
and audit fees, which are taken from the fund's assets and lower investor
return. Different funds may have different expenses and fees ratios, relative to
the fund assets. Therefore, selection of a fund with higher expenses and fees
may have lower performance than a comparable fund with a lower expense
ratio.
Industry Risk
The possibility of investment losses related to a specific industry or market
sector stemming from economic or regulatory change, instability, volatility or
market shift from a particular industry. These losses may increase in relation
to overall portfolio weighting towards that industry.
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January 28, 2026 • A14023V37
Inflation Risk
Inflation causes tomorrow’s dollar to be worth less than today’s. Inflation
reduces the purchasing power of a bond investor’s future interest payments
and principal, collectively known as “cash flows.” Inflation also leads to higher
interest rates, which in turn leads to lower bond prices.
Interest Rate Risk
The possibility that the value of a security, especially a bond, will reduce as a
resulting from a rise in interest rates.
Inverse Market ETF
Risk
Inverse ETFs are designed to replicate the opposite direction of the matching
or indicated index. These ETFs often use a combination of futures, swaps,
short sales, and other derivatives to achieve these inverse objectives. As
complex products, inverse ETFs may not track the underlying or contra
benchmark as expected and are often designed to achieve their results on a
daily basis only. That means over periods longer than a trading day, the value
of these ETFs can and usually do deviate from the reciprocal performance of
the associated index to which they correlate. Over longer periods of time or in
situations of high volatility, these deviations can be substantial.
Legal Risk
Liquidity Risk
The risk that a legal contract or financial transaction won't be fulfilled because
it breaks a law or there is a regulatory conflict. In addition, companies involved
in legal actions may have to increase cash reserves for settlement, which may
restrict their growth ability, lower their relative profit or income potential,
and be more volatile.
The risk that investors may have difficulty finding a buyer when they want to sell
a security and may be forced to sell at a significant discount to its expected market
value. Liquidity risk is greater for thinly traded securities.
Market Capitalization
Risk
A company's market capitalization, one measure of potential growth, is the
value calculated from the company's shares outstanding multiplied by the
price per share. The basic market cap categories are large-cap, mid-cap and
small-cap. Large-cap stocks, representing companies over $10 billion in size,
are generally researched and followed more by analysts or investors. Many
large-cap companies are called “Blue Chips”. Large-caps historically
experience comparatively slower growth, with less risk, than smaller-sized
companies. Smaller-sized companies typically are not as financially strong but
are expected to grow at a faster rate with greater investment return potential.
Smaller-sized companies and funds may experience greater up/down price
and value volatility. Within investment guidelines, many strategies, ETFs or
mutual funds focus their funds in investing in specific market cap sized
companies. Market capitalization risk exists when comparative-sized
companies, such as large, mid- or small-caps as a whole and the ETFs and
funds targeted to the cap, would decline, bringing the associated values down
regardless of the fundamental characteristics or investment potential.
Strategy allocations that over- or under-weight asset classes, including market
caps, may have greater volatility missed return potential, or relative loss.
Market Risk
Also called systematic or undiversifiable risk: The risk that the stock or bond
market as a whole would decline, bringing the value of individual securities
down with it regardless of their fundamental characteristics or investment
potential.
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January 28, 2026 • A14023V37
Model Risk
The possibility that the analysis, investment or allocation decisions for a
strategy model may be unreliable or provide incorrect signals in volatile
market conditions.
Pandemic Risk
Large-scale outbreaks of infectious disease that can greatly increase morbidity
and mortality over a wide geographic area, crossing international boundaries,
and causing significant economic, social, and political disruption.
Regulatory Risk
The risk that changes in laws and regulations will impact a security, business,
sector or market. A change in laws or regulations made by the government or
a regulatory body can increase the costs of operating a business, reduce the
attractiveness of investment, and/or change the competitive landscape.
Reinvestment Risk
Also see inflation risk. Risk occurs, especially in a declining interest rate
environment, when an income producing bond or security is sold or called and
the reinvested funds may yield a lower rate than the original security. The
reinvested assets may provide a lower cash flow than expected or required to
meet the investor’s investment objectives.
Security Selection Risk
Sociopolitical Risk
The risk that an investor chooses a security that underperforms the market
for reasons that cannot be anticipated. The possibility of investment losses
related to a specific company or security stemming from economic or
regulatory change, business climate, earnings surprise or legal action relative
to a specific company. These losses may increase in relation to the security's
overall portfolio weighting.
Tax Risk
The danger that political or cultural changes or instability in a location or a
country could turn against an investment.
For taxable accounts, the possibility that the security holdings, interest,
dividends and timing of the buys/sell transactions will increase one's tax
liability. Tax risk may also occur when investing just prior to dividend or
capital gain activities for ETFs or mutual funds.
Time Horizon Risk
Investment time horizon generally reflects the total length of time the investor
expects to invest before the assets are used for their financial goal (e.g.,
retirement income). Because different security types, such as equities, bonds
and cash have different reward and risk characteristics, a client's time horizon
is important in influencing the investment and strategy decisions. Generally,
the shorter the client's time horizon, the less time available to the client to
recover from any incurred losses.
Timing Risk
The risk that an investment performs poorly after its purchase or better after
its sale. This risk may reflect security selection made either too soon or too
late, relative to historical review, and thereby missing profit opportunities or
increasing loss potential.
Tracking Error Risk
Also called active risk. The possibility that a security, such as ETF or mutual
fund, deviates from and does not accurately track its defined index or
benchmark. The fund does not work as effectively as intended, resulting in
unexpected asset allocation and price behavior for the holding.
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January 28, 2026 • A14023V37
Trading Volume Risk
Trading volume occurs as a direct result of supply and demand. Generally, the
greater the trading volume, the more liquid it is and the spread between
buy/sell transactions is smaller. A lightly-traded security may have more
volatile pricing, be less liquid and have higher transaction costs due the
buy/sell spreads.
Turnover Rate Risk
Turnover rate or ratio reflects the frequency that managers buy or sells
securities within a portfolio. There is no turnover rate that is correct for all
accounts – the rate will vary upon the strategy type, securities held, or
investment conditions. In effect, a high turnover rate may reflect excessive
trading, resulting in potentially higher costs or transaction expenses,
increased capital gains tax liability of the portfolio, and reduced relative
performance. A low turnover rate, again not conclusive, may reflect low
investment
account management activity or decreased available
opportunities.
Valuation Risk
Yield Curve Risk
Difficulty in pricing/fairly valuing securities that are thinly or infrequently
traded, not readily accessible, illiquid, or of varying quality. In the absence of
accurate security valuation, buy or sell transactions may be higher or lower
than anticipated. Securities that increase or decrease in price may result in
overweight or underweight conditions relative to a model or benchmark,
increasing diversification risk.
The yield curve represents the relationship between rate of return or interest
rates and time to maturity. For bond holders, risk occurs when bond values
decrease, impacting portfolio value, when interest rates go up or when needed
fixed income or cash flow decrease when bond prices go up. The yield curve
will slope, up/down and widen or narrow, in relationship between short term
bond yields and long-term bond yields and varying maturities. To compensate
for the liquidity risk of tying up one's money for long periods of time, a typical
investor expects a higher rate of return for a longer time to maturity.
Page 28
Synovus Securities, Inc. Disclosure Brochure
January 28, 2026 • A14023V37
Additional Brochure: SYNOVUS SECURITIES, INC. APPENDIX 1 WRAP BROCHURES (2026-01-28)
View Document Text
It em 1 – Cover Page
Synovus Securities, Inc.
33 W est 14 th Street, 3 rd Floor
Columbus, GA 31901
(706) 649- 2327
January 28, 2026
This Wrap Fee Program Brochure provides information about the qualifications and business practices of
Synovus Securities, Inc. (“SSI”). If you have any questions about the contents of this Brochure, please contact
Gene Gunderson, Chief Compliance Officer at (706) 644-0298 or by email at genegunderson@synovus.com.
The information in this Brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Synovus Securities, Inc. is a registered investment adviser. Registration of an investment adviser does not
imply any level of skill or training. The oral and written communications of an adviser provide you with
information about which you determine to hire or retain an adviser.
Additional information about Synovus Securities, Inc. also is available on the SEC’s website at
www.adviserinfo.sec.gov.
i
It em 2 – Mat erial Changes
This Wrap Fee Program Brochure (the "Brochure") dated January 28, 2026, is a revised document prepared
according to the Securities and Exchange Commission's requirements and rules. This Item will discuss only
specific material changes that are made to the Brochure and provide clients with a summary of such changes.
Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and
subsequent Brochures within 120 days of the close of our business' fiscal year. We may further provide other
ongoing disclosure information about material changes as necessary. We will further provide you with a new
Brochure as necessary based on changes or new information, at any time, without charge.
This Brochure does not contain any material changes but has been updated since the previous version filed
with the Securities and Exchange Commission dated November 3, 2025, to include refreshed totals for assets
under management.
Effective January 1, 2026, Synovus Securities, Inc. became a wholly owned subsidiary of Pinnacle Financial
Partners, Inc. as a result of a merger between Synovus Financial Corp. and Pinnacle Financial Partners, Inc.
Please review these updates, and all sections of this Brochure, carefully before making investment decisions.
We will further provide you with a new Brochure as necessary based on changes or new information, at any
time, without charge. Copies of this Brochure may be requested by contacting Gene Gunderson, Chief
Compliance Officer at (706) 644-0298 or genegunderson@synovus.com. It is also available free of charge via
our website at https://www.synovus.com/about-us/our-companies. Clients have the option to electronically
receive copies of this Brochure, along with any subsequent updates. Please contact your Financial Advisor for
more information about electing electronic delivery for future brochures.
ii
It em 3 - Table of Content s
It em 1 – Cover Page ................................................................................................................................... i
It em 2 – Mat erial Changes ....................................................................................................................... ii
It em 3 - Table of Cont ent s ...................................................................................................................... iii
It em 4 – Services, Fees and Compensat ion ........................................................................................... 1
It em 5 – Account Requirement s and Types of Client s ....................................................................... 10
It em 6 – Port folio Manager Select ion and Evaluat ion ....................................................................... 10
It em 7 – Client Informat ion Provided t o Port folio Managers........................................................... 11
It em 8 – Client Cont act wit h Port folio Managers .............................................................................. 11
It em 9 – Addit ional Informat ion ............................................................................................................ 11
iii
It em 4 – Services, Fees and Compensat ion
Synovus Securities, Inc., (“SSI”) is a full-service brokerage and investment advisory firm headquartered in
Columbus, Georgia, with offices across Georgia, Alabama, Florida, South Carolina, and Tennessee. SSI is owned
by Pinnacle Financial Partners, Inc., a multi-billion dollar publicly traded bank holding company based in
Atlanta, Georgia. SSI is a registered broker-dealer and registered investment adviser with the Securities and
Exchange Commission, as well as a member of FINRA and various state regulatory agencies.
As of January 1, 2026, Synovus Securities, Inc.’s assets under management were $4,987,877,578 on a
discretionary basis, and $3,457,205,437 on a non-discretionary basis.
The general investment services offered to clients are outlined in the bullet points below. The specific details
of each investment program (each a “Program” or collectively “Programs”) available to clients follow.
•
•
•
•
•
•
•
•
•
•
Collecting detailed information about the client’s current financial situation;
Identifying client’s goals and objectives;
Developing an appropriate asset allocation model;
Providing asset management services, including individually managed accounts;
Offering mutual fund model portfolios;
Selecting of money managers;
Evaluating performance and monitoring services;
Periodic rebalancing;
Executing of securities transactions; and,
Providing custody of assets through National Financial Services (“NFS”).
Where applicable, portfolio managers selected to manage client accounts may buy, sell or otherwise trade
securities of SSI’s parent company, Pinnacle Financial Partners, Inc. , in client accounts. While this may appear
to create a conflict of interest, these decisions are made solely at the discretion of the manager and are not
influenced by SSI or any of its affiliates. SSI does not recommend the purchase or sale of any stock issued by
Pinnacle Financial Partners, Inc. to advisory clients.
Each Program may impose account minimums and due to these minimums, adequate diversification may not
be achieved. The number of accounts within any given program varies, including some with a limited number
of investor accounts. More information about each program is available from your Financial Advisor.
Clients in each Program pay a program fee (“Program Fee”) that includes all fees associated with management,
custodial and brokerage-related expenses for the client’s account, subject to certain exceptions. Additional
costs not part of the Program Fee include, but are not limited to, transactions executed away from SSI, dealer
mark-ups, electronic fund and wire transfers, market maker spreads, exchange fees, redemption fees and
account maintenance fees. SSI pays part of the Program Fee to third party managers managing client assets.
Fees vary depending on the manager. Details of these fees are provided by Program in Item 4 of this brochure.
Clients grant SSI the authority to debit Program Fees directly from their account. Clients will receive a
SSI urges clients to review the information on the statement for accuracy and compare the
statement, usually monthly but no less than quarterly, showing all account holdings and transactions in their
information to any reports received directly from their SSI Representative.
account.
If the client does not have a sufficient cash/cash equivalent balance to cover the fee, SSI may liquidate assets
to generate sufficient funds for the fee to be paid. Conversely, a portion of accounts may be maintained in (and
assessed fees on) cash or other cash equivalents.
Page 1
For new Synovus Investment Strategies Program client accounts, the initial fee is calculated the day after
assets are placed in the Program, debited the following month, and will be prorated based on the number of
calendar days left in the month. If the client deposits or withdraws $10,000 or more to their account during
the month, SSI calculates a new fee, or rebate for withdrawals, prorating the additional funds for the remainder
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
of the month.
January 28, 2026 W14023V36
Advisory agreements may be terminated by either party, without penalty, immediately upon receipt of written
notice by the other party. Any such termination will not affect a party’s status, obligations or liabilities. If an
account is terminated and all assets are withdrawn from the Program prior to the end of a month, the client
will receive a refund of the Program Fee prorated based on the number of calendar days left in the month. At
the time of termination, any unpaid fees will be due.
Clients may receive comparable services from other broker-dealers or investment advisers and pay fees that
are higher or lower than those charged under these Programs. The fees for the various Programs may be more
or less than the client would have paid if the services (account management, custody and brokerage
transactions) were purchased separately outside of the Program. SSI Representatives recommending the
Program are compensated based on the client’s participation in the Program; therefore, they have a financial
incentive to recommend these Programs over other services offered by SSI. Not all Program fees are the same
and the fees Synovus receives vary by Program. This creates a financial incentive for SSI to recommend the
advisory Programs for which it receives the most compensation. However, this conflict is mitigated by
working with current and prospective clients to clearly identify each person’s goals, objectives, financial needs,
risk appetite, investment preferences, and other facts unique to the investor. This fact-finding process is
designed to identify the Program (or Programs) we recommend based upon the investor’s best interest. We
further mitigate this conflict by providing transparent fee pricing for each Program offered, including fees
clients pay to Synovus, those paid to third party managers (if any), and to Envestnet, with whom we have
partnered to deliver the technology platform used in managing clients’ accounts. We encourage you to review
the various Program offerings described in this brochure and to compare the fees found in Item 5 of this
brochure associated with each Program.
SSI requires all client accounts, with very limited exceptions, to be custodied at NFS and all transactions to be
executed by NFS through SSI. This creates a conflict of interest, as SSI is in effect acting as both broker and
adviser on behalf of the client. Not all investment advisers require clients to use a specific broker-dealer. This
direction to itself may represent a conflict of interest, as SSI is limited in its ability to seek out brokers with
different pricing structures or broader services, or to receive more favorable pricing on securities transactions.
Therefore, by directing brokerage, clients may not receive best execution on transactions though it is SSI’s aim
to provide the most cost effective executions based upon prevailing conditions at the time of trade. In some
accounts under SSI’s Outside Money Manager Program, neither SSI nor the manager is directed to execute
transactions through SSI/NFS. Consequently, transactions are expected to be executed primarily away from
SSI and accordingly are likely to incur additional costs such that the account will not operate as traditional
“wrap” account. In such case, the third party manager is responsible for obtaining best execution under their
current policies and procedures.
SSI does not typically aggregate trades for multiple clients, unless trading for clients invested in the same
investment strategy. However, SSI and third party managers are permitted to aggregate trades according to
their trading policies and procedures. SSI believes aggregating trades will allow the managers to achieve more
favorable pricing and/or better execution at the time of the trade, as well as supporting equitable prices
allocations across client accounts.
SSI is dependent upon NFS, as its clearing firm, for having agreements in place with mutual fund sponsors in
order for SSI’s investment advisory customers to have access to mutual funds. While NFS has agreements in
place with a large variety of mutual fund sponsors, not all mutual funds are available through NFS. Moreover,
many mutual funds offer different share classes, often for the same fund, representing different fee and
expense structures paid by shareholders of a fund. Certain classes of shares may not be available through NFS
and consequently SSI clients may not have access to a lower costing share class otherwise available to
investors directly from the fund, a different clearing firm, or other financial intermediaries. This limitation
could result in SSI clients purchasing and/or holding a more expensive share class of a mutual fund thereby
reducing the investment returns.
Page 2
SSI’s clearing firm, NFS, sponsors a “No Transaction Fee” program (the “NTF Program”) whereby NFS does not
charge SSI a transaction fee for purchase or sell orders SSI submits on a client’s behalf for mutual funds
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
participating in the NTF Program. SSI benefits from this cost savings, therefore creating a conflict in that SSI
January 28, 2026 W14023V36
may be incented to recommend or use the mutual funds participating in the NTF Program for advisory client
accounts over those mutual funds which do not participate. However, SSI does not influence, recommend,
promote, advise or otherwise direct any third party investment adviser (e.g., Envestnet) to select or give
preference to mutual funds participating in the NTF Program over those funds which do not participate.
Additionally, upon a client's request, SSI will provide at no cost a list of any NTF eligible mutual funds held
within the account and will make a representative available to the client to answer any questions related to
the share class selected along with any other share classes available from the same fund. Information for
contacting SSI is provided on the first page of this Wrap Brochure.
Many mutual funds are offered with more than one type of fee structure, commonly called “share classes”.
There are several factors to consider when selecting a mutual fund share class. For example it is important to
evaluate whether a share class involves payment of a commission at the time of purchase (commonly referred
to as “front end loads”), at the time of liquidation (“back end loads”), incrementally while the investor owns
the share class (“level loads”) or no commission at all (“no-loads”). Share classes also differ in terms of what
fees and expenses are deducted from the mutual fund’s pooled investment assets, since these fees and
expenses are often not billed separately to a mutual fund shareholder. While there a variety of fees investors
may encounter when purchasing a mutual fund, common fees/expenses include management fees paid to the
fund’s investment manager, operating expenses used to pay for the day-to-day costs incurred to operate the
mutual fund, and distribution fees (known as “12b-1” fees) used to promote, advertise, or compensate financial
professionals for aiding in sales of a mutual fund. Though not all mutual fund shares classes include each of
the fees/expenses presented here, what remains consistent is that a mutual fund’s share class with a lower
total annual expense as compared to another share class of the same fund can result in a significant difference
in investment returns over time. It is common for mutual funds to set eligibility requirements, such as minimum
investment amounts, for an investor to qualify for purchasing a lower cost share class. Investors can learn more
about a specific mutual fund’s available share classes, their fees, loads, expenses, and eligibility requirements by
reading the fund’s investment prospectus. In addition, we encourage clients to ask their representative about the
fees and expenses associated with mutual funds currently owned by the clients or those presented to them. The
programs described in this brochure do not offer, or may not qualify for, all share classes offered by a fund company.
Therefore, it is possible you could invest in a lower costing share class of the same fund if purchased outside the
programs outlined in this brochure, though without the benefit of the advice and related services we offer through
our programs. Despite SSI’s reasonable efforts to utilize cost-effective share classes, there is no guarantee that
a client will always be in the most cost advantageous share class. Ask your representative about shares classes
available to you.
With respect to funds that pay 12b-1 fees, SSI’s intent is to limit the use of such funds by opting to use a share
class of the same fund which does not include 12b-1 fee payments wherever possible. However, in cases where
SSI receives 12b-1 payments from a fund, the Firm generally will seek to credit the entire 12b-1 payment to
the advisory client(s) account holding the asset which generated the payment from the fund. These credits
are intended to but may not guarantee the same effect as investing into a non-12b-1 class. Credits to client
accounts generally occur monthly and represent the total 12b-1 fee payments credited during the preceding
month. Additionally, SSI will generally seek to issue a check to the most recent address of record of closed
client accounts representing 12b-1 payments the Firm received as a result of funds owned during the quarter
in which the account was closed.
Page 3
In conjunction with offering the Synovus Choice UMA, SSI receives access to Envestnet Fiduciary Solutions
Program (“EFS”) free of charge. The EFS Program provides SSI additional access to research, watch lists, alerts,
Large Case Support, Overlay Services and other Envestnet investment-related intellectual capital. Without
offering the Synovus Choice UMA, SSI would have to pay Envestnet for access to the EFS Program. This creates
the potential for a conflict of interest because without offering the Synovus Choice UMA, SSI would incur extra
cost for the research content available from the EFS Program. To mitigate potential conflicts, SSI’s cost-free
access to the EFS Program is not contingent upon any minimum asset values in the Synovus Choice UMA
program, nor are there any requirements to offer certain Separate Account Managers, mutual funds, ETFs, or
any other products—including those proprietary to Envestnet or its affiliates. Furthermore, clients in the
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
Synovus Choice UMA do not pay additional fees as compared to any other of SSI’s UMA offerings, nor do SSI
January 28, 2026 W14023V36
representatives receive more compensation for asset within the Synovus Choice UMA over assets in SSI’s other
UMA offerings. SSI’s access to the EFS Program content is intended to benefit the Firm’s customers by
providing SSI associated persons additional research and investment information used in the management of
client assets.
To the extent that a client of the SIS Advisor Directed or the SSI Individually Managed Account Program invests
in new issues of an equity or fixed-income security purchased in their account, SSI will receive a selling
concession, or other similar type of compensation, as described in the prospectus or offering document of the
security. SSI receives this compensation in addition to the Program Fee received for investment advisory
services. You have the option to restrict the purchase of new issues in your account or to revoke at any time
previous authorization granted to purchase them.
SSI’s advisory clients may also maintain non-advisory SSI brokerage accounts. Representatives of SSI are
compensated through commissions assessed on the transactions executed in these accounts or through some
other manner, such as 12b-1 fees. This creates an incentive for the representative to recommend investment
products based on the compensation received rather than on the client’s needs. However, SSI’s brokerage
services are generally performed on a non-discretionary basis; therefore, except in rare instances whereby a
customer has granted an SSI representative written discretionary authority, transactions are approved by the
client in advance and clients receive trade confirmations inclusive of the commissions charged. Moreover,
clients are provided a copy of SSI's brokerage account commissions schedule at the time of account opening.
Additional copies of the brokerage commissions schedule are available free of charge upon request by
contacting your account representative or the SSI home office by calling 706-649-2327. In addition, advisory
fees are not charged on such brokerage accounts. To address this conflict, an SSI Designated Principal reviews
each new brokerage and advisory account for appropriateness based upon the expressed needs of the client.
While it is the policy of SSI to charge investment management fees to its clients in accordance with the fee
schedules in effect at the time of executing the investment management agreement, fees are subject to
negotiation and reflect circumstances that may apply to a specific client relationship or account. Thus, fees
paid by clients do vary from the program schedules described later in this section, and it is possible clients
with similar asset levels to have differing fee schedules and pay different fees, even within the same program.
The fees specific to each client account are detailed in that account’s advisory contract.
If a client requests and the firm agrees to a flat fee arrangement instead of the tiered program schedules
described later in this Brochure, the client may pay more fees than if the relevant program's tiered fee schedule
had been used. This scenario is more likely to occur when the client's account asset value crosses one or more
of the program schedule's fee discount tiers. The potential for a flat fee arrangement causing a client to pay
more in fees versus the program's standard tiered schedule creates a conflict whereby the firm and/or its
representatives could be incented to recommend a flat fee schedule in order to receive more compensation.
To mitigate this conflict, SSI and its representatives are bound to act solely in the client's best interest including
when advising on fee arrangements. Moreover, SSI has implemented procedures at account opening and
throughout the account's lifecycle to assess (and remediate as deemed prudent) the impact a negotiated flat
fee schedules will have, or has had, on a client's fees. Clients can qualify for SSI advisory fee discounts by
combining household balances of related accounts within Synovus’s investment advisory offerings. This is
accomplished by notifying your Financial Advisor of any accounts sharing the same residential address for
which you want to link for fee billing purposes (“household discounts”). Accounts qualifying for household
discounts can be added to, or removed from, the linked group at your direction. SSI has determined to offer
employees, associated persons and their immediate family fee discounts resulting in lower fees than those
published in this brochure. SSI reserves the right to amend or terminate this program at its discretion.
Page 4
SSI has partnered with Pinnacle Bank, an SSI affiliate and Federal Deposit Insurance Corporation (“FDIC”)
member bank, to offer certain advisory clients the option of sweeping free credit balances within the
investment account to a Pinnacle Bank deposit account chosen as those clients’ core investment vehicle (the
“Bank Sweep Program”). SSI receives an annual fee from Pinnacle Bank of $25 to $50 for each account
participating in the Bank Sweep Program. Item 9 of this Wrap Program Brochure contains additional
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
information and important disclosures about the Bank Sweep Program.
January 28, 2026 W14023V36
The SIS Program includes unregistered securities offerings of alternative investments such as private equity,
private debt, and hedge funds. To invest in these offerings, you must meet the definition of an Accredited
Investor or a Qualified Purchaser, depending on the specific offering. An investment in alternative assets
entails a high degree of risk (including the possible loss of a substantial part, or even the entire amount, of an
investment) and no assurance can be given that any alternative investment will achieve its objectives or that
investors will receive a return of their capital. Further, such investments may not be subject to the same levels
of regulatory scrutiny as publicly listed investments, and as a result, investors may have access to significantly
less information than they can access with respect to publicly listed investments. Prospective investors should
also note that investments in the products described typically involve long lock-ups and do not provide
investors with liquidity. This Brochure is not intended to provide you with a full description of risks and
considerations related to alternative investments offered through the SIS Program; rather, each alternative
investment has its own offering memorandum which contains these and other important details. Reviewing
the offering memorandum is essential before making an investment decision and you are strongly encouraged
to discuss its contents with your Financial Advisor.
SYNO VUS INVESTMENT STRATEGIES P RO GRAM
Separately Managed Account
1
SSI offers the Synovus Investment Strategies Program
(“SIS Program”) through Envestnet Asset Management,
Inc. (“Envestnet”). Envestnet is a registered investment adviser that operates a technology platform to assist
SSI in providing a variety of managed account offerings, recommending asset allocations or specific investment
managers and/or investment products to our clients. Envestnet is not affiliated with SSI. A complete
description of the SIS Program and the services provided by Envestnet are outlined in Envestnet’s ADV Part 2,
which you should read carefully. The following describes SSI’s offerings available through the SIS Program.
SSI offers a Separately Managed Account Program through our relationship with Envestnet. This provides
our clients with access to more than 1000 investment strategies available from over 100 portfolio
managers selected by Envestnet through their due diligence and portfolio manager evaluation processes.
The Separately Managed Account Program is designed to provide our clients the ability to tailor an
investment portfolio to their specific financial needs such as diversification or tax-conscious investing,
along with affording clients further customization of their portfolio by placing reasonable investment
restrictions on the types of assets allowed within the account. Portfolio managers are recommended based
on the client’s investment objectives as determined from the Client Risk Tolerance Questionnaire.
Manager changes would be recommended if SSI’s or Envestnet’s due diligence reviews indicate the
portfolio manager is no longer suitable for a particular investment strategy or if a client’s investment
objectives change. The minimum account value for the Separately Managed Account Program varies based
Mutual Fund & ETF Asset Allocation W rap Strategies Program ("Strategist Program")
upon the subadviser(s) chosen.
SSI offers mutual fund and ETF asset allocation portfolios (“fund portfolios”) via the Envestnet platform.
The Firm offers fund portfolios created by affiliated and unaffiliated investment advisers who directly
manage the assets on or use one or more model portfolios created by one or more independent investment
advisers (collectively “Strategist”). The Strategists available through SSI are first screened by Envestnet
for inclusion on the Envestnet platform. From that pool, SSI then reviews and approves certain Strategists
the Firm then makes available to our customers.
A number of no load/load-waived mutual funds or exchange-traded funds from various fund families are
available within the portfolios. An asset allocation model is selected based on each client’s risk score as
determined by the Client Risk Tolerance Questionnaire (the “RTQ”). The client may modify the RTQ at any
time by completing the requisite documentation with their adviser representative. After initial fund
1 Synovus Managed Account Solutions Platform ("MAS") prior to October 3, 2016
Page 5
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
January 28, 2026 W14023V36
portfolio selection, the Strategists will make portfolio changes on a discretionary basis for their respective
Advisor Directed Program
models as deemed necessary or appropriate to maintain the agreed upon investment approach.
SSI, through its licensed advisory representatives, provides asset management services to clients. The Advisor
Directed Accounts are managed on an individualized basis. Clients have the option to assign investment
discretion to SSI and select SSI investment advisory representatives (individually referred to as “Advisory
Representative” and collectively “Advisory Representatives”) whom the firm has approved to offer discretionary
services. Alternatively, clients can elect to have their account managed on a non-discretionary basis
whereby the SSI Advisory Representative provides recommendations to the client, who has ultimate
decision-making authority in determining whether to proceed with any recommendation. For clients
electing to open a discretionary account, SSI, through selected Advisory Representatives, has full
discretion to supervise, manage and direct the assets in the client’s account within the mandates of the
client’s stated investment objectives, tolerance for risk, time horizon for investing the assets, and other
suitability factors (collectively referred to as the “Client Investment Profile”) provided to SSI by the client
during the account opening and/or review process. Clients participating in either the discretionary or
non-discretionary offering are free to change or update their Client Investment Profiles at any time by
contacting the Advisory Representative assigned to the account, and should do so whenever the
information previously provided to SSI is no longer current or accurate. By providing written notice to the
Firm, clients may elect to revoke the discretion granted to SSI and/or the Advisory Representative and opt
to have their Advisor Directed accounts managed a non-discretionary basis. In such cases, the account will
remain non-discretionary unless or until a client elects to grant discretion in writing to SSI and/or its
Advisory Representative.
SSI may use professional services of other third parties, including its affiliates, in servicing either
discretionary or non-discretionary Advisor Directed Accounts. Clients working with SSI’s Advisory
Representatives selected to offer discretionary Advisor Directed Accounts are limited to using only those
investments approved by SSI’s Investment Policy Committee based upon research and recommendations
made by SSI’s Investment Advisory Group. Investments and any strategy used are determined based upon
the client’s responses and completion of the RTQ. Though not an exhaustive list, SSI primarily utilizes
mutual funds, stocks, bonds, exchange-traded funds, cash or cash equivalents. On a limited basis, clients
participating in the non-discretionary Advisor Directed Program may also utilize options within their
portfolios, subject to additional suitability and investor experience criteria specific to investing in options.
Finally, clients in either discretionary or non-discretionary offerings have the option to provide specific
guidelines or impose reasonable restrictions on the management of the portfolio. For this reason, each
portfolio’s investment results will differ, including those with similar investment objectives, and clients
should not expect the performance of their portfolios will be identical with another client of SSI. The
Unified Managed Account ("UMA") Program
minimum account value for the Advisor Directed Account Program is $100,000.
Through our relationship with Envestnet, SSI offers the Unified Managed Account (“UMA”) Program, which
allows clients access to multiple investment strategies by using Separate Account Managers, mutual funds
and/or ETFs, Strategists, model providers, and/or models provided by SSI to facilitate diversification
within an individually managed account. The UMA program includes a Synovus-branded offering called
Synovus Choice, offering access to a broad array of asset classes through use of mutual funds, ETFs, and/or
Separate Account Managers. The fees associated with Synovus Choice are the same as SSI’s other UMA
offerings and, importantly, SSI representatives do not receive any extra financial compensation for
recommending the Synovus Choice UMA over any other UMA program offered by SSI. The SSI
Representative will structure the account based upon the client’s stated goals and objectives as articulated
through the RTQ. The minimum account value for the UMA Program is $100,000.
Page 6
In conjunction with offering the Synovus Choice UMA, SSI receives access to Envestnet Fiduciary Solutions
Program (“EFS”) free of charge. The EFS Program provides SSI additional access to research, watch lists,
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
January 28, 2026 W14023V36
alerts, Large Case Support, Overlay Services and other Envestnet investment-related intellectual capital.
Without offering the Synovus Choice UMA, SSI would have to pay Envestnet for access to the EFS Program.
This creates the potential for a conflict of interest because without offering the Synovus Choice UMA, SSI
would incur extra cost for the research content available from the EFS Program. To mitigate potential
conflicts, SSI’s cost-free access to the EFS Program is not contingent upon any minimum asset values in the
Synovus Choice UMA program, nor are there any requirements to offer certain Separate Account
Managers, mutual funds, ETFs, or any other products—including those proprietary to Envestnet or its
affiliates. Furthermore, clients in the Synovus Choice UMA do not pay additional fees as compared to any
other of SSI’s UMA offerings, nor do SSI representatives receive more compensation for asset within the
Synovus Choice UMA over assets in SSI’s other UMA offerings. SSI’s access to the EFS Program content is
intended to benefit the Firm’s customers by providing SSI associated persons additional research and
investment information used in the management of client assets.
SSI INDIVIDUALLY M ANAGED ACCO UNT P RO GRAM
SSI provides asset management services to clients and manages each client’s account on an individualized
basis. Accounts may be managed on a discretionary or non-discretionary basis, depending on the needs of the
client. SSI may use professional services of other third parties, including its affiliates, in managing accounts.
Investments are determined based upon the client's investment objectives, risk tolerance, net worth, net
income and various other suitability factors. Clients may provide specific guidelines or impose reasonable
restrictions on the management of the portfolio. For this reason, performance of portfolios, including those
within the same investment objective, is likely to differ and clients should not expect that the performance of
their portfolios will be identical with another client of SSI. SSI only accepts accounts that have a minimum
asset value of $100,000. However, accounts with a lesser value may be accepted at SSI’s discretion.
O UTSIDE M O NEY M ANAGER P RO GRAM
Synovus Securities, Inc. may refer customers to other investment advisers or portfolio managers outside of
the various Programs listed above. SSI recommends the money management services of non-affiliated
companies (“Managers”). Managers are recommended based upon the investment objectives of the client, but
the ultimate decision to hire an outside manager is made by each client. SSI regularly monitors and reviews
the services provided by the Manager and will recommend changes if the Manager is no longer suitable for a
particular investment strategy or if a client’s investment objectives change. Clients participating in the Outside
Money Manager Program complete customer investment profile information and/or questionnaires designed
to identify their investment objectives and risk appetite.
Each Manager imposes account minimums varying from $25,000 to $5,000,000. SSI will recommend
managers for whom the client meets the minimum investment amount. SSI has no ability to waive the
---------------------------------------------------
minimum account size imposed by any particular manager.
Standard Program Fee Schedules
SSI SYNO VUS INVESTMENT STRATEGIES
Clients’ payments for advisory services contain three general components: (a) fees paid to SSI for investment
advice and related services; (b) fees paid to the subadviser(s) managing the portfolio; (c) fees paid to
Envestnet for use of their technology platform and administration of client accounts. The total cost to a client
is the combination of these fee components and the following shows the maximum costs associated with each
Separately Managed Account (SMA) Program
program offered.
Page 7
Synovus Investment Strategies SMA program fees are billed monthly in advance based on the prior month's
ending market value. The annual rates are shown in the table that follows:
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
January 28, 2026 W14023V36
SYNO VUS INVESTMENT STRATEGIES SMA P RO GRAM
Varies by subadviser chosen
Amount paid to SSI
1.40%
1.30%
1.20%
1.10%
Amount paid to subadviser(s)*
0.13% to 1.02%
0.13% to 1.02%
0.13% to 1.02%
0.13% to 1.02%
Amount paid to Envestnet
0.17%
0.17%
0.17%
0.17%
Asset Range
first $500,000
next $500,000
next $1,000,000
Account Minimum†
Amount over $2,000,000
*The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not
limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does
not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific
subadvisory fees, are provided to clients no later than at the time of each account’s establishment.
SSI has compensation arrangements in place that provide more compensation to the Advisor than the amount paid to SSI listed above.
The additional compensation will be paid by SSI. These compensation arrangements will not increase the amount paid by the client to SSI.
† The minimums may be waived at the sole discretion of SSI and/or the program's money manager
Advisor Directed Program and Mutual Fund/ ETF Asset Allocation W rap Strategies Program
(“Strategist”)
SYNO VUS INVESTMENT STRATEGIES-STRATEGIC ALLO CATIO N P RO GRAM
Synovus Investment Strategies Strategist program fees are billed monthly in advance based on the prior
month's ending market value. The annual rates are shown in the table that follows:
Amount paid to SSI
Amount paid to subadviser(s)*
Amount paid to Envestnet
Asset Range
First $500,000
Next $500,000
Next $1,000,000
Account Minimum†
Amount over $2,000,000
1.26%
1.16%
1.06%
0.96%
0.00% to 0.18%
0.00% to 0.18%
0.00% to 0.18%
$50,000
0.00% to 0.18%
0.13%
0.13%
0.13%
0.13%
SYNO VUS INVESTMENT STRATEGIES-TACTICAL ALLO CATIO N P RO GRAM
$50,000
Asset Range
First $500,000
Next $500,000
Next $1,000,000
Account Minimum†
Amount over $2,000,000
Amount paid to SSI
1.30%
1.20%
1.10%
1.00%
Amount paid to subadviser(s)*
0.25% to 0.35%
0.23% to 0.30%
0.20% to 0.25%
0.15% to 0.25%
Amount paid to Envestnet
0.13%
0.13%
0.13%
0.13%
SYNO VUS INVESTMENT STRATEGIES-FO UNDATIO NS
Amount paid to SSI
Amount paid to subadviser
Amount paid to Envestnet
Asset Range
First $500,000
Next $1,500,000
Account Minimum†
Amount over $2,000,000
0.10%
0.10%
$15,000
0.10%
0.10%
0.10%
0.10%
1.15%
1.05%
0.95%
SYNO VUS INVESTMENT STRATEGIES-ADVISO R DIRECTED P RO GRAM
‡
Amount paid to SSI
Amount paid to Envestnet
0.08%
0.08%
0.08%
0.08%
Page 8
Asset Range
1.46%
first $500,000
1.36%
next $500,000
next $1,000,000
1.26%
$100,000
Account Minimum†
1.16%
Amount over $2,000,000
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
January 28, 2026 W14023V36
*The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not
limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does
not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific
subadvisory fees, are provided to clients no later than at the time of each account’s establishment.
In addition to the amount paid to SSI for advisory services, clients also pay to SSI the portfolio construction fee which is reflected in the column titled
Amount paid to SSI. This fee is like the amount paid by clients utilizing subadvisers to construct and manage portfolios. As a result, the portion of a
‡
client’s total fee paid to, and retained by SSI, is more than other Strategist programs since SSI does not have to pay a portion of the client fees to another
subadviser. This presents a potential conflict of interest whereby the Advisor Directed Program is recommended over the other Wrap Strategist
Allocation Programs. However, clients using the Advisor Directed Program may find their overall cost to be less than other Strategist programs
depending on the management fee charged by the subadviser. Moreover, SSI does not receive additional compensation (e.g., revenue sharing) from
the fund companies utilized within the Advisory Directed Program models.
† The minimums may be waived at the sole discretion of SSI and/or the program's money manager.
Unified Managed Account Program
SYNO VUS INVESTMENT STRATEGIES-UMA P RO GRAM
Synovus Investment Strategies UMA program fees are billed monthly in advance based on the prior month's
ending market value. The annual rates are shown in the table that follows:
Amount paid to SSI
Amount paid to subadviser(s)*
Amount paid to Envestnet
Asset Range
1.40%
1.30%
1.20%
1.10%
0.15% to 0.67%
0.15% to 0.67%
0.15% to 0.67%
$100,000
0.15% to 0.67%
0.12%
0.12%
0.12%
0.12%
First $500,000
Next $500,000
Next $1,000,000
Account Minimum†
Amount above $2,000,000
*The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but
not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings.
SSI does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive
of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment.
SSI has compensation arrangements in place that provide more compensation to the Advisor than the amount paid to SSI listed above.
The additional compensation will be paid by SSI. These compensation arrangements will not increase the amount paid by the client to
SSI.† The minimums may be waived at the sole discretion of SSI and/or the program's money manager
SSI INDIVIDUALLY M ANAGED ACCO UNT AND O UTSIDE M O NEY M ANAGER P RO GRAMS
Depending on the money manager, fees are either billed monthly or quarterly in advance based on the prior
month's/quarter’s ending market value. The annual rates are shown in the table that follows:
INDIVIDUALLY M ANAGED ACCO UNTS AND O UTSIDE M O NEY M ANAGER
P RO GRAM
Asset Range
Amount paid to SSI
Amount paid to
subadviser(s)*
Amount paid for
technology platform
1.40%
1.30%
1.20%
1.10%
0.30% to 1.00%
0.30% to 1.00%
0.30% to 1.00%
Varies by subadviser chosen
0.30% to 1.00%
None
None
None
None
first $500,000
next $500,000
next $1,000,000
Account Minimum†
Amount over $2,000,000
*The subadvisers used in the Separately Managed Account Program charge varying fees as represented above. The fees’ variance is impacted by a
variety of factors such as, but not limited to, portfolio objective, securities used within the portfolio, and sectors or geographic region represented in the
portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total amount a client will pay for their investment advisory account,
inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment.
†The minimums may be waived at the sole discretion of SSI and/or the money manager.
Page 9
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
January 28, 2026 W14023V36
It em 5 – Account Requirement s and Types of Client s
SSI generally provides services to individuals, high net worth individuals, banks or thrift institutions, pension
and profit-sharing plans, corporations, and trusts, estates and charitable organizations.
Each investment Program offered by SSI imposes an account minimum in order to be eligible for the Program.
SSI, in its sole discretion, may waive the minimum asset size for any of its investment Programs. However, to
the extent that the client does not meet the minimums imposed by a portfolio manager or program sponsor,
SSI may not have the ability to waive those requirements.
SSI provides offerings to investors seeking to roll over balances held in employer-sponsored retirement plans
(often referred to as a “rollover”). Individuals with investments in a former employer’s retirement plan
generally have five options for those assets: (1) Leave the investments in that plan, (2) roll the assets into
his/her new employer’s plan, (3) rollover the money to an Individual Retirement Account, (4) liquidate the
investments and cash out the money, or (5) some combination of the previous four options. Each option
presents different considerations—including tax implications— and no one solution is right for every investor.
We encourage you to talk with your adviser about these options and to consult with a tax professional
regarding the potential impacts each of the options may have to your specific situation. SSI has an economic
incentive to recommend a rollover because assets rolled into one of our advisory programs will generate
investment management fees. In discussing and evaluating your options, it is important you know you are
under no obligation to rollover assets to us.
It em 6 – Port folio Manager Select ion and Evaluat ion
Information about minimum account size requirements for each Program can be found in Item 4.
Managers are selected for each client based on the specific needs of each client. Clients provide information
which is used to determine their risk tolerance, time horizon, asset allocation and overall investment
objectives.
SSI offers advisory services through the Programs described in Item 4 of this Brochure. The Programs involve
the selection of investment models or separate account managers based on the assessment of each client’s
investment goals and objectives.
SSI has implemented a due diligence process to review various facets of the manager’s business, such as
investment style, performance, portfolio management, trading and operations, and compliance. With respect
to the SIS Program described earlier in this Brochure, SSI employs use of both internal and external resources
as part of the due diligence process. Envestnet, as part of the services they perform for SSI, conduct reviews
of prospective and current money managers approved for inclusion on the platform used for the SIS Program.
SSI leverages the research and assessment Envestnet performs of third-party money managers for the
following SIS offerings:
•
•
•
Separately Managed Account Program;
Strategist Program; and,
Unified Managed Account Program.
Details concerning these program offerings are found under Item 4 of this Brochure.
Page 10
SSI’s Investment Advisory Group researches and evaluates prospective and current money managers and/or
investment model providers utilized via the SIS Program, primarily in connection with the Advisor Directed
offering, as described in Item 4 of this brochure. Information, reviews and recommendations prepared by SSI’s
Investment Advisory Group are supplied to SSI’s Due Diligence Committee, who has final authority to add or
remove a money manager or investment model provider from the Firm’s offerings. The composition and asset
allocation of each client portfolio may differ depending on a variety of factors, including client specific
investment goals, risk tolerance, and overall economic and market conditions. While not the primary focus of
the SSI Investment Advisory Group, team personnel may from time to time also perform due diligence reviews
of other SIS Platform money managers previously reviewed by Envestnet to gain additional perspective and
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
information in support of SSI’s general oversight efforts of the Firm’s selected advisory partners.
January 28, 2026 W14023V36
Depending on the Program selected, performance information may be prepared by the individual managers
and may not be calculated on a uniform and consistent basis. Performance calculations have not been
It em 7 – Client Informat ion Provided t o Portfolio Managers
reviewed by any third party to confirm its accuracy.
When a client selects a portfolio manager, the client provides information which is used to determine their
risk tolerance, time horizon, asset allocation and overall investment objectives. From that data, SSI provides
the portfolio manager with relevant personal information about the client (i.e. name, address and other
identifying information) as well as certain financial information to provide evidence that the manager’s
investment strategy suits the client’s needs. Information is provided to the portfolio manager initially when
the manager is selected and updated subsequently when there are any material changes to the client’s
It em 8 – Client Cont act wit h Port folio Managers
information.
Client relationships are managed by SSI Representatives. Third party managers are not directly accessible to
SSI clients. However, at a client’s request, SSI will make an attempt to arrange a conference call with the third-
party manager.
It em 9 – Addit ional Informat ion
Disciplinary Informat ion
Synovus Securities, Inc. is required to disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of SSI or the integrity of SSI’s management. In October of 2025, the Firm
and the Financial Industry Regulatory Authority (FINRA) formalized a regulatory action known as a Letter of
Acceptance, Waiver, and Consent whereby SSI, without admitting or denying the findings, consented to
sanctions and findings by FINRA that, from January 2022 to September 2025, SSI failed to establish, maintain,
and enforce a supervisory system and procedures reasonably designed to address forgery and falsification of
electronic signatures; as a result, FINRA found that SSI violated FINRA Rules 3110, 4511, and 2010, Section 17
(A) of the Securities Exchange Act of 1934, and Exchange Act Rule 17A-3. The Firm agreed to a censure and to
a fine of $315,000. Information concerning this matter is also available via www.brokercheck.com and
www.adviserinfo.sec.gov by either searching under the firm name Synovus Securities, Inc., or the firm
Ot her Financial Indust ry Act ivit ies and Affiliat ions
CRD#14023.
SSI is also a broker-dealer registered with the Securities and Exchange Commission, FINRA and various state
regulatory agencies. In this capacity, SSI is involved in the sale of various types of securities, such as stock, bonds,
and mutual funds. Employees providing investment advisory services to clients are also registered representatives
and are able to affect securities transactions on behalf of clients. Clients may maintain SSI brokerage accounts that
are not advisory accounts. In these accounts, SSI Representatives are compensated based on commissions or other
fees paid by the client as a result of the purchase or sale of an investment product. This may represent a conflict of
interest when determining recommendations for the client, as there is an incentive to recommend investment
products based on the compensation received rather than on the client’s needs.
Page 11
Brokerage services are offered to clients generally on a non-discretionary basis. Except in rare instances
whereby a customer has granted an SSI representative written discretionary authority, transactions are
approved by the client in advance and clients receive trade confirmations inclusive of the commissions
charged. Moreover, representatives of SSI do not receive separate commissions on advisory accounts.
Likewise, advisory fees are not charged on non-advisory brokerage accounts. SSI recognizes that a potential
conflict exists when SSI offers both brokerage services and investment advisory services to its clients. SSI
requires its Representatives, when offering both types of services, to explain the different services and identify
the capacity in which they are acting when making recommendations.
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
January 28, 2026 W14023V36
SSI is a licensed insurance company in all five of the Firm’s footprint states including Georgia, Florida, Alabama,
South Carolina, Tennessee and various other states outside the company’s brick and mortar locations in the
aforementioned footprint states. Additionally, SSI has affiliations with other insurance companies in those
states. Individuals of SSI may also be licensed insurance agents. To the extent that a representative of SSI
recommends insurance products and services, SSI and/or the representative will receive commissions on the
sale of those products. These commissions are paid directly from the insurance company underwriting the
insurance policy and are not paid separately by the client. In addition, SSI may receive additional
compensation from one or more of its insurance partners upon meeting a pre-determined level of business
production with the carrier(s).
SSI also offers investment advisory services under a separate division, known as Creative Financial Group
(CFG). Advisory services offered through CFG are substantially different than the services offered through
SSI’s wrap programs. CFG’s business practices are described in a separate Brochure (available upon request).
SSI is a wholly owned subsidiary of Pinnacle Financial Partners, Inc. a publicly traded financial services
company and a registered bank holding company headquartered in Atlanta, Georgia. Pinnacle provides
integrated financial services including commercial and retail banking, financial management, insurance and
mortgage services to its customers through Pinnacle Bank.
SSI is under common control with the following entities that have material business arrangements with SSI.
Certain employees, directors and members of SSI’s executive management may also serve as employees,
directors and/or executive management of these entities:
Synovus Trust Company, N.A. (a National Trust Company)
33 West 14 th Street
Columbus, Georgia 31901
Pinnacle Bank (a Tennessee state chartered bank)
21 Platform Way South, Suite 2300
Nashville, TN 37203
In limited circumstances advisory clients may utilize the custody services of Synovus Trust Company. These
arrangements are usually initiated by the trust company. As a general practice, SSI does not refer advisory
clients to Synovus Trust Company for custody services. In the normal course of its business, SSI
Representatives may refer clients that are in need of Trust services to Synovus Trust Company. SSI is
compensated for such referrals and such compensation is shared with the Representative. Neither SSI nor its
Representatives provide additional advisory services to the client.
In coordination with NFS, SSI also offers to brokerage and investment advisory customers the participation in
the Bank Sweep Program as their core investment vehicle, subject to the exclusions noted under Item 10 of
this Brochure. Participants in the program have free credit balances within their brokerage/investment
advisory account automatically swept to an interest bearing bank deposit account at Pinnacle Bank, a Federal
Deposit Insurance Corporation (“FDIC”) member bank and SSI affiliate. Client balances swept into a deposit
account at Pinnacle Bank are eligible for FDIC insurance coverage up to $250,000 per depositor in each
insurable capacity. Examples of separate insurable capacities include the following non-exhaustive list:
individual accounts, joint accounts, certain trust arrangements, etc. However, a client’s cash balance in the
Bank Sweep Program is subject to aggregation with other deposit assets the client has at Pinnacle Bank outside
of the Bank Sweep Program. Neither SSI nor Pinnacle Bank will monitor the aggregate amount of deposits a
client has with Pinnacle Bank either directly or through participation in the Bank Sweep Program to determine
the extent of deposit insurance coverage available at any time for program participants. Therefore, each client
participating in the Bank Sweep Program is responsible for monitoring the aggregate total of deposited assets
and determining the extent of deposit insurance applicable to the client’s deposits.
Page 12
Through the Bank Sweep Program arrangement, SSI and its affiliates benefit financially. Pinnacle Bank earns
net income from the difference in interest paid to the Bank Sweep Program participants for balances held in
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
their core investment accounts and income received from new lending or investment activity derived from the
January 28, 2026 W14023V36
program deposits (referred to as “spread”). As with any depository institution, Pinnacle Bank’s income
increases when the spread between interest paid and income received widens. Pinnacle Bank has no
obligation to base its interest payments to the Bank Sweep Program participants on the profitability of the
income generated from the spread. In addition, SSI receives from Pinnacle Bank an annual fee ranging from
$25 to $50 for each account participating in the Bank Sweep Program. Together, these financial benefits to
SSI and its affiliates create a conflict of interest as accounts participating in the program may be more
profitable to Pinnacle Financial Partners, Inc. than those who do not participate. To address this conflict,
clients may decline participation in the Bank Sweep Program and SSI offers alternative choices for core
investment vehicles for free credit balances. In addition, SSI excludes eligibility from the Bank Sweep Program
any ERISA plan accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase Plans, etc.) and
any foreign domiciled account. Lastly, at the time of account opening, or election into the program, clients
eligible for participation in the Bank Sweep Program are provided with important disclosure documents and
agreements containing further details. These documents may be obtained at any time free of charge upon the
request of current or prospective clients.
In such instances, clients are exposed to unique risks not otherwise inherent to
From time to time, clients may elect to use margin lending or pledge assets held in their advisory accounts as
this strategy is not suitable for everyone
their advisory accounts and
collateral for a loan.
. Before a client decides to use
margin lending or pledge their advisory assets as collateral for a loan, care must be given to consider the
•
following:
•
Changes in market conditions could impact your account at any time and affect the value of the
securities in your account to establish and maintain margin or pledged as collateral. Should the value
of your assets fall below the amount of your loan or margin maintenance requirement, you may be
unable to draw upon your account, pledged securities may need to be sold for less than the original
price you paid, and/or other appropriate steps may need to be taken to ensure you can still meet your
obligation to your margin lender (NFS) or Pinnacle.
•
If you are required to sell some of the margined or pledged securities, any long-term investment
strategies and goals may be impacted. Therefore, it is important you discuss with your advisory
representative your investment goals, objectives, risk tolerance, strategies and time horizon
concerning any advisory account in which you employ margin or pledge as collateral.
.
•
Should loan repayment terms not be met, the lender may instruct us to sell some or all margined or
pledged securities as payment against the loan. In this instance, you are not able to choose which
securities are liquidated. You would also be responsible for any shortfall in the loan after such sale. It
is essential that you carefully review the provisions outlined in your loan agreement and the
corresponding collateral control agreement, as it contains details such as who has trading authority,
amongst other important information
•
SSI is not a tax advisor. We encouraged you to discuss with your tax professionals the implications of
using margin or pledging securities as collateral.
•
SSI is an affiliate of Pinnacle Bank (the “Bank”), and both are subsidiaries of Pinnacle Financial
Partners, Inc. By establishing an investment advisory account used to collateralize a loan, you will be
responsible for paying to SSI any advisory/management fees, and any other fees as outlined in Item 5
of this Brochure, in addition to paying to the Bank any interest, fees, or other agreed upon expenses.
Your SSI advisory representative may also be a dual employee of the Bank, and your Bank loan officer
may also be an advisory representative of SSI. SSI advisory representatives and/or the Bank’s loan
officers may receive incentive compensation relating to loans and advisory accounts used as collateral.
There is no guarantee that returns of any advisory account will meet or exceed your loan costs.
Carefully consider the interest rate and repayment terms of the loan before making a final decision.
Page 13
As part of its relationship with NFS, SSI’s clients have access to margin lending financed through NFS. Clients
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
must apply and qualify for this additional service. Use of margin introduces additional risks and it not a
January 28, 2026 W14023V36
strategy suitable for everyone. These special risks are covered in more detail under Item 8 of this brochure.
Moreover, clients electing the use of margin will be subject to interest charges on any amount borrowed. The
interest paid by the investor is in addition to the asset management fees paid. SSI receives from NFS a portion
of the margin interest paid by investors. This creates a conflict of interest whereby SSI receives an economic
benefit from both margin interest and the asset management fees charged. SSI mitigates this conflict by
limiting the use of margin within advisory accounts to only a select number of overlay programs that employ
the use of option securities and further limits the availability of such programs to investors meeting eligibility
requirements such as a high liquid net worth and investible assets. Margin borrowing is not allowed in
advisory accounts outside of these select overlay programs.
Code of Et hics
SSI’s Code of Ethics (the “Code”) sets forth a professional business standard to guide SSI and its employees to
place our clients’ interests before our own. No SSI associated person shall prefer his or her own interest to
that of the advisory client. SSI requires its associated persons to act in accordance with applicable federal,
state and regulatory agency regulations governing investment advisory practices. The standards of conduct
outline our fiduciary responsibilities and the Code includes our policies related to insider trading, personal
securities transactions, privacy of client information and reporting requirements.
SSI’s employees may purchase and sell securities for their own accounts that have also been recommended to
clients. The Code is designed to prevent personal securities transactions and interests of SSI employees from
interfering with making decisions in the best interest of clients. Nonetheless, because the Code permits
employees to invest in the same securities as clients, there is a possibility that employees might benefit from
market activity by a client. Certain security types, such as Initial Public Offerings and Private Placements, may
be prohibited or subject to a pre-clearance requirement. SSI’s associated persons are required to provide a
quarterly report to the Firm’s Compliance Department showing investment transactions in their personal
accounts, as well as disclosing annually all securities held on their behalf. Governing regulations provide that
certain securities are exempt from this reporting requirement based upon the determination such securities
would not pose any material conflicts. These reports are monitored regularly in an effort to reasonably
prevent conflicts of interest between SSI and its clients. Clients or prospective clients may request a copy of
the firm's Code of Ethics by contacting SSI’s Chief Compliance Officer, Gene Gunderson, at 706-644-0298.
Participation or Int erest in Client Transact ions
SSI or its associated persons may engage in principal transactions and/or agency cross transactions, subject
to Section 206(3) of the Investment Advisers Act of 1940. In accordance with the regulation, SSI will disclose
the capacity in which it acted and will obtain client consent from both parties involved in the transaction prior
to the trade settlement date. These disclosures and consents are required to make all necessary facts known
and to alert clients to SSI’s potential conflicts of interest in a principal, riskless principal, or agency cross
transaction.
Review of Accounts
New accounts are reviewed by an SSI Designated Principal to ensure all information is in order and
documentation is complete.
SSI Representatives provide a regular review of client accounts, the frequency of which is determined based
upon the client’s preferences and expectations. Nonetheless, SSI Representatives are expected to initiate
contact with clients at least annually in order to confirm the accuracy of information regarding the client’s
financial situation and the investment objective(s) of an account.
Page 14
Clients receive account statements and transaction confirmations directly from the account custodian usually
monthly, but not less than quarterly. Clients may request quarterly reports from SSI providing such
information as asset allocation and account performance data. Depending on the Program selected,
Synovus Securities, Inc. Disclosure Brochure – Appendix 1
January 28, 2026 W14023V36
performance information is prepared by the individual managers and may not be calculated on a uniform and
Client Referral and Ot her Compensation
consistent basis.
SSI and its representatives do not receive any economic benefits from any third party with respect to the
advisory services offered to clients other than the fees described in this Brochure. Product sponsors, mutual
fund companies or other third parties may offer SSI Representatives invitations to training sessions, due
diligence visits or other meeting or events at the expense of the third party. These invitations are not offered
directly as a result of any amount of business placed with the third party, but the volume of business placed
with a particular sponsor may be indirectly related.
Envestnet may reduce its fees to SSI upon SSI reaching certain levels of assets under management in its various
programs. Therefore, SSI may have a financial incentive to recommend this program over other Programs or
services.
SSI entered into a promotional agreement (the “agreement”) with GLOBALT, an unaffiliated investment
adviser, on a limited basis. Pursuant to this agreement, representatives of SSI can refer clients directly to
GLOBALT and receive a referral fee. The fee paid to SSI by GLOBALT is a percentage of the advisory fee
GLOBALT collects from the referred client. The client does not pay a higher fee as a result of the referral;
rather, GLOBALT shares with SSI a percentage of the fee they receive from the client. The client enters into an
investment advisory agreement directly with GLOBALT. SSI or its representative provides no additional
advisory services to the client.
SSI has entered into promotional agreements with various unaffiliated third-party professionals such as
attorneys, certified public accountants, or investment advisers (collectively “promotors”). The promotors can
refer clients to SSI and receive a referral fee. SSI pays a percentage of its fees collected from advisory clients
to the promotor who originated the client referral. The client does not pay a higher fee as a result of the
referral, however. The client enters into an investment advisory agreement directly with SSI. Any other
financial services provided by these promotors to clients are separate from their promotional arrangement
with SSI, and neither SSI nor its representatives make any claim or warranty regarding such services. The
promotors have a financial incentive to promote the advisory services provided by SSI, creating a conflict of
interest whereby the advisory services SSI provides are recommended over those offered by other investment
advisers. Investors should independently evaluate the advisory offerings of competing firms before engaging
SSI as a result of a promotor’s recommendation.
Pinnacle Bank makes investment products available to its customers, including the advisory services offered
by SSI and revenues generated and/or expenses occurred may be shared between the affiliated companies.
Nevertheless, SSI’s advisory clients do not pay a higher fee as a result of these revenue sharing or expense
arrangements. Conversely, SSI Representatives may refer clients to Pinnacle Bank for banking services.
Pinnacle Bank may, at its discretion, pay an incentive to SSI and/or its Representatives for referrals made for
banking services. Notwithstanding referral incentive programs, if any, sponsored by Pinnacle Bank, SSI
customers are under no obligation to utilize Pinnacle Bank for any banking services, and the establishment of
an advisory relationship with SSI is not contingent upon a client opening or maintaining a banking relationship
with Pinnacle Bank.
In the normal course of its business, SSI Representatives may refer clients that are in need of Trust services to
Synovus Trust Company. SSI is compensated for these referrals and such compensation is shared with the
Financial Informat ion
Representative. Neither SSI nor its Representatives provide additional advisory services to the client.
Synovus Securities, Inc. is required to provide you with certain financial information or disclosures about its
financial condition. SSI has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients, and has not been the subject of a bankruptcy proceeding.
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Synovus Securities, Inc. Disclosure Brochure – Appendix 1
January 28, 2026 W14023V36