Thurston Springer Advisors

F O R M A D V P A R T 2 A Firm Brochure Thurston Springer Advisors, LLC H e a d q u a r t e r s 9000 Keystone Crossing, Seventh Floor · Indianapolis, Indiana 46240 (317) 581-4000 · (317) 581-4014 fax · www.thurstonspringer.com September 25, 2026 D E D I C A T E D T O T H E C R E A T I O N A N D P R E S E R V A T I O N O F W E A L T H This brochure provides information about the qualifications and business practices of Thurston Springer Advisors, LLC (“Thurston Springer”). If you have any questions about the contents of this brochure, please contact us at (317) 581-4000 or compliance@thurstonspringer.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. Thurston Springer is an investment adviser registered with the Securities and Exchange Commission. Registration of an investment adviser does not imply any level of skill or training. Additional information about Thurston Springer is available on the SEC’s website at www.adviserinfo.sec.gov. Item 1 – Cover Page  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Item 2 – Material Changes This brochure, dated September 25, 2026, describes only the material changes made since the last annual update dated September 11, 2025 (amended October 14, 2025): ■ Item 4 – Advisory Business. Updated assets under management as of June 30, 2026; named the principal owners of Thurston Springer’s parent; described the wrap fee programs and the availability of Charles Schwab & Co., Inc. (“Charles Schwab”) as custodian for Compass Accounts. ■ Item 5 – Fees and Compensation. Added the fee range, your IAR’s role and incentive in setting your rate, planning-fee ceiling, transaction charges, billing timing by program and custodian, and the fee schedule for retirement plan services. Added estate planning services through Wealth.com and the consulting fee your IAR charges for them. Disclosed that Thurston Springer Financial, its affiliated broker-dealer, retains compensation from Wells Fargo Clearing Services, LLC (“First Clearing”) and Charles Schwab & Co., Inc. (“Charles Schwab”) on cash sweep and margin balances (your account uses the custodian’s default sweep unless your IAR changes it, and the options pay Thurston Springer Financial different amounts), marks up both custodians’ charges, and receives Platform Support on PIM accounts; each is a conflict of interest for Thurston Springer. Disclosed that your net return on cash is negative when the fee rate exceeds the cash yield. ■ Item 8 – Risk of Loss. Condensed methods of analysis; added options, margin, short- sale and frequent-trading risks. ■ Item 9 – Disciplinary Information. Updated Thurston Springer Financial’s 2025 FINRA matter. ■ Item 10 – Affiliations. Role-based management disclosure; affiliated insurance agencies; the affiliated private fund and the placement fee Thurston Springer Financial receives on it; the conflict from Thurston Springer Financial’s First Clearing compensation. ■ Item 11 – Code of Ethics. Disclosed related persons’ financial interest in truEdge Opportunity Fund I. ■ Item 12 – Brokerage Practices. Restated Thurston Springer Financial’s transaction- charge and mark-up revenue at both custodians; disclosed that the Charles Schwab and First Clearing agreements are each priced on client assets held there, an incentive to keep client assets at those custodians; disclosed the research and other services Thurston Springer receives from Charles Schwab and First Clearing in connection with client accounts, the conflict they create, and how Thurston Springer seeks best execution. ■ Items 13 and 14. Described account reviews; disclosed the revenue share Thurston Springer receives from Wealth.com and the referral fee and revenue share EPIC Services Company pays IARs and Thurston Springer, each an incentive to recommend that provider; removed the ended bank networking arrangement. ■ Items 15 and 16. Custody basis restated (fee deduction only); non-discretionary programs identified. September 25, 2026 · thurstonspringer.com Page 2 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure A copy of this brochure is available at any time without charge by contacting Thurston Springer at (317) 581-4000 or compliance@thurstonspringer.com, or at www.adviserinfo.sec.gov. Item 3 – Table of Contents Item 1 – Cover Page.........................................................................................................................................................................................1 Item 2 – Material Changes.........................................................................................................................................................................2 Item 3 – Table of Contents.........................................................................................................................................................................3 Item 4 – Advisory Business........................................................................................................................................................................3 Item 5 – Fees and Compensation.........................................................................................................................................................5 Item 6 – Performance-Based Fees and Side-By-Side Management..........................................................................7 Item 7 – Types of Clients.............................................................................................................................................................................7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss.....................................................................8 Item 9 – Disciplinary Information.........................................................................................................................................................9 Item 10 – Other Financial Industry Activities and Affiliations.........................................................................................10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading............11 Item 12 – Brokerage Practices...............................................................................................................................................................12 Item 13 – Review of Accounts.................................................................................................................................................................13 Item 14 – Client Referrals and Other Compensation............................................................................................................14 Item 15 – Custody............................................................................................................................................................................................15 Item 16 – Investment Discretion..........................................................................................................................................................15 Item 17 – Voting Client Securities........................................................................................................................................................15 Item 18 – Financial Information............................................................................................................................................................15 Item 4 – Advisory Business Thurston Springer is an investment adviser registered with the Securities and Exchange Commission since November 2018 and is wholly owned by Financial Services Holdings, LLC (“FSH”). FSH is owned principally by Richard Parker and a trust of which he is trustee. Thurston Springer’s affiliates, including Thurston Springer Financial, its affiliated broker-dealer, are described in Item 10. This brochure uses the term “investment adviser representative” or “IAR” to mean the individual representative you work with. Advisory Services Thurston Springer provides financial planning services including estate planning, retirement planning, multi-generational planning, portfolio management and reviews, and fee-based management services. IARs also provide consulting services on matters such as retirement plan consulting, alternative and complex products, net-worth accumulation, household money management, portfolio manager selection, and review of an individual 401(k) or 403(b) account. Fees for these services are described in Item 5; you can terminate them in writing at any time and will receive a refund of any unused prepaid fee. September 25, 2026 · thurstonspringer.com Page 3 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Tailored Services / Client Preferred Restrictions Advisory services are tailored to the financial goals and individual needs of each client. Your individual and family circumstances are important to determining how your account will be invested. If you want to restrict investment in certain securities or types of securities, notify your IAR in writing. Your IAR will attempt to accommodate the request, but any restriction you impose can affect portfolio performance. Wrap Fee Programs Thurston Springer sponsors the Compass Account and six programs offered on the First Clearing platform (the “First Clearing programs”): Private Investment Management (PIM), Personalized UMA (PUMA), FundSource, CustomChoice, Asset Advisor and Private Advisor Network (PAN). Program accounts are held at Thurston Springer Financial and its clearing firm, Wells Fargo Clearing Services, LLC (“First Clearing”); Compass Account clients can instead hold their account at Charles Schwab. In the Compass Account’s Advisor Managed Portfolio and in PIM, your IAR chooses your investments as portfolio manager. In the Compass Account’s Firm Managed Portfolio, offered only under Compass III, Thurston Springer’s portfolio manager chooses them, using its exchange-traded fund (“ETF”) model, its institutional share class mutual fund model, or the Tactical Momentum or Earnings Momentum strategy. In PUMA and FundSource, the account is invested according to a model made available through First Clearing. In CustomChoice and Asset Advisor, you make the investment decisions with your IAR’s recommendations, and Thurston Springer does not have investment discretion. In PAN, you enter into a separate agreement with a third-party portfolio manager available through First Clearing, which manages the account on a discretionary basis; you pay that manager’s fee in addition to Thurston Springer’s fee. In each program you pay an asset-based wrap fee, of which Thurston Springer retains a portion for advisory and administrative services and pays a portion to your IAR. In the Compass II option you also pay a transaction charge on each trade, as described in Item 5. Assets held in a program account that are not eligible program assets are outside the wrap fee and are subject to the custodian’s customary brokerage charges. Thurston Springer manages wrap fee accounts in the same manner as its other advisory accounts. Wrap programs are described in the Wrap Fee Program Brochure (Part 2A, Appendix 1). Assets under Management Assets under Management (Discretionary): $5,368,844,279 Assets under Management (Non- discretionary): $639,456,448 Date Amounts Calculated: June 30, 2026 ERISA 3(21) and 3(38) Fiduciary Services for Employer-Sponsored Plans Thurston Springer provides services to employer-sponsored retirement plans governed by the Employee Retirement Income Security Act of 1974 (“ERISA”) and to their plan sponsors and fiduciaries. As a fiduciary under ERISA Section 3(21)(A)(ii), Thurston Springer provides non- discretionary advice — assisting with the investment policy statement, recommending and monitoring plan investment options, and educating plan fiduciaries — and the plan fiduciaries retain decision-making authority. As an investment manager under ERISA Section 3(38), Thurston Springer selects, monitors and replaces plan investments on a discretionary basis; the plan sponsor remains responsible for prudently selecting and monitoring Thurston Springer. In either role Thurston Springer acknowledges its fiduciary status in writing, and the scope of services and fees are set out in a written agreement with the plan. Plan assets Thurston September 25, 2026 · thurstonspringer.com Page 4 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Springer manages on a discretionary basis are included in the assets under management shown above. Fees are described in Item 5. Item 5 – Fees and Compensation Thurston Springer’s advisory fee is a percentage of assets under management, charged according to the fee schedule in your advisory agreement. Fees range from 0.25% to 2.50% annually depending on the program, the services provided, the size of the account and the fee you negotiate with your IAR. Fees are negotiable. Your IAR sets your rate within the limits of the Firm’s fee schedules, receives a portion of it, and has an incentive not to reduce it; clients with similar accounts and services pay different rates. Compare Thurston Springer’s fees with those of other advisers before engaging it. Program fee schedules are in the Wrap Fee Program Brochure. Financial planning and consulting fees are charged at an hourly rate that does not exceed $250 or at a fixed fee, in either case agreed in writing before services begin. Planning fees are invoiced when the engagement begins or as agreed in writing; if you terminate before the work is complete, any prepaid fee is refunded less the value of work completed at the hourly rate. Fees for employer-sponsored retirement plan services are described separately below. In the PAN program, the third-party manager’s fee is separate from and in addition to Thurston Springer’s fee. Estate Planning Services. Your IAR offers estate planning services through Wealth.com, an unaffiliated online estate planning platform operated by Wealth, Inc., in which you complete your documents in Wealth.com’s client portal. Your IAR helps you identify your goals and explains how the documents fit your financial plan; your IAR does not draft, edit or give legal advice on estate planning documents. Your IAR charges a consulting fee for these services on the planning and consulting terms described above — an hourly rate that does not exceed $250 or a fixed fee agreed in writing. The fee is stated in your Compass IV agreement with Thurston Springer and is separate from and in addition to your asset-based advisory fee. Wealth.com charges you directly for optional services you order from it, including attorney consultations, printing and shipping of your documents, mobile notary services and deed preparation to fund a trust; those fees are set by Wealth.com, are paid to Wealth.com, and are in addition to the fees you pay Thurston Springer. Thurston Springer’s compensation from Wealth.com is described in Item 14. The advisory fee is deducted from your account each quarter by the custodian unless you elect to pay it from another account or to be billed directly. A portion of the account is kept in cash to pay the advisory fee. Where you have more than one account and fees cannot be withdrawn from one of them without penalty or tax consequence (for example, an IRA), you can direct that the fee for all accounts be deducted from an account that permits withdrawal. Fees for the PIM, PUMA, FundSource, CustomChoice, Asset Advisor and PAN programs are billed quarterly in advance on the prior quarter-end value; a prorated fee or refund for additions and withdrawals during the quarter is applied only when it is at least $40. Compass Account fees are billed quarterly in arrears on quarter-end value for accounts held at Thurston Springer Financial and First Clearing, and quarterly in advance on the prior quarter-end value for accounts held at Charles Schwab, where prorated fees and refunds for additions and withdrawals are applied without a minimum. Either party can terminate the agreement on written notice; fees paid in advance are refunded pro rata for the unused portion of the quarter, and fees payable in arrears are charged pro rata to the termination date. September 25, 2026 · thurstonspringer.com Page 5 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Compass II clients pay a transaction (ticket) charge on each trade. At Thurston Springer Financial the charge is $5.00 per mutual fund trade, $10.50 per stock, ETF or option trade plus $0.50 per option contract, and $12.50 per bond trade. Under Compass II at Charles Schwab you pay Thurston Springer Financial’s transaction charge, set above what Charles Schwab charges; under Compass III Thurston Springer pays Charles Schwab’s transaction charges. In Compass III and the First Clearing programs the wrap fee covers transaction costs, except that in the First Clearing programs the fee does not cover dealer mark-ups and mark-downs, odd-lot differentials, transfer taxes, exchange fees, execution fees or ADR custodial pass-through fees. Depending on the program and your activity, you also pay custodian charges when they apply, such as annual IRA fees, wire and electronic funds fees, account transfer and closing fees, margin interest, and postage and handling. You also bear the internal expenses of mutual funds and ETFs described in each fund’s prospectus. Thurston Springer Financial sets the custodian and account service charges you pay above what First Clearing or Charles Schwab charges and retains the difference. These include account transfer, termination, wire and IRA maintenance charges and the Compass II transaction charges at either custodian. The charges are stated in the fee schedule provided with your account agreement. See Item 12. The IAR or portfolio manager sells securities deposited into a discretionary account to implement the selected investments; a large position can be sold in stages over time. Most of Thurston Springer’s IARs are also registered representatives of Thurston Springer Financial and licensed insurance agents. In those separate capacities they receive commissions on securities transactions in brokerage accounts and on insurance products, and Thurston Springer Financial receives 12b-1 (distribution) fees and other product compensation on brokerage accounts. Class A mutual fund shares held in advisory accounts pay 12b-1 fees to Thurston Springer Financial; those fees are rebated to your account, and neither Thurston Springer, Thurston Springer Financial nor your IAR retains them. Commission and insurance compensation is separate from advisory fees and creates an incentive to recommend products based on the compensation received rather than solely on your needs. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make product recommendations that are in your best interest. You can purchase recommended products through brokers or agents not affiliated with Thurston Springer. Advisory fees are not reduced to offset commissions or other product compensation received. Compensation from custodians. Thurston Springer Financial retains compensation from First Clearing and Charles Schwab on cash and margin balances in your account: a share of the revenue the custodian earns on cash sweep balances, administrative fees on the money market funds used for cash sweep, and a share of margin interest. Your account uses the sweep option First Clearing or Charles Schwab sets as its default unless your IAR selects a different sweep option or money market fund for you. Thurston Springer Financial receives more from some options than others, and lower-paying options, including money market funds that pay it nothing, are available; your IAR receives no portion of the sweep revenue. In the PIM program it also receives payments from mutual funds and actively managed ETFs held in your account for marketing support, recordkeeping and sub-accounting (“Platform Support”); funds and share classes that pay no Platform Support are available. September 25, 2026 · thurstonspringer.com Page 6 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure These payments are in addition to the advisory fee. The advisory fee is charged on cash balances at either custodian, which also generate sweep compensation; when the advisory fee rate exceeds the yield on cash, your net return on that cash is negative. Because the advisory fee is calculated on the gross value of the account, including any margin balance, margin increases the fee paid to Thurston Springer and to your IAR. Thurston Springer receives none of these payments, but it and Thurston Springer Financial are under common ownership. The payments therefore create an incentive for Thurston Springer to hold cash in your account, to recommend the PIM program and funds that pay Platform Support, and to recommend margin, and for your IAR to recommend margin. Thurston Springer addresses these conflicts by disclosing them in this brochure, by paying IARs no portion of these payments, and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. Fees for Employer-Sponsored Retirement Plan Services This section applies only to employers and plan fiduciaries that engage Thurston Springer as an ERISA 3(21) or 3(38) fiduciary for their company retirement plan (a “Plan”). It does not apply to individual accounts, including IRAs, held in the advisory programs described in Item 4; those accounts pay the advisory fees described above. The Plan pays Thurston Springer a fee based on a percentage of the assets held in the Plan (up to 1.25% annually), on an hourly basis (up to $250 per hour), or on a flat rate basis, as negotiated between the Plan and the IAR and stated in the Plan’s written agreement. Total fees paid to Thurston Springer by a Plan, whether asset- based, hourly, flat or combined, will not exceed 1.25% of the Plan’s assets per year. The fee is payable in advance or in arrears, quarterly or monthly, as agreed among the Plan, the IAR and Thurston Springer. Asset-based fees are calculated on the value of Plan assets at the end of the billing period or, for fees paid in advance, at the end of the prior period, as reported by the Plan’s custodian or recordkeeper. If a fee is paid in advance and the agreement is terminated, the Plan receives a pro rata refund of the unearned portion. Fees are paid by the Plan or the plan sponsor, by invoice or by deduction from Plan assets by the custodian or recordkeeper. Plans also bear the fees of their investment options, recordkeeper and other service providers, which are not paid to Thurston Springer. Item 6 – Performance-Based Fees and Side-By-Side Management Thurston Springer and its supervised persons do not receive performance-based fees. Item 7 – Types of Clients Thurston Springer’s services include providing investment advice and portfolio management services to individuals, high net worth individuals, corporations and other business entities, corporate pension and profit-sharing plans, charitable institutions, foundations, endowments, estates and trusts. Program minimums range from $7,500 to $25,000 depending on the program; PIM, CustomChoice and PAN have no program minimum; other services have no minimum. Thurston Springer makes exceptions in its discretion. September 25, 2026 · thurstonspringer.com Page 7 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. The methods of analysis include charting, fundamental analysis, technical analysis and cyclical analysis. Charting uses graphical price and volume history to identify trends. Fundamental analysis evaluates a company’s earnings, dividends and financial condition to estimate its value. Technical analysis uses past price and volume patterns to anticipate price direction. Cyclical analysis seeks to invest in industries whose fortunes rise and fall with economic cycles, over holding periods of months to years. Thurston Springer’s portfolio manager runs the Tactical Momentum and Earnings Momentum strategies, which rely on technical and fundamental indicators; they involve more frequent trading, higher transaction costs and concentration in fewer securities. Strategies include buy-and-hold, asset allocation, rebalancing, value investing, short-term trading, short sales, margin and options (covered and uncovered writing, purchases and spreads). The primary types of securities are mutual funds, equities and bonds. Before investing, review the account agreement, the Wrap Fee Program Brochure and any prospectus or offering document you receive. Material risks include: Call Risk Call risk is the risk that, during a period of falling interest rates, the issuer can redeem a security by repaying it early, which reduces income if the proceeds are reinvested at lower interest rates. Credit Risk Credit risk refers to the possibility that the issuer of a security will not be able to make payments of interest and principal when due. Changes in an issuer's credit rating or the market’s perception of an issuer’s creditworthiness can also affect the current value of an investment in that issuer. Equity Securities Risk Stock markets are volatile. The price of equity securities fluctuates based on changes in a company’s financial condition and overall market and economic conditions. Selection Risk Selection risk is the risk that the securities selected will underperform the markets or relevant indices. Small-Cap and Emerging Growth Securities Risk Small-cap or emerging-growth companies often have limited product lines or markets, are less financially secure than larger, more established companies, and depend on a more limited management group than larger capitalized companies. They are also subject to substantially greater volatility due to limited liquidity. Mid-Cap Securities Risk The securities of mid-cap companies generally trade in lower volumes and are generally subject to greater and less predictable price changes than the securities of large capitalization companies. September 25, 2026 · thurstonspringer.com Page 8 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Emerging Markets Risk Emerging markets are riskier than more developed markets because they tend to develop unevenly and can fail to develop fully. Investments in emerging markets are speculative. Emerging markets are more likely to experience hyperinflation and currency devaluations, which adversely affect returns to U.S. investors. In addition, many emerging securities markets have far lower trading volumes and less liquidity than developed markets. Interest Rate Risk Interest rate risk is the risk that prices of bonds and other fixed-income securities will increase as interest rates fall and decrease as interest rates rise. Frequent Trading Strategies that trade frequently, including in the Compass II option where a charge applies to each trade, increase transaction costs and can generate short-term taxable gains, which reduce returns. Options Purchased options can expire worthless; written options and spreads can lose more than the premium received; uncovered calls have potentially unlimited loss. Options are also subject to time decay. Margin Borrowing on margin magnifies both gains and losses, requires you to pay interest, and can result in the forced sale of securities at an unfavorable time to meet a margin call. Margin also increases the advisory fee paid to Thurston Springer and to your IAR, an incentive to recommend margin that Thurston Springer addresses as described in Item 5. Short Sales Short sales carry the risk of unlimited loss because a security's price can rise without limit, and they require margin and payment of borrowing costs. Item 9 – Disciplinary Information Thurston Springer and its management persons have no legal or disciplinary events that are material to a client’s evaluation of Thurston Springer or the integrity of its management. Thurston Springer’s affiliated broker-dealer, Thurston Springer Financial (CRD #8478), which shares management with Thurston Springer, has the following event within the past ten years. ■ FINRA — Letter of Acceptance, Waiver and Consent, March 31, 2025. Without admitting or denying the findings, Thurston Springer Financial consented to findings that it failed to establish, maintain and enforce written supervisory procedures reasonably designed to achieve compliance with certain of its obligations. The findings covered Regulation Best Interest, Form CRS, electronic correspondence review, Form U4 disclosure updates, outside brokerage account review, office inspections and supervisory control testing. Sanctions: censure, a $150,000 fine, and an undertaking to review certain electronic communications and certify implementation of a reasonably designed supervisory system, which Thurston Springer Financial completed in May 2025. Information about Thurston Springer Financial is available at brokercheck.finra.org. September 25, 2026 · thurstonspringer.com Page 9 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation Thurston Springer is affiliated with Thurston Springer Financial (CRD #8478), a FINRA-member broker-dealer, through common ownership. Most IARs are also registered representatives of Thurston Springer Financial, and certain of Thurston Springer’s management persons hold securities registrations with it. Except for Compass Accounts held at Charles Schwab, advisory accounts are brokerage accounts at Thurston Springer Financial, cleared by First Clearing, to which advisory services are added; program assets are not charged commissions. When a representative executes brokerage transactions for a client outside the advisory relationship, the representative acts in a separate capacity as a registered representative and receives commissions. This creates an incentive to recommend brokerage products or services, and to recommend that assets be held in a brokerage rather than an advisory account, based on the compensation received. Thurston Springer addresses this conflict as described in Item 5. Thurston Springer Financial’s compensation on advisory accounts — Compass II transaction charges, custodian-charge mark-ups and the First Clearing payments — is described in Items 5 and 12. Because the firms are under common ownership, that compensation is a conflict of interest for Thurston Springer in recommending accounts at Thurston Springer Financial and First Clearing, which Thurston Springer addresses as described in Item 5. Neither Thurston Springer nor any management person is registered, or has an application pending, as a futures commission merchant, commodity pool operator or commodity trading advisor. Affiliated Entities Thurston Springer is a wholly owned subsidiary of FSH. FSH also owns Thurston Springer Financial, Thurston Springer Insurance, LLC and Bristal Lane Group, LLC (a compliance consulting and accounting firm). Thurston Springer is under common ownership with Peak Brokerage Services, LLC (broker-dealer), Blackridge Asset Management, LLC (investment adviser) and Top Advisors Group, LLC (insurance agency). Through common ownership by the principals of FSH, it is also affiliated with truEdge Asset Management, LLC (investment adviser) and truEdge Capital LLC, the general partner of a private fund described below. Thurston Springer shares office space, personnel and back-office, supervisory and compliance functions with Thurston Springer Financial, Peak Brokerage Services and Blackridge Asset Management. Insurance Thurston Springer Insurance, LLC (“TSI”) and Top Advisors Group, LLC (“TAG”), both affiliates, are insurance agencies through which representatives of Thurston Springer and its affiliated firms place life, health, fixed and indexed annuity, long-term care, disability and similar insurance products. IARs sell insurance as licensed agents, not as representatives of Thurston Springer, through TSI, TAG or unaffiliated agencies; when business is placed through TSI or TAG, the agency receives commissions from the carrier and pays a portion to the representative. Insurance commissions are in addition to advisory fees and create an incentive to recommend insurance products; Thurston Springer addresses this conflict as described in Item 5. You are under no obligation to purchase insurance through TSI, TAG or the representative. September 25, 2026 · thurstonspringer.com Page 10 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Affiliated Private Fund truEdge Capital LLC, an affiliate under common ownership, is the general partner of truEdge Opportunity Fund I, a private fund advised by truEdge Asset Management, LLC. IARs recommend the Fund to eligible clients, and Thurston Springer is identified in truEdge Asset Management’s Form ADV as a party that markets the Fund. Thurston Springer Financial acts as placement agent for the Fund and receives a placement fee on each subscription, which it retains; Thurston Springer and your IAR receive no compensation from the Fund or the placement fee. Because the Fund’s general partner is owned by principals of FSH and Thurston Springer’s affiliate is paid on each sale, those persons and that affiliate have a financial interest in your investing in the Fund, which creates a conflict of interest. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that the Fund is recommended only when consistent with its fiduciary duty and in your best interest. Thurston Springer’s Supervision department reviews and approves each client investment in the Fund, as it does every alternative investment, before it is processed. The Fund is illiquid, available only to accredited investors, and described in its offering documents. You are under no obligation to invest in the Fund. Recommendation or Selection of Other Investment Advisers Thurston Springer recommends and selects third-party portfolio managers to manage certain client accounts, as described in Items 4 and 5. In the PAN program, the manager’s fee is separate from and in addition to Thurston Springer’s fee, and Thurston Springer receives no part of it. Thurston Springer receives no other compensation from third-party managers. Management Disclosures Thurston Springer’s management persons — its executive officers and Chief Compliance Officer — hold the same positions with Thurston Springer Financial, and certain of them also serve as officers of FSH, TSI and Bristal Lane Group, LLC. Certain management persons hold ownership interests in FSH. Management persons who are registered representatives of Thurston Springer Financial receive brokerage compensation when they effect brokerage transactions, as described above. Because the same individuals manage Thurston Springer and its affiliates, they have an interest in the success of each affiliate, which creates a conflict of interest that Thurston Springer addresses through the disclosures in this Item. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Thurston Springer has adopted a Code of Ethics for all employees and associated persons of Thurston Springer, describing its standards of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All employees and associated persons at Thurston Springer must acknowledge receipt of the terms of the Code of Ethics upon hire, again annually or as amended. A copy of Thurston Springer’s Code of Ethics will be provided to any client or prospective client upon request at no charge. September 25, 2026 · thurstonspringer.com Page 11 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Employees and IARs are permitted to buy and sell the securities that clients hold or trade, and an employee who knows of a pending client order has an incentive to trade ahead of it for the employee’s own account. The Code of Ethics requires pre-clearance and reporting of personal trades and prohibits trading ahead of client orders, and Compliance reviews employee trading against client activity. Material Financial Interest IARs recommend truEdge Opportunity Fund I, a private fund whose general partner, truEdge Capital LLC, is owned by principals of FSH, to eligible clients. Those persons have a financial interest in the Fund’s success, which creates a conflict of interest when the Fund is recommended. This relationship and how Thurston Springer addresses it are described in Item 10. Affiliated and employee accounts trade in the same securities as client accounts, aggregated with client orders when consistent with best execution; all participating accounts receive the average price and share costs equally, and partially filled orders are allocated pro rata. Thurston Springer does not effect principal or agency cross transactions for client accounts and does not cross trades between client accounts. Item 12 – Brokerage Practices Selection of Broker-Dealer; Directed Brokerage Thurston Springer generally requires clients to maintain their advisory accounts at Thurston Springer Financial, its affiliated broker-dealer, which clears through First Clearing. Compass Account clients can instead hold their account at Charles Schwab, an unaffiliated broker-dealer and custodian. Except as described above, clients cannot direct brokerage elsewhere. Because of this requirement, transactions are executed by the custodian that holds your account rather than routed to the broker-dealer offering the best price on a given trade, and you can pay more than you would elsewhere. Thurston Springer seeks best execution within that arrangement and reviews the custodians’ execution quality, services and cost. Not all advisers require their clients to direct brokerage. As described in Item 5, Compass II clients pay a transaction charge on each trade. Thurston Springer Financial retains the difference between that charge and what the custodian charges it, so it earns more when those accounts trade more; it likewise retains the mark-up on the custodian charges and the custodian compensation described in Item 5, at either custodian. This revenue is not shared with Thurston Springer or its IARs, but because the firms are affiliates it is a conflict of interest for Thurston Springer, which has an incentive to recommend Compass II and to keep client assets at either custodian. Thurston Springer’s custody agreement with Charles Schwab and Thurston Springer Financial’s clearing agreement with First Clearing are each negotiated based on the client assets held at that custodian, an incentive to keep client assets there. The research and other services Charles Schwab and First Clearing provide to Thurston Springer, and the incentive they create to recommend those custodians, are described below under Research and Other Soft Dollar Benefits. Thurston Springer addresses these conflicts by disclosing them in this brochure and through policies and procedures reasonably designed to ensure that program and custodian recommendations are consistent with its fiduciary duty and in your best interest. September 25, 2026 · thurstonspringer.com Page 12 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Trade Aggregation Thurston Springer aggregates trades when doing so is advantageous to each participating account, for example to reduce costs or improve price; otherwise trades are placed individually. Aggregated trades are allocated to participating accounts as specified before the order is placed, at the average price; best price is not guaranteed. Accounts traded separately can receive a different, and sometimes less favorable, price. Research and Other Soft Dollar Benefits Thurston Springer receives research, products and services other than execution from Charles Schwab and First Clearing, the custodians that hold and execute transactions for its client accounts. These benefits are made available to Thurston Springer because its clients maintain accounts and effect transactions on those platforms; they are not purchased with client commissions or transaction charges, Thurston Springer does not pay for them, and neither custodian conditions them on the amount of client assets held there. Thurston Springer benefits because it does not have to produce or pay for them. This gives Thurston Springer an incentive to recommend Charles Schwab or First Clearing as custodian based on the benefits it receives rather than solely on your interests. Thurston Springer does not select or recommend a custodian for these benefits, and reviews each custodian’s execution quality, services and cost. The transaction charges you pay are set by the custodian’s pricing and Thurston Springer Financial’s mark-up and do not change based on these benefits; Thurston Springer does not agree to higher charges to obtain them, and does not direct client transactions to any broker- dealer in return for them. During Thurston Springer’s last fiscal year these benefits included: access to client account data such as trade confirmations and account statements; trade execution and the allocation of aggregated trade orders; research, pricing and other market data; facilitation of the payment of Thurston Springer’s fees from client accounts; back-office, recordkeeping and client reporting support; compliance consulting; and discounts or waivers of fees the custodians would otherwise charge. The research, market data and trading tools aid investment decision-making and trade execution; the fee-payment, back-office, compliance- consulting and fee-discount benefits do not, and are not eligible research or brokerage services under Section 28(e) of the Securities Exchange Act of 1934. Thurston Springer uses these benefits to service all of its client accounts and does not allocate them to accounts in proportion to the transactions or assets that generate them. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. Thurston Springer does not consider, in selecting or recommending broker-dealers, whether Thurston Springer or a related person receives client referrals from a broker-dealer or third party. Item 13 – Review of Accounts Your IAR reviews your account at least annually and when you report a change in your circumstances or objectives. Supervisory principals in Thurston Springer’s Supervision department review trading in advisory accounts trade by trade through Thurston Springer’s September 25, 2026 · thurstonspringer.com Page 13 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure trade blotter, which also flags certain trades and trading patterns for further review, and review changes to account profile information such as investment objective and risk tolerance. Firm Managed Compass portfolios are rebalanced according to the model selected, subject to any restrictions you impose. Account Reviews Your IAR is available to meet with you on request. Reviews consider the appropriateness of the account in light of its activity and your investment objectives. Other than the custodian’s statements described in Item 15, Thurston Springer does not provide regular reports; your IAR provides written performance or consolidated reports on request. Item 14 – Client Referrals and Other Compensation Thurston Springer does not compensate any person for client referrals. Thurston Springer and its IARs receive economic benefits from persons who are not clients as described in Item 5 (First Clearing; Wealth.com), Item 12 (Charles Schwab and First Clearing) and below. Thurston Springer receives a share of the revenue Wealth.com earns from clients Thurston Springer’s IARs refer to its estate planning platform, and IARs receive a consulting fee from clients who use it. These payments are separate from and in addition to your advisory fee and create an incentive for Thurston Springer and your IAR to recommend Wealth.com rather than another estate planning provider or an attorney you select. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. You are under no obligation to use Wealth.com. The services and fees are described in Item 5. When an IAR who participates in the EPIC Services Company (“EPIC”) program refers a client to EPIC, an unaffiliated company that provides estate planning services and seminar and lead- generation systems to advisers, EPIC pays a fee to the IAR and a share of its revenue to Thurston Springer. These payments are made by EPIC, are separate from and in addition to your advisory fee, and create an incentive for Thurston Springer and your IAR to refer you to EPIC rather than to another provider of estate planning services. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. You are under no obligation to use EPIC’s services. IARs attend educational conferences sponsored by mutual fund and annuity companies, which pay their travel and related expenses and certain costs of client events. This creates an incentive to recommend those sponsors’ products. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures that limit gifts and entertainment and are reasonably designed to ensure that recommendations are in your best interest. September 25, 2026 · thurstonspringer.com Page 14 of 15  Thurston Springer Advisors, LLC Form ADV Part 2A · Firm Brochure Item 15 – Custody Program account assets are held by a qualified custodian — First Clearing, the clearing firm for accounts introduced through Thurston Springer Financial, or Charles Schwab for Compass Account clients who maintain their account at Charles Schwab. Other accounts are held by the qualified custodian named in your agreement. Thurston Springer does not take physical possession of client funds or securities. Thurston Springer is deemed to have custody of client assets under the Advisers Act custody rule because clients authorize the custodian to deduct Thurston Springer’s advisory fees directly from their accounts. Thurston Springer’s custody is subject to an annual surprise examination by an independent public accountant. Your custodian sends you an account statement at least quarterly showing all holdings, transactions and fees, including the advisory fee deducted. Review these statements carefully. Reports you receive from Thurston Springer, including consolidated reports, draw on custodian data, are not official statements, and can differ from custodial statements because of accounting procedures, reporting dates or valuation methods; compare them with your custodian’s statements. Item 16 – Investment Discretion In the Compass Account, PIM, PUMA, FundSource and PAN programs and in ERISA 3(38) engagements, you grant discretionary authority in the account agreement to Thurston Springer, its portfolio manager, your IAR, First Clearing (for PUMA and FundSource models) or the third-party manager. That authority is used to select the securities and the amounts to be bought or sold without obtaining your approval for each transaction. Thurston Springer does not have investment discretion in the CustomChoice and Asset Advisor programs, in ERISA 3(21) consulting engagements, or in other accounts you have designated as non-discretionary; in those accounts you make the investment decisions. Discretion is exercised consistent with your stated investment objectives and any written restrictions. Item 17 – Voting Client Securities Thurston Springer does not have authority to and does not vote proxies on behalf of advisory clients. A PAN manager votes proxies when your agreement with it gives it that authority. You retain responsibility for voting proxies for the securities in your account; the custodian sends proxies and other solicitations to you, and you can ask your IAR questions about a particular solicitation. Item 18 – Financial Information Thurston Springer does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Thurston Springer has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients and has not been the subject of a bankruptcy proceeding. September 25, 2026 · thurstonspringer.com Page 15 of 15 

F O R M A D V P A R T 2 A , A P P E N D I X 1 Wrap Fee Program Brochure Thurston Springer Advisors, LLC H e a d q u a r t e r s 9000 Keystone Crossing, Seventh Floor · Indianapolis, Indiana 46240 (317) 581-4000 · (317) 581-4014 fax · www.thurstonspringer.com September 25, 2026 D E D I C A T E D T O T H E C R E A T I O N A N D P R E S E R V A T I O N O F W E A L T H This wrap fee program brochure provides information about the qualifications and business practices of Thurston Springer Advisors, LLC (“Thurston Springer”). If you have any questions about the contents of this brochure, please contact us at (317) 581-4000 or compliance@thurstonspringer.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. Thurston Springer is an investment adviser registered with the Securities and Exchange Commission. Registration of an investment adviser does not imply any level of skill or training. Additional information about Thurston Springer is available on the SEC’s website at www.adviserinfo.sec.gov. Item 1 – Cover Page  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure Item 2 – Material Changes This brochure, dated September 25, 2026, describes only the material changes made since the wrap fee program brochure dated September 11, 2025: ■ Scope. The brochure now covers every wrap fee program Thurston Springer sponsors: the Compass Account (Compass II and Compass III options) and the six programs offered on the platform of Wells Fargo Clearing Services, LLC (“First Clearing”). ■ Item 4. Program descriptions, minimums and fees for each program, including the Compass fee schedule and how the rate is set (schedule, breakpoint or negotiated rate) and your IAR’s incentive in setting it, the 2.00% standard fee for the First Clearing programs, the PUMA and PAN manager fee ranges, billing timing by program and custodian. Described what the Program Fee does not cover, including Compass II ticket charges and the transaction charges of Charles Schwab & Co., Inc. (“Charles Schwab”), which is available as custodian for Compass Accounts. Disclosed that Thurston Springer Financial, Thurston Springer’s affiliated broker-dealer, retains compensation from First Clearing and Charles Schwab on cash sweep and margin balances (your account uses the custodian’s default sweep unless your IAR changes it, and the options pay Thurston Springer Financial different amounts), marks up both custodians’ charges, and receives Platform Support on PIM accounts; each is a conflict of interest for Thurston Springer. Disclosed that the Charles Schwab and First Clearing agreements are each priced on client assets held there, an incentive to keep client assets at those custodians. Disclosed that your net return on cash is negative when the Program Fee rate exceeds the cash yield, and that the research and other services Thurston Springer receives from Charles Schwab and First Clearing are described in Item 9. ■ Item 6. Portfolio manager selection and review for all programs, including Thurston Springer’s role in PAN; the conflict arising from Thurston Springer acting as both sponsor and portfolio manager; condensed methods of analysis and risk disclosures. ■ Item 9. Updated disciplinary, affiliation (including the placement fee Thurston Springer Financial receives on the affiliated private fund), Code of Ethics, account review and client referral disclosures; disclosed the research and other services Thurston Springer receives from Charles Schwab and First Clearing in connection with client accounts, the conflict they create and how Thurston Springer seeks best execution; disclosed the revenue share Thurston Springer receives from Wealth.com and the referral fee and revenue share EPIC Services Company pays IARs and Thurston Springer, each an incentive to recommend that provider; removed the ended bank networking arrangement. A copy of this brochure is available at any time without charge by contacting Thurston Springer at (317) 581-4000 or compliance@thurstonspringer.com, or at www.adviserinfo.sec.gov. Item 3 – Table of Contents Item 1 – Cover Page.........................................................................................................................................................................................1 Item 2 – Material Changes.........................................................................................................................................................................2 Item 3 – Table of Contents.........................................................................................................................................................................2 Item 4 – Services, Fees and Compensation...................................................................................................................................3 September 25, 2026 · thurstonspringer.com Page 2 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure Item 5 – Account Requirements and Types of Clients..........................................................................................................7 Item 6 – Portfolio Manager Selection and Evaluation...........................................................................................................7 Item 7 – Client Information Provided to Portfolio Managers...........................................................................................8 Item 8 – Client Contact with Portfolio Managers......................................................................................................................9 Item 9 – Additional Information............................................................................................................................................................9 Item 4 – Services, Fees and Compensation The Programs. Thurston Springer sponsors the Compass Account and six programs offered on the First Clearing platform (the “First Clearing programs”): Private Investment Management (PIM), Personalized UMA (PUMA), FundSource, CustomChoice, Asset Advisor and Private Advisor Network (PAN). This brochure uses the term “investment adviser representative” or “IAR” to mean the individual representative you work with. In each program you pay a single asset-based fee (“Program Fee”) that covers Thurston Springer’s advisory services and, except in the Compass II option, the cost of executing transactions in your account; in PUMA and PAN the manager’s fee is additional. Accounts are held at Thurston Springer Financial, Thurston Springer’s affiliated broker-dealer, and cleared and held in custody by First Clearing; Compass Account clients can instead hold their account at Charles Schwab. Compass Account. Thurston Springer’s own program, managed on a discretionary basis. Under an Advisor Managed Portfolio your IAR chooses your investments. Under a Firm Managed Portfolio, offered only under Compass III, Thurston Springer’s portfolio manager chooses them, using its exchange-traded fund (“ETF”) model, its institutional share class mutual fund model, or the Tactical Momentum or Earnings Momentum strategy. There are two options. Under Compass II (Advisor Managed only) you pay a transaction (ticket) charge on each trade, to Thurston Springer Financial or, for accounts held at Charles Schwab, to Charles Schwab, in addition to the Program Fee. Under Compass III the Program Fee covers transaction costs at either custodian. Minimum: $25,000 per account under Compass III ($10,000 for the Firm Managed ETF portfolio); $25,000 per household under Compass II. PIM. Your IAR manages the account on a discretionary basis using securities available through First Clearing. PUMA. The account is invested in one of the Allocation Advisors model portfolios constructed by Wells Fargo Investment Institute; First Clearing implements the model and rebalances the account. Your IAR helps you select the portfolio. Minimum: $7,500 to $25,000 depending on the portfolio; minimum quarterly fee $75. FundSource. The account is invested in a model mutual fund portfolio constructed by Wells Fargo Investment Institute, or in a portfolio your IAR customizes from FundSource’s recommended list of institutional, no-load and load-waived funds; First Clearing implements the model and rebalances the account. Minimum: $25,000 ($10,000 for FundSource Foundations). CustomChoice and Asset Advisor. Client-directed, non-discretionary programs. Your IAR recommends investments — a mutual fund mix from the CustomChoice fund universe, or stocks, bonds, funds and other eligible securities in Asset Advisor — and you decide what to September 25, 2026 · thurstonspringer.com Page 3 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure buy, sell or hold. Thurston Springer does not have investment discretion. Asset Advisor minimum: $25,000. PAN. You enter into a separate agreement with a third-party portfolio manager available through First Clearing, which manages the account on a discretionary basis; you pay that manager’s fee in addition to Thurston Springer’s Program Fee, as described below. Thurston Springer does not impose a program minimum for PIM, CustomChoice or PAN; the custodian's account requirements and any third-party manager's minimum apply. Program Fees. Compass Account: the annual fee is the Fee Schedule A rate for the option and portfolio you select, summarized below. Under an Advisor Managed Portfolio you pay the Advisor Managed rate under both Compass II and Compass III, except that under Compass II a portfolio of institutional mutual funds is charged a lower rate because you also pay a transaction charge on each trade. Under a Firm Managed Portfolio (Compass III only) you pay the Firm Managed rate, lower than the Advisor Managed rate at most tiers. When an existing Compass account grows into a higher asset tier, its rate moves to that tier’s lower rate (a breakpoint). Your IAR can instead agree with you to a negotiated rate, which, like the schedule rate, does not exceed 1.50%. Your IAR receives a portion of the fee and has an incentive not to reduce it; clients with similar accounts and services pay different rates. Compass Account fees are billed quarterly in arrears on quarter-end value for accounts held at Thurston Springer Financial and First Clearing, and quarterly in advance on the prior quarter-end value for accounts held at Charles Schwab, where prorated fees and refunds for additions and withdrawals are applied without a minimum. First Clearing programs: the standard annual fee is 2.00% of account assets unless a different contracted fee, not exceeding 2.50%, is set in your Program Features and Fee Schedule; fees are billed quarterly in advance on the prior quarter- end value, and a prorated fee or refund for additions and withdrawals during the quarter is applied only when it is at least $40. Across all programs, Program Fees are negotiable and range from 0.25% to 2.50% annually. Compare Thurston Springer’s fees with those of other advisers before engaging it. Fees are calculated on the gross value of assets, including any margin balance, and cash is billed at the same rate as the other assets in the account. Compass Fee Schedule A — selected tiers (annual fee, % of account value) Account value Advisor Managed — Compass II institutional mutual fund portfolios Advisor Managed — Compass II (stocks, ETFs, bonds, options) and Compass III Firm Managed — Compass III (ETF and institutional fund models, momentum strategies) Less than $100,000 1.500 0.950 1.200 $100,000 – $199,999 1.450 0.925 1.165 $200,000 – $299,999 1.400 0.900 1.130 $500,000 – $599,999 1.250 0.825 1.025 $1,000,000 – $1,099,999 1.000 0.700 0.850 $2,500,000 – $2,599,999 0.850 0.625 0.700 $5,000,000 – $5,249,999 0.750 0.575 0.648 $10,000,000 – $10,999,999 0.650 0.525 0.597 $25,000,000 – $25,999,999 0.575 0.488 0.560 $50,000,000 – $51,999,999 0.462 0.431 0.498 September 25, 2026 · thurstonspringer.com Page 4 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure Account value Advisor Managed — Compass II institutional mutual fund portfolios Advisor Managed — Compass II (stocks, ETFs, bonds, options) and Compass III Firm Managed — Compass III (ETF and institutional fund models, momentum strategies) $98,000,000 – $99,999,999 0.402 0.402 0.438 $100,000,000 and over 0.400 0.401 0.435 The table shows selected tiers; fees decline in smaller increments between the tiers shown. The complete schedule is in your Compass Account Agreement and is available on request. What the Program Fee does not cover. Compass II transaction charges on each trade: at Thurston Springer Financial, $5.00 per mutual fund trade, $10.50 per stock, ETF or option trade plus $0.50 per option contract, and $12.50 per bond trade. Under Compass II at Charles Schwab you pay Thurston Springer Financial’s transaction charge, set above what Charles Schwab charges; under Compass III Thurston Springer pays Charles Schwab’s transaction charges. In all programs: the internal expenses of mutual funds and ETFs, described in each fund’s prospectus, and custodian charges such as account transfer, wire, IRA maintenance and margin interest. When your account holds Class A mutual fund shares that pay 12b-1 fees to Thurston Springer Financial, those fees are rebated to your account. Thurston Springer Financial sets the custodian and account service charges you pay above what First Clearing or Charles Schwab charges and retains the difference. These include account transfer, termination, wire and IRA maintenance charges and the Compass II transaction charges at either custodian. The charges are stated in the fee schedule provided with your account agreement. In the Compass Account, fixed-income securities are bought and sold on a net basis; no mark-up, mark-down or spread is charged to program accounts. In the First Clearing programs, the Program Fee does not cover dealer mark-ups and mark-downs, odd-lot differentials, transfer taxes, exchange fees, execution fees or ADR custodial pass-through fees. Under PUMA and PAN a separate manager fee applies, as described under Compensation below. Assets in a program account that are not eligible program assets are subject to customary brokerage charges. Compensation from custodians. Thurston Springer Financial retains compensation from First Clearing and Charles Schwab on cash and margin balances in your account: a share of the revenue the custodian earns on cash sweep balances, administrative fees on the money market funds used for cash sweep, and a share of margin interest. Your account uses the sweep option First Clearing or Charles Schwab sets as its default unless your IAR selects a different sweep option or money market fund for you. Thurston Springer Financial receives more from some options than others, and lower-paying options, including money market funds that pay it nothing, are available; your IAR receives no portion of the sweep revenue. In the PIM program it also receives payments from mutual funds and actively managed ETFs held in your account for marketing support, recordkeeping and sub-accounting (“Platform Support”); funds and share classes that pay no Platform Support are available. These payments are in addition to the Program Fee. The Program Fee is charged on cash balances at either custodian, which also generate sweep compensation; when the Program Fee rate exceeds the yield on cash, your net return on that cash is negative. Because the Program Fee is calculated on the gross value of the account, including any margin balance, margin increases the fee paid to Thurston Springer and to your IAR. September 25, 2026 · thurstonspringer.com Page 5 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure Thurston Springer receives none of these payments, but it and Thurston Springer Financial are under common ownership. The payments therefore create an incentive for Thurston Springer to hold cash in your account, to recommend the PIM program and funds that pay Platform Support, and to recommend margin, and for your IAR to recommend margin. Thurston Springer addresses these conflicts by disclosing them in this brochure, by paying IARs no portion of these payments, and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. Cost comparison and conflicts. A wrap fee program costs more or less than paying for advice and transactions separately, depending on how actively the account trades, the size of the account and the fee negotiated; in a low-activity account the wrap fee can exceed what you would pay in commissions. Your IAR receives a portion of the Program Fee, which can be more than the IAR would receive if you paid separately for advice and brokerage; this creates an incentive to recommend a wrap program. Because the Program Fee covers transaction costs under Compass III and the First Clearing programs, Thurston Springer has an incentive to trade less frequently in those accounts. The standard First Clearing program fee (2.00%) is higher than the top Compass rate (1.50%), an incentive for your IAR to recommend a First Clearing program; Compass II adds a charge per trade that Thurston Springer Financial retains, an incentive for Thurston Springer, through its affiliate, to recommend Compass II over Compass III. Thurston Springer Financial retains the custodian compensation and mark-ups described above at either custodian and sets the transaction and account service charges you pay above what the custodian charges, so it earns more when your account trades more. Thurston Springer’s custody agreement with Charles Schwab and Thurston Springer Financial’s clearing agreement with First Clearing are each negotiated based on the client assets held at that custodian, an incentive to keep client assets there. Charles Schwab and First Clearing provide research and other services to Thurston Springer at no charge, described under Client Referrals and Other Compensation in Item 9, an incentive to recommend those custodians. Thurston Springer addresses these conflicts by disclosing them in this brochure and through policies and procedures reasonably designed to ensure that program and custodian recommendations are consistent with its fiduciary duty and in your best interest. Payment and termination. Fees are deducted from your account by the custodian unless you elect to pay from another account or to be billed directly. Either party can terminate on written notice; fees paid in advance are refunded pro rata and fees payable in arrears are charged pro rata to the termination date. Compensation of Thurston Springer and portfolio managers. For the Compass Account, Thurston Springer and your IAR are the portfolio managers and receive the entire Program Fee; Thurston Springer retains a portion and pays the balance to your IAR. Under PUMA, the manager’s fee, currently 0% to 0.50% of account value a year depending on the strategy, is charged in addition to the Program Fee and stated in your Program Features and Fee Schedule. Under FundSource, the model manager is Wells Fargo Investment Institute and no separate manager fee is charged. The PAN manager’s fee, generally 0% to 1.00% of account value a year depending on the manager, is set by the manager and stated in your agreement with it; it is debited from your account in addition to the Program Fee, on the manager’s invoice, or, if you elect, included in the Program Fee. Neither Thurston Springer nor First Clearing verifies the manager’s invoice. For PIM, CustomChoice and Asset Advisor, your IAR is the portfolio manager and no fee is paid to a third-party manager. September 25, 2026 · thurstonspringer.com Page 6 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure Item 5 – Account Requirements and Types of Clients Thurston Springer provides the programs to individuals, high-net-worth individuals, trusts and estates, corporations and other business entities, pension and profit-sharing plans, and charitable organizations. Minimum account sizes for each program are stated in Item 4. Item 6 – Portfolio Manager Selection and Evaluation Selection and review. Compass Accounts are managed by Thurston Springer’s portfolio manager or your IAR, and PIM accounts by your IAR; Thurston Springer selects and supervises them. PUMA and FundSource portfolios are constructed by Wells Fargo Investment Institute and made available through First Clearing; Thurston Springer reviews the models made available on the platform but does not select the underlying securities. PAN managers are third-party investment advisers made available through First Clearing, which performs due diligence on them. Thurston Springer assists you in selecting a manager from that reviewed list and removes a manager from the list or changes its status when its review warrants; it does not advise on the individual securities in a PAN account. The manager places trades through Thurston Springer for execution through First Clearing. Your IAR recommends a portfolio, model or manager based on, among other things, your investment objective, risk tolerance, time horizon, financial situation and any restrictions you impose. Thurston Springer replaces a portfolio manager or model when it no longer meets Thurston Springer’s standards for performance relative to its benchmark, adherence to the stated strategy, or service. Thurston Springer calculates Compass Account performance on a uniform and consistent basis and reviews it internally; First Clearing provides performance information for its programs, which Thurston Springer does not review or verify. Related persons as portfolio managers. Thurston Springer and its IARs act as portfolio managers in the Compass Account and PIM, and IARs customize FundSource portfolios and make the investment recommendations in CustomChoice and Asset Advisor. Because Thurston Springer sponsors the programs and also manages or directs the accounts, it does not select portfolio managers for those programs as it would an unaffiliated manager, and it receives the portion of the Program Fee that would otherwise be paid to an unaffiliated manager. This is a conflict of interest. Related-person portfolio managers are subject to the same selection and review as other portfolio managers in the programs, and Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures that apply its fiduciary duty and best-interest standard to every program account, regardless of program or portfolio manager. Advisory Business Thurston Springer manages program accounts in the same manner as its other advisory accounts and receives a portion of the Program Fee. Thurston Springer also provides financial, estate and retirement planning. Tailored Services / Client Preferred Restrictions Advisory services are tailored to your financial goals, investment objectives and needs. You can restrict investment in certain securities or types of securities by completing the client September 25, 2026 · thurstonspringer.com Page 7 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure preferences section of the program agreement; your IAR will tell you whether and how the restriction can be accommodated. Performance-Based Fees and Side-By-Side Management Thurston Springer and its supervised persons do not receive performance-based fees. Methods of Analysis, Investment Strategies and Risk of Loss The methods of analysis include charting, fundamental analysis, technical analysis and cyclical analysis. Charting uses graphical price and volume history to identify trends. Fundamental analysis evaluates a company’s earnings, dividends and financial condition to estimate its value. Technical analysis uses past price and volume patterns to anticipate price direction. Cyclical analysis seeks to invest in industries whose fortunes rise and fall with economic cycles, over holding periods of months to years. Thurston Springer’s portfolio manager runs the Tactical Momentum and Earnings Momentum strategies, which rely on technical and fundamental indicators; they involve more frequent trading, higher transaction costs and concentration in fewer securities. Strategies include buy-and-hold, asset allocation, rebalancing, value investing, short-term trading, short sales, margin and options (covered and uncovered writing, purchases and spreads). The primary types of securities recommended are mutual funds, bonds and equities. Investing in securities involves risk of loss that you should be prepared to bear. Past performance is not indicative of future results. Before investing, review the program agreement, this brochure, your IAR’s brochure supplement and any prospectus or offering document you receive. The material risks of each strategy and type of security are described in Item 8 of Thurston Springer’s Firm Brochure (Form ADV Part 2A). Strategies that trade frequently, including in the Compass II option where a charge applies to each trade, increase transaction costs and can generate short-term taxable gains, which reduce returns. Voting Client Securities Thurston Springer does not have authority to and does not vote proxies for advisory clients; you retain that responsibility, and the custodian sends proxies and other solicitations to you. A PAN manager votes proxies when your agreement with it gives it that authority. You can ask your IAR questions about a particular solicitation. Item 7 – Client Information Provided to Portfolio Managers Thurston Springer’s portfolio managers and your IAR receive the information in your account application and program agreement — investment objective, risk tolerance, time horizon, financial situation and any restrictions you impose — and updates you provide. For PUMA and FundSource, First Clearing receives the information needed to implement the model, and for PAN the third-party manager receives the information needed to manage the account, including your investment objective and restrictions. September 25, 2026 · thurstonspringer.com Page 8 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure Item 8 – Client Contact with Portfolio Managers You can contact your IAR at any time. Your IAR has direct access to Thurston Springer’s portfolio managers and will arrange contact on request. Third-party managers in PAN and the Wells Fargo Investment Institute teams behind PUMA and FundSource portfolios do not communicate directly with clients; contact is through your IAR. Item 9 – Additional Information Disciplinary Information Thurston Springer and its management persons have no legal or disciplinary events that are material to a client’s evaluation of Thurston Springer or the integrity of its management. Thurston Springer’s affiliated broker-dealer, Thurston Springer Financial (CRD #8478), which shares management with Thurston Springer, has the following event within the past ten years. ■ FINRA — Letter of Acceptance, Waiver and Consent, March 31, 2025. Without admitting or denying the findings, Thurston Springer Financial consented to findings that it failed to establish, maintain and enforce written supervisory procedures reasonably designed to achieve compliance with certain of its obligations. The findings covered Regulation Best Interest, Form CRS, electronic correspondence review, Form U4 disclosure updates, outside brokerage account review, office inspections and supervisory control testing. Sanctions: censure, a $150,000 fine, and an undertaking to review certain electronic communications and certify implementation of a reasonably designed supervisory system, which Thurston Springer Financial completed in May 2025. Information about Thurston Springer Financial is available at brokercheck.finra.org. Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation Thurston Springer is affiliated with Thurston Springer Financial (CRD #8478), a FINRA-member broker-dealer, through common ownership. Most IARs are also registered representatives of Thurston Springer Financial, and certain of Thurston Springer’s management persons hold securities registrations with it. When a representative executes brokerage transactions for a client outside the advisory relationship, the representative acts in a separate capacity as a registered representative and receives commissions. This creates an incentive to recommend brokerage products or services, and to recommend that assets be held in a brokerage rather than an advisory account, based on the compensation received. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. Thurston Springer Financial’s compensation on program accounts — Compass II transaction charges, custodian- charge mark-ups and the First Clearing payments — is described in Item 4. Because the firms are under common ownership, that compensation is a conflict of interest for Thurston Springer in recommending accounts at Thurston Springer Financial and First Clearing, which Thurston Springer addresses as described in Item 4. Neither Thurston Springer nor any management September 25, 2026 · thurstonspringer.com Page 9 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure person is registered, or has an application pending, as a futures commission merchant, commodity pool operator or commodity trading advisor. Affiliated Entities Thurston Springer is a wholly owned subsidiary of Financial Services Holdings, LLC (“FSH”). FSH also owns Thurston Springer Financial, Thurston Springer Insurance, LLC and Bristal Lane Group, LLC (a compliance consulting and accounting firm). Thurston Springer is under common ownership with Peak Brokerage Services, LLC (broker-dealer), Blackridge Asset Management, LLC (investment adviser) and Top Advisors Group, LLC (insurance agency). Through common ownership by the principals of FSH, it is also affiliated with truEdge Asset Management, LLC (investment adviser) and truEdge Capital LLC, the general partner of a private fund described below. Thurston Springer shares office space, personnel and back- office, supervisory and compliance functions with Thurston Springer Financial, Peak Brokerage Services and Blackridge Asset Management. Insurance Thurston Springer Insurance, LLC (“TSI”) and Top Advisors Group, LLC (“TAG”), both affiliates, are insurance agencies through which representatives of Thurston Springer and its affiliated firms place life, health, fixed and indexed annuity, long-term care, disability and similar insurance products. IARs sell insurance as licensed agents, not as representatives of Thurston Springer, through TSI, TAG or unaffiliated agencies; when business is placed through TSI or TAG, the agency receives commissions from the carrier and pays a portion to the representative. Insurance commissions are in addition to advisory fees and create an incentive to recommend insurance products. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make product recommendations that are in your best interest. You are under no obligation to purchase insurance through TSI, TAG or the representative. Affiliated Private Fund truEdge Capital LLC, an affiliate under common ownership, is the general partner of truEdge Opportunity Fund I, a private fund advised by truEdge Asset Management, LLC. IARs recommend the Fund to eligible clients, and Thurston Springer is identified in truEdge Asset Management’s Form ADV as a party that markets the Fund. Thurston Springer Financial acts as placement agent for the Fund and receives a placement fee on each subscription, which it retains; Thurston Springer and your IAR receive no compensation from the Fund or the placement fee. Because the Fund’s general partner is owned by principals of FSH and Thurston Springer’s affiliate is paid on each sale, those persons and that affiliate have a financial interest in your investing in the Fund, which creates a conflict of interest. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that the Fund is recommended only when consistent with its fiduciary duty and in your best interest. Thurston Springer’s Supervision department reviews and approves each client investment in the Fund, as it does every alternative investment, before it is processed. The Fund is illiquid, available only to accredited investors, and described in its offering documents. You are under no obligation to invest in the Fund. Recommendation or Selection of Other Investment Advisers Thurston Springer recommends and selects third-party portfolio managers to manage certain client accounts, as described in Item 6. In the PAN program, the manager’s fee is separate from September 25, 2026 · thurstonspringer.com Page 10 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure and in addition to Thurston Springer’s Program Fee, and Thurston Springer receives no part of it. Management Disclosures Thurston Springer’s management persons hold the same positions with Thurston Springer Financial, and certain of them serve as officers of, or hold ownership interests in, FSH and other affiliates. Their interest in the success of each affiliate is a conflict of interest that Thurston Springer addresses through the disclosures in this Item. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Thurston Springer has adopted a Code of Ethics for Thurston Springer, and employees and associated persons of Thurston Springer, describing its standards of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All employees and associated persons at Thurston Springer must acknowledge receipt of the terms of the Code of Ethics upon hire, again annually or as amended. A copy of Thurston Springer’s Code of Ethics will be provided to you at no charge upon request. Employees and IARs are permitted to buy and sell the securities that clients hold or trade, and an employee who knows of a pending client order has an incentive to trade ahead of it for the employee’s own account. The Code of Ethics requires pre-clearance and reporting of personal trades and prohibits trading ahead of client orders, and Compliance reviews employee trading against client activity. Material Financial Interest IARs recommend truEdge Opportunity Fund I, in which principals of FSH have a financial interest, to eligible clients; see Affiliated Private Fund above. Affiliated and employee accounts trade in the same securities as client accounts, aggregated with client orders when consistent with best execution; all participating accounts receive the average price and share costs equally, and partially filled orders are allocated pro rata. Review of Accounts Your IAR reviews your account at least annually and when you report a change in your circumstances or objectives. Supervisory principals in Thurston Springer’s Supervision department review trading in program accounts trade by trade through Thurston Springer’s trade blotter, which also flags certain trades and trading patterns for further review, and review changes to account profile information such as investment objective and risk tolerance. Your IAR is available to meet with you on request. Your custodian sends you an account statement at least quarterly showing activity, fees and charges. Other than the custodian’s statements, Thurston Springer does not provide regular reports; your IAR provides written performance or consolidated reports on request, which draw on custodian data and are not official statements; compare them with your custodian’s statements. September 25, 2026 · thurstonspringer.com Page 11 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure Client Referrals and Other Compensation Thurston Springer does not compensate any person for client referrals. Thurston Springer and its IARs receive economic benefits from persons who are not clients as described in Item 4 (First Clearing; Charles Schwab) and below. Thurston Springer receives research, products and services other than execution from Charles Schwab and First Clearing, the custodians that hold and execute transactions for its client accounts. These benefits are made available to Thurston Springer because its clients maintain accounts and effect transactions on those platforms; they are not purchased with client commissions or transaction charges, Thurston Springer does not pay for them, and neither custodian conditions them on the amount of client assets held there. Thurston Springer benefits because it does not have to produce or pay for them. This gives Thurston Springer an incentive to recommend Charles Schwab or First Clearing as custodian based on the benefits it receives rather than solely on your interests. Thurston Springer does not select or recommend a custodian for these benefits, and reviews each custodian’s execution quality, services and cost. The transaction charges you pay are set by the custodian’s pricing and Thurston Springer Financial’s mark-up and do not change based on these benefits; Thurston Springer does not agree to higher charges to obtain them, and does not direct client transactions to any broker- dealer in return for them. During Thurston Springer’s last fiscal year these benefits included: access to client account data such as trade confirmations and account statements; trade execution and the allocation of aggregated trade orders; research, pricing and other market data; facilitation of the payment of Thurston Springer’s fees from client accounts; back-office, recordkeeping and client reporting support; compliance consulting; and discounts or waivers of fees the custodians would otherwise charge. The research, market data and trading tools aid investment decision-making and trade execution; the fee-payment, back-office, compliance- consulting and fee-discount benefits do not, and are not eligible research or brokerage services under Section 28(e) of the Securities Exchange Act of 1934. Thurston Springer uses these benefits to service all of its client accounts and does not allocate them to accounts in proportion to the transactions or assets that generate them. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. Thurston Springer receives a share of the revenue Wealth.com, an unaffiliated online estate planning platform operated by Wealth, Inc., earns from clients Thurston Springer’s IARs refer to it, and IARs receive a consulting fee from clients who use it. These payments are separate from and in addition to your Program Fee and create an incentive for Thurston Springer and your IAR to recommend Wealth.com rather than another estate planning provider or an attorney you select. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. You are under no obligation to use Wealth.com. The services and fees are described in Item 5 of Thurston Springer’s Firm Brochure (Form ADV Part 2A). When an IAR who participates in the EPIC Services Company (“EPIC”) program refers a client to EPIC, an unaffiliated company that provides estate planning services and seminar and lead- September 25, 2026 · thurstonspringer.com Page 12 of 13  Thurston Springer Advisors, LLC Form ADV Part 2A, Appendix 1 · Wrap Fee Program Brochure generation systems to advisers, EPIC pays a fee to the IAR and a share of its revenue to Thurston Springer. These payments are made by EPIC, are separate from and in addition to your Program Fee, and create an incentive for Thurston Springer and your IAR to refer you to EPIC rather than to another provider of estate planning services. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures reasonably designed to ensure that IARs meet Thurston Springer’s fiduciary duty under the Investment Advisers Act and make recommendations that are in your best interest. You are under no obligation to use EPIC’s services. IARs attend educational conferences sponsored by mutual fund and annuity companies, which pay their travel and related expenses and certain costs of client events. This creates an incentive to recommend those sponsors’ products. Thurston Springer addresses this conflict by disclosing it in this brochure and through policies and procedures that limit gifts and entertainment and are reasonably designed to ensure that recommendations are in your best interest. Financial Information Thurston Springer does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Thurston Springer has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients and has not been the subject of a bankruptcy proceeding. September 25, 2026 · thurstonspringer.com Page 13 of 13