TRANSAMERICA FINANCIAL ADVISORS, LLC

ITEM 1 – COVER PAGE TRANSAMERICA FINANCIAL ADVISORS, LLC Form ADV Part 2A Appendix 1 TFA365 Advisory Program Platform Brochure October 6, 2025 Two Liberty Place 50 South 16th Street Suite 3700 Philadelphia, PA 19102 (770) 248-3271 WWW.TFACONNECT.COM Transamerica Financial Advisors, LLC Mailing Center 6400 C Street SW Cedar Rapids, IA 52499 This Form ADV Part 2A – Appendix 1 (“Wrap Fee Brochure”) provides information about the qualifications and business practices of Transamerica Financial Advisors, LLC (“TFA”) as they relate to the TFA365 Advisory Program. If you have any questions about the contents of this Brochure, please contact us at (770) 248-3271. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about TFA is also available at the SEC’s website www.adviserinfo.sec.gov. (Select “Firm” and type Transamerica Financial Advisors, LLC). TFA is a federally registered investment adviser with the SEC. Registration with the SEC does not imply a certain level of skill or training.  ITEM 2 – MATERIAL CHANGES TFA has made the following changes to this brochure since the last update on March 28, 2025: • TFA has disclosed a securities-backed lending arrangement available under its TFA365 Advisory Program. When we update the Disclosure Brochure with material changes, we will either send you a copy or offer to send you a copy (either by electronic means (email) or in hard copy form) within the required timeframe. If you would like a copy of this Disclosure Brochure, you may download it from the SEC’s public disclosure website (IAPD) at www.adviserinfo.sec.gov, download it at www.tfaconnect.com, or contact us at (770) 248-3271. 2  ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE ........................................................................................................................ 1 ITEM 2 – MATERIAL CHANGES ........................................................................................................... 2 ITEM 3 – TABLE OF CONTENTS ......................................................................................................... 3 ITEM 4 – SERVICES, FEES AND COMPENSATION ............................................................................ 4 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ................................................... 12 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION ................................................. 13 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ................................... 14 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS .......................................................... 14 ITEM 9 – ADDITIONAL INFORMATION .............................................................................................. 15 3  ITEM 4 – SERVICES, FEES AND COMPENSATION THE COMPANY Transamerica Financial Advisors, LLC (“we/our/us/TFA”) is a federally registered investment advisor and has been registered with the SEC since 1991. TFA is also a broker-dealer and has been a member of the Financial Industry Regulatory Authority (FINRA) since 1984 and member Municipal Securities Rulemaking Board (MSRB). TFA offers investment related products, variable insurance products, employer retirement solutions, and advisory and asset management services to the retail public. TFA and some of TFA’s financial advisors also act in the capacity of broker-dealer and registered representatives respectively. When TFA is acting as a broker-dealer neither TFA nor its financial advisors are acting as fiduciaries under the law, but each has a responsibility to deal fairly with all clients. TFA is directly owned by AUSA Holding, LLC, which is an indirect, wholly owned subsidiary of the ultimate parent, AEGON N.V., a publicly traded company listed on the New York Stock Exchange (NYSE) and trading under the symbol AEG. SERVICES The information in this Wrap Fee Brochure only pertains to the TFA365 Advisory Program (“TFA365”), however, TFA, in its capacity as a federally registered investment advisor offers other advisory services which are generally described in TFA’s Form ADV Part 2A and the specific service brochure. These offerings may include access to Portfolio Managers who manage model portfolios on behalf of clients, referrals to third-party providers that offer certain administrative services relating to employee benefit plans, access to a wrap fee program that offers clients access to fee-based investment management, access to a suite of risk-based allocations to strategies and access to a digital advice program under which clients receive investment portfolio recommendations and investment management of the assets held in their accounts. TFA’s advisory services are made available to clients through individuals registered with TFA as investment advisor representatives (“Advisors”). For more detailed information about these programs, please request a copy of TFA’s Form ADV Part 2A from your Advisor or you can access the form directly by visiting TFA’s public website at www.tfaconnect.com. At the time your Advisor offers you TFA advisory services they, with the assistance of firm tools and online resources, will conduct an interview with you and collect financial information to determine your financial needs, time horizon, and objectives. Your Advisor will analyze your current financial situation, investment goals, time horizon, risk tolerance, and present investment strategies, if any. Your Advisor will then provide investment recommendations to you based on the Advisor’s analysis. TFA and TFA Advisors do not provide legal, tax, or accounting advice. Your Advisor cannot retain custody of any of your assets, including stocks or bond certificates or cash. When providing funding for your account, if you are using a check, you should only make any check 4  payable to National Financial Services, LLC. You should never make checks payable to your Advisor or any other entity. If your Advisor determines that your stated investment objectives would be best met by using the TFA365 platform, your Advisor will assist you in opening an account. Your Advisor will also explain the investment management process, investment objectives, and the investment strategies undertaken as part of the service; review and assist you in completing the electronic and/or written materials required to open the account; and answer questions about the program. Your Advisor will meet with you, at least annually, to review your stated investment objectives and goals and to assess whether a TFA365 account is still suitable for you given your then current investment objectives. There is no additional charge for this service. You are strongly encouraged to meet with you Advisor more frequently if you have questions about your account or if your personal financial circumstances change. TFA365 is available to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. TFA has entered into an agreement with Fidelity Institutional Wealth Adviser LLC (“FIWA”), whereby TFA will administer and sponsor TFA365 using the Fidelity Managed Account Xchange℠ managed account platform (the “FMAX Platform” or “FMAX”). FIWA is a registered investment adviser and an indirect, wholly owned subsidiary of FMR LLC (collectively with FIWA and its affiliates, “Fidelity Investments,” “Fidelity”). FIWA does not maintain custody of your assets in connection with the services it provides to TFA365. NFS, a registered broker-dealer and affiliate of FIWA, has custody of assets on the FMAX Platform and performs certain services for the benefit of TFA clients, including the execution of trading instructions, as well as custodial and related services. TFA365 consists of three different programs which TFA Advisors may offer their clients: the TFA365 Advisory Strategist Program, the TFA365 Advisory Separately Managed Account Program, and the TFA365 Advisory Unified Managed Account Program (together, the “Programs” and individually a “Program”). Your Advisor will assist you in selecting the Program that meets your investment goals and objectives. Utilizing the FMAX Platform tools, you and your Advisor will allocate your assets among the different options within the selected Program and determine the appropriateness of the asset allocation and investment options for you, based on your stated investment objectives, investment time horizon, risk tolerance and any other pertinent factors. The model portfolios available in TFA365 offer several types of investment alternatives that vary in terms of strategies and investment style. Types of investments used can consist of, but are not necessarily limited to, individual stocks, mutual funds, bonds, and exchange traded products. For a complete listing of the securities that may be used in your model portfolio, please consult the FIWA Form ADV Part 2A titled Fidelity Managed Account Xchange® for additional details or the Portfolio Manager’s Form ADV Part 2A or other Disclosure Brochure(s). Clients may allocate to investment options that fall within their risk profile. If allocating outside of that risk range clients would need to complete a new risk tolerance questionnaire to match their current risk profile and sign the newly generated Investment Policy Statement. Your Advisor will conduct a review of your investment advisory account with you, at least annually, to determine whether any of the above noted information has changed and assist you in updating your investments if warranted. 5  By signing their Client Services Agreement, Client gives written authorization to TFA and Advisor the exercise limited discretionary authority to replace and update allocation weightings for Portfolio Managers as long as the changes only occur within Client’s risk tolerance noted on Client’s most current Statement of Investment Selection on file with TFA. Any changes to allocations outside of Client’s stated risk tolerance, would require a new client signed Statement of Investment Selection. Clients may impose reasonable investment restrictions on the management of their accounts. If a requested investment restriction is deemed to be unreasonable, or if TFA determines that a previous restriction has become unreasonable, TFA will notify the client that, unless the instructions are modified, TFA may reject or terminate the client relationship at its discretion and upon notification to the client pursuant to the notification terms in the applicable Advisory Brochure and this Appendix. Clients may choose whether to reinvest any dividends received back into the underlying investments or whether to receive them in cash. Clients should consult with their tax professional regarding the tax treatment for any dividends received. FIWA has retained Envestnet Asset Management, Inc. (“EAM”), an unaffiliated investment adviser, to provide model implementation, overlay management, and other administrative duties. You agree and acknowledge that EAM will have discretionary authority over your accounts and is responsible for the implementation of models received from model providers in your accounts. EAM also provides overlay management services (together with model implementation this function is referred to as “Implementation Manager”). Please refer to the current FIWA Form ADV Part 2A titled Fidelity Managed Account Xchange® for additional details. FIWA may at its discretion in the future utilize other affiliated or unaffiliated investment advisers to act in the role of Implementation Manager. Additional information about FIWA is available on the SEC’s website at www.adviserinfo.sec.gov. TFA may recommend tax and values overlay services (“Tax Overlay” and “Values Overlay”) for wrap fee clients. Tax Overlay seeks to consider tax implications that may detract from a client’s after-tax returns. Values Overlay allows FIWA to integrate ESG factors and other client-directed priorities into their investments based on a client’s request. If selected by the Client after discussion with their Advisor, the Implementation Manager provides the Tax Overlay or Values Overlay (or both) services to an account. The Tax Overlay services are designed to enhance the after-tax return for the client. TFA, FIWA or the Implementation Manager do not provide tax planning advice or services. TFA recommends that any questions about Tax Overlay be directed to your tax professional. Please discuss any general questions you may have with your Advisor. EAM will liquidate securities that are transferred in-kind into a clients’ account typically upon receipt. The Implementation Manager has the authority to liquidate such assets, and absent special circumstances or direction from TFA, Implementation Manager will treat the transfer of securities into the account as an instruction to liquidate the securities at market price. Clients should thus be aware that if they transfer in- kind assets into an account, EAM will liquidate such assets immediately or at a future point in time unless explicit special instructions are received from you prior to funding. In certain circumstances, clients will have a taxable event when the Implementation Manager liquidates such assets. Accordingly, clients should consult with their Advisor and seek tax advice from their tax consultant before transferring in-kind assets into a TFA365 account. Advisors do not provide tax advice. 6  Clients, at their request, may hold “unsupervised” assets within their account. The Advisor will provide no advice regarding such assets and will not receive any compensation on the assets while the assets are held as unsupervised. These assets are not part of the advisory billing or performance reporting. These assets will appear on your custodial statement and be subject to the custodial platform fee and brokerage terms and conditions. Depending on your elections, you will either receive trade-by-trade confirmations from NFS for any transactions in your account or quarterly trade confirmations; however, with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the core Fidelity money market fund, a client’s account statement serves in lieu of a confirmation. In addition, clients will receive statements from NFS at least quarterly that detail all holdings and transaction information, including trades, additions, withdrawals, shifts in investment allocations, fees, and estimated gain/loss and tax basis information. Statements and confirmations are also available online at Fidelity.com or WealthscapeSM and by enrolling in electronic delivery. You should carefully review all statements and other communications in connection with your accounts upon receipt and raise any discrepancies related to the same immediately, but in any case, no later than 30 days after receipt of the statement. If you wish to receive paper statements, which will be subject to a fee, contact your Advisor. TFA has a revenue sharing arrangement with a third-party lender (“Lending Sponsor”) that allows clients to use certain brokerage and advisory accounts as collateral to obtain secured loans. This arrangement allows clients to borrow against the value of their investment account for purposes other than the purchase of additional securities. This type of lending can provide quicker access to funds without selling securities. However, if the value of the securities in the investment account declines, clients may be required to provide additional collateral, or the lender may force the sale of the securities in the account to repay the loan. The Lending Sponsor compensates TFA for making the respective loan program available on TFA’s platform and covers various administrative costs associated with servicing the loan and regulatory reporting. Compensation can be up to 25 basis points of the outstanding loan amount. This arrangement presents a conflict of interest, as TFA has a financial incentive to promote loans from its Lending Sponsor over other lenders who do not provide TFA compensation. Although TFA does not share this compensation with its Financial Professionals (“FPs”), and your FP does not have a direct financial incentive to recommend the sponsor over other lenders, both TFA and its FPs may still be incentivized to recommend borrowing over asset liquidation. This is because maintaining account assets allows TFA and your FP to continue earning brokerage commissions and 12b-1 fees or advisory fees. While client information is considered confidential, it will be provided to Fidelity, EAM and NFS as required to open and maintain the account, as described in TFA’s Privacy Policy. Termination The Client Services Agreement (“Services Agreement”) for the Programs described in this Brochure may be terminated, changed or modified by TFA at any time in its sole discretion. The Service Agreement may also be terminated at any time by you upon signed written notice to TFA in accordance with the terms of the Service Agreement. 7  If you or TFA terminate the Service Agreement, a prorated amount of the asset-based fee will be refunded to you. Terminated accounts will be closed in accordance with one of the scenarios described below: Terminations initiated by TFA. TFA may terminate any account with thirty (30) days’ notice or earlier if provided for under the law. If you fail to provide written instructions for account disposition within thirty (30) day period, the account will be a) liquidated and the proceeds mailed to your address of record then on file with TFA or to an intermediary of your choice or b) transferred in-kind to a non-advisory TFA brokerage account. Advisory or institutional share classes may not be available in such non-advisory accounts. Terminations initiated by the Client. If you elect to voluntarily terminate your Service Agreement and your account, you must provide instructions for account disposition within thirty (30) days or your account will be liquidated and the proceeds mailed to your address of record then on file with TFA regardless of tax consequences. Termination of any account may incur additional charges, including certain brokerage fees associated with your NFS brokerage account. Note: TFA may change, modify or terminate the Programs, the Portfolio Managers, or Program accounts described in this Brochure at any time in its sole discretion upon thirty (30) days’ notice to you. Bankruptcy - Should TFA need to file for protection under bankruptcy laws and a protective decree would need to be issued under the Securities Investor Protection Act (SIPA), any fees owed by you, as of such date, shall be collected by Fidelity from your account as described in this Brochure. Your account will also be subject to certain service fees separate from the Total Program Fee that you pay. Refer to the Fees and Compensation section below for additional information. FEES AND COMPENSATION TFA and your Advisor are compensated in several ways. We want to ensure that you understand how TFA and your Advisor are compensated, as well as the other costs associated with your account. You will pay a Total Annual Program Fee (“Total Program Fee”) as outlined in the TFA365 Advisory Program Fee Schedule below. The Total Program Fee is comprised of your Advisor’s fee, a Platform Fee, and an Investment Management Fee. Negotiable Fees While we have a maximum fee that can be charged to manage your account, the Total Program Fee is negotiable between you and your Advisor. The Advisor fee may be more than what your Advisor would receive if you participated in our other advisory offerings or paid separately for investment advice, brokerage services, or other services. Therefore, your Advisor may have a financial incentive to recommend TFA365 over other advisory offerings or services. There are many factors that you should consider when negotiating the Advisor fee with your Advisor. These include such things as the complexity of your financial situation, your specific investment 8  objectives, needs and risk tolerance. Other factors that would be appropriate to consider include the programs or services your Advisor offers and the amount of time and due diligence necessary to research both investments you currently own as well as recommendations for any future investments. You and your Advisor should also consider the frequency of meetings and contact necessary to serve your needs as well as any potential involvement between your Advisor and your other professional service providers, such as accountants and attorneys. This is not meant to be an exhaustive list of the items to be considered but rather serves as a guideline for you to consider when negotiating the Advisor fee with your Advisor. Your advisory fees may be higher or lower than those paid by other clients who are also participating in TFA365 based on this negotiation. Your Total Program Fee may change based upon you and your Advisor re-negotiating the Advisor Fee. If you and your Advisor negotiate a new Advisor Fee, you will be provided a new Statement of Investment Selection (“SIS”) with your new Fee Schedule. The Total Program Fee may also change based upon TFA’s discretion to change the Platform Fee at any time. The total feel may also increase or decrease if a Portfolio Manager changes their fee or upon a reallocation to a Portfolio Managers with different fee schedules. Platform and Investment Management Fees The Platform Fee and the separate Portfolio Manager Fee, if applicable, are not negotiable. You will receive notice of a change in the Platform and/or Portfolio Manager fee at least thirty (30) days prior to any change. Multi-Account Discount You may qualify to take advantage of reduced advisory fees, through a multi-account discount. In general, the value of additional qualifying accounts, accounts for your immediate dependents and spouse could be aggregated to achieve a lower advisory fee. Please consult with your Advisor regarding any questions you may have about your eligibility. All client discounts are considered a tailored service and require an assessment and a discussion with your Advisor. These discounts do not lead to any additional compensation received by TFA or your Advisor. You Pay Your Advisory Fees in Advance The total annual Program Fee is paid monthly in advance. Advisory fees are computed based on the prior month’s average daily balance. The applicable Program Fee will be determined based on the amount of assets held in your TFA365 account. Fidelity will deduct its fees and fees related to TFA365 from your account. Fidelity will be responsible for paying each Portfolio Manager the appropriate fee for their participation in the TFA365 Advisory Program. All brokerage, custodial, and administrative costs associated with TFA365, as described further below, will be clearly noted on your statements. Please refer to the fee schedule below. Fees are automatically deducted from your advisory account. If you terminate your account prior to the end of month, we will refund any advisory fees owed to you on a prorated basis. TFA has established the following tiered fee schedule for Program participants that results in a blended rate. 9  TFA365 Advisory Program Annual Fee Schedule Range of Assets* Maximum Platform Fee*** Portfolio Manager Fee**** Maximum Investment Advisor Rep Fee** Maximum Total Annual Program Fee ***** $0 - $150,000 1.25% 0.50% 0.00% - 1.00% 2.75% >$150,000 - $250,000 1.25% 0.50% 0.00% - 1.00% 2.75% >$250,000 - $500,000 1.25% 0.47% 0.00% - 1.00% 2.75% >$500,000 - $1,000,000 1.25% 0.44% 0.00% - 1.00% 2.75% 1.25% 0.38% 0.00% - 1.00% 2.75% >$1,000,000 - $2,000,000 1.25% 0.34% 0.00% - 1.00% 2.75% >$2,000,000 - $5,000,000 >$5,000,000 1.25% 0.33% 0.00% - 1.00% 2.75% * The initial minimum account size for TFA365 accounts differ by Program (please see below): TFA365 Advisory Strategist Program Minimum Account Value: $25,000 Below Minimum Annual Account Fee $35 TFA365 Advisory Separately Managed Account Program Minimum Account Value: $100,000 Below Minimum Annual Account Fee $150 TFA365 Advisory Unified Managed Account Program Minimum Account Value: $25,000 Below Minimum Annual Account Fee $35 TFA reserves the right to waive the account minimum at its discretion. For TFA365 accounts that fall below the applicable Program account minimum, a minimum annual account fee will apply to the total client fee or fees charged by the custodian. Minimum accounts fees are expressed in annual amounts but are determined and assessed based on the account asset value at the end of each month. For example, if an account has a $150 minimum annual account Program Fee, it will be assessed a minimum of $12.50 every month based on the average daily balance of the account during the previous calendar month. Therefore, if a client has large asset inflows or outflows during the year that cross the minimum asset value threshold, it is possible for an account to be assessed a minimum fee for a particular month even if at the end of the year a look back over the account’s average balance for the entire year would have placed it above the minimum asset value threshold. ** This fee can be negotiated with your Advisor. 10  *** TFA receives a portion of the Total Platform Fee as the Program sponsor and the remainder of the Total Platform Fee is retained by Fidelity for FMAX Platform Fees. **** Fees are expressed as an annual percentage of assets under management. All Portfolio Manager Fees are paid to the Portfolio Managers. These fees are subject to change at the discretion of the Portfolio Manager. Based upon the investments you selected; you should refer to the applicable Portfolio Managers Form ADV Part 2A or other disclosure documents for more information. ***** Fees are expressed as an annual percentage of assets under management. The Total Program Fee charged to the Client is dependent on the model portfolio(s) selected. FIWA shall retain the amounts due FIWA in connection with the Program and shall disburse the remainder of the Fee to TFA and/or to any applicable FIWA affiliate in accordance with their instructions. FIWA, as agent for Client, shall retain or distribute to Portfolio Managers, Implementation Manager, and any third-party service providers any amounts due such parties in connection with the FMAX Platform. Client may also incur certain charges imposed by third parties other than TFA in connection with investments made through Client’s TFA365 account, including, without limitation, the following types of charges: dealer markups, markdowns, or spreads charged on transactions in over-the-counter securities; the internal charges and fees that may be imposed by any funds (such as fund operating expenses, management fees, redemption fees, 12b-1 fees, and other fees and expenses; further information regarding charges and fees assessed by funds may be found in the appropriate prospectus) or other regulatory fees; brokerage commissions or other charges imposed by broker-dealers or entities other than FIWA’s affiliated broker-dealers if and when trades are executed by another broker-dealer; postage and handling charges, returned check charges, transfer taxes, stock exchange fees, or other fees mandated by law; ACAT transfer, electronic fund and wire transfer charges; individual retirement account (“IRA”) trustee or custodian fees and tax-qualified retirement plan annual account fees and annual and termination fees for retirement accounts (such as IRAs); maintenance fees, any brokerage commissions or other charges, including contingent deferred sales charges (“CDSC”), imposed upon the liquidation of “in- kind assets” that are transferred into the FMAX Platform. In addition to the redemption fees described above, client may incur redemption fees when TFA, Implementation Manager or Portfolio Manager determines that it is in Client’s overall interest, in conjunction with the stated goals of the investment strategy, to divest from certain funds prior to the expiration of the minimum holding period of the funds. Some mutual funds also assess redemption fees to clients upon the short-term sale of its funds. Depending on the particular mutual fund, this may include sales for rebalancing purposes. Please see the prospectus for the specific mutual fund for detailed information regarding such fees. To the extent that such fees are incurred, they are borne by the Client. If there is insufficient cash in the account(s) at the time the applicable Fee is to be debited from the account(s), TFA, Implementation Manager or discretionary Portfolio Managers may sell any amount of the assets held in client’s TFA365 account to generate sufficient cash to pay the applicable Fee. This may create a taxable gain or tax loss for the client. Please refer to the FIWA Form ADV Part 2A titled Fidelity Managed Account Xchange® for additional details related to Fees you may incur. The cost of investment advisory services provided through TFA365 may be more or less than the cost of purchasing similar services separately or from another registered investment advisor. 11  Assets under management is the total value of the assets in the account. The Platform fees will be charged whether the assets are held in securities or other instruments or whether they are held in cash or cash equivalents. Changes in Fees TFA, upon 30 days prior notice to clients, may at its discretion revise any aspect of the Total Client Fees which include three components (1) the Advisor’s fee, (2) the Platform fee, and (3) the Portfolio Manager fee, including in a way that may cause the fees paid by the client to increase. Client will be deemed to have approved a fee change unless he or she objects to the fee change by sending written notice pursuant to the Notice section in the Client Services Agreement and/or Applicable Appendix to TFA within 30 days from the date of the fee increase notification. TFA further reserves the right to negotiate, discount or waive any fees associated with its advisory programs or payable by any client or group of clients at its sole discretion. Furthermore, TFA employees and employees of affiliates may be entitled to fee discounts by virtue of their employment. Securities Backed Lending Fees Clients may be offered access to securities-backed lending programs through a third-party bank. These loans are collateralized by securities held in clients' advisory account. While TFA does not directly receive compensation for these loans, it does receive revenue share. The Lending Sponsor compensates TFA for making the respective loan program available on TFA’s platform and covers various administrative costs associated with servicing the loan and regulatory reporting. Compensation can be up to 25 basis points of the outstanding loan amount. A conflict of interest exists because TFA and its financial professionals have an incentive to recommend such programs. Clients are not obligated to participate in the lending program and should consider the risks, including the possibility of liquidation of pledged assets, and tax implications. Securities used as collateral in a loan are subject to liquidation if the value falls below maintenance levels, which may negatively impact the client's investment strategy. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS TFA provides advisory services to individuals, employer retirement plans, corporations or other businesses, trusts, estates, and charitable organizations. To open a TFA365 account a client must complete a new investor account profile which provides TFA with information such as client name, address, date of birth and other information used to identify you. TFA will use third-party sources to verify and/or update the information provided and may also request to see your driver’s license or other identifying documents in compliance with federal law. You will also complete a Client Advisory Services Agreement. TFA365 accounts have minimum investment requirements. The initial minimum account size for TFA365 accounts differ by Program. Please refer to Item 4: Services, Fees and Compensation section above for specific information related to account minimums. A summary of each TFA365 Program can be found below: 12  TFA365 Advisory Strategist Program This Program consists of turnkey asset allocation portfolios using mutual funds and exchange traded funds. Fund Strategist Portfolios (“FSPs”) provide clients access to investment strategists who construct distinct portfolio solutions to help meet the ever-increasing demands of today’s investors. FSP solutions espouse various approaches to portfolio construction and asset allocation: whereas most FSP portfolios employ a long-term, strategic asset allocation approach, others take a dynamic or tactical approach and actively shift allocations to take advantage of short- term market movements. TFA365 Advisory Separately Managed Account Program This Program provides you access to institutional asset managers who implement a single or multi-asset class strategy utilizing individual securities, ETFs, bonds, and/or mutual funds. A Separately Managed Account (“SMA”) can refer to several different types of investment accounts managed by third-party or independent investment management firms. TFA365 Advisory Unified Managed Account Program This Program offers a single account that offers the greatest degree of customization, allowing the ability to combine multiple SMAs, FSPs, individual mutual funds and ETFs. A Unified Managed Account (“UMA”) offers a single account with investments designed to meet a client’s specific investment needs. For the UMA Program, you and your Advisor will select the frequency in which your account will be rebalanced to the original allocation weightings. Clients should discuss the frequency and preferred rebalancing timing with their Advisor. For UMA portfolio updates or changes submitted by TFA to FIWA via the FMAX Platform before 1:00 p.m. Eastern Standard Time, FIWA shall rebalance on the same business day. For model updates or changes submitted by TFA after 1:00 p.m. Eastern Standard Time, FIWA shall use commercially reasonable efforts to rebalance on the same business day. Notwithstanding the foregoing, certain rebalance instructions may take more than one business day to implement because of security liquidity constraints, the fund company order processing capacity, market conditions or other client account specific conditions including, but not limited to, reconciliation breaks, trade restrictions or constraints, and if the account is otherwise “not in good order.” Please refer to the FIWA Form ADV Part 2A titled FIWA Managed Account Xchange® for additional information related to these Programs. Multiple accounts may be established for a client based upon the number of Programs selected with each account using the same account registration and Social Security number of the client. As a result, a client will receive multiple statements, IRS Form 1099, other tax related documentation, and any other legally required information. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION Investment Strategy, Fund Research and Due Diligence FIWA maintains fundamental and quantitative portfolio manager research teams to perform investment due diligence for the FMAX Platform. FIWA provides investment research and due diligence on Fund 13  Strategists, SMAs and mutual funds using four categories of investment research ratings: Available, Meets-Quantitative, Meets-Qualitative, and Preferred. Generally, TFA will offer only a curated list of strategies that are FIWA rated “Meets-Quantitative”, “Meets-Qualitative” and “Preferred”, however, TFA may offer “Available” strategies if the strategies meet TFA’s due diligence requirements. The methods of analysis, sources of information and investment strategies used by Portfolio Managers and mutual funds offered through TFA365 will vary among managers. TFA encourages you to read each Portfolio Manager’s Disclosure Brochure, Form ADV Part 2A and/or mutual fund prospectus prior to selecting a Portfolio Manager and/or mutual fund in TFA365. If a model portfolio or mutual fund is underperforming for an extended time, TFA will then decide if removal of a particular model portfolio, Portfolio Manager or mutual fund from TFA365 Advisory Program is warranted. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Your Advisor will assist you in completing your risk tolerance questionnaire within the TFA365 Platform to obtain a risk score to assist in determining a suitable selection of one or more model portfolios. The selection of your model portfolio(s) will be based upon your stated investment objectives, risk tolerance, time horizon, and financial circumstances. In addition, your Advisor will gather the following information (not meant to be an exhaustive list) to assist in this selection: Income Investment Objective Investment Experience • • Age • Number of Dependents • Employment Status • Marital Status • Tax Bracket • Net Worth • Risk Tolerance • • Your information will be retained by TFA to allow it to continue to ensure that model portfolios used in your TFA365 account are appropriate for you. Your information is not provided to the Portfolio Managers. ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Generally, you will not have any direct contact or consultation with your Portfolio Manager. 14  ITEM 9 – ADDITIONAL INFORMATION All investments in securities include a risk of loss of your principal. Stock markets and bond markets fluctuate over time and clients may lose money. Investments are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. All investments have risk and there is no guarantee that utilizing TFA365 and TFA’s advisory consulting services will produce favorable results. The level of overall investment market diversification will vary depending on the Program used as well as the underlying exposures of the underlying funds. The risk in a Program or Programs is a function of the underlying asset classes used and many factors affect the performance of each investment and account. Further, all investment strategies involve risk, and the investment performance and success of any strategy cannot be predicted or guaranteed. Past performance should not be used to forecast future results. No returns are guaranteed and you may lose money by investing. Securities-backed lines of credit are not appropriate for all clients and involve significant risks. The use of such loans can magnify losses, and the forced liquidation of securities may occur in declining markets. Clients should carefully consider the impact of borrowing against their investment portfolio, including the potential for loss of principal, interruption to their investment strategy, and tax consequences. Investments and accounts are also subject to volatility in non-U.S. markets through either direct exposure or indirect effects in the U.S. markets from events abroad. Investments or accounts that seek exposure to debt are subject to risks of prepayment or default, and model portfolios that concentrate in particular industries or are otherwise subject to particular segments of the market may be significantly impacted by events affecting those industries or markets. In addition, the investments in your advisory account may be subject to the following specific risks: Investing in Mutual Funds and Exchange-Traded Funds (ETFs): Your account bears all the risk of the investment strategies employed by the mutual funds and ETFs held in your account, including the risk that a mutual fund or ETF will not meet its investment objectives. For the specific risks associated with a mutual fund or ETF, please see the applicable prospectus for each. Investing in Exchange Traded Notes (ETNs): ETNs are unsecured debt obligations of the issuer (often a bank). As such, ETN holders are directly exposed to the issuer's credit or default risk. Investing in Environmental, Social and Governance (ESG): ESG investing, also known as “socially responsible investing,” focuses on the environmental, social, and governance standards or the sustainability factors of an investment. Some investment strategies use criteria to supplement financial analysis when considering a particular issuer or security, while others affirmatively select “socially responsible” investments or screen out or exclude investments in companies that engage in certain activities. This may limit the type and number of investments available in a strategy and cause the strategy to underperform other strategies without an ESG based focus. ESG strategies may underperform the market as a whole. Companies and issuers selected in a ESG based strategy may not or may not continue to demonstrate ESG based characteristics. Incorporating a social objective or other nonfinancial objective into recommendations, advice, and/or the selection of a third-party manager or sub-advisor to manage the investments will result in investments and recommendations/advice that are 15  not solely focused on maximizing a financial return for you or your account(s). All investments involve risk, including the possible loss of principal. Past performance is no guarantee of future results. Reliance on Technology; Cybersecurity: Certain TFA investment activities and investment strategies are dependent upon algorithms, as well as various other computer and telecommunications technologies, many of which are provided by or are dependent upon third parties such as data feed, data center, telecommunications, or utility providers. The successful deployment, implementation, and/or operation of such activities and strategies, and various other critical activities of TFA on behalf of its clients, could be severely compromised by system or component failure, telecommunications failure, power loss, a software-related “system crash,” fire or water damage, human errors in using or accessing relevant systems, unauthorized system access or use (e.g., “hacking”), computer viruses, or various other events or circumstances. It is not possible to provide fool-proof protection against all such events, and no assurance can be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunications systems or operations could have a material adverse effect on TFA’s clients, including preventing Fidelity and/or EAM from trading, modifying, liquidating, and/or monitoring its clients’ investments. In addition, clients should be aware of the risk of attempted cyber-attacks and harm to technology infrastructure and data from misappropriation or corruption. With respect to TFA365, due to TFA’s, Fidelity’s and EAM’s interconnectivity with third party vendors, central agents, exchanges, clearing houses, and other financial institutions, TFA, Fidelity, and EAM could be adversely impacted if any of the companies are subject to a cyber- attack or other information security event. Although TFA, Fidelity, and EAM take proactive measures and endeavor to modify them as circumstances warrant, their computer systems, software, and networks may be vulnerable to unauthorized access, issues, computer viruses or other malicious code, and other events that could have a security impact. Investment Risk: Every mutual fund and ETF is run by a manager who is making decisions on which stocks and bonds to buy and sell. These securities can lose money causing the mutual fund or ETF to lose money. Operation Risk: Every ETF and fund is an investment company that is run by an advisor and a board of directors that is responsible for managing the funds operations and following the laws and regulations relevant to ETFs and mutual funds. The managers of the fund company may commit fraud, malfeasance, or simply make bad decisions that result in higher expenses for the funds investors, mistaken calculations of the ETF’s or fund’s true value, and losses of ETF and fund assets. Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market value to decline, and vice versa. Market Risk: The price of investments in your advisory account may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Economies and financial markets throughout the world are increasingly interconnected. Economic, financial, or political events, trading and tariff arrangements, terrorism, pandemics, technology 16  and data interruptions, natural disasters and other circumstances in one country or region could be highly disruptive to, and have profound impacts on, global economies or markets. During periods of market disruption, the underlying investments exposure to the risks described else wherein this section will likely increase. As a result, whether the underlying investments are in securities of issuers located in or with significant exposure to the countries directly affected, the value and liquidity of the underlying investments may be negatively affected. Also, liquidity of investments, or even an entire market segment, can deteriorate rapidly, particularly during times of market turmoil, and those investments may be difficult or impossible to trade. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar last year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments can be subject to fluctuations in the value of the investment in U.S. dollars, which are due to fluctuations in the currency of the investment’s originating country. Reinvestment Risk: This is the risk that future proceeds from investments may be reinvested at a potentially lower rate of return (i.e., interest rate). Concentration Risk: To the extent a client account concentrates its investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry, or such government could be considerably greater than if they did not concentrate their investments to such an extent. Business Risk: These risks are associated with a particular industry or a particular company within an industry. Financial Risk: Excessive borrowing to finance a business’s operations increases the risk of bankruptcy, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or declining market value. Fixed Income Risk: Portfolios that invest in fixed income securities are subject to several general risks, including interest rate risk, credit risk, and market risk, which could reduce the yield that an investor receives from his or her portfolio. These risks may occur from fluctuations in interest rates, a change in an issuer’s individual situation or industry, or events in the financial markets. Credit Risk: Changes in financial condition of an issuer or counterparty, and changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security’s or instrument’s credit quality or value. Lower quality debt securities and certain types of other securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. Foreign Risk: Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which may be greater in emerging markets. These risks are particularly significant for securities that focus on a single country, region, or emerging markets. Foreign markets may be more volatile than U.S. markets and can perform differently from the 17  U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates may also be extremely volatile. Tax Risk: Securities in the investment strategy may be bought and sold without regard to a client’s individual tax ramifications, and so portfolio turnover could cause the client to incur tax obligations that negatively affect the after-tax return. Tactical Asset Allocation Risk: Tactical asset allocation is an investment strategy that actively adjusts a strategy’s asset allocation. A strategy’s tactical asset management discipline may not work as intended. A strategy may not achieve its objective and may not perform as well as other strategies using other asset management styles, including those based on fundamental analysis (a method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial, and other factors) or strategic asset allocation (a strategy that involves periodically rebalancing the fund in order to maintain a long-term goal for asset allocation). The sub-adviser’s evaluations and assumptions in selecting underlying funds or individual securities may be incorrect in view of actual market conditions and may result in owning securities that underperform other securities. The management process might also result in a strategy’s having exposure to asset classes, countries or regions, or industries or groups of industries that underperform other management styles. In addition, a strategy’s risk profile with respect to particular asset classes, countries and regions, and industries may change at any time based on the sub-adviser’s allocation decisions. Disciplinary Information TFA is both a broker-dealer and a registered investment adviser. In the last ten years, TFA has experienced four disciplinary events that are material to your evaluation of us. Two of the events involve charges brought by the Securities and Exchange Commission (“SEC”). Two of the events involve charges brought by TFA’s self-regulatory organization, Financial Industry Regulatory Authority, Inc. (“FINRA”). SEC Proceedings • On March 11, 2019, the SEC issued an Order Instituting Administrative and Cease-and- Desist Proceedings, pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order (“Order”) relating to TFA’s disclosure of its mutual fund share class selection practices and the 12b-1 fees TFA and its associated persons received. Specifically, the SEC alleged that TFA failed to adequately disclose in its Form ADV or elsewhere the conflicts of interest related to a) its receipt of 12b-1 fees and/or b) its selection of mutual funds share classes that pay such fees. TFA self- reported this matter to the SEC pursuant to the SEC Division of Enforcement’s Share Class Selection Disclosure Initiative. TFA settled this matter with the SEC. TFA agreed to a censure, to pay disgorgement of $5,364,292.04 plus $658,780.64 in interest, and to cease and desist from violating certain securities laws and regulations. The disgorgement and interest were paid to a Distribution Fund (“Fund”) for distribution to investors who purchased or held 12b-1 fee paying share class mutual funds in advisory accounts when a lower-cost share class of the same fund was available to the client. The Order states that these investors are to receive from the Fund the 12b-1 fees attributable to the investor during the relevant period, plus interest, subject to a de minimis 18  threshold. The foregoing is only a summary of the Order. A copy of the Order is available on the SEC’s website at www.sec.gov. • On August 27, 2018, the SEC settled public administrative Cease-and-Desist proceeding naming TFA and certain of its affiliates (“Order”). As to TFA, the Order relates to, among other things, errors in certain models used by TFA in its Transamerica I-Series® and Transamerica® ONE programs. The Order also states that the parties failed to make appropriate disclosures regarding these matters. In addition, the Order states that the parties failed to have adequate policies and procedures. The models at issue in the case were managed by an affiliate, AEGON USA Investment Management, LLC (“AUIM”) and by F-Squared Investments, Inc. (“F-Squared”). The models managed by AUIM were the Global Tactical Allocation – Conservative, Global Tactical Allocation–Balanced, Global Tactical Allocation – Growth, Tactical Fixed Income, Global Tactical Income and Global Tactical Rotation models. The models managed by F-Squared were the AlphaSector Rotation Index, AlphaSector Premium Index and World Allocator Premium Index. These strategies are no longer offered by TFA and neither AUIM nor F-Squared currently provide model management services to TFA. The strategies developed by AUIM and F-Squared were offered by TFA in the Transamerica I-Series® and Transamerica® ONE programs between 2011 and 2015. TFA settled this matter with the SEC. TFA agreed to a censure, to pay a penalty of $800,000, to pay disgorgement of $1.7 million plus $258,162 in pre-judgment interest, and to cease and desist from violating certain securities laws and regulations. The disgorgement, interest and penalties have been paid to a Fair Fund (“Fund”) for eventual distribution to affected investors who purchased or held an interest in the AUIM and F-Squared strategies in the Transamerica I- Series® and Transamerica® ONE programs from July 2011 through June 2015. The Order states that these investors are to receive from the Fund an amount related to the pro rata fees and commissions paid by them during that period, plus interest, subject to a de minimis threshold. In accepting the settlement, the SEC considered the substantial cooperation and the remedial efforts of TFA and its named affiliates. In the Order, the SEC acknowledged that, after the start of the SEC staff’s investigation but before the settlement, TFA and the named affiliates had voluntarily retained a compliance consultant to conduct a comprehensive independent review of certain compliance policies and procedures, internal controls and related procedures, and that the consultant’s written findings had been received and proposed changes implemented. The SEC also acknowledged that, in advance of receiving recommendations from the independent compliance consultant, TFA and its affiliates had already begun making revisions and improvements to their compliance policies and procedures. The SEC also considered that TFA and its affiliates retained the independent compliance consultant for further reviews. The settlement does not impose any restrictions on the business of TFA. The foregoing is only a summary of the Order. A copy of the Order is available on the SEC’s website at www.sec.gov. FINRA Proceedings • On December 21, 2020, TFA and FINRA entered into a Letter of Acceptance, Waiver and Consent in which TFA agreed to settle alleged FINRA rule violations. TFA consented to the sanctions and to 19  the entry of findings that it failed to reasonably supervise its representatives’ recommendations of three different products – variable annuities, mutual funds and 529 Plans. TFA was censured, fined $4,400,000 and required to pay $4,354,160 in restitution to customers. A copy of this Order is available on FINRA’s website at www.finra.org/rules- guidance/oversight- enforcement/finra-disciplinary-actions-online. • On July 27, 2015, TFA and FINRA entered into a Letter of Acceptance, Waiver, and Consent in which TFA agreed to settle alleged FINRA rule violations. TFA agreed to a censure and fine of $85,000 and paid restitution to impacted clients in the amount of $51,066.08 (plus interest). This matter pertained to TFA failing to identify and apply volume discounts to certain clients’ eligible purchases of non-traded real estate investment trusts (REITs) and business development companies (BDCs), resulting in customers paying excessive sales charges of approximately $51,000. TFA also failed to establish, maintain, and enforce a supervisory system and written supervisory procedures with respect to the sale of non-traded REITs and BDCs. Other Financial Industry Activities and Affiliations TFA is also a broker-dealer. In general, TFA’s Advisors, management team, and most of TFA’s Investment Committee members are registered representatives of TFA’s broker- dealer. The majority of TFA’s Advisors are also affiliated with World Financial Group Insurance Agency, LLC, an insurance agency that is affiliated with TFA. TFA is a member of the Transamerica Group of companies. These companies include investment companies that offer mutual funds and fixed and variable insurance products. Many of these products can be purchased by the various TPMMs or Portfolio Managers available in TFA’s advisory programs. Based on TFA’s affiliation with various investment companies and insurance companies, a conflict of interest exists due to the compensation paid to TFA by these companies and compensation gained by our affiliates through fees and expenses charged to you on their products. This compensation is in addition to the advisory fees you pay to TFA. TFA mitigates these conflicts by monitoring the appropriateness of the recommendations made to you by TFA’s Advisors with regard to all advisory services they offer you and, on all products, you purchase including those products issued by TFA’s affiliates. TFA has contracts with third-party money managers and portfolio managers (collectively referred to as “Managers”) who are also investment advisors that offer fee-based advisory programs. These Managers may or may not be affiliated with TFA. If the Manger is affiliated this may result in a conflict of interest. TFA mitigates this conflict by monitoring the appropriateness of the recommendations made to you by TFA Advisors on all advisory services you purchase including any affiliated money manager. Broker-Dealers under Common Control with AEGON N.V. The following FINRA registered broker-dealers are under common control with TFA. TFA and each of these other broker-dealers are indirect, wholly owned subsidiaries of AEGON N.V. Transamerica Investors Securities Corporation Transamerica Capital, LLC • • 20  Transamerica Capital, LLC (“TCL”) is the principal underwriter for variable annuity and life insurance products offered by TFA’s affiliated insurance companies. TFA has a selling agreement with this broker- dealer under which TFA is compensated for selling these products. TCL is also a wholesale distributor of Transamerica products. Such compensation creates a conflict of interest for TFA, its registered representatives, and its Advisors. TFA mitigates this conflict by monitoring the appropriateness of the recommendations made to you by TFA registered representatives and Advisors on all products and advisory services you purchase including those products issued by our affiliates. Investment Companies under Common Control with AEGON N.V. TFA has an agreement to sell mutual funds of one of our related investment companies, Transamerica Funds. TFA offers insurance products through affiliated insurance companies which contain shares of the Transamerica Series Trust and/or Transamerica Partners Funds, both of which are affiliated investment companies. TFA receives compensation from these sales. Such compensation creates a conflict of interest for TFA, its registered representatives and its Advisors. TFA mitigates this conflict by monitoring the appropriateness of the recommendations made to you by TFA registered representatives and Advisors. Registered Investment Advisers under Common Control with AEGON N.V. The following SEC Registered Investment Advisers are under common control with TFA. TFA and each of these advisory firms are indirect, wholly owned subsidiaries of AEGON N.V. Transamerica Asset Management, Inc. (“TAM”) AEGON USA Investment Management, LLC (“AUIM”) Transamerica Retirement Advisors, Inc. (“TRA”) • • • Insurance Companies or Agencies under Common Control with AEGON N.V. TFA has material relationships or arrangements with a select group of product sponsors (“Sponsoring Companies”), some of which are affiliated insurance companies/agencies. In certain cases, some of TFA’s officers may be affiliated with our affiliated insurance companies/agencies. In its capacity as a broker-dealer, TFA receives additional compensation in the form of revenue sharing payments when you purchase products through these insurance companies/agencies. A summary of TFA’s revenue sharing arrangements and current Sponsoring Company compensation arrangements can be found at the home page of TFA’s website at www.tfaconnect.com under Disclosures - Revenue Sharing Arrangements and Payments by Sponsoring Companies Client Disclosure Statement. These revenue sharing payments create a conflict of interest for TFA, its registered representatives and its Advisors. Your Advisor does not receive any portion of the revenue sharing. All revenue sharing compensation is paid directly to TFA. TFA mitigates this conflict by monitoring the appropriateness of the recommendations made to you by Advisors and registered representatives on all services and products you purchase including those services and products offered and issued by our affiliates. The following is a list of TFA’s affiliated insurance companies/agencies with which TFA conducts business: Transamerica Premier Life Insurance Company InterSecurities Insurance Agency, Inc. Transamerica Life Insurance Company • • • 21  • • Transamerica Financial Life Insurance Company World Financial Group Insurance Agency, Inc. (d/b/a World Financial Insurance Agency, Inc. in California) World Financial Group Insurance Agency of Hawaii, Inc. World Financial Group Insurance Agency of Massachusetts, Inc. WFG Insurance Agency of Puerto Rico, Inc. • • • Your Advisor may also be an insurance agent and be able to offer you insurance products through his or her affiliation with one or more of these agencies. When you purchase insurance products through our Affiliated Agencies, the Affiliated Agencies will receive commission compensation. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading TFA has adopted a Code of Ethics and an Insider Trading Policy (together “Code”). This Code is designed to ensure that TFA meets its fiduciary obligation to you and our prospective clients, that TFA conducts its advisory services with the highest level of ethical standards, and that TFA instills a culture of compliance within our firm. Our Code is comprehensive and is distributed to each home office employee and Advisor (collectively “Access Persons”) at the time of hire and acknowledged annually thereafter. TFA also supplements the Code with annual training and ongoing monitoring of the activity of Access Persons. TFA’s Code includes the following requirements for TFA Access Persons: • • Maintain the principles of honesty, integrity, and professionalism and comply with federal and state securities laws; Follow all policies and procedures contained in our manuals, bulletins, and supervisory directives and cooperate with any investigation or inquiries; Maintain the privacy and confidentiality of information provided by our clients; Refrain from: • • insider trading o o accepting gifts and entertainment that exceed our policy standards o participating in any initial public offerings o executing a personal transaction in a security for which the Access Person already has a pending buy or sell order for a client. Report all gifts and business entertainment; Pre-clear personal securities transactions; Report all personal securities transactions; and Annually review and certify compliance with our Code. • • • • TFA has also established the following guidelines for TFA Access Persons: • Our directors, officers and employees are not allowed to buy or sell securities for their personal portfolio(s) unless the information is also available to the investing public. Access Persons are not to place their own interests above yours. • 22  • Any Access Person not complying with these guidelines may be subject to disciplinary action including termination. You may request a complete copy of our Code by contacting TFA at the address or telephone number displayed on the cover page of this Disclosure Brochure. Review of Accounts TFA’s supervisory structure includes Regional Branch Managers (“RBMs”) located in various field offices and the Home Office Supervision Department. Field RBMs are responsible for general day-to-day supervision of all Advisors assigned to their branch office. Home Office supervisory personnel supervise the offering of advisory programs by Advisors and sale of securities products by TFA’s registered representatives. The appropriate supervisor conducts reviews of client account for conformity with company policy and procedures. You should review your account(s) with your Advisor at least one time each year. Your Advisor will undertake reasonable efforts to contact you to discuss your current financial situation and investment objectives to determine whether the account continues to meet your investment objectives and is still suitable. You and your Advisor can access account statements, and trade confirmations from the Fidelity website. If you wish to receive paper statements, you can request those documents for an additional fee. TFA urges you to carefully review these account statements, and trade confirmations. The information in your TFA365 performance reports may vary from your custodial statements due to accounting procedures, reporting dates, or valuation methodologies of certain securities. In the event of any discrepancies, you should rely on the statements you receive from NFS. From time-to-time investors in TFA advisory programs may receive Albridge Personalized Account Statements directly from their advisors. These statements may include lists of your account holdings, including, mutual funds and securities, but are not official account statements. We urge you to compare these reports to the official account statements of your account holdings provided to you at least quarterly by NFS to ensure that the mutual fund and securities holdings listed on these reports provided by your Advisor match the mutual fund and securities holdings reflected on the official account statements. Client Referrals and Other Compensation In certain cases, third-party money managers (“TPMMs”), Portfolio Managers, and other service providers may pay TFA marketing compensation. The amount and terms of this marketing compensation may increase or decrease from time to time. Any additional marketing compensation paid by the TPMMs, Portfolio Managers or other service providers to TFA will not affect your account, the services provided to you, the fee for advisory services or other service provider, or the compensation paid by TFA to your Advisor. The existence of a marketing compensation agreement with TPMMs, Portfolio Managers or other service providers creates a conflict of interest for your Advisor and TFA. TFA will earn more revenue due to such marketing compensation agreements, and although the marketing compensation is not shared with your Advisor, your Advisor may indirectly benefit from this additional revenue through different educational and marketing initiatives conducted by TFA to promote these services. All marketing compensation is paid directly to TFA. 23  Each of the TPMMs, Portfolio Managers, or other service providers that have marketing arrangements with TFA may attend, contribute to, or sponsor education and training meetings for our Advisors. A TPMM, Portfolio Manager, or other service provider may reimburse TFA for up to 100% of the cost of these meetings. These contributions and reimbursements create a conflict of interest because meeting sponsors have more opportunities to provide Advisors with education on their investments, their investment management services, industry trends, and other issues; and because TFA benefits from these contributions and reimbursements. Advisors, if they are licensed with World Financial Group Insurance Agency, LLC, are permitted to participate in award and incentive programs sponsored by the same in which they could receive trips, promotions or non-cash compensation based on their insurance sales as insurance agents. These events may influence their decision to recommend a particular insurance product to you in their capacity as an insurance agent for consideration. Additional information regarding conflicts of interest can be found in TFA’s Client Relationship Summary and at www.tfaconnect.com/disclosures. A copy of these disclosures can also be requested by calling TFA at (770) 248-3271. Voting Client Securities (Proxy Voting) When you open a TFA365 account, you are responsible for directing the manner in which proxies for the securities held in your account are voted. TFA and its Advisors do not vote proxies on behalf of our clients. Through Fidelity, you can elect to either directly perform proxy voting or delegate proxy voting, as applicable, to either the Implementation Manager or the discretionary Portfolio Manager to whom you have allocated your assets. If delegated by the you, the Implementation Manager or discretionary Portfolio Manager, as applicable, shall be responsible for voting or abstaining from voting with respect to any proxy solicitations for any securities purchased on your behalf. You should review the proxy voting policies and procedures as described in the FIWA Form ADV Part 2A titled Fidelity Managed Account Xchange® and the discretionary Portfolio Manager’s Form ADV Part 2A as applicable. Financial Information To the best of TFA’s knowledge, we are not aware of any financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. TFA has not been the subject of a bankruptcy petition at any time, including any time during the past ten years. 24 

ITEM 1 – COVER PAGE TRANSAMERICA FINANCIAL ADVISORS, LLC Form ADV Part 2A October 6, 2025 Two Liberty Place 50 South 16th Street Suite 3700 Philadelphia, PA 19102 (770) 248-3271 WWW.TFACONNECT.COM Transamerica Financial Advisors, LLC Mailing Center 6400 C Street SW Cedar Rapids, IA 52499 This Form ADV Part 2A (“Brochure”) provides information about the qualifications and business practices of Transamerica Financial Advisors, LLC (“TFA”). If you have any questions about the contents of this brochure, please contact us at (770) 248-3271. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about TFA is also available at the SEC’s website: www.adviserinfo.sec.gov (select “Firm” and type Transamerica Financial Advisors, LLC). TFA is a federally registered investment adviser with the SEC. Registration with the SEC does not imply a certain level of skill or training.  ITEM 2 – MATERIAL CHANGES TFA has made the following changes to this brochure since the last update on March 28, 2025: • TFA has disclosed a securities-backed lending arrangement available under its TFA365 Advisory Program. When we update the Disclosure Brochure with material changes, we will either send you a copy or offer to send you a copy (either by electronic means (email) or in hard copy form) within the required timeframe. If you would like a copy of this Disclosure Brochure, you may download it from the SEC’s public disclosure website (IAPD) at www.adviserinfo.sec.gov, download it at www.tfaconnect.com, or contact us at (770) 248-3271. 2  ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE ........................................................................................................................ 1 ITEM 2 – MATERIAL CHANGES ........................................................................................................... 2 ITEM 3 – TABLE OF CONTENTS ......................................................................................................... 3 ITEM 4 – ADVISORY BUSINESS .......................................................................................................... 4 ITEM 5 – FEES AND COMPENSATION ................................................................................................ 8 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................... 17 ITEM 7 – TYPES OF CLIENTS ............................................................................................................ 17 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ..................... 17 ITEM 9 – DISCIPLINARY INFORMATION ............................................................................................ 23 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVTIES AND AFFILIATIONS ...................................... 25 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ....................................................................................................... 27 ITEM 12 – BROKERAGE PRACTICES ................................................................................................ 27 ITEM 13 – REVIEW OF ACCOUNTS .................................................................................................. 29 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ..................................................... 30 ITEM 15 – CUSTODY .......................................................................................................................... 31 ITEM 16 – INVESTMENT DISCRETION.............................................................................................. 31 ITEM 17 – VOTING CLIENT SECURITIES (PROXY VOTING) ............................................................ 32 ITEM 18 – FINANCIAL INFORMATION ............................................................................................... 32 3  ITEM 4 – ADVISORY BUSINESS The Company Transamerica Financial Advisors, LLC (“we/our/us/TFA”) is a federally registered investment advisor registered with the SEC since 1991. TFA is also a broker-dealer and has been a member of the Financial Industry Regulatory Authority (FINRA) since 1984 and member of the Municipal Securities Rulemaking Board (MSRB). TFA offers investment related products, variable insurance products, employer retirement solutions, and advisory and asset management services to the retail public. TFA also acts in the capacity of a broker-dealer and some of TFA’s investment advisor representatives (“Advisors”) act in the capacity of registered representatives of the broker-dealer. When TFA is acting as a broker-dealer neither TFA nor its Advisors are acting as fiduciaries under the law, but each has a responsibility to deal fairly with all clients. TFA is directly owned by AUSA Holding, LLC, which is an indirect, wholly owned subsidiary of the ultimate parent, AEGON N.V., a publicly traded company listed on the New York Stock Exchange (NYSE) and trading under the symbol AEG. Advisory Services Offered In its capacity as a federally registered investment advisor, TFA offers access to third-party money managers who manage model portfolios on behalf of clients, referrals to third-party providers that offer certain administrative services relating to employee benefit plans, access to wrap fee programs that offer clients access to fee-based investment management, access to a suite of risk-based allocations to strategies and access to a digital advice program under which clients receive investment portfolio recommendations and investment management of the assets held in their accounts. TFA’s advisory services are made available to clients through individuals registered with TFA as investment advisor representatives. At the time TFA offers you advisory services, our Advisors with the assistance of firm tools and online resources, conduct an interview with you and collect financial information to determine your financial needs, time horizon, and objectives. The Advisor will analyze your current financial situation, investment goals, time horizon, risk tolerance, and present investment strategies, if any. The Advisor will then provide you investment recommendations based on the analysis. TFA Advisors do not provide legal, tax or accounting advice. Our Advisors may offer you one or more of the following advisory services: TFA365 Advisory Program The TFA365 Advisory Program (“TFA365”) is a wrap fee program that offers clients access to a fee- based investment management program. TFA365 is available to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. TFA has entered into an agreement with Fidelity Institutional Wealth Adviser LLC (“FIWA”), whereby TFA will administer and sponsor TFA365 Advisory Program using the Fidelity Managed Account Xchange℠ managed account platform (the “FMAX Platform” or “FMAX”). 4  Within TFA365, you may invest in: (1) the Fund Strategist Portfolio Program (“FSP”), which provides access to asset-allocated portfolios which invest in mutual funds, Exchange-Traded Funds (“ETFs”), and other products; (2) the Separately Managed Account Program (“SMA”), which provides access to portfolios of individual equities, fixed income, mutual funds and ETFs; and (3) the Unified Managed Account Program (“UMA”), which allows you to invest in FSPs, SMAs, individually selected mutual funds, and ETFs within one account. Within each TFA365 Advisory Program model portfolio, the client owns the underlying securities in his or her account. Please refer to the current FIWA Form ADV Part 2A titled Fidelity Managed Account Xchange® for additional details. NFS is the broker-dealer and the custodian for the TFA365 Advisory Program accounts. For clients of the TFA365 Advisory Program, TFA has a revenue sharing arrangement with a third-party lender (“Lending Sponsor”) that allows clients to use certain brokerage and advisory accounts as collateral to obtain secured loans. This arrangement allows clients to borrow against the value of their investment account for purposes other than the purchase of additional securities. This type of lending can provide quicker access to funds without selling securities. However, if the value of the securities in the investment account declines, clients may be required to provide additional collateral, or the lender may force the sale of the securities in the account to repay the loan. The Lending Sponsor compensates TFA for making the respective loan program available on TFA’s platform and covers various administrative costs associated with servicing the loan and regulatory reporting. Compensation can be up to 25 basis points of the outstanding loan amount. This arrangement presents a conflict of interest, as TFA has a financial incentive to promote loans from its Lending Sponsor over other lenders who do not provide TFA compensation. Although TFA does not share this compensation with its Financial Professionals (“FPs”), and your FP does not have a direct financial incentive to recommend the sponsor over other lenders, both TFA and its FPs may still be incentivized to recommend borrowing over asset liquidation. This is because maintaining account assets allows TFA and your FP to continue earning brokerage commissions and 12b-1 fees or advisory fees. Additional information about the TFA365 Advisory Program can be found in the TFA365 Advisory Program Brochure (Form ADV Part 2A Appendix 1). Transamerica® ONE Wealth Management Platform The Transamerica® ONE Wealth Management Platform (“Transamerica® ONE”) is a wrap fee program that offers clients access to a fee-based investment management program. “Wrap- fee” means that you will pay a single fee for the services provided by the program, as opposed to purchasing and paying for the services separately. There are, however, other fees associated with the accounts you hold, which could include, but are not limited to paper statements fees, IRA fees, low balance fees, and opening and closing account fees, which you will pay for outside of the wrap-fee. Transamerica® ONE is available to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. TFA has entered into an agreement with Goldman Sachs Group, Inc. ("Goldman Sachs"), whereby TFA will administer and sponsor Transamerica® ONE using Goldman Sachs Advisor Solutions’ internet- based platform. Additionally, the Transamerica I-Series® model portfolios are available within Transamerica® ONE. TFA is the Model Manager for the Transamerica I-Series® portfolios. Transamerica I- Series® model 5  portfolios use strategic, tactical, and alternative asset allocation models in accordance with particular investment objectives and risk targets. In addition to using our proprietary investment model portfolios within the Transamerica® ONE Program, TFA has retained independent firms to create model portfolios (“Third-Party Model Portfolios”). These independent asset managers are referred to as “Model Managers.” TFA may, from time to time, replace existing Model Managers or hire others to create Third- Party Model Portfolios. The Model Managers are responsible for all investment selections for the model portfolios that they manage. From time to time, Model Managers will update their model portfolios. TFA monitors the performance of the investments in the Third-Party model portfolios on an ongoing basis. Within Transamerica® ONE, you may select from multiple model portfolios, allowing you to pursue different investment strategies within a single account. Depending upon the model portfolios selected, the underlying assets can consist of, but are not necessarily limited to, individual stocks and bonds, mutual funds, and ETFs (collectively “Investment Products”). Within each Transamerica® ONE model portfolio, the client owns the underlying securities in his or her account. TFA also offers Transamerica® Strategy Solutions which are a suite of risk-based allocations to strategies on the Transamerica® One platform. There are five allocations, one for each of the five risk categories. Transamerica® Strategy Solutions are intended for clients whose primary focus is achieving a level of risk in the overall portfolio that matches the client’s risk tolerance. Goldman Sachs Custody Solutions is the broker-dealer and the primary custodian for your accounts. Goldman Sachs is the custodian for IRA accounts. Additional information about Transamerica® ONE and Transamerica® Strategy Solutions can be found in the Transamerica® ONE Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1). Transamerica® ALPHA Digital Investment Program TFA has entered into an agreement with Betterment, LLC. ("Betterment"), whereby TFA will sponsor Transamerica® ALPHA using Betterment’s internet-based platform. Betterment serves as a sub-advisor for the program. TFA’s Advisor will assist you in determining if the Transamerica® ALPHA Program is suitable for your initial and ongoing stated investment objectives and time horizon. Betterment provides an internet-based platform through which Betterment provides discretionary managed account services as the program’s sub-advisor. Model portfolios are developed and overseen by Betterment, Vanguard, or TFA. Betterment uses a strategic asset allocation method for investing assets and uses ETFs as the underlying investments for client assets. Betterment Securities, an affiliate of Betterment, is the broker- dealer and Apex Clearing Corporation is the clearing broker for the Transamerica® ALPHA Program. Millennium Trust Company serves as the custodian for Betterment IRA accounts. TFA and your Advisor will not have, nor exercise, discretionary authority over your account in the Transamerica® ALPHA Program. Additional information about Transamerica® ALPHA can be found in the Transamerica® ALPHA Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1). Clients and prospective clients will receive, and should review, a copy of Betterment’s Form ADV Part 2A (“Betterment Disclosure Brochure”) which contains additional information regarding Betterment’s services, processes, and policies. 6  Clients and prospective clients should understand that the Transamerica® ALPHA program is a digital offering and that the primary method of communicating with clients and providing clients investment advice will be through the Transamerica® ALPHA website, mobile applications, or other digital interfaces that may become available in the future. Third-Party Money Management Programs Our Advisors have access to third-party money managers (“TPMMs”) that focus on providing managed model portfolios to clients. Depending on the TPMM selected, the TPMM will typically utilize either exchange traded products (“ETPs”) or mutual funds within their investment strategies. In some cases, TPMMs may include equity securities, municipal securities, US government securities, and/or other securities products within their investment strategies (please refer to the specific TPMM’s Form ADV Part 2A or other disclosure document for a complete listing of the types of investments it may use in a client’s model portfolio). Within each Third-Party Money Management Program, the TPMM selected will have discretionary authority over your account to conduct the necessary trading activity. If you own a no-load/non-commissionable Variable Annuity (“Advisory VA”) policy our Advisors may offer you advisory services on the subaccount allocations in your Advisory VA. These services are offered by TPMMs recommended by your Advisor and are designed to provide you with ongoing investment management services on the subaccount allocations within your Advisory VA. Employee Retirement Services/Transamerica Retirement Plan Exchange For retirement plan services, TFA Advisors may refer clients to the Transamerica Retirement Plan Exchange (“the Exchange”), administered by TAG Resources (“TAG”), a third-party administrator. The Exchange allows for small and mid-sized businesses to provide a retirement plan to employees without having to take on many of the administrative and fiduciary responsibilities. TAG will choose an investment firm to select and monitor the plan’s investment lineup and to assume ERISA 3(38) fiduciary responsibilities. Businesses offering a retirement plan through the Exchange become a participating employer. their Transamerica Retirement Solutions (“TRS”) serves as the record keeper for this business, handling benefit payments and enrollments and providing support up to and through the plan participant’s transition to retirement. TRS allows plan sponsors and their plan participants to monitor and better manage investment performance reports, quarterly participant investment choices with statements, and a participant website at TA-Retirement.com. The retirement plan services will be described in detail in the retirement plan provider’s agreement, or other appropriate disclosure brochure. Client should refer to such documents for a complete discussion of the services offered, including a description of all fees and expenses associated with the program. Third Party Referral Services TFA has entered into referral arrangements with various third-party investment advisers that participate in, manage, or sponsor different types of money management services and investment advisory programs. These referral arrangements are structured in accordance with the marketing rule 206(4)-1 under the Advisers Act which requires that we disclose to you the compensation we receive for referring you to a third-party adviser, whether your Advisor is a client of the third-party manager and any other conflicts that may exist between your Advisor and the third-party manager. Where we act solely as a referrer, you will not enter into an agreement directly with us. In such an arrangement, you will establish a direct relationship with the third-party investment adviser, and we will receive a referral 7  fee from the adviser based on a percentage of the advisory fee they charge you. This compensation creates a conflict of interest and serves as an incentive for your Advisor to recommend the services of third-party investment advisers with which we maintain these referral relationships. The referral disclosure you receive when you establish an account with the third-party adviser will specify the total fee you will pay and what portion of that fee is payable to TFA. The amount of the fee varies by the referral arrangement with a maximum fee of 2.75%. You should read the third-party adviser’s brochure, and any compensation disclosure statements provided. Third-Party Unaffiliated Investment Advisors TFA acts as a sub-advisor to an unaffiliated registered investment advisory firm and has entered into an arrangement as an approved money manager on an advisory platform or program sponsored by an unaffiliated investment advisor. TFA manages models or portfolios by allocating assets among various mutual funds or exchange traded funds (together “funds”) on a discretionary basis using one or more of its proprietary investment strategies (collectively referred to as “investment strategy”) for clients of an unaffiliated investment advisor. In doing so, TFA may cause the unaffiliated investment advisors’ platform to buy, sell, exchange and/or transfer shares of funds based upon the investment strategy. TFA receives compensation for providing model management or other advisory services to unaffiliated investment advisors. This compensation is generally an asset-based fee charged on assets invested in managed portfolios and is ultimately part of the fees clients of the unaffiliated investment advisors pay. These money manager fees may be more or less expensive than other available options to these clients. Since TFA relies on the Investment Advisor Representative to choose portfolios for their clients, TFA will earn compensation on assets invested in these portfolios without any direct relationship with clients. Types of Investments Within each of the advisory services described above, specific securities to be used are determined by the selected TPMM, Portfolio Manager, or Model Manager. restrictions, and the TFA Advisors provide assistance to their clients by explaining the investment management process, investment objectives, any applicable securities investment strategies undertaken as part of the service; in reviewing and completing the written or electronic materials required by each program; annually reviewing the client's ongoing needs and financial situation; and in answering questions about the service. Assets Under Management (AUM) Regulatory AUM of $1.7 billion as of December 31, 2024. ITEM 5 – FEES AND COMPENSATION TFA and your Advisor are compensated in several ways. We want to be sure you understand how TFA and your Advisor are compensated, as well as other costs associated with your account. Below are important details about the fees and costs associated with your account. The fees and costs charged differ among our programs. You will find details for each program below. You should carefully examine your advisory service agreement for the advisory program you select. It provides greater detail with respect to the fees and costs that you will pay for the program you have selected. 8  Program Fees Deducted from Your Account Other Expenses Charged to Your Account1 Total Annual Program Fees Advisor Portion of the Total Fee is Negotiable between You & Your Advisor Annual Advisory Fee Account Aggregation Discount Offered Yes Dependent on the TPMM program selected. Not to exceed 2.75% TPMM Programs (non-Variable Product)2 Specific to the TPMM (Please refer to their Form ADV Part 2A). Specific to the TPMM (Please refer to their Form ADV Part 2A). Yes Not to exceed 1.20%3 TPMM Programs (Variable Product)2 Specific to the TPMM (Please refer to their Form ADV Part 2A). Specific to the TPMM (Please refer to their Form ADV Part 2A). Dependent on the TPMM program selected and variable product expenses as described in your product prospectus.3 Yes Yes Monthly in arrears. Not to exceed 2.0% Transamerica® ONE Wealth Management Platform Please refer to Transamerica® ONE Wrap Fee Brochure for additional fee information. Yes Employee Retirement Services Not to exceed 1.10%4 Specific to selected platform. Please refer to the provider’s fee disclosure document. Specific to Employee Retirement Services provider. Specific to selected platform. Please refer to the provider’s fee disclosure document. Yes Yes Monthly in arrears. 0.65% - 0.95%5 Transamerica® ALPHA Program Please refer to Transamerica® ALPHA Wrap Fee Brochure for additional fee information. Yes Yes Monthly in advance. Not to exceed 2.75%6 TFA365 Advisory Program Wealth Series Platform Please refer to TFA365 Advisory Program Brochure for additional fee information. 9  1 Client may also incur certain charges imposed by third parties other than TFA and Advisor in connection with investments made through Client’s account, including, without limitation, the following types of charges which are generally charged by mutual funds and fully disclosed in the prospectus for each fund: 12(b)-1 fees, management fees and administrative servicing fees, other transaction charges and service fees, and IRA and Qualified Retirement Plan fees. These costs and fees are in addition to the Total Program Fee Client will pay to participant in the Programs noted above. Some mutual fund share classes that are available on the platforms charge a distribution fee pursuant to Rule 12(b)-1 under the Investment Company Act of 1940, also known as trails. You should carefully review the mutual fund prospectuses associated with recommendations made by your Financial Professional prior to investing. The Model Managers on the Transamerica® ONE Wealth Management Platform maintain a practice of purchasing the lowest cost mutual fund share class made available through our custodian, Goldman Sachs Custody Solutions and do not allow for any funds that have a 12(b)-1 fee. For accounts held at a TPMM, the lowest cost mutual fund share class made available will be purchased. In certain instances, the share classes purchased by the TPMM will pay 12(b)-1fees. TFA does not receive any portion of these fees. Rather, the fees are either received by the TPMM and subsequently rebated to the customer or are retained by the custodian. For accounts held at TFA365 Advisory Program, the lowest cost mutual fund share class made available will be purchased. In certain instances, the share classes purchased by a model manager will pay a 12 (b)-1 fee. TFA does not receive any portion of these fees. Rather, the fees are rebated to the customer by the custodian. For self-directed brokerage accounts managed by The Pacific Financial Group (“TPFG”) and TFA, you are not charged an advisory fee. Instead, TPFG’s affiliate, Pacific Financial Group, LLC (“PFG”), receives an advisory fee from the PFG Mutual Funds for providing investment advice to the Funds. In addition, for services provided by TFA and the Advisor, TFA receives a fee paid by TPFG from the profits earned by TPFG and PFG. A portion of these fees is paid by TFA to the Advisor. PFG Mutual Funds only have one share class available, therefore, you will invest in that share class. For accounts on the Retirement Plan Exchange, Transamerica Retirement Solutions (TRS), an affiliate of TFA, will not always purchase the lowest cost mutual fund share class available. TRS does receive 12b-1 fees in connection with these services. TFA does not receive any portion of these 12b-1 fees from TRS. 2 TFA’s Advisors do not establish the fee charged by the TPMM. TFA’s Advisors also do not establish the termination procedures for the TPMM. Clients pay advisory fees directly to the TPMM and the TPMM in turn compensates TFA. TFA pays a portion of this fee to its Advisors. TFA does not mark up the fees charged by the TPMM. TPMMs will typically require that Clients authorize automatic fee deduction from their advisory account. In many cases, the TPMM will also charge fees on cash positions held within client accounts. Clients should refer to the TPMM’s Form ADV Part 2A or other Disclosure Brochure for a complete discussion of the fees and termination procedures associated with the advisory program in which they choose to participate. All fees paid by a client to a TPMM for model portfolio management services are separate and distinct from the fees and expenses which may be charged by investment companies such as mutual fund and exchange traded product fees and expenses. Such fees and expenses will generally include, but are not limited to, a management fee, other fund operating expenses, distribution fees, and/or administrative fees. Participation in TPMM advisory services offered through TFA may cost you more than purchasing similar services directly from a TPMM. However, certain TPMM services may not be offered directly to clients and may only be available through an introducing registered investment adviser such as TFA. 10  Your TFA Advisor’s portion of your total fee will be in addition to the TPMM’s fee which can be found in the TPMM’s Form ADV Part 2A or other Disclosure Brochure. Your total fee may be charged monthly or quarterly in arrears or in advance depending on the TPMM. Also, other fees such as plan establishment fees, plan conversion fees, and plan administration and compliance fees may be applicable, and will be disclosed in the account establishment documentation. 3 The Annual Advisory Fee does not represent those fees and expenses charged by the variable product issuer such as Mortality and Expense, Administrative Charges, and Product Rider or Enhancement Charges, or Variable Subaccount Operating Expenses. For a more complete description of these fees and expenses, please refer to your variable product account establishment paperwork and prospectus(es). TFA Advisors may only provide advisory services for subaccount allocations on no-load/non- commissionable variable annuities, otherwise known as an “Advisory VA.” These services are offered by TPMMs recommended by your Advisor and are designed to provide you with ongoing investment management services on the subaccount allocations within your Advisory VA. Within each Third-Party Money Management Program, the TPMM selected will have discretionary authority over your account to conduct the necessary trading activity. 4 For retirement plans, the Advisor’s fee range will be between 0.05% and 1.10% annually. This fee can be negotiated with your TFA Advisor. 5 The Total Annual Advisory Fee charged may be higher than the fees charged by other investment advisors for similar services. For instance, Betterment, LLC offers direct-to- consumer services similar to Transamerica® ALPHA. Therefore, clients would pay a lower advisory fee for algorithm-driven, automated (“Digital Advisor”) investment advisory services by going direct to Betterment, LLC or other similar Digital Advisors. TFA reserves the right to waive or lower the fee in certain cases. 6 Fees are expressed as an annual percentage of assets under management. The Total Program Fee to the client is dependent on the model portfolio(s) selected and the advisor fee negotiated. Client may also incur certain charges imposed by third parties other than by TFA and TFA’s Advisor in connection with investments made through Client’s Account. For more details related to these charges, please refer to the TFA365 Advisory Program Brochure (Form ADV Part 2A Appendix 1) under Fees and Compensation. For TFA365 Advisory Program accounts that fall below the applicable Program account minimum, a minimum annual account fee will apply to the total client fee or fees charged by the custodian. Minimum account fees are expressed in annual amounts but are determined and assessed based on the account asset value at the end of each month. For example, if an account has a $150 minimum annual account Program Fee, it will be assessed a minimum of $12.50 every month based on the average daily balance of the account during the previous calendar month. Therefore, if a client has large asset inflows or outflows during the year that cross the minimum asset value threshold, it is possible for an account to be assessed a minimum fee for a particular month even if at the end of the year a look back over the account’s average balance for the entire year would have placed it above the minimum asset value threshold. The TFA365 Advisory Program account minimums and minimum annual account fees are specified below: TFA365 Advisory Program Strategist Program (Account Minimum: $25,000): $35 Minimum Annual Account Fee TFA365 Advisory Program Separately Managed Account Program (Account Minimum: $100,000): $150 Minimum Annual Account Fee TFA365 Advisory Program 365 Unified Managed Account Program (Account Minimum: $25,000): $35 Minimum Annual Account Fee 11  Additional Information about Third-Party Money Management Programs Depending on your account balance and/or model portfolios selected within the Third-Party Money Management programs available through TFA, the same or similar investment management strategies or model portfolios may be available within Transamerica® ONE or TFA365 at different pricing levels which may be more or less expensive to you. The TPMMs may use other custodians such as, but not limited to, Schwab, Pershing, or Fidelity. These custodians will deduct the advisory fee directly from your account or, if you have more than one account, from the account you have designated for payment of your advisory fees. Please refer to your account establishment paperwork, custodial account paperwork, and/or TPMM’s Form ADV Part 2A or similar Disclosure Brochure for additional details on fees and expenses. You will receive periodic financial statements (or notification that your financial statements are available to view online) directly from your account custodian. These statements will show all transactions, positions, and credits/debits (deposits/withdrawals) in your account. These statements will reflect deductions for advisory fees paid by you. Transamerica® ONE Wealth Management Platform For detailed information on fees and billing, please see the TransOne appendix. Depending on your account balance and/or model portfolios selected within Transamerica® ONE or TFA365, the same investment management strategies or model portfolios may be available within the Third-Party Money Management programs available through TFA at different pricing levels which may be more or less expensive to you. Transamerica® ALPHA Wrap Fee Program For detailed information on fees and billing, please see the TransAlpha appendix. TFA will pay the TFA Advisor a portion of its fee according to a compensation grid that may change from time to time. The amount of this compensation may be higher than the fees charged by other investment advisor firms for similar services. For instance, Betterment, LLC offers direct-to-consumer services similar to Transamerica® ALPHA. Therefore, clients would pay a lower advisory fee for algorithm-driven, automated (“Digital Advisor”) investment advisory services by going direct to Betterment, LLC, or other similar Digital Advisors. The relative cost of the Transamerica® ALPHA program is affected by such factors as the administrative costs associated with wrap fee arrangements, the fees charged when investment advisory and brokerage services are purchased separately, and the size of a client’s account. TFA365 Advisory Program For detailed information on fees and billing, please see the TFA365 Advisory Program appendix. Depending on your account balance and/or model portfolios selected within TFA365, the same investment management strategies or model portfolios may be available within the Third-Party Money Management programs available through TFA at different pricing levels which may be more or less expensive to you. Please refer to the account establishment paperwork for the TFA365 Advisory Program for additional details on fees and expenses. 12  Refunds For clients with assets managed within Third-Party Money Management Programs, please refer to the termination provisions and, if applicable, fee refund provisions in your TPMM advisory service agreement, account opening paperwork, and/or Form ADV Part 2A or similar Disclosure Brochure. For clients receiving investment advisory services on variable products who terminate their advisory relationship with us or their selected TPMM, your assets will remain under the custody of the issuing insurance company or the issuing insurance company’s designated custodian. You should refer to the termination provisions and, if applicable, fee refund provisions in your TPMM’s advisory service agreement, account opening paperwork, and/or Form ADV Part 2A or similar Disclosure Brochure. For clients with assets in Transamerica® ONE, the Client Services Agreement will continue in effect until you or TFA terminates it by giving written notice to the other, effective as of the date of the notice. The Client Services Agreement will also terminate should the agreement between TFA and Goldman Sachs terminate. Upon termination, neither TFA, Advisor, Goldman Sachs nor any of the Model Managers will have any obligation to recommend or take any action regarding the securities, cash, or other investments in your Transamerica® ONE account. Upon termination of the Client Services Agreement with TFA, your account assets held within your Transamerica® ONE account will remain under the custody of Folio until you provide the required account transfer instructions to Goldman Sachs. For clients with assets in Transamerica® ALPHA, the Client Services Agreement will continue in effect until you or TFA terminates it by giving written notice to the other, effective as of the date of the notice. The Client Services Agreement will also terminate should the agreement between TFA and Betterment terminate. Upon termination, neither TFA, nor your Advisor, will have any obligation to recommend or take any action regarding the securities, cash, or other investments in your Transamerica® ALPHA account. Upon termination of the Client Services Agreement with TFA, your account assets held within your Transamerica® ALPHA account will remain under the custody of Betterment Securities or Millennium Trust Company (for IRA accounts) until you provide the required account transfer instructions to Betterment. For clients with assets in TFA365, the Client Services Agreement will continue in effect until you or TFA terminates it by giving written notice pursuant to the specific terms found in the TFA365 Appendix, effective as of the date of the notice. The Client Services Agreement will also terminate should the agreement between TFA and Fidelity terminate. Upon termination, neither TFA, nor your Advisor, will have any obligation to recommend or take any action regarding the securities, cash, or other investments in your TFA365 Advisory Program account. Upon termination of the Client Services Agreement with TFA, your account assets held within your TFA365 Advisory Program account will remain under the custody of NFS until you provide the required account transfer instructions to Fidelity. Changes in Fees TFA, upon 30 days prior notice to clients, may at its discretion revise any aspect of the Total Program Fees which include three components (1) the TFA Advisor’s fee, (2) the Platform fee, and (3) the Portfolio Manager fee, including in a way that may cause the fees payable by the client to increase. A client will be deemed to have approved a fee change unless he or she objects to the fee change by 13  sending written notice pursuant to the Notice section in the Client Services Agreement and/or applicable Program Appendix to TFA within 30 days from the date of the fee increase notification. TFA further reserves the right to negotiate, discount or waive any fees associated with an advisory program in general or payable by any client or group of clients in TFA’s sole discretion. Furthermore, TFA employees and employees of affiliates may be entitled to fee discounts by virtue of their employment. Conflicts of Interest Transamerica® ALPHA Digital Investment Program TFA and your TFA Advisor will receive a portion of your total fee for our ongoing advisory, administrative, and marketing services related to the program. Two service model options are available to clients: a Standard Service Model priced at 0.65% on all assets and a Premier Service Model priced at 0.95% on assets above $10,000 and 0.65% for assets $10,000 and below (based on the combined assets in all accounts within Transamerica® ALPHA by the client). Of the 0.65% in the Standard and Premier Service Models, TFA will receive an annualized fee of 0.40% for its investment advisory and administrative services and Betterment will receive 0.25%. Of the 0.95% in the Premier Service Model, TFA will receive an annualized fee of 0.70% for its investment advisory and administrative services and Betterment will receive 0.25%. The Total Annual Advisory Fee charged may be higher than the fees charged by other investment advisor firms for similar services. For instance, Betterment, LLC offers direct-to-consumer services similar to Transamerica® ALPHA. Therefore, clients would pay a lower advisory fee for algorithm- driven, automated (“Digital Advisor”) investment advisory services by going direct to Betterment, LLC, or other similar Digital Advisors. TFA reserves the right to waive or lower the fee in certain cases at its discretion with notice to clients as provided for in this brochure. Transamerica® ONE Wealth Management Platform TFA is the sponsor of and one of several Model Managers within the Transamerica® ONE program. TFA may earn additional compensation that it would not otherwise earn when you elect to participate in the Transamerica® ONE program as opposed to other investment management or similar advisory service programs. Transamerica® ONE is a wrap fee program which uses strategic, tactical, and alternative asset allocation model portfolios to establish an individualized model portfolio in accordance with your particular investment objectives and risk tolerance. Depending upon the model portfolios selected, types of investments used can consist of, but are not limited to, individual stocks, mutual funds, and ETFs (collectively “Investment Products”). Due to TFA’s advisory service fees within the Transamerica® ONE program, you may be able to purchase such investment products in other accounts or programs at a lower cost than participating in the model portfolios available to you in this program. Additionally, TFA is the Model Manager for the Transamerica I-Series® model portfolios available within Transamerica® ONE. Transamerica I-Series® model portfolios use strategic, tactical, and alternative asset allocation models in accordance with particular investment objectives and risk targets. Within Transamerica® ONE, you may select multiple model portfolios allowing you to pursue different investment strategies within a single account. Within each Transamerica®ONE model portfolio, the client owns the underlying securities in his or her account. 14  TFA also offers Transamerica® Strategy Solutions, which are a suite of risk-based allocations to strategies in the Transamerica® One platform. There are five allocations, one for each of the five risk categories. Transamerica® Strategy Solutions are intended for clients whose primary focus is achieving a level of risk in the overall portfolio that matches the client’s risk tolerance. TFA365 Advisory Program TFA and your Advisor will receive a portion of your total fee for our ongoing advisory, administrative, and marketing services related to the program. TFA365 Advisory Program is a program which uses strategic, tactical, and alternative asset allocation model portfolios to establish an individualized model portfolio in accordance with your stated investment objectives, time horizon and risk tolerance. Depending upon the model portfolios selected, types of investments used can consist of, but are not limited to, individual stocks, bonds, mutual funds, and ETFs (collectively “Investment Products”). Due to TFA’s advisory service fees within the TFA365 Advisory Program, you may be able to purchase such investment products in other accounts or programs at a lower cost than participating in the model portfolios available to you in this program. TFA offers affiliated funds, Transamerica mutual funds, within the TFA365 UMA program. This offering creates a conflict of interest in that Transamerica Asset Management, Inc., TFA’s affiliated company, receives more overall revenue due to TFA offering its affiliated mutual fund products within the TFA365 UMA program than it would from offering similar unaffiliated mutual fund products within the TFA365 UMA program. In addition, the operating and management expenses charged by the affiliated mutual funds may be more expensive than the operating and management expenses of similar unaffiliated mutual fund products. You should carefully consider this conflict of interest and thoroughly review the mutual fund prospectuses associated with recommendations made by your Financial Professional prior to investing. Clients may be offered access to securities-backed lending programs through third-party banks. These loans are collateralized by securities held in clients' advisory account. While TFA does not directly receive compensation for these loans, it does receive revenue share. The Lending Sponsor compensates TFA for making the respective loan program available on TFA’s platform and covers various administrative costs associated with servicing the loan and regulatory reporting. Compensation can be up to 25 basis points of the outstanding loan amount. A conflict of interest exists because TFA and its financial professionals have an incentive to recommend such programs. Clients are not obligated to participate in the lending program and should consider the risks, including the possibility of liquidation of pledged assets, and tax implications. Securities used as collateral in a loan are subject to liquidation if the value falls below maintenance levels, which may negatively impact the client's investment strategy. Sale of Other Financial Products Your TFA Advisor may also be able to offer you fixed insurance products through his or her affiliation with World Financial Group Insurance Agency (“WFGIA”). If you purchase a fixed insurance policy from your TFA Advisor acting in his or her capacity as a WFGIA Agent, you will pay a normal and customary insurance commission for the purchase of the policy. In these cases, your TFA Advisor is not acting in their capacity as an Advisor, but rather as an insurance agent of WFGIA and they will receive a commission as an insurance agent. Such commission is paid to the applicable TFA Advisor, as an insurance agent, from the issuer of the insurance product through WFGIA. Receipt of these commission payments creates a conflict of interest. The Advisor has an incentive to recommend certain non-variable insurance contracts that are available through his or her affiliation with WFGIA, an affiliate 15  of TFA, for which the TFA Advisor may receive greater compensation instead of certain investment advisory services through TFA that may be more suitable for you. TFA is also registered as a broker-dealer. This allows TFA Advisors to recommend the purchase of commission-based securities products to clients. The compensation paid on these individual products may be greater than the compensation on investment advisory services, which creates a conflict of interest for the TFA Advisor. TFA endeavors to mitigate the risks associated with these conflicts by providing training and guidance to its Advisors regarding the assessment of best interest and suitability given the client’s stated investment objectives and time horizon. is available Retirement Plan Exchange The Retirement Plan Exchange through an agreement between TFA and Transamerica Retirement Solutions (“TRS”) which is administered by TAG Resources (“TAG”), a third- party administrator and 3(16) fiduciary. In connection with the provision of retirement plan services for the Client within the Exchange, you may be able to purchase less expensive share classes of mutual funds in other accounts or programs than the ones currently being used in the Exchange. TRS will not always purchase the lowest cost mutual fund share class available. TRS does receive 12b-1 fees in connection with these services. TFA does not receive any portion of these 12b-1 fees from TRS. TFA, TRS and TAG are affiliated companies under common control. The parent company of TFA, TRS and TAG will receive additional compensation if TRS and/or TAG is selected by the client. Additional Conflicts of Interest Summit Global Investments, LLC (“SGI”), an unaffiliated third-party money management firm and independent investment adviser registered with the Securities and Exchange Commission, has entered into agreements with TFA to provide certain investment advisory services to TFA clients. Richard Thawley is registered with one or more of TFA’s affiliated insurance companies/agencies with which TFA conducts business. Mr. Thawley is not registered or associated with TFA as a registered representative or an investment advisor representative. Mr. Thawley’s trust is a private investor in SGI, as such Mr. Thawley will benefit from business referred to SGI by TFA Advisors. Mr. Thawley’s access to TFA Advisors could lead to certain TFA Advisors being influenced to recommend SGI to clients. We resolve this conflict by monitoring the appropriateness of the recommendations made to you by our Advisors. In certain cases, TPMMs, Portfolio Managers, and other service providers may pay TFA for marketing services per a marketing services agreement. The amount and terms of this marketing compensation may increase or decrease from time to time. Any additional marketing services agreement paid by the TPMMs, Portfolio Managers, or other service providers to TFA will not affect your account, the services provided to you, the fee for advisory services that you pay to the TPMM, Portfolio Managers, or other service provider, or the compensation paid by TFA to your Advisor. The existence of a marketing services agreement with TPMMs, Portfolio Managers, or other service providers can create a conflict of interest for your TFA Advisor and TFA. TFA will earn more revenue due to such marketing services agreements, and although your TFA Advisor does not receive any of this revenue directly they indirectly benefit from this additional revenue through different educational and marketing initiatives conducted by a TPMM, Portfolio Manager, or other service provider. 16  Each of the TPMMs, Portfolio Managers, or other service providers that have marketing arrangements with TFA may attend, contribute to, or sponsor education and training meetings for our Advisors. A TPMM, Portfolio Manager, or other service provider may reimburse TFA for up to 100% of the cost of these meetings. These contributions and reimbursements create a conflict of interest because meeting sponsors have more opportunities to provide Advisors with education on investments, their investment management services, industry trends, and other issues; and because TFA benefits from these contributions and reimbursements. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT TFA does not charge advisory fees based on a share of the capital gains on or capital appreciation of funds or securities in your account. These fees are also called performance-based fees. TFA’s advisory fee compensation is charged only as disclosed above in Item 5. ITEM 7 – TYPES OF CLIENTS TFA provides investment advisory services to individuals, employer retirement plans, corporations or other businesses, trusts, estates, and charitable organizations. Certain programs available through us have minimum investment amounts starting at $10.00, however, this minimum may vary depending on the account program selected by you. TPMMs selected by you have discretion to waive an account minimum depending on the account program and if you have other related accounts managed by the TPMM. Employer retirement plans, such as 401K plans, can in certain cases be opened with no account minimum. TFA has established conditions for opening and maintaining advisory accounts. Specifically, advisory clients must complete an Investor Profile. This will provide us with information such as name, address, date of birth and other information used to identify you. TFA may use third- party sources to verify and/or update the information provided and may also request to see your driver’s license or other identifying documents. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Third-Party Money Manager Programs Advisors will assist you in selecting a TPMM whose investment strategies suit your needs and financial objectives. Assistance will also be provided to you in explaining the differences among the TPMMs available. Advisors will also provide assistance to you by explaining the investment management process, investment objectives, and the investment strategies undertaken as part of the service; in reviewing and completing the electronic or written materials required by the TPMM; annually monitoring your ongoing needs and financial situation; and in answering questions about the service. TFA selects TPMMs who are registered investment advisors based upon, but not limited to, the following criteria: Investment strategy • Track record • • Disclosure documents, including disciplinary history 17  The methods of analysis, sources of information and investment strategies used by TPMMs will vary. We encourage you to read each TPMM’s Disclosure Brochures, Form ADV Part 2A and any other document you receive prior to entering into an agreement with a TPMM. TPMMs will exercise discretion over your account assets. Certain strategies may involve reinvesting client dividends. A risk associated with this type of analysis is that past performance is not a guarantee of future results. While a TPMM may have demonstrated a certain level of success in past economic times, the TPMM may not be able to replicate that success in future markets. In addition, just because a TPMM may have invested in a certain manner in past years, such TPMM has discretion to change how it manages its strategies in future years. To mitigate this risk, TFA conducts annual due diligence on the TPMMs to ensure the TPMMs meet compliance and regulatory requirements. Transamerica® ONE Wealth Management Platform Additional information related to the method of analysis, investment strategies, and risk of loss relevant to Transamerica® ONE can be found in the Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1). Transamerica® ALPHA Wrap Fee Program Additional information related to the method of analysis, investment strategies, and risk of loss relevant to Transamerica® ALPHA can be found in the Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1). TFA365 Advisory Program Additional information related to the method of analysis, investment strategies, and risk of loss relevant to TFA365 Advisory Program can be found in the Program Brochure (Form ADV Part 2A Appendix 1). Transamerica I-Series® Program In the Transamerica I-Series® program (“I-Series Program”), TFA makes available its own proprietary investment model portfolios. These were created using risk/return analysis of historical data that includes multiple market cycles. TFA also analyzes the performance of various asset classes such as equity, fixed income, commodities, real estate, and cash. These asset classes are then broken out into further subsets based on factors such as market capitalization and international and domestic markets. The ETFs for each asset class or subclass are selected based on various data including expense ratio, performance history, liquidity, tracking to underlying index, provider diversification and number of holdings. Each asset allocation model portfolio is rebalanced periodically to the targeted asset allocation. Transamerica I-Series® strategies typically invest in ETFs and/or mutual funds (“funds”). Each of these funds or ETFs invests in at least 20 individual stocks, bonds, futures, or options. In consultation with their TFA Advisor, clients may select an investment strategy that ranges from I- Series Ultra Conservative, which is primarily invested in bond ETFs and/or funds, to I- Series Aggressive, which is primarily invested in stock ETFs and/or funds. Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in Investment Products involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original 18  principal. Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. Investment Strategies For a full detailed explanation of investment strategies within the I-Series program, please refer to the Transamerica® ONE Appendix. Transamerica® Strategy Solutions Transamerica® Strategy Solutions are a suite of risk-based allocations to strategies in the Transamerica® One platform. There are five allocations, one for each of the five risk categories. For more details, see the Transamerica® ONE appendix. Transamerica® ALPHA Stars Strategy Transamerica® ALPHA Stars Strategy invests in a diversified portfolio of both stock and bond ETFs in a blend that seeks to balance returns with risk. The balance between stocks and bonds and between returns and risk will be based solely on the time remaining until the target goal date with risk management taking more precedence as the goal date approaches. To automate rebalancing of the portfolio as the target date approaches, the client must have the “Auto Update” feature turned on. The strategy will hold equities throughout a bear market and will NOT seek to reduce equity downside during such time. The strategy will instead seek tax efficiency by reducing trading frequency and preferring long-term gains and losses over short- term gains and losses. Investments are allocated on a long term, buy, and hold basis to a select group of U.S. and international stock and bond categories. One or two ETFs are purchased and held for each category. These ETFs are reviewed by TFA periodically and are replaced as needed based on a review of the ETF’s ratings, returns, downside risk, daily liquidity, and other measurements. Material Investment Risks TFA’s advisory programs offer multiple Model Portfolios to satisfy a wide variety of investment and risk profiles, ranging from the most aggressive portfolios to the most conservative. In general, the advisory programs offered through TFA are subject to the risks noted below. However, Model Portfolios that have higher concentrations in equity investments are subject to greater risk, such as stock market volatility and foreign exposure. Model Portfolios that have a higher concentration in fixed income securities have greater exposure including, but not limited to, credit, interest rate, and liquidity risks. Risk of Loss: Although TFA works hard to preserve your capital assets and increase your wealth, investing in Investment Products involves a risk of loss to your principal (invested amount) and any unrealized profits. For example, securities may not be sold at the appropriate time to achieve a profit. Certain model portfolios impose more risk than others. As a fiduciary, TFA will strive to provide investment advice that is in your best interest. TFA and its Advisors will strive to provide investment advice for your assets to the best of our ability; however, we cannot guarantee any level of performance or prevent losses in your account assets. All investments in securities include a risk of loss of your principal and any unrealized profits. Stock markets and bond markets fluctuate over time and clients may lose money. You should be prepared to lose money in any investment account. Investments are not a deposit of a bank and are not insured or 19  guaranteed by the Federal Deposit Insurance Corporation or any other government agency. You may lose money by investing in Investment Products. Each investment strategy offered by the advisory programs offered by TFA pose risks, and many factors affect each investment or account’s performance. Securities-backed lines of credit are not appropriate for all clients and involve significant risks. The use of such loans can magnify losses, and the forced liquidation of securities may occur in declining markets. Clients should carefully consider the impact of borrowing against their investment portfolio, including the potential for loss of principal, interruption to their investment strategy, and tax consequences. Investments or accounts are also subject to volatility in non-U.S. markets through either direct exposure or indirect effects in the U.S. markets from events abroad. Investments or accounts that seek exposure to debt are subject to risks of prepayment or default, and Model Portfolios that concentrate in particular industries or are otherwise subject to particular segments of the market may be significantly impacted by events affecting those industries or markets. In addition, the investments in your advisory account may be subject to the following specific risks: Investing in Mutual Funds and Exchange-Traded Funds (“ETFs”): Your account bears all the risk of the investment strategies employed by the mutual funds and ETFs held in your account, including the risk that a mutual fund or ETF will not meet its investment objectives. For the specific risks associated with a mutual fund or ETF, please see its prospectus. Investing in Exchange Traded Notes (“ETNs”): ETNs are unsecured debt obligations of the issuer (often a bank). As such, ETN holders are directly exposed to the issuer's credit or default risk. Investing in Environmental, Social, and Governance (“ESG”): ESG investing, also known as “socially responsible investing,” focuses on the social values or environmental, social, and governance standards or the sustainability factors of an investment. Some investment strategies use criteria to supplement financial analysis when considering a particular issuer or security, while others affirmatively select “socially responsible” investments or screen out or exclude investments in companies that engage in certain activities. This may limit the type and number of investments available in a strategy and cause the strategy to underperform other strategies without a ESG based focus or with a different type of focus or screening methodology. ESG strategies may underperform the market as a whole. Companies and issuers selected in an ESG based strategy may not or may not continue to demonstrate ESG based characteristics. Reliance on Technology; Cybersecurity: Certain TFA investment activities and investment strategies are dependent upon algorithms, as well as other various computer and telecommunications technologies, many of which are provided by or are dependent upon third parties such as data feed, data center, telecommunications, or utility providers. The successful deployment, implementation, and/or operation of such activities and strategies, and various other critical activities of TFA on behalf of its clients, could be severely compromised by system or component failure, telecommunications failure, power loss, a software-related “system crash,” fire or water damage, human errors in using or accessing relevant systems, unauthorized system access or use (e.g., “hacking”), computer viruses, or various other events or circumstances. It is not possible to provide fool-proof protection against all such events, and no assurance can be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunications systems or operations 20  could have a material adverse effect on TFA’s clients, including preventing TFA, Betterment, Goldman Sachs, Fidelity, EAM, and/or a Model Manager from trading, modifying, liquidating, and/or monitoring its clients’ investments. In addition, clients should be aware of the risk of attempted cyber-attacks and harm to technology infrastructure and data from misappropriation or corruption. With respect to the TFA365, Transamerica® ALPHA and Transamerica® ONE programs, due to TFA’s, Goldman Sachs’, Fidelity’s, and Betterment’s interconnectivity with third party vendors, central agents, exchanges, clearing houses, and other financial institutions, TFA, Goldman Sachs, Fidelity, and Betterment could be adversely impacted if any of them is subject to a cyber- attack or other information security event. Although TFA, Goldman Sachs, Fidelity, and Betterment take proactive measures and endeavor to modify them as circumstances warrant, their computer systems, software, and networks may be vulnerable to unauthorized access, issues, computer viruses or other malicious code, and other events that could have a security impact. Algorithm Risks (Transamerica® ALPHA): The use of algorithms to provide investment advisory advice carries the risk that changes to algorithm’s code may not have the desired effect with respect to client accounts. While this risk increases if changes to the algorithms are insufficiently tested prior to implementation, even extensively tested changes may not produce the desired effect over time. The algorithms used in the Transamerica® ALPHA program are based on a number of assumptions, which may have inherent limitations and may not prove to be accurate. Investment Risk: Every mutual fund and ETF is run by a manager who is making decisions on which stocks and bonds to buy and sell. These securities can lose money causing the mutual fund or ETF to lose money. Operation Risk: Every ETF and mutual fund are investment companies that are run by an advisor and a board of directors that is responsible for managing the funds operations and following the laws and regulations relevant to ETFs and mutual funds. The managers of the fund companies may commit fraud, malfeasance, or simply make bad decisions that result in higher expenses for the funds investors, mistaken calculations of the fund’s true value, and losses of fund assets. Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market value to decline, and vice versa. Market Risk: The price of investments in your advisory account may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Economies and financial markets throughout the world are increasingly interconnected. Economic, financial, or political events, trading and tariff arrangements, terrorism, pandemics, technology and data interruptions, natural disasters and other circumstances in one country or region could be highly disruptive to, and have profound impacts on, global economies or markets. During periods of market disruption, the underlying investments’ exposure to the risks described elsewhere in this section will likely increase. As a result, whether the underlying investments are in securities of issuers located in or with significant exposure to the countries directly affected, the value and liquidity of the underlying investments may be negatively affected. Also, liquidity of investments, or even an entire market segment, can deteriorate rapidly, particularly during times of market turmoil, and those investments may be difficult or impossible to trade. 21  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar last year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments can be subject to fluctuations in the value of the investment in U.S. dollars, which are due to fluctuations in the currency of the investment’s originating country. Reinvestment Risk: This is the risk that future proceeds from investments may be reinvested at a potentially lower rate of return (i.e., interest rate). Concentration Risk: To the extent a significant portion of the assets in a client’s account are concentrated in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry, or such government could be considerably greater than if the client did not concentrate their investments to such an extent. Business Risk: These risks are associated with a particular industry or a particular company within an industry. Financial Risk: Excessive borrowing to finance a business’s operations increases the risk of bankruptcy, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or declining market value. Fixed Income Risk: Portfolios that invest in fixed income securities are subject to several general risks, including interest rate risk, credit risk, and market risk, which could reduce the yield that an investor receives from his or her portfolio. These risks may occur from fluctuations in interest rates, a change in an issuer’s individual situation or industry, or events in the financial markets. Credit Risk: Changes in financial condition of an issuer or counterparty, and changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security or instrument’s credit quality or value. Lower quality debt securities and certain types of other securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. Foreign Risk: Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which may be greater in emerging markets. These risks are particularly significant for securities that focus on a single country, region, or emerging markets. Foreign markets may be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates may also be extremely volatile. Tax Risk: Securities in the investment strategy may be bought and sold without regard to a client’s individual tax ramifications, and so portfolio turnover could cause the client to incur tax obligations that negatively affect the after-tax return. Tactical Asset Allocation Risk: Tactical asset allocation is an investment strategy that actively adjusts a strategy’s asset allocation. A strategy’s tactical asset management discipline may not work as intended. A strategy may not achieve its objective and may not perform as well as other strategies using other asset management styles, including those based on fundamental analysis (a method of evaluating 22  a security that entails attempting to measure its intrinsic value by examining related economic, financial and other factors) or strategic asset allocation (a strategy that involves periodically rebalancing the fund in order to maintain a long-term goal for asset allocation). This strategy may not work as intended. The sub-adviser’s evaluations and assumptions in selecting underlying funds or individual securities may be incorrect in view of actual market conditions and may result in owning securities that underperform other securities. The management process might also result in a strategy having exposure to asset classes, countries or regions, or industries or groups of industries that underperform other management styles. In addition, a strategy’s risk profile with respect to particular asset classes, countries and regions, and industries may change at any time based on the sub-adviser’s allocation decisions. ITEM 9 – DISCIPLINARY INFORMATION TFA is both a broker-dealer and a federally registered investment adviser. In the last ten years, TFA has had four disciplinary events that are material to your evaluation of us. Two of the events involve charges brought by the Securities and Exchange Commission (“SEC”). Two of the events involve charges brought by TFA’s self-regulatory organization, Financial Industry Regulatory Authority, Inc. (“FINRA”). SEC Proceedings • On March 11, 2019, the SEC issued an Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order (“Order”) relating to TFA’s disclosure of its mutual fund share class selection practices and the 12b-1 fees TFA and its associated persons received. Specifically, the SEC alleged that TFA failed to adequately disclose in its Form ADV or elsewhere the conflicts of interest related to a) its receipt of 12b-1 fees and/or b) its selection of mutual funds share classes that pay such fees. TFA self-reported this matter to the SEC pursuant to the SEC Division of Enforcement’s Share Class Selection Disclosure Initiative. TFA settled this matter with the SEC. TFA agreed to a censure, to pay disgorgement of $5,364,292.04 plus $658,780.64 in interest, and to cease and desist from violating certain securities laws and regulations. The disgorgement and interest were paid to a Distribution Fund (“Fund”) for distribution to investors who purchased or held 12b-1 fee paying share class mutual funds in advisory accounts when a lower-cost share class of the same fund was available to the client. The Order states that these investors are to receive from the Fund the 12b-1 fees attributable to the investor during the relevant period, plus interest, subject to a de minimis threshold. The foregoing is only a summary of the Order. A copy of the Order is available on the SEC’s website at www.sec.gov. • On August 27, 2018, the SEC settled public administrative Cease-and-Desist proceeding naming TFA and certain of its affiliates (“Order”). As to TFA, the Order relates to, among other things, errors in certain models used by TFA in its Transamerica I-Series® and Transamerica® ONE programs. The Order also states that the parties failed to make appropriate disclosures regarding these matters. In addition, the Order states that the parties failed to have adequate policies and procedures. The models at issue in the case were managed by an affiliate, AEGON USA Investment Management, LLC (“AUIM”) and by F-Squared Investments, Inc. (“F-Squared”). The models managed by AUIM were the Global Tactical Allocation – Conservative, Global Tactical Allocation–Balanced, Global Tactical Allocation – Growth, Tactical Fixed Income, Global Tactical Income and Global Tactical Rotation models. The models managed by F-Squared were the AlphaSector Rotation Index, 23  AlphaSector Premium Index and World Allocator Premium Index. These strategies are no longer offered by TFA and neither AUIM nor F-Squared currently provide model management services to TFA. The strategies developed by AUIM and F-Squared were offered by TFA in the Transamerica I- Series® and Transamerica® ONE programs between 2011 and 2015. TFA has settled this matter with the SEC. TFA agreed to a censure, to pay a penalty of $800,000, to pay disgorgement of $1.7 million plus $258,162 in pre-judgment interest, and to cease and desist from violating certain securities laws and regulations. The disgorgement, interest and penalties have been paid to a Fair Fund (“Fund”) for eventual distribution to affected investors who purchased or held an interest in the AUIM and F- Squared strategies in the Transamerica I- Series® and Transamerica® ONE programs from July 2011 through June 2015. The Order states that these investors are to receive from the Fund an amount related to the pro rata fees and commissions paid by them during that period, plus interest, subject to a de minimis threshold. In accepting the settlement, the SEC considered the substantial cooperation and the remedial efforts of TFA and its named affiliates. In the Order, the SEC acknowledged that, after the start of the SEC staff’s investigation but before the settlement, TFA and the named affiliates had voluntarily retained a compliance consultant to conduct a comprehensive independent review of certain compliance policies and procedures, internal controls and related procedures, and that the consultant’s written findings had been received and proposed changes implemented. The SEC also acknowledged that, in advance of receiving recommendations from the independent compliance consultant, TFA and its affiliates had already begun making revisions and improvements to their compliance policies and procedures. The SEC also considered that TFA and its affiliates retained the independent compliance consultant for further reviews. The settlement does not impose any restrictions on the business of TFA. The foregoing is only a summary of the Order. A copy of the Order is available on the SEC’s website at www.sec.gov. FINRA Proceedings • On December 21, 2020, TFA and FINRA entered into a Letter of Acceptance, Waiver and Consent in which TFA agreed to settle alleged FINRA rule violations. TFA consented to the sanctions and to the entry of findings that it failed to reasonably supervise its representatives’ recommendations of three different products – variable annuities, mutual funds and 529 Plans. TFA was censured, fined $4,400,000 and required to pay $4,354,160 in restitution to customers. A copy of this Order is available on FINRA’s website at www.finra.org/rules-guidance/oversight- enforcement/finra-disciplinary-actions-online. • On July 27, 2015, TFA and FINRA entered into a Letter of Acceptance, Waiver, and Consent in which TFA agreed to settle alleged FINRA rule violations. TFA agreed to a censure and fine of $85,000 and paid restitution to impacted Clients in the amount of $51,066.08 (plus interest). This matter pertained to TFA failing to identify and apply volume discounts to certain clients’ eligible purchases of non- traded real estate investment trusts (REITs) and business development companies (BDCs), resulting in customers paying excessive sales charges of approximately $51,000. TFA also failed to establish, maintain, and enforce a supervisory system and written supervisory procedures with respect to the sale of non-traded REITs and BDCs. 24  ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVTIES AND AFFILIATIONS TFA is also a broker-dealer. In general, TFA’s Advisors, management team, and most of TFA’s Investment Committee members are Registered Representatives of TFA’s broker-dealer. The majority of TFA’s Advisors are also affiliated with World Financial Group Inc., a financial services marketing company that is affiliated with TFA. TFA is a member of the Transamerica Group of companies. These companies include investment companies that offer mutual funds and fixed and variable insurance products. Many of these products can be purchased by the various TPMMs or Model Managers available in TFA’s programs. Based on TFA’s affiliation with various investment companies and variable insurance companies, a conflict of interest exists due to the compensation paid to TFA by these companies and compensation gained by our affiliates through fees and expenses charged to you on their products. This compensation is in addition to the advisory fees you pay to TFA. TFA mitigates these conflicts by monitoring the appropriateness of the recommendations made to you by TFA’s Advisors regarding all advisory services they offer you and on all products you purchase, including those products issued by TFA’s affiliates. TFA has contracts with TPMMs who are also investment advisors that offer fee-based advisory programs. These relationships were described in Item 4. These third-party money managers are not affiliated with TFA, and they pay TFA a portion of the fees you pay to them. This is considered a conflict of interest. The cost of placing your assets with one of these TPMMs may be higher than placing your assets in another advisory account. TFA also has arrangements with a third-party bank to facilitate securities-backed lending for its clients. TFA receives compensation related to clients' participation in these programs. This creates a conflict of interest, as the firm may be incentivized to recommend or facilitate loans that generate revenue. We mitigate this conflict by disclosing it to our clients, ensuring any lending recommendations are made in the client's best interest, and requiring additional supervision and compliance review for such transactions. Broker-Dealers under Common Control with AEGON N.V. The following FINRA registered broker-dealers are under common control with TFA. TFA and each of these other broker-dealers are indirect, wholly owned subsidiaries of AEGON N.V. • Transamerica Investors Securities Corporation • Transamerica Capital, LLC Transamerica Capital, LLC (“TCL”) is the principal underwriter for variable annuity and life insurance products offered by TFA’s affiliated insurance companies. TFA has a selling agreement with this broker- dealer that compensates TFA for selling these products. TCL is also a wholesale distributor of Transamerica products. Such compensation creates a conflict of interest for TFA and its Advisors. TFA mitigates this conflict by monitoring the appropriateness of the recommendations made to you by TFA Registered Representatives and Advisors on all products and advisory services you purchase including those products issued by our affiliates. 25  Investment Companies under Common Control with AEGON N.V. TFA has an agreement to sell mutual funds of one of its related investment companies, Transamerica Funds. TFA offers insurance products through affiliated insurance companies which contain shares of the Transamerica Series Trust and/or Transamerica Partners Funds, both of which are affiliated investment companies. TFA receives compensation from these sales. Such compensation creates a conflict of interest for TFA and its Advisors. TFA mitigates this conflict by monitoring the appropriateness of the recommendations made to you by TFA Registered Representatives and Advisors. Registered Investment Advisers under Common Control with AEGON N.V. The following SEC Registered Investment Advisers are under common control with TFA. TFA and each of these advisory firms are indirect, wholly owned subsidiaries of AEGON N.V. • Transamerica Asset Management, Inc. (“TAM”) • AEGON USA Investment Management, LLC (“AUIM”) • Transamerica Retirement Advisors, Inc. (“TRA”) Insurance Companies or Agencies under Common Control with AEGON N.V. TFA has material relationships or arrangements with a select group of product sponsors (“Sponsoring Companies”), some of which are affiliated insurance companies/agencies. In certain cases, some of TFA’s officers may be affiliated with our affiliated insurance companies/agencies. In its capacity as a broker-dealer, TFA receives additional compensation in the form of revenue sharing payments when you purchase products through these insurance companies/agencies. A summary of TFA’s revenue sharing arrangements and current Sponsoring Company compensation arrangements can be found at the Home Page of TFA’s website at www.tfaconnect.com under Disclosures - Revenue Sharing Arrangements and Payments by Sponsoring Companies Client Disclosure Statement. These revenue sharing payments create a conflict of interest for TFA, its Registered Representatives, and its Advisors. TFA mitigates this conflict by monitoring the appropriateness of the recommendations made to you by TFA Advisors and Registered Representatives on all services and products you purchase including those services and products offered and issued by our affiliates. The following is a list of TFA’s affiliated insurance companies/agencies with which TFA conducts business: • Transamerica Premier Life Insurance Company • InterSecurities Insurance Agency, Inc. • Transamerica Life Insurance Company • Transamerica Financial Life Insurance Company • World Financial Group Insurance Agency, Inc. (DBA World Financial Insurance Agency, Inc. in California) • World Financial Group Insurance Agency of Hawaii, Inc. • World Financial Group Insurance Agency of Massachusetts, Inc. • WFG Insurance Agency of Puerto Rico, Inc. Your Advisor may also be an insurance agent and be able to offer you insurance products through his or her affiliation with one or more of these agencies. When you purchase insurance products through our Affiliated Agencies, TFA’s Affiliated Agencies will receive commission compensation. 26  INTEREST IN CLIENT ITEM 11 – CODE OF ETHICS, PARTICIPATION OR TRANSACTIONS AND PERSONAL TRADING TFA has adopted a Code of Ethics and an Insider Trading Policy (“Code”). This Code is designed to ensure that TFA meets its fiduciary obligation to you and our prospective clients, that TFA conducts its advisory services with the highest level of ethical standards, and that TFA instills a culture of compliance within our firm. Our Code is comprehensive and is distributed to each home office employee and Advisor (collectively “Access Persons”) at the time of hire and acknowledged annually thereafter. TFA also supplements the Code with annual training and ongoing monitoring of the activity of Access Persons. TFA’s Code includes the following requirements for TFA Access Persons: • Maintain the principles of honesty, integrity, and professionalism and comply with federal and state securities laws; • Follow all policies and procedures contained in our manuals, bulletins, and supervisory directives and cooperate with any investigation or inquiries; • Maintain the privacy and confidentiality of information provided by our clients; • Refrain from: insider trading; o o accepting gifts and entertainment that exceed our policy standards o participating in any initial public offerings o executing a personal transaction in a security for which the Access Person already has a pending buy or sell order for a client. • Report all gifts and business entertainment; • Pre-clear personal securities transactions; • Report on a quarterly basis all personal securities transactions; • Annually review and certify compliance with our Code. TFA has also established the following guidelines for TFA Access Persons: • Our directors, officers, and employees are not allowed to buy or sell securities for their personal portfolio(s) unless the information is also available to the investing public. • Access Persons are not to place their own interests above yours. • Any Access Person not complying with these guidelines may be subject to disciplinary action including termination. the address or You may request a complete copy of our Code by contacting TFA at telephone number displayed on the cover page of this Disclosure Brochure. ITEM 12 – BROKERAGE PRACTICES TFA does not have authority to determine which broker-dealer will be used for the advisory services described in Item 4 above. The TPMMs choose their own brokerage and soft-dollar practices, and such practices will be disclosed in the TPMM’s Form ADV Part 2A or other disclosure brochure. Clients should refer to the TPMM’s disclosure document for a complete discussion of brokerage practices, trade allocation and research or other soft- dollar benefits. 27  Transamerica® ONE Wealth Management Platform When you select Transamerica® ONE, Folio Investments, Inc., a Goldman Sachs Company (“Folio”), is the broker-dealer and custodian. Your securities transactions will be executed through, and your assets held at this firm. TFA will be solely responsible for directing your purchases and sale transactions to Folio. Additionally, TFA will periodically direct one or more transactions for your account when rebalancing is required for all Transamerica I-Series® models. Model managers on the Transamerica® ONE platform that are not affiliated with TFA will periodically direct one or more transactions for your account when rebalancing is required. Rebalancing is the process of buying and selling portions of your model portfolio to adjust the weight of each asset class to your original asset allocation model portfolio. Folio attempts to obtain the best execution for you; however, there is no guarantee that this will be accomplished. Due to this arrangement with Folio, TFA may be limited or unable to negotiate commissions, aggregate your orders, or seek execution of transactions as efficiently as possible and at the best price for your account. You may also be paying higher fees and/or commissions than TFA’s other advisory clients should a situation arise when trades are placed outside of Folio’s standard trading windows which generally occur at 11:00 a.m. Eastern time, and 2:00 p.m. Eastern time. Transamerica® ALPHA Wrap Fee Program In connection with your participation in Transamerica® ALPHA, the client will authorize all trades for his or her Account to be placed with Betterment Securities, in its capacity as an introducing broker-dealer, to be cleared and settled through Apex. Clients will bear the risks associated with these transactions and should understand that Betterment will send all trades to Betterment Securities for execution (which will use Apex for clearance and settlement) even if the use of a different broker-dealer may result in lower prices or more favorable execution. Clients will receive the price at which such orders are executed in the marketplace. Additional information related to brokerage practices relevant to Transamerica® ALPHA can be found in the Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1). TFA365 Advisory Program When you select TFA365 Advisory, NFS is the broker-dealer and custodian. Your securities transactions will be executed through, and your assets held at NFS. Envestnet Asset Management, Inc. (“EAM”), an unaffiliated investment adviser, will be responsible for directing your purchases and sale transactions to NFS. EAM will periodically direct one or more transactions for your account when rebalancing is required. Rebalancing is the process of buying and selling portions of your model portfolio to adjust the weight of each asset class to your original asset allocation model portfolio. NFS attempts to obtain the best execution for you; however, there is no guarantee that this will be accomplished. Due to this arrangement with NFS, TFA may be limited or unable to negotiate commissions, aggregate your orders, or seek execution of transactions as efficiently as possible and at the best price for your account. Trade Aggregation and Allocation Policy TFA does not have the ability to execute trades on behalf of clients and as a result, does not aggregate or allocate the purchase or sale of securities for various client accounts. Within Transamerica® ONE, Goldman Sachs may aggregate securities purchases or sales orders for Client’s Account with similar orders for other accounts if, in its judgment, such aggregation is reasonably likely to result in an overall 28  economic benefit to client. Some of these aggregated transactions may be made at different prices due to the volume of securities purchased or sold. In such event, allocation of the securities to be purchased or sold, as well as the expenses incurred in the transaction, will be made by Goldman Sachs in a manner consistent with industry practices. Within Transamerica® ALPHA, Betterment places aggregated orders involving multiple Betterment accounts trading in the same securities. In conducting these transactions no client is favored over any other client and each client that participates in an aggregated transaction will participate at the average share price for transactions in the aggregated order. Within TFA365, Fidelity may aggregate securities purchases or sales orders for your account with similar orders for other accounts if, in its judgment, such aggregation is reasonably likely to result in an overall economic benefit to you. Some of these aggregated transactions may be made at different prices due to the volume of securities purchased or sold. In such event, allocation of the securities to be purchased or sold, as well as the expenses incurred in the transaction, will be made by Fidelity in a manner consistent with industry practices and with the disclosures in Fidelity’s Form ADV Part 2A. Agency Cross Transactions TFA does not engage in agency cross transactions. An agency cross transaction is a transaction in which TFA would act as an investment advisor and broker-dealer for you on one side of the transaction and another client on the other side of the transaction. However, TFA or any person associated with TFA may buy or sell securities identical to those recommended to you for their personal accounts. Principal Trading TFA does not engage in principal trading. Class Action Lawsuits TFA does not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor does TFA initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. ITEM 13 – REVIEW OF ACCOUNTS Registered Principals within the Home Office Supervision Department supervise the offering of advisory programs by Advisors and sale of securities products by TFA’s registered representatives. Home Office supervisory personnel conduct reviews of client accounts for conformity with company policy and procedures. Review of accounts will be done at least on an annual basis and will be conducted by your TFA Advisor. Your TFA Advisor will undertake reasonable efforts to contact you to discuss your financial situation and investment objectives to determine whether the account continues to meet your investment needs. Betterment’s algorithms continuously review client accounts on the Transamerica® ALPHA platform. 29  You will receive monthly or quarterly account statements, transaction confirmations, and/or performance reports. The nature and frequency of client reports will vary by program. We urge you to carefully review these reports and compare your custodial statements with your performance reports. The information in your performance reports may vary from your custodial statements due to accounting procedures, reporting dates, or valuation methodologies of certain securities. In the event of any discrepancies, you should rely on the statements you receive from the custodian of your assets. From time-to-time investors in TFA advisory programs may receive Albridge Personalized Account Statements directly from their advisors. These statements may include lists of your account holdings, including mutual funds and securities, but are not official account statements. We urge you to compare these reports to the official account statements of your account holdings provided to you at least quarterly by the custodian of your account to ensure that the mutual fund and securities holdings listed on these reports provided by your Advisor match the mutual fund and securities holdings reflected on the official account statements. Annually, the TFA Chief Compliance Officer, or designee, delivers the firm’s Annual Due Diligence Questionnaire to all TPMMs with which TFA has agreements. RIA Compliance and Investment Research or designee(s), review and score each questionnaire. Scores will be used to determine such things as further requests for documentation; further action; on-site visits; placement of the firm on a watch list. Results of the reviews and scores are reported to the TFA Investment Committee. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Registration Arrangements Many of TFA’s Advisors are also Registered Representatives of our broker-dealer. If your TFA Advisor is also a TFA Registered Representative they may recommend that you place securities transactions through TFA’s broker-dealer. These transactions could include, but are not limited to, the purchase or sale of mutual funds, variable annuities, or other financial products. All sales charges and expenses are disclosed in the product prospectus, which you will receive at or before the time of your purchase of the product. Marketing Compensation Arrangements In certain cases, TPMMs, Portfolio Managers and other service providers may pay TFA for marketing services per a marketing services agreement. The amount and terms of this marketing compensation may increase or decrease from time to time. Any additional marketing services agreement paid by the TPMMs, Portfolio Managers, or other service providers to TFA will not affect your account, the services provided to you, the fee for advisory services that you pay to the TPMM, Portfolio Managers, or other service provider, or the compensation paid by TFA to your Advisor. The existence of a marketing services agreement with TPMMs, Portfolio Managers, or other service providers create a conflict of interest for your TFA Advisor and TFA. TFA will earn more revenue due to such marketing services agreements, and although your TFA Advisor does not receive any of this revenue directly, they indirectly benefit from this additional revenue through different educational and marketing initiatives. Each of the TPMMs, Portfolio Managers, or other service providers that have marketing and referral arrangements with TFA may attend, contribute to, or sponsor education and training meetings for our Advisors. A TPMM, Portfolio Manager, or other service provider may reimburse TFA for up to 100% of the cost of these meetings. These contributions and reimbursements create a conflict of interest because meeting sponsors have more opportunities to provide Advisors with education on investments, their 30  investment management services, industry trends, and other issues; and because TFA benefits from these contributions and reimbursements. Other Compensation Arrangements If a TFA Advisor is associated with World Financial Group, Inc., they are permitted to participate in award and incentive programs sponsored by World Financial Group, Inc. in which they could qualify to receive trips, promotions or non-cash compensation based on their volume of fixed insurance sales only. These events may influence their decision to recommend particular fixed insurance products to you for consideration. Some TFA Advisors may participate in incentive trips and receive other forms of non-cash compensation based on the amount of their sales and services through TFA or product manufacturers. To the extent your Advisor participates in an incentive trip or receives other forms of non-cash compensation, a conflict of interest exists in connection with the Advisor’s recommendation of products and services for which they receive these additional economic benefits. TFA allows representatives to receive marketing reimbursements from product providers to help defray these expenses. There is no requirement or expectation that representatives refer clients to or place assets with such providers. TFA receives revenue sharing compensation from a third-party lender when its clients engage in securities-backed lending. Such arrangements create a conflict of interest, which we disclose to our clients and manage through our compliance policies and procedures. ITEM 15 – CUSTODY TFA does not take custody of client funds or securities. Client funds and securities are held with a qualified custodian. You will receive account statements directly from your qualified custodian at least quarterly. We urge you to carefully review these statements as they are the official record of your account and assets. ITEM 16 – INVESTMENT DISCRETION TFA Advisors do not accept discretionary authority in connection with the accounts opened through its TPMM relationships. TPMMs may maintain discretionary authority, but such authority would be fully disclosed to clients in the TPMM’s Form ADV Part 2A or other disclosure document. Clients may impose reasonable investment restrictions on the management of their accounts at the time of opening their account or at a later time by written notice. If a requested investment restriction is deemed to be unreasonable, or if TFA determines that a previous restriction has become unreasonable, TFA will notify the client that, unless the instructions are modified, TFA may reject or terminate the client relationship at its discretion and upon notification to the client pursuant to the notification terms in the applicable Client Services Agreement. When you open a Transamerica® ALPHA account, you give Betterment discretionary authority. You may impose reasonable limitations and restrictions at the time of opening your account or at a later time by written notice. When you open a TFA365 Advisory account, you authorize TFA and Advisor the limited discretionary authority to replace and update allocation weightings for Portfolio Managers as long as the changes 31  only occur within Client’s risk tolerance noted on Client’s most current Statement of Investment Selection on file with TFA. Any changes to allocations outside of Client’s stated risk tolerance, would require a new client signed Statement of Investment Selection. You also give FIWA and EAM discretionary authority. You may impose reasonable limitations and restrictions at the time of opening your account or at a later time by written notice. ITEM 17 – VOTING CLIENT SECURITIES (PROXY VOTING) When you open a Transamerica® ONE or TFA365 Advisory account, you are responsible for directing the manner in which proxies for the securities held in your account are voted. TFA does not vote proxies on behalf of our clients in Transamerica® ONE, or TFA365 Advisory, including those managed by TPMMs. You should refer to the TPMMs’ disclosure documents for a complete description of their proxy voting procedures. These documents will explain whether you will receive proxies or other solicitations directly from the custodian or a transfer agent. When you open a Transamerica® ALPHA account, you delegate to Betterment the authority to receive and vote all proxies and related materials for any security held in Betterment accounts. Betterment will do so in a way that is reasonably expected to ensure that proxy matters are conducted in the best interest of clients. Betterment will only vote on proxies and respond to corporate actions associated with securities that Betterment recommends be purchased for client accounts. Clients may request information regarding how Betterment voted a client’s proxies, and clients may request a copy of Betterment’s proxy policies and procedures, which may be updated from time to time, by emailing support@betterment.com. ITEM 18 – FINANCIAL INFORMATION To the best of TFA’s knowledge, we are not aware of any financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. TFA has not been the subject of a bankruptcy petition at any time, including any time during the past ten years. 32