Transamerica Financial Advisors, LLC

ITEM 1 – COVER PAGE Form ADV Part 2A – Appendix 1 TFA365 Advisory Program Brochure March 31, 2026 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 -3271. The information in this Brochure has This Form ADV Part 2A – Appendix 1 (“Wrap Fee Brochure” or “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, plea se contact us at (770) 248 not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. www.adviserinfo.sec.gov (select Additional information about TFA is also available on the SEC’s website at “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. 2  ITEM 2 – MATERIAL CHANGES Item 2 provides a summary of material changes that were made to this Brochure since its last annual amendment on March 28, 2025. Below is a summary of the material changes: backed lending arrangement became available. • TFA disclosed a securities • A default bank deposit sweep program was added to all accounts with free cash balance. When TFA updates this Brochure with material changes, TFA will either send you a copy of the updated Brochure 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 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. 3  ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE ..................................................................................................................................... 2 ITEM 2 – MATERIAL CHANGES .......................................................................................................................... 3 ITEM 3 – TABLE OF CONTENTS ......................................................................................................................... 4 ITEM 4 – SERVICES, FEES AND COMPENSATION............................................................................................... 5 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................ 14 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION.................................................................... 14 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ...................................................... 15 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS ............................................................................ 15 ITEM 9 – ADDITIONAL INFORMATION ............................................................................................................ 15 4  ITEM 4 – SERVICES, FEES AND COMPENSATION er (“RIA”) and -dealer and has been a member of the Financial “FINRA ”) since 1984 as well as a member of the Municipal Securities Rulemaking The Company Transamerica Financial Advisors, LLC (“we/our/us/TFA”) is a federally registered investment advis has been registered with the SEC since 1991. TFA is also a broker Industry Regulatory Authority ( Board ( “MSRB ”). -related products and advisory and asset management services to the retail public. TFA /FPs ”) also act in the (“RRs”) respectively. When TFA or an IAR is acting in a those TFA offers investment and some of its investment adviser representatives (“IARs or Financial Professionals capacity of broker -dealer and registered representatives broker-dealer or registered representative capacity rather than providing investment advisory services, the fiduciary standard applicable under the Investment Advisers Act of 1940 generally does not apply to brokerage activities. “NYSE ”) and trading under the TFA is directly owned by AUSA Holding, LLC, which is an indirect, wholly owned subsidiary of the ultimate parent, AEGON Ltd, a publicly traded company listed on the New York Stock Exchange ( symbol AEG. -party money managers who manage model portfolios on -based investment management. TFA’s Advisory Services Offered In its capacity as an RIA, TFA offers access to third behalf of clients and wrap fee programs that offer clients access to fee advisory services are made available to cl ients through individuals registered with TFA as IARs. . TFA IARs other advisory services described in other Brochures. For more detailed information about The information in this Wrap Fee Brochure only pertains to the TFA365 Advisory Program (“TFA365”) can offer clients these programs, IAR s can provide clients with a copy of TFA’s Form ADV Part 2A or it can be accessed directly by visiting TFA’s public website at www.tfaconnect.com . tegies, if any. The IAR will then provide the client with investme nt advice At the time of or prior to offering advisory services, an IAR will meet with the client to collect and analyze financial information to determine the client’s financial needs, time horizon, risk tolerance, investment objectives, and current investment stra based on the analysis. TFA and its IARs do not provide legal, tax, or accounting advice. , including stocks or bond certificates or cash. When the client should only make any check (“NFS”). Client s should never make checks payable to their IAR or any TFA does not take custody of client funds or securities providing funding for a client’s account, if the client is using a check, payable to National Financial Services, LLC entity other than NFS . -sharing plans, trusts, estates, charitable organizations, TFA365 TFA365 is available to individuals, pension and profit corporations, and other business entities. TFA has entered into an agreement with Fidelity Institutional Wealth Adviser LLC (“FIWA”), whereby F IWA will administer and act as Platform sponsor of the TFA365 Advisory 5  Program using the Fidelity Managed Account Xchange managed account platform (the “FMAX Platform” or “FMAX”). provides to TFA365. NFS is the broker -dealer and custodian for TFA365 directing purchases and 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 client assets in connection with the services it accounts; securities transactions will be executed through, and assets held at, NFS. Envestnet Asset Management, Inc. (“EAM”), an unaffiliated investment adviser, will be responsible for sale transactions to NFS. EAM will periodically direct one or more transactions for client accounts when rebalancing is required. Rebalancing is the process of buying and selling portions of a model portfolio to adjust the weight o f each asset class to the original asset allocation model portfolio. NFS attempts to obtain the best execution; 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 orders, or seek ently as possible and at the best price. execution of transactions as effici their stated investment objectives would be best met by using the TFA365 the client in completing the electronic and/or written materials required to open the account; If a client ’s IAR determines that platform, the client ’s IAR will assist them in opening an account. The c lient’s IAR will also explain the investment management process, investment objectives, and the investment strategies undertaken as part of the service; review and assist and answer questions about the program. current investment IARs provide ongoing monitoring of client portfolios in investment advisory programs. IARs will contact advisory clients at least annually to determine whether the account continues to align with the client’s objectives and financial circumstances . TFA365 consists of three different programs which IARs may recommend to their clients As named Intermediatory, TFA has full discretion and sole responsibility to determine the services, features and investments of TFA365. which are summarized below : exchange -traded funds provide clients with access to investment strategists who -increasing demands of today’s investors. FSP TFA365 Advisory Strategist Program This Program consists of turnkey asset allocation portfolios using mutual funds and (“ET Fs ”). Fund Strategist Portfolios (“FSPs”) construct distinct portfolio solutions to help meet the ever 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. -asset class -party or TFA365 Advisory Separately Managed Account Program This Program provides access to institutional asset managers who implement a single or multi strategy utilizing individual securities, ETFs, bonds, and/or mutual funds. A Separately Managed Account Program (“SMA”) can refer to several different types of investment accounts managed by third independent investment management firms. 6  funds, and ETFs. A Unified Managed Account Program TFA365 Advisory Unified Managed Account Program This Program offers a single account that provides the greatest degree of customization, allowing the ability to combine multiple SMAs, FSPs, individual mutual (“UMA”) offers a single account with investments designed to meet a client’s specific investment needs. For IAR will select the frequency in which the client’s account will be IAR . Within each TFA365 Advisory Program model portfolio, the client owns the 2A titled Fidelity A client’s IAR will assist them in selecting the Program that meets their investment goals and objectives. the UMA Program, the client and their rebalanced to the original allocation weightings. Clients should discuss the frequency and preferred rebalancing timing with their underlying securities in their account. Please refer to the current FIWA Form ADV Part Managed Account Xchange for additional details. ST , ny order processing capacity, market For UMA portfolio updates or changes submitted by TFA to FIWA via the FMAX Platform before 1:00 p.m. E FIWA shall rebalance on the same business day. For model updates or changes submitted by TFA after 1:00 p.m. E ST , 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 compa c onditions 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.” 99, other tax related documentation, and any other legally required 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 10 information. nds, and exchange traded products. For a complete listing of the securities 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, bo that may be used in a clients model portfolio, please consult the FIWA Form ADV Part 2A titled Fidelity Managed Account Xchange® for additional details or the Portfolio Manager’s F orm ADV Part 2A or other Disclosure Brochure(s). ion (“SIS”) on file with TFA. Any changes to allocations outside of the a new SIS. Clients also give FIWA s the client to complete ations and restrictions at the Clients who open TFA365 Advisory accounts grant TFA and their IAR the discretionary authority to replace model portfolios, mutual funds, and ETFs so long as the changes match the client’s risk tolerance noted on their current Statement of Investment Select client’s current stated risk tolerance require discretionary authority to conduct trading. Clients may impose reasonable limit time of opening an account or later by written notice to their IAR. tionship at its discretion and upon notification to the client pursuant to the 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 rela notification terms in the applicable Advisory Brochure and this Appendix. 7  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. their accounts and is responsible their accounts. EAM also provides overlay FIWA has retained EAM, to provide model implementation, overlay management, and other administrative duties. Clients agree and acknowledge that EAM will have discretionary authority over for the implementation of models received from model providers in 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 additiona l 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 . -tax returns. Values Overlay a client’s tax professional. Clients 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 allows FIWA to integrate ESG fact ors and other client -directed priorities into their investments based on a client’s IAR , the Implementation Manager provides the Tax request. If selected by the Client after discussion with their The Tax Overlay services are designed to enhance Overlay or Values Overlay (or both) services to an account. 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 should discuss any general questions they may have with their IAR . -kind into a clients’ account typically upon receipt. The will treat the transfer of securities into the account as an instruction -kind assets into an ure point in time unless explicit special the client prior to funding. In certain circumstances, clients will have a taxable -kind assets into a TFA365 account. IAR s EAM will liquidate securities that are transferred in Implementation Manager has the authority to liquidate such assets, and absent special circumstances or direction from TFA, Implementation Manager to liquidate the securities at market price. Clients should thus be aware that if they transfer in account, EAM will liquidate such assets immediately or at a fut instructions are received from event when the Implementation Manager liquidates such assets. Accordingly, clients should consult with their IAR and seek tax advice from their tax consultant before transferring in do not provide tax advice. IAR will not provide advice Clients, at their request, may hold “unsupervised” assets within their account. The 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 a client’s custodial statement and be subject to the custodial platform fee and brokerage terms and conditions. a client’s elections, they will either receive trade Bank Deposit Sweep Program , Depending on -by-trade confirmations from NFS for any transactions in their account or quarterly trade confirmations; however, with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the a client’s account statement serves in lieu of a confirmation. 8  clients wish to receive paper statements, which 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 on. Statements and confirmations are also available online at Fidelity.com and gain/loss and tax basis informati by enrolling in electronic delivery. Clients should carefully review all statements and other communications in connection with their 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 will be subject to a fee, the client should contact their IAR . account can participate in TFA ’s securities backed lending allows -purpose loans. C lients are allowed tment account declines, clients may be required to provide additional C lients with a TFA365 Advisory Program arrangement with a third-party lender (“Lending Sponsor”) . The securities backed lending arrangement clients to use certain advisory accounts as collateral to obtain secured non 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 inves collateral, or the Lending Sponsor may force the sale of the securities in the acc ount to repay the loan. have a direct financial incentive to recommend the Lending Sponsor tinue earning advisory 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 IARs and IARs do not over other lenders, both TFA and its IARs may still be incentivized to recommend borrowing over asset liquidation. This is because maintaining account assets allows TFA and its IARs to con fees because the assets remain in the account . advisory account, TFA in conjunction with its clearing broker, NFS, ank, it is protected by FDIC If you have a non -retirement account, a client may opt out of the Bank Deposit Bank Deposit Sweep Program If you hold uninvested cash in your TFA365 automatically transfers these amounts into interest bearing deposit accounts at participating FDIC insured banks (the “Bank Deposit Sweep Program”). When cash is swept to a participating b insurance up to applicable limits and is no longer covered by SIPC. The Bank Deposit Sweep Program is the default option for uninvested cash. Sweep Program when you open your account or anytime thereafter by contacting your IAR. a client receive s is lower than the return the client the client . This results in lower returns to the client than the client’s uninvested cash. This creates a significant conflict of interest clients’ cash in the Bank Deposit Sweep Program instead of clients a higher yield. TFA addresses this conflict of interest through a Sweep Program, associated conflicts of clients’ uninvested cash is available in the Bank Deposit Sweep Under the Bank Deposit Sweep Program, TFA, not the participating banks, sets the interest rate you receive. TFA’s rates are not always the highest available. The interest rate could earn through other available cash options. TFA receives compensation from the participating banks that in most cases will be higher than the interest paid to alternative investment options for because TFA has a financial incentive to keep recommending alternatives that may pay combination of disclosures and policies and procedures regarding Bank Deposit Sweep Program availability and the free -credit balance. More information about the Bank Deposit interest, and a lternative investments for Disclosure document available at https://www.tfaconnect.com/disclosure s or you can contact your IAR. 9  While client information is considered confidential, it will be provided to Fidelity, EAM and NFS as required to open and maintain advisory account s , as described in TFA’s Privacy Policy. the Termination For TFA365, the Client Services Agreement will continue in effect until the client or TFA terminates it by giving The written notice pursuant to the specific terms found in this Brochure, effective as of the date of the notice. Client Services Agreement will also terminate should the agreement between TFA and Fidelity terminate. Upon termination, neither TFA, nor its IAR, will have any obligation to recommend or take any action regarding securities, cash, or other investments in the TFA365 Advisory Program account. TFA365 under the custody of NFS until the client provides the required account Upon termination of the Client Services Agreement with TFA, account assets held within the client’s Advisory Program account will remain transfer instructions to Fidelity. Terminated accounts will be closed in accordance with one of the scenarios described below: . TFA may terminate any account with thirty (30) days’ notice or earlier if the client’s address of record the clients choice which may cause a taxable event, or b) to a non -advisory TFA brokerage account. Advisory or institutional share Terminations initiated by TFA provided for under the law. If the client fail s to provide written instructions for account disposition within thirty (30) day period, the account will be a) liquidated and the proceeds mailed to then on file with TFA or to an intermediary of transferred in -kind, if possible, classes may not be available in such non -advisory accounts. . If the client elect s to voluntarily terminate their Service Agreement and (30) days or their account the client’s address of record then on file with TFA regardless Terminations initiated by the Client account, the client must provide instructions for account disposition within thirty will be liquidated and the proceeds mailed to of tax consequences. , but not limited to, certain brokerage fees Termination of any account may incur additional charges, including associated with the client ’s 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 the client . and a protective decree would need the client , as of such date, Bankruptcy . Should TFA need to file for protection under bankruptcy laws to be issued under the Securities Investor Protection Act (SIPA), any fees owed by shall be collected by Fidelity from the client’s account as described in this Brochure. the Client’s account will also be subject to certain service fees separate from the Total Program Fee that client pay s . Refer to the Fees and Compensation section below for additional information. 10  . It is important to us that clients Fees and C ompensation TFA and IARs receive compensation through several different methods understand how both TFA and its IARs are compensated, along with any other costs or fees associated with their advisory accounts . include three components: (1) the IAR’s fee, (2) the Platform fee, and The client will pay a Total Annual Program Fee (“Total Program Fee”) as outlined in the TFA365 Advisory Program Fee Schedule below. The Total Program Fee (3) the Portfolio Manager fee . the client and their IAR . The IAR fee may be more than what a client’s account, the IAR fee portion of the Total the client’s IAR the client’s IAR may have a financial incentive to recommend Negotiable Fees While we have a maximum fee that can be charged to manage Program Fee is negotiable between would receive if the client participated in our other advisory offerings or paid separately for investment advice, brokerage services, or other services. Therefore, TFA365 over other advisory offerings or services. the client should consider when negotiating the the client’s financial situation, their specific investment objectives, IAR fee with their IAR . These include needs, and their IAR the client currently own The client and their IAR should also consider the the client’s needs as well as any involvement between but rather serves as a guideline for the client to IAR fee with their IAR . The client’s advisory fees may be higher or lower than those There are many factors that such things as the complexity of risk tolerance. Other factors that would be appropriate to consider include the programs or services offers and the amount of time and due diligence necessary to research both investments as well as recommendations for any future investments. frequency of meetings and contact necessary to serve their IAR and the client’s other professional service providers, such as accountants and attorneys. This is not meant to be an exhaustive list of the items to be considered consider when negotiating the paid by other clients who are also participating in TFA365 based on this negotiation. the client and their IAR re-negotiating the IAR Fee. If the Total Program Fee may also increase or decrease if a Portfolio The client’s Total Program Fee may change based upon client and their IAR negotiate a new IAR Fee, the client will be provided a new Statement of Investment Selection (“SIS”) with the client ’s new Fee Schedule. The Total Program Fee may also change based upon TFA’s discretion to change the Platform Fee at any time. The Manager changes their fee or upon a reallocation to Portfolio Managers with different fee schedules. The Platform Fee and the separate Portfolio Manager Fee, if applicable, are not negotiable. by aggregating eligible accounts on the TFA365 they may have about their Multi-Account Discount The client may take advantage of reduced advisory fees Advisory Platform . The client should consult with their IAR regarding any questions eligibility. Clients Pay their Advisory Fees in Advance The Annual Total Program Fee is billed monthly in advance. Advisory fees are computed based on the prior month’s average daily balance. The applicable Total Program Fee will be determined based on the amount of 11  the client’s TFA365 account. Fidelity will deduct its fees and fees related to TFA365 from the be clearly noted in the client ’s statement. Please refer to the fee a client’s advis ory account. If a client terminate s their assets held in client’s 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 schedule below. Fees are automatically deducted from account prior to the end of month, the client will be issued a prorated refund of any advisory fees. TFA has established the following tiered fee schedule for Program participants that results in a blended rate. TFA365 Advisory Annual Total Program Fee Schedule Maximum Maximum Portfolio Maximum Annual Range of Assets 1 Investment Advisor Platform Fee 3 Manager Fee 4 Total Program Fee 5 Rep Fee 2 $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% >$1,000,000 - 1.25% 0.38% 0.00% - 1.00% 2.75% $2,000,000 >$2,000,000 - 1.25% 0.34% 0.00% - 1.00% 2.75% $5,000,000 >$5,000,000 1.25% 0.33% 0.00% - 1.00% 2.75% . Please refer to the fees on each program stated in this ity for 1 The initial minimum account size for TFA365 accounts differ by Program Brochure. 2 This fee can be negotiated with the client’s IAR. 3 TFA receives a portion of the Platform Fee as the Program sponsor, and the remainder of the Platform Fee is retained by Fidel FMAX Platform Fees. 4 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 selected by the cl ient, ion. t on the client should refer to the applicable Portfolio Managers Form ADV Part 2A or other disclosure documents for more informat 5 Fees are expressed as an annual percentage of assets under management. The Annual Total Program Fee to the client is dependen the model portfolio(s) selected and the negotiated IAR Fee. The client may also incur certain charges imposed by third partie s other than by TFA and its IARs in connection with investments made through client’s account. In addition to the redemption fees described above, client may incur redemption fees when TFA, Implementation Manager or Port folio Manager determines that it is in client’s overall best interest, in conjunction with the stated goals of the investment strat egy, to divest from certain funds prior to the expiration of the minimum holding period of the funds. Some mutual funds also assess redemption fe es to clients upon the short -term sale of its funds. Depending on the particular mutual fund, this may include sales for rebalancing purposes. Please 12  TFA365 Advisory Strategist Program Minimum Account Value: $10,000 Below Minimum Annual Account Fee : $35 TFA365 Advisory Separately Managed Account Program Minimum Account Value: $ 250,000 TFA365 Advisory Unified Managed Account Program Minimum Account Value: $ 10,000 Below Minimum Annual Account Fee : $35 below Below m inimum 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. account fees are expressed in annual amounts but are determined and assessed based on the account asset value at the end of each month. TFA, at its discretion, may waive the Minimum Account Value . in 30 days from the date of the fee rmore, Changes in Fees Upon 30 days prior notice to clients, TFA may, at its discretion, revise any aspect of the Total Program Fee which include three components: (1) the IAR’s fee, (2) the Platform fee, and (3) the Portfolio Manager fee. Revisions may include an increase in th e fees payable by the client. Clients will be deemed to have approved a fee change unless they object to the fee change by sending written notice pursuant to the Notice section in the Client Services Agreement and/or applicable Program Brochure to TFA with 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. Furthe TFA employees and employees of affiliates may be entitled to fee discounts by virtue of their employment. a securities backed lending program through third -party bank s . The securities - Securities Backed Lending Fees Clients may be offered access to backed lending arrangement allows clients to use certain advisory accounts as collateral to obtain secured non purpose loans. Clients are allowed to borrow against the value of their investment account for purposes other than the purchase of additional securities. Securities used as collateral in a loan are subject to liquidation if the see the prospectus for the specific mutual fund for detailed information regarding such fees. To the extent that such fees ar e 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 d ebited from the account(s), TFA, Implementation Manager or discretionary Portfolio Managers may sell any amount of the assets held in client’s TFA365 acc ount 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 a client may incur. The cost of investment advisory services provided through the TFA365 Advisory Program may be more or less than the cost of pu rchasing similar services separately or from another registered investment advisor. 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, other instruments, cash or cash equivalents. 13  This type of value falls below maintenance levels, which may negatively impact the client's investment strategy. lending can provide quicker access to funds without selling securities. servicing the loan and regulatory reporting. Compensation can be IARs have Clients are not obligated to partici pate in the lending program and 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 up to 25 basis points of the outstanding loan amount. A conflict of interest exists because TFA and its an incentive to recommend such programs. should consider the risks, including the possibility of liquidation of pledged assets, and tax implications. uninvested cash in TFA365 advisory significant conflict of interest because TFA has a financial incentive to nding alternatives that may pay Bank Deposit Sweep Program TFA in conjunction with its clearing broker, NFS, automatically transfers accounts into interest bearing deposit accounts at participating FDIC insured banks (the “Bank Deposit Sweep Program”). TFA receives compensation from the participating banks that in most cases will be higher than the interest paid to the client. This results in lower returns to the client than alternative investment options for the client’s uninvested cash. This creates a keep clients’ cash in the Bank Deposit Sweep Program instead of recomme clients a higher yield. TFA addresses this conflict of interest through a combination of disclosures and policies and procedures regarding Bank Deposit Sweep Program availability and the free -credit balance. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS -sharing plans, trusts, estates, TFA provides investment advisory services to individuals, pensions, profit charitable organizations, corporations, and other businesses. , a client must complete a new investor account profile which provides TFA with birth, and other information used to identify the client . TFA will the client’s The client will also complete a To open a TFA365 account information such as client name, address, date of use third -party sources to verify and/or update the information provided and may also request to see driver’s license or other identifying documents in compliance with federal law. Client 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. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION Investment Strategy, Fund Research and Due Diligence investment research ratings: Available, Meets -Quantitative, 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 Strategists, SMAs and mutual funds using four categories of Meets -Qualitative, and Preferred. Generally, TFA will offer only a curated list of strategies that are FIWA rated 14  “Meets-Quantitative ”, “Meets-Qualitative” , and “Preferred ”. However , TFA may offer “Available” strategies if the strategies meet TFA’s due diligence requirements. FIWA’s investment research and due diligence is provided to TFA’s Investment Committee for review. If a model portfolio or mutual fund is underperforming for an extended time, the Investment Committee will then decide if removal of a particular model portfolio, Portfolio Manager or mutual fund from TFA365 Advisory Program is warranted. clients to read each Portfolio 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 Manager’s Brochure, Form ADV Part 2A and/or mutual fund prospectus prior to selecting a Portfolio Manager and/or mutual fund in TFA365. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS . TFA shares this nonpublic information with The client’s IAR will assist the client in completing a risk tolerance questionnaire , which collects information such as financial information, investment objectives, and risk tolerance Portfolio Managers consistent with the disclosures made in TFA’s Privacy Policy . ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Generally, clients will not have any direct contact or consultation with their Portfolio Manager. ITEM 9 – ADDITIONAL INFORMATION Material Investment Risks e greater exposure to risks such as TFA’s advisory programs offer multiple model portfolios to satisfy a wide variety of investment and risk profiles, ranging from aggressive portfolios to conservative. In general, the advisory programs offered through TFA are subject to the risks noted belo w. However, model portfolios that have higher concentrations in equity investments are generally subject to greater risk, such as stock market volatility and foreign exposure. Model portfolios that have a higher concentration in fixed income securities hav credit, interest rate, and liquidity. Risk of Loss: Although TFA works hard to preserve client’s capital assets and help clients achieve their investment objectives, investing in Investment Products involves a risk of loss to principal (invested amount) and any unrealized profits . Certain model portfolios impose more risk than others. TFA and its IARs will strive to provide investment advice for client’s assets to the best of our ability; however, we cannot guarantee any level of performance or prevent losses in account assets. All investments in securities include a risk of loss of pri ncipal and any unrealized profits. Stock and bond markets fluctuate over time. Clients should be prepared to lose money in any investment account. Investments are not a bank deposit and are not insured or guaranteed by the Federal Deposit Insurance Corpora tion or any other government agency. Clients 15  poses risks, and may lose money by investing in investment products. Each investment strategy offered by TFA 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 im pact of borrowing against their investment portfolio, including the potential for loss of principal, interruption to their investment strategy, and tax consequences. -U.S. markets through either direct exposure or default, and model portfolios that concentrate in particular industries or are Investments and accounts are also subject to volatility in non 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 otherwise subject to particular segments of the market may be significantly impacted by events affecting those industries or markets. In addition, the investments in advisory account s may be subject to the following specific risks: Account bears all the risk of the investment strategies employed by the Investing in Mutual Funds and ETFs: mutual funds and ETFs held in the 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. “ESG ”): nalysis when considering a particular issuer or security, while others ments available in a strategy and cause Investing in Environmental, Social and Governance ( 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 a 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 invest 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 selecte d in an ESG based strategy may not or may not continue to demonstrate ESG based characteristics. and Cybersecurity: y providers. The possible to provide fool -proof protection against all such events, Certain investment activities and investment strategies are Reliance on Technology dependent upon 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 utilit 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, telecommunicatio ns 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 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 TFA, Fidelity, EAM, and/or a Model Manager from 16  trading, modifying, liquidating, and/or monitoring its clients’ investments. In addition, clients should be aware of the risk of cyber -attacks and harm to technology infrastructure and data from misappropriation or corruption . EAM take proactive s 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 them is -attack or other information security event. Although TFA, Fidelity, and subject to a cyber measures and endeavor to modify them as circumstances warrant, computer systems, software, and networks may be vulnerable to unauthorized access, issues, computer viruses or other malicious code, and other event 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. unds’ investors, mistaken calculations of the funds’ true Operation Risk: Every ETF and mutual fund are investment companies that are run by an adviser and a board of directors that are 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 f value, or 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. s may drop in re sponse to tangible and intangible Market Risk: The price of investments in advisory account 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. ral disasters, and other circumstances in one country or region could be here in this section will likely quidity Economies and financial markets throughout the world are increasingly interconnected. Economic, financial, or political events, trading and tariff arrangements, terrorism, war, global conflicts, epidemics, pandemics, technology and data interruptions, natu 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 elsew increase. As a result, whether investments are in securities of issuers located in or with significant exposure to the countries directly affected, the value and liquidity of investments may be negatively affected. Also, li of individual investments, or even entire market segments, can deteriorate rapidly, particularly during times of market turmoil making those investments more 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 erod es 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. 17  Future proceeds from investments may be reinvested at a potentially lower rate of return Reinvestment Risk: (i.e., interest rate). could be considerably greater than if the client did not 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 concentration area concentrate their investments to such an extent. Business Risk: These risks are associated with a particular industry or a particular company within an industry. and bad times. During periods of financial stress, the 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 inability to meet loan obligations may result in bankruptcy and/or declining market value. Portfolios that invest in fixed income securities are subject to several general risks, Fixed Income Risk: including interest rate, credit, and market risk, which could reduce a client’s yield. These risks may occur from fluctuations in interest rates, a change in an issuer’ s individual situation or industry, or general market events. instrument’s credit quality or value. Lower quality debt Credit Risk: Changes in the 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 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. ion, or emerging market. Foreign markets may be more volatile than differently than U.S. market s . Emerging markets can be subject to greater social, 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, reg U.S. markets and can perform economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates may also be extremely volatile. Tax Risk: Securities may be bought and sold without regard to a client’s individual tax ramifications. Therefore, -tax return. portfolio turnover could cause a client to incur tax obligations that negatively affect the after Tactical asset allocation is an investment strategy that actively adjusts a er strategies using other asset ial, and other factors) or - This strategy may not work as intended. The sub -adviser’s evaluations and Tactical Asset Allocation Risk: 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 oth 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, financ strategic asset allocation (a strategy that involves periodically rebalancing the fund in order to maintain a long term goal for asset allocation). 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 18  - 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 ies and regions, and industries may change at any time based on the sub particular asset classes, countr adviser’s allocation decisions. Disciplinary Information -dealer and a federally registered investment adviser. In the last ten years, TFA has had SEC, and one involves an action TFA is both a broker three material disciplinary events. Two events involve actions brought by the brought by 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 12 b-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 rel evant 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 e case were managed -Squared Investments, Inc. (“F - –Conservative, Global Tactical certain of its affiliates (“Order”). As to TFA, the Order relates to, among other things, errors in certain models -Series and Transamerica ONE programs. The Order also states that the used by TFA in its Transamerica I 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 th by an affiliate, AEGON USA Investment Management, LLC (“AUIM”) and by F Squared”). The models managed by AUIM were the Global Tactical Allocation Allocation –Balanced, Global Ta ctical Allocation –Growth, Tactical Fixed Income, Global Tactical Income and -Squared were the AlphaSector Rotation Index, Global Tactical Rotation models. The models managed by F 19  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. -judgment interest, and to cease and desist from violating ement, interest and penalties have been paid to a Fair -Series and Transamerica ONE programs f rom July 2011 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 certain securities laws and regulations. The disgorg 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 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. nd the named affiliates had voluntarily retained a compliance een e policies and procedures. The SEC also considered 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 a 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 b 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 complianc 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 a Letter of Acceptance, Waiver and Consent in which TFA ent products – A copy of this Order is available on FINRA’s website a t 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 differ 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. www.finra.org/rules -guidance/oversight -enforcement/finra -disciplinary -actions -online . Other Financial Industry Activities and Affiliations -dealer. In addition, the majority inancial Group Insurance Agency, Inc. (“WFGIA”), an affiliated insurance TFA is a member of the Transamerica group of companies. Most of TFA’s IARs, members of management, and Investment Committee members are also registered with TFA’s affiliated broker of TFA’s IARs are affiliated with World F agency. 20  registered index -linked issued by companies affiliated with -affiliated products. As a result, TFA h as a financial on-affiliated products. Affiliated Products may also -party money managers (“TPMMs”) or model managers used in TFA advisory TFA makes available variable universal life insurance products, variable annuities, annuities, mutual funds, 529 plans, ETFs and unit investment trusts (“UITs”) TFA (“Affiliated Products”). When clients purchase Affiliated Products, TFA and/or its affiliates receive additional fees or compensation that are not received for the sale of non incentive to recommend Affiliated Products over similar n be accessed through third programs. -based id by clients with TFA, which creates conflict of interest because TFA has contractual relationships with TPMMs that are independent investment advisers offering fee advisory programs. These relationships were described in Item 4. These TPMMs are not affiliated with TFA. TPMMs share a portion of the advisory fees pa TFA has an incentive to recommend TPMMs that compensate TFA. In some cases, the cost of these arrangements may be higher than other advisory options. r our affiliates receive additional fees and compensation -affiliated products. Many of programs. -affiliated products. TFA mitigates this Some of the insurance and annuity products and mutual funds that TFA makes available are Affiliated Products. Affiliated Products are issued by one of our affiliated companies. In addition to any commission associated with purchasing the product, TFA and/o related to Affiliated Products that TFA does not receive in connection with non these products can be purchased by the various TPMMs or Model Managers available in TFA’s Because TFA and/or our affiliates make additional money when TFA and IARs sell Affiliated Products, TFA has an incentive to recommend these Affiliated Products over similar non conflict by supervising all recommendations made by IARs. that are also investment advisers offering fee -based advisory programs. These placing client’s assets with one TFA has contracts with TPMMs relationships were described in Item 4. These TPMMs are not affiliated with TFA, and they pay TFA a portion of the fees clients pay to them. This is considered a conflict of interest. The cost of of these TPMMs may be higher than placing the assets in another advisory account. TFA offers access to securities backed lending programs through third party lenders. TFA receives compensation from the lending sponsors, which creates a conflict of interest. Please refer to Item 4 for a description of these conflicts and related risks. TFA offers a bank deposit sweep program as its default option for uninvested cash in your accounts. TFA receives compensation from the banks involved in the program. Please refer to Item 4 for a description of the conflicts related to this program. AEGON Ltd. Affiliates Under Common Control with TFA and the following entities are indirect, wholly owned subsidiaries of AEGON Ltd. Broker -Dealers • Transamerica Investors Securities Corporation • Transamerica Capital, LLC (“TCL”) TCL serves as principal underwriter and wholesale distributor for certain variable annuity and life 21  insurance products issued by affiliated insurance companies. TFA receives compensation under selling agreements for these products, creating a conflict of interest. Investment Company • Transamerica Asset Management (“TAM”) TAM 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. Registered Investment Advisers • Transamerica Asset Management, Inc. (“TAM”) • AEGON USA Investment Management, LLC (“AUIM”) • Transamerica Retirement Advisors, Inc. (“TRA”) -dealer capacity, TFA receives revenue -sharing compensation when clients Other Affiliated Companies TFA has material relationships with certain product sponsors, including affiliated insurance companies and agencies. In its broker purchase products through these sponsors. Current revenue -sharing arrangements and sponsoring companies are disclosed on TFA’s website at www.tfaconnect.com under Indirect Compensation Disclosure and Sponsoring Companies List . • Transamerica Retirement Solutions, LLC Transamerica Retirement Solutions, LLC (“TRS”) TRS is a retirement services firm offering a range of services, including recordkeeping, participant education and communications, Plan design, Plan testing, general ERISA, and IRS compliance. • WFG Securities of Canada (WFGS) WFGS offers mutual funds and referral arrangements in Canada. Affiliated insurance companies and agencies include: • Transamerica Premier Life Insurance Company • Transamerica Life Insurance Company • Transamerica Financial Life Insurance Company • World Financial Group Insurance Agency, Inc. • World Financial Group Insurance Agency of Hawaii, Inc. • World Financial Group Insurance Agency of Massachusetts, Inc. • WFG Insurance Agency of Puerto Rico, Inc. • World Financial Group Insurance Agency Canada Inc. affiliated products or Conflict Management The a ffiliations described above create financial incentives to recommend certain services. TFA addresses these conflicts through disclosure and supervisory oversight of 22  recommendations made by its IARs. IARs may also be licensed insurance agents and offer fixed insurance products through these affiliated agencies. When clients purchase fixed insurance products, the affiliated agencies receive commission compensation. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading TFA has adopted a Code of Ethics (“Code”) designed to ensure that TFA meets its fiduciary obligation to clients advisory services with the highest level of ethical standards, and our prospective clients, that TFA conducts its and that TFA instills a culture of compliance within our firm. ust acknowledge their understanding of and agreement to abide by the The Code applies to TFA Access Persons, defined as TFA IARs, directors, officers, and other persons who are subject to TFA’s supervision. It is distributed to Access Persons at the time of becoming an Access Person and annually thereafter. Access Persons m Code. TFA supplements the Code with annual training and ongoing monitoring of the activity of Access Persons. TFA’s Code outlines the duties of Access Persons, including requirements to: • maintain TFA’s reputation as a firm that operates with the principles of honesty, integrity, and professionalism; • comply with applicable federal and state securities laws; • read, know, understand, and follow all policies and procedures prescribed by TFA manuals, bulletins, or supervisory directives; • cooperate with any investigation or inquiry conducted or authorized by TFA Management and/or Supervisory Personnel; • follow TFA’s Privacy Policy and related procedures; and • report personal securities transactions by obtaining approval for outside brokerage accounts and reporting such accounts as described in the Code Additionally, the Code prohibits Access Persons from actions such as: • purchasing or selling securities for their own accounts or others while in the possession of information which might be considered “insider” (material, non -public) information or discussing the information with a third party; • participating in any Initial Public Offering or Private Securities Transaction; and • accepting or offering inappropriate and/or excessive gifts, favors, entertainment, special accommodations, or other things of material value. Any Access Person not complying with these guidelines may be subject to disciplinary action up to and including termination. Clients may request a complete copy of our Code by contacting TFA at the address or telephone 23  number displayed on the cover page of this Brochure. Review of Accounts IARs provide ongoing monitoring of client portfolios in investment advisory programs. IARs will contact advisory clients at least annually to determine whether the account continues to align with the client’s investment objectives and financial circumstanc es . Clients 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 clients to carefully review these reports and compare custodial statements with performance reports, if applicable. The information in performance reports may vary from custodial statements due to accounting procedures, reporting dates, or valuation m ethodologies of certain securities. In the event of any discrepancies, clients should rely on the statements they receive from the custodian of the assets. performance reports. he custodian of the account to In addition to account statements and transaction confirmations, clients may receive Periodically, clients may receive Albridge Personalized Account Statements directly from their IARs. These reports and statements may include lists of account holdings, including mutual funds and securities, but are not e clients to compare these reports and statements to the official account official account statements. We urg statements of their account holdings provided to them at least quarterly by t ensure that the holdings listed on these reports provided by the IAR match those reflected on the official custodial account statements. Client Referrals and Other Compensation Registration Arrangements broker-dealer . If an IAR is also a TFA Registered -dealer. variable universal life insurance -linked annuities, mutual funds, 529 plans, ETFs, and UITs . All sales us, which clients will receive at or before the time of Many of TFA’s IARs are also Registered Representatives of TFA’s Representative, they may recommend that clients place securities transactions through TFA’s broker These transactions could include, but are not limited to, the purchase or sale of products, variable annuities, registered index charges and expenses are disclosed in the product prospect the purchase of the product. Marketing Compensation Arrangements s , Portfolio Manager s , or other service provider s may t services, industry trends, and other issues; and be cause TFA Each of the TPMMs, Portfolio Managers, or other service providers may attend, contribute to, or sponsor education and training meetings for our IARs. TPMM 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 IARs with education on investments, their investment managemen benefits from these contributions and reimbursements. Other Compensation Arrangement s WFGIA , they are permitted to participate in award and incentive programs If an IAR is associated with sponsored by WFGIA in which they could qualify to receive trips, promotions, or non -cash compensation based 24  on their volume of fixed insurance sales. These events may influence their decision to recommend particular fixed insurance products to clients. -cash compensation based on the f non-cash compensation, a conflict of interest exists in connection with s to help defray these expenses. Some IARs may participate in incentive trips and receive other forms of non amount of their sales and services through TFA or product providers. To the extent an IAR participates in an incentive trip or receives other forms o the IAR’s recommendation of products and services for which they receive these additional economic benefits. TFA allows IARs to receive marketing reimbursements from product provider TFA does not require or have any expectation that IARs refer clients to or place assets with such providers. TFA monitors recommendations made by its IARs to ensure that they are in each client’s best interests. revenue sharing compensation from a third -party lender when its clients engage in securities TFA receives backed lending. TFA also receives fees from its arrangement with its Bank Deposit Sweep Program sponsor. Such arrangements create conflicts of interest which we disclose to clients and manage through TFA’s policies and procedures. 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. 25 

Form ADV Part 2A – Appendix 1 Transamerica ONE Wealth Management Wrap Fee Brochure March 3 1, 2026 Two Liberty Place 50 South 16 th 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 – Appendix 1 (“Wrap Fee Brochure” or “Brochure”) provides information se contact us at (770) 248 -3271. This Form ADV Part 2A about the qualifications and business practices of Transamerica Financial Advisors, LLC (“TFA”). If you have any questions about the contents of this Brochure, plea 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 on the SEC’s website at 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. 1  ITEM 2 – MATERIAL CHANGES Item 2 provides a summary of material changes that were made to this Brochure since its last annual amendment on March 28, 2025. Transamerica ONE officially closed to new business. However, current clients who own a Transamerica ONE account may add money to their existing account or, in limited circumstances, open a new Transamerica ONE account. When TFA updates this Brochure with material changes, TFA will either send you a copy of the updated Brochure or offer to send you a copy (either by electronic means (email) or in hard copy form) within the required timeframe. www.adviserinfo.sec.gov , download it from TFA’s website at If you would like a copy of this Brochure, you may download it from the SEC’s public disclosure website (IAPD) at www.tfaconnect.com, or contact us at (770) 248 -3271. 2  ITEM 3 – TABLE OF CONTENTS 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 ................................ ................................ 12 ........................... ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ................................ ................................ ........ 13 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................ ................................ ................................ ........ 14 ITEM 9 – ADDITIONAL INFORMATION ................................ ................................ ................................ ................................ 14 .......................... 3  ITEM 4 – SERVICES, FEES, AND COMPENSATION The Company -dealer and FINRA”) since 1984 as well as Transamerica Financial Advisors, LLC (“we/our/us/TFA”) is a federally registered investment adviser (“RIA”) and has been registered with the SEC since 1991. TFA is also a broker has been a member of the Financial Industry Regulatory Authority (“ a member of the Municipal Securities Rulemaking Board (“MSRB”). -related products and advisory and asset management services to the -dealer and registere d representatives -dealer or registered representative TFA offers investment retail public. TFA and some of its investment adviser representatives (“IARs” or “Financial Professionals/FPs”) also act in the capacity of broker (“RRs”) respectively. When TFA or an IAR is acting in a broker capacity rather than providing investment advisory services, the fiduciary standard applicable under the Investment Advisers Act of 1940 ge nerally does not apply to those brokerage activities. on the New York Stock Exchange TFA is directly owned by AUSA Holding, LLC, which is an indirect, wholly owned subsidiary of the ultimate parent, AEGON Ltd., a publicly traded company listed (“NYSE”) and trading under the symbol AEG. -party money managers who manage model -based ients through Advisory Services Offered In its capacity as an RIA, TFA offers access to third portfolios on behalf of clients and wrap fee programs that offer clients access to fee investment management. TFA’s advisory services are made available to cl individuals registered with TFA as IARs. Transamerica ONE Wealth Management Platform . Transamerica ONE is no longer open to new business. However, ONE account may add money to their existing account or The information in this Brochure pertains to the (“Transamerica ONE”) only current clients who own a Transamerica in limited circumstances open a new Transamerica ONE account. other advisory services described in other Brochures. For more detailed TFA IARs can offer clients information about these programs, IAR s can provide clients with a copy of TFA’s Form ADV Part 2A or it can be accessed directly by visiting TFA’s public website at www.tfaconnect.com . advisory services, an IAR will meet with the client to collect and time horizon, risk tolerance, analysis. TFA and its IRAs do not provide legal, tax , or accounting At the time of or prior to offering analyze financial information to determine the client’s financial needs, investment objectives, and current investment strategies, if any. The IAR will then provide investment advice based on the advice. 4  Goldman Sachs . Clients should never make checks payable to TFA does not take custody of client funds or securities, including stocks or bond certificates or cash. When providing funding for a client’s account, if the client is using a check, the client should only make any check payable to their IAR or any entity other than Golman Sachs . and answer questions about the service. The IAR will also explain any special instructions for the management of the assets in a Transamerica ONE account; the investment management process, investment objectives, investment strategies undertaken as part of the service; IARs will contact advisory clients at least annually to determine whether the account continues to align with the client’s investment objectives and financial circumstances . s, profit -sharing plans, employer retirement nsamerica ONE using Goldman Sachs Advisor Solutions’ internet s access to a fee TFA has contractual arrangements with various - -based Model Transamerica ONE is available to individuals, pension plans, trusts, estates, charitable organizations, corporations, and other business entities. TFA entered into an agreement with Goldman Sachs Group, Inc. ("Goldman Sachs"), whereby TFA administers and sponsors Tra based platform. Transamerica ONE is a wrap fee program that offer investment management program. Managers to develop model portfolios to include in Transamerica ONE. designed to meet each client’s stated investment ONE Platform tools, TFA IARs will allocate a client’s funds to investment options that fall within their risk profile below. For example, a client with a Moderate risk profile can make , and/or Moderate , clients would need to complete a Model Portfolios are accessed by an IAR through the Transamerica ONE website. For all programs offered through Transamerica ONE, TFA IARs will compile pertinent financial and demographic information to develop an investment program goals and objectives. Utilizing the Transamerica assets among the different options in the program selected and determine the appropriateness of the asset allocation and investment options for the client, based on the client’s stated investment objectives, investment time horizon, risk tolerance and any other pertinent factors. Clients can allocate , one risk level above , or one risk level allocation changes to portfolios that are Moderate, Moderate Aggressive Conservative. However, if allocating outside of that risk range new risk tolerance questionnaire to match their current risk profile and sign the newly generated Investment Policy Statement. it will be provided to Goldman Sachs as required to open and maintain the TFA may terminate managers/strategies and reallocate impacted client assets if the client/advisor do es not proactively choose another allocation. While client information is considered confidential, account, as described in our Privacy Policy. Clients’ accounts are managed by the Model Managers that participate in the Transamerica program. Clients may, however, impose reasonable investment restrictions ONE on the management 5  TFA may reject or terminate the client relationship at its of their accounts. If a requested investment restriction is deemed to be unreasonable, or if we determine that a previous restriction has become unreasonable, TFA will notify the client that, unless the instructions are modified, discretion and upon notification to the client pursuant to the notification terms in the applicable Brochure and this Appendix. Transamerica ONE offer various types of investment y and investment style and are dependent upon the model a model portfolio, please funds (“ETFs”). For a complete listing of the see the Model Manager’s Form ADV Part The model portfolios available in alternatives that vary in terms of strateg portfolio selected. Types of investments used can consist of, but are not necessarily limited to, individual stocks, mutual funds, and exchange traded securities that may be used in 2A or other disclosure documents. -Series Model Portfolios (I -Series) ONE. The I -Series Model ET Fs and mutual funds. the I-Series models solely in its role as model manager. TFA IARs do not Transamerica I TFA also offers its own proprietary model portfolios in Transamerica Portfolios consist of asset allocation model portfolios invested primarily in TFA has discretion over have discretion over any client account. portfolios do NOT have the ability to liquidate .S . Treasuries, which have historically performed Except for the I-Series Managed Risk Strategy, these holdings to 100% cash in the event of a market correction. In the event of a market correction, the I-Series Managed Risk Strategy can move to U well in times of equity market turmoil. Fixed income allocations can be concentrated in certain higher risk sectors such as high yield bonds, convertible bonds, emerging market sovereign debt, senior bank loans, U.S. long term Treasury bonds, or preferred stock. • : In this portfolio, global stocks , including Real Estate Investment Trusts • , including REITs , typically range modest levels of current income as a -tolerant investors who are willing to • I-Series Aggressive (“REITs”), typically comprise 100% of assets. A version that substitutes some stocks with commodities is also available. This strategy is designed primarily to seek capital appreciation for aggressive investors who can tolerate volatility. I-Series Moderate Aggressive : In this portfolio, global stocks from 83% to 87% of assets. A version that includes commodity exposure is also available. Fixed income and cash are used for the remainder of the portfolio. This strategy is designed for investors primarily seeking capital appreciation with secondary objective. This strategy is intended for risk accept volatility. I-Series Moderate : In this portfolio, global stocks typically range from 65% to 69% of assets. A version that includes commodity exposure is also available. Fixed income and cash are used for 6  • : In this portfolio, global stocks typically range from 46% to 50% • : In this portfolio, global stocks typically range from 30% to 34% of assets. oth current • : In this portfolio, global stocks are typically less than 20% of assets. both • : In this portfolio, global bonds, fixed income and cash make up the • metals, global real • : The I -Series Managed Risk Strategy seeks to grow assets through the remainder of the portfolio. This strategy is designed for investors primarily seeking capital appreciation with modest current income as a secondary objective. This strategy is intended for investors who can tolerate moderate levels of volatility. I-Series Moderate Conservative of assets. A version that includes commodity exposure is also available. Fixed income and cash are used for the remainder of the portfolio. This strategy is designed for investors primarily seeking current income with capital appreciation as a secondary objective. I-Series Conservative A version that includes commodity exposure is also available. Fixed income and cash are used for the remainder of the portfolio. This strategy is designed for investors seeking b income and stability of capital. I-Series Ultra Conservative A version that includes commodity exposure is also available. Fixed income and cash are used for the large majority of the portfolio. This strategy is designed for investors seeking current income and capital preservation. I-Series Global Fixed Income majority of the portfolio. This strategy is designed for investors seeking both moderate current income and capital stability. I-Series Strategic Alternative Core : The objective of the Strategic Alternative Core Model Portfolio is to provide diversification by using multiple asset classes and alternative strategies and to provide a hedge against inflation while remaining relatively uncorrelated to the equity and fi xed income markets. Growth equity exposure serves as a hedge to inflation, while United States sovereign debt is intended to function as a stabilizer in deflationary environments. Uncorrelated alternative asset classes, such as natural resources, precious estate , and hard currency are incorporated to serve as a hedge against market volatility in unfavorable market conditions. I-Series Managed Risk diversified equity exposure while reducing declines in the portfolio by adjusting portfolio allocations. Allocation changes are made when the potential for significant declines in equity mar kets changes materially. are ferred. The goal of • : This portfolio maintains a 100% exposure to U.S. stocks, with a To estimate the potential of a significant decline in equities, multiple market indicators considered. When TFA’s Portfolio Management Committee determines the potential is considered low, a “Risk On” allocation of primarily stocks is preferred. When the potential for equity declines is considered high, a “Risk Off” allocation of bonds is pre changing allocations is to attempt to avoid major equity market declines. Both the “Risk On” and “Risk Off” allocations can be adjusted at the d iscretion of TFA’s Portfolio Management Committee. I-Series U.S. Strategic Growth heavy weighting to large -cap growth stocks. This strategy is designed to seek capital 7  appreciation for aggressive investors who can tolerate substantial volatility. • : This portfolio has a 100% allocation to floating -rate and short -term I-Series Ultra Stable Bonds fixed income instruments. The strategy is designed for investors seeking current income and capital preservation with minimal volatility. -Series Managed Risk, I -Series U .S . Strategic Growth, and I -Series Ultra Stable s of risk. These allocations are created using a ,” which attempts to find an asset allocation that al return s , volatility (as measured by standard deviation) , and Methods of Analysis Except for the I Bonds strategies, TFA investment decisions rely primarily on investing according to a series of long -term asset allocations with various level method known as “mean variance optimization would achieve the highest historical return for each level of risk. To determine these asset allocations, this method uses historic correlation for many diverse global asset classes. -optimal. The asset classes are chosen so that large parts of the global market are represented and to IARs , However, there is no guarantee that future returns, volatility, or correlation will be similar to historical returns , so the resulting asset allocations used may be sub used in allocations ensure that positions have differing risk/return/correlation metrics. In consultation with their clients will select a particular strategy by matching their stated risk tolerance with the historical risk levels of the asset allocations. -party research providers to evaluate the potential Third -Party Research Providers The I -Series Managed Risk Strategy uses third of a significant decline in the equities market. TFA reserves the right to add or discontinue the use of third -party research providers at any time. ® Strategy Solutions which is a suite of risk -based allocations to One Platform Transamerica ® Strategy Solutions allocations are TFA also offers Transamerica strategies on the Transamerica intended for clients whose primary focus is achieving a level of risk in the overall portfolio that matches the client’s targeted risk level. -satellite portfolio construction principles . Based managed investments tend to outperform actively -70% allocation to passively -Series strategies with appropriate risk characteristics. That “core” allocation is opportunities How Strategies are Selected Each Strategy Solution was created using core on extensive research showing that passively managed strategies, the Strategy Solutions generally target a 50% managed I complemented with 2 -3 actively managed satellite strategies to provide investors to outperform the market on a risk -adjusted basis. To avoid manager -specific risk, no Strategy 8  Solution allocates more than 20% to any single actively managed strategy. are determined by using mean -variance -base d allocation index. As a result, Strategy Solutions towards to fixed income strategies, Within these parameters, satellite allocations optimization to find combinations of strategies that maximize historical returns at different risk levels. The historical analysis covers 10 or more years of historical returns, volatility, and correlations, contingent on data availability. For each risk category, the Strategy Solution was designed to have historical volatility (as measured by standard deviation of returns) within 5% of the corresponding Dow Jones risk the conservative side of the risk spectrum have a heavy weighting while Strategy Solutions towards the aggressive side of the risk spectrum are primarily invested in equities. can access performance reports from the Goldman Sachs website. Folio -dealer and the primary custodian -mail Clients and their IARs Financial, Inc. (“Folio”), a Goldman Sachs company, is the broker for Trans america ONE accounts. As the custodian, Folio/Goldman Sachs will send e notifications to you when statements and confirmations are posted to your account. If you wish to receive paper statements or performance reports, you can request those documents from Folio/Goldman Sac hs for an additional fee. the Investment Advisor Representative Fee a wrap fee program that pays them more the IAR c ould receive from other advisory programs or if a client IARs may over other A client’s advisory fees may be higher or lower than what other clients are due to the ability of a client to negotiate the IAR Fees and C ompensation Clients will pay a Total Annual Advisory Fee (“Total Fee”) as outlined in the Transamerica ONE Fee Schedule below. The Total Fee is comprised of , TFA’s Platform Fee, and a separate Model Portfolio Management Fee, where applicable. Clients can negotiate the IAR Fee with their IAR . The fee an IAR is paid under the Transamerica ONE Fee Schedule may be more than what paid separately for investment advice, brokerage services, or other services. Therefore, have a financial incentive to recommend programs or services. paying that are participating in Transamerica ONE Fee . following fee schedule for more details. Since TFA is the sponsor of Transamerica ONE, TFA earns additional fees for providing administrative services. Please see the Transaction costs are included in the Total Fee ; however separate service fees as previously described may apply. The Total Fee is paid monthly in arrears and calculated based on an account’s average daily balance during the preceding month. The applicable Total Fee will be determined based on the amount of assets held in all accounts established in Transamerica ONE under the identical primary social security or administrative costs associated with the Transamerica ONE will be clearly noted on tax ID number. All brokerage, custodial, and a client’s 9  TFA , deduct other is responsible for paying each Model Manager statements. Folio will deduct its own fees and will also, at the direction of applicable fees related to Transamerica ONE. TFA the appropriate fee for their participation in Transamerica ONE. , and mailing fees. A complete listing of service fees is available at the website Accounts may also be subject to certain service fees that are separate from the advisory fee such as wire https://www.folioinstitutional.com/resources/service -fees.jsp . , which means for the first $250,000 that paid will be between 1.60% is invest ed in a - 2.00% . - 1.75% will be will continue as set forth in the schedule below or as For accounts within Transamerica ONE, TFA has established the following blended rate fee schedule. The below fees are tiered Transamerica O NE account, the Total Annual Advisory Fee For the next $250,001 to $500,000 a Total Annual Advisory Fee between 1.35% paid. The Total Annual Advisory Fee negotiated for each level. 10  Transamerica ONE Wealth Management Platform Annual Fee Schedule 1 TFA Platform Fee 3 Model Portfolio Range of Assets Total Annual Advisory Fee 5 Management Fee 4 Investment Advisor Representative Fee 2 1.10% 1.00% 0.90% 0.80% 0.50% 0.35% 0.25% 0.20% 0.00% - 0.40% 0.00% - 0.40% 0.00% - 0.40% 0.00% - 0.40% 1.60% - 2.00% 1.35% - 1.75% 1.15% - 1.55% 1.00% - 1.40% $0 - $250,000 $250,001 - $500,000 $500,001 - 1,000,000 $1,000,001 - $2,000,000 $2,000,001+ 0.70% 0.15% 0.00% - 0.40% 0.85% - 1.25% Total Fee n. TFA further reserves the right , or waive any fees associated with an advisory program in general C hanges in Fees TFA, upon 30 days prior notice to clients, may at its discretion revise any aspect of the in a way that may cause the fees paid 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 sending written notice to TFA within 30 days from the date of the fee increase notificatio to negotiate, discount or payable by any client or group of clients at our sole discretion. Furthermore, TFA employees and employees of affiliates may be entitled to fee discounts by virtue of their employment. Account Termination The Client Services Agreement (“ CSA ”) with TFA may be terminated by either party effective upon the date of written notice to the other party. Clients who terminate the CSA within five (5) a portion of the Platform Fee to Goldman Sachs for technology, billing, custody, and clearing -Party Model Managers. 1 Fees are expressed as an annual percentage of assets under management. Assets under management is the total value of the assets in the account. 2 This fee can be negotiated with the IAR . 3 The Platform Fee will be charged whether account assets are held in securities, other instruments, cash, or cash equivalents. TFA pays services. 4 All Model Portfolio Management Fees are paid to the Third 5 The Total Fee paid by the client is dependent on the model portfolio(s) selected. Clients may also incur certain charges imposed by third parties other than TFA and IAR in connection with investments made through the client’s account, including, without l imitation, the following types of charges which are generally charged by mutual funds and fully disclosed in the prospectus for each fund: 12b transaction charges and service fees, and IRA an -1 fees, management fees and administrative servicing fees, other d Qualified Retirement Plan fees. Managers on the Some mutual fund share classes that TFA makes available to clients on its platforms charge a distribution fee pursuant to Rule 12b -1 under the Investment Company Act of 1940, also known as trails. The Model Transamerica ONE Wealth Management Platform maintain a practice of purchasing the lowest cost mutual fund share class made available through our custodian, Folio. TFA requires Model Managers to periodically attest that they are purchasing the lowest cost s hare class available for model portfolios on this platform. Clients with multiple accounts in Transamerica ONE should refer to the account establishment paperwork for additional details on aggregating fees. 11  may charge if an account is terminated. Clients should refer to the information. Clients’ TFA CSA will also terminate business days of signing will receive a full refund of all fees and expenses. All advisory fees paid to us for investment advice are separate from any additional fees and expenses that Folio or Goldman Sachs Folio/Goldman Sachs client agreement for more should the agreement between TFA and Goldman Sachs terminate. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS -sharing plans, employer , and other business TFA provides investment advisory services to individuals, pensions, profit retirement plans, trusts, estates, charitable organizations, corporations entities . The minimum account size for Transamerica ONE is $25,000. TFA reserves the right to waive the minimum account size requirement at its discretion. Transamerica Strategy Solutions are intended for clients whose primary focus is achieving a level and who are interested of risk in the overall portfolio that matches the client’s targeted risk level in a diversified portfolio with a blend of passive and active strategies. The typical client does not have a strong preference towards any single strategy or manager and is not looking for tactical Instead, these clients are interested overlay services that actively rebalance between strategies. in achieving reasonable returns while attempting to reduce downside risk where possible. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION to the following list TFA selects Model Managers based upon various guidelines and criteria that we consider as part of our due diligence review of each Model Manager. TFA may make exceptions of criteria when reviewing new Model Managers and it is not necessarily a comprehensive list of everything that TFA reviews during due diligence of Model Managers: • Available S trateg ies /Model Portfolio s • Use of leverage • Use of hedging • Performance vs. Benchmark (audited to GIPS standards) • At least 3 years of actual performance history • Management fees • AUM (minimum $100MM ) • Federal regist ration • Form ADV Part 1 and 2A disclosures • Staffing experience and turnover • Pending or previous regulatory matters 12  of information , and investment strategies used by TFA’s Model for an extended time, the Advisory the IAR will contact clients as necessary to inform them of any impact to their account . Impacted clients will not have the option of , however, clients will be given a period clients • Financial information The methods of analysis, sources Managers will vary . TFA encourages clients to read each Model Manager’s Form ADV Part 2A prior to selecting a Model Manager . At least quarterly, TFA’s Advisory Services Team will monitor and review the performance results of each model portfolio. If a model portfolio is underperforming Services Team will consult with the Model Manager to identify the cause of the underperformance. The Advisory Services Team and the Investment Committee will decide if removal of a particular model portfolio or Model Manager from Transamerica ONE is warranted. If a model portfolio or Model Manager is removed, TFA and/or this change in status and continuing to remain invested in the removed model portfolio of time to work with their IAR to move to a comparable model portfolio (or set of portfolios). If do not provide instruction s , their investment will be automatically reallocated to a comparable model portfolio. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS TFA IARs will assist clients with completing the risk tolerance questionnaire within the Goldman Sachs platform to obtain a risk score to assist in determining a suitable selection of one or more model portfolios. a client’s stated investment objectives, risk IARs will gather the following The selection of model portfolio(s) will be based upon tolerance, time horizon, and financial circumstances. In addition, information (not meant to be an exhaustive list) to assist in this selection: Income • • Age • Number of Dependents • Employment Status • Marital Status • Tax Bracket • Net Worth • Risk Tolerance • • Investment Objective s Investment Experience applicable rules and regulations and used model portfolios used in client’s Transamerica ONE account(s) each client’s risk tolerance and investment objectives . It is important Client information will be retained by TFA pursuant to for TFA to continue to ensure that remain appropriate given that clients notify their TFA IAR of any updates to their risk tolerance and/or investment objectives 13  in a timely manner. Client information is not provided to the Model Managers. ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Generally, clients will not have any direct contact or consultation with the Model Managers. ITEM 9 – ADDITIONAL INFORMATION . Stock markets and bond markets fluctuate over , including th eir Risks All investments in securities include a risk of loss time, and clients may lose money. Clients should be prepared to lose money principal, in an investment account. Investments are not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. have exposure to debt are subject to risks of model portfolios that concentrate in specific industries or are to segments of the market may be significantly impacted by events affecting program pose risks, and many factors The investment strategies utilized in the Transamerica ONE affect the performance of each investment or account. 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 prepayment or default, and otherwise subject those industries or markets. In addition, the investments in your account may be subject to the following specific risks: -Traded Funds (ETFs): The client’s a ccount bears all the the account, Investing in Mutual Funds and Exchange risk of the investment strategies employed by the mutual funds and ETFs held in 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. Social , and Governance (“ESG”): ESG investing, also known as ble” investments or screen out or exclude Investing in Environmental, “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 responsi 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 or with a focus that involves 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. 14  and Cybersecurity: Certain investment activities and investment technologies, many of which are provided by or are dependent upon third providers. The successful failure, power loss, a software -related “system crash,” fire It is not Reliance on Technology strategies are dependent upon algorithms, as well as other various computer and telecommunications parties such as data feed, data center, telecommunications, or utility 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 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. 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 TFA from trading, modifying, liquidating, and/or monitoring its clients’ investments. In addition, clients should be aware of the risk of cyber -attacks and harm to technology infrastructure and data from misappropriation or corruptio n. , and Folio’s interconnectivity with third party vendors, central , and are subject to a cyber -attack or other information , and Folio take proactive measures and endeavor warrant, their computer systems, software, and networks may be er malicious code, and other Due to TFA’s, Goldman Sach’s agents, exchanges, clearing houses, and other financial institutions, TFA, Goldman Sachs Folio could be adversely impacted if any of them security event. Although TFA, Goldman Sachs to modify them as circumstances vulnerable to unauthorized access, issues, computer viruses or oth events that could have a security impact. money, causing the mutual fund or 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 ETF to lose money. funds. The managers of the fund company may result in higher expenses for the Operation Risk: Every mutual fund and ETF is an investment company that is run by an advis er and a board of directors that is responsible for managing the funds operations and following the laws and regulations relevant to ETFs and mutual commit fraud, malfeasance, or simply make bad decisions that funds investors, mistaken calculations of the fund’s true value, or losses of fund assets. Fluctuations in interest rates may cause investment prices to fluctuate. For Interest Rate Risk: example, when interest rates rise, yields on existing bonds become less attractive, causing their market value to decline, and vice versa. 15  Market Risk: The price of investments in advisory account s may drop in response 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. disasters , and other circumstances in one country or underlying investments with significant exposure to ’ exposure to the risks described As a result, whether the underlying investments are the countries directly affected, fected. Also, liquidity of investments, or even entire market segment s , can deteriorate rapidly, particularly 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 region could be highly disruptive to, and have profound impacts on, global economies or markets. During periods of market disruption, the elsewhere in this section will likely increase. in securities of issuers located in or the value and liquidity of the underlying investments may be negatively af individual during times of market turmoil, making those investments more 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 erod es at the rate of inflation. Overseas investments can be subject to fluctuations in the value of the Currency Risk: investment in U.S. dollars, which are due to fluctuations in the currency of the investment’s originating country. Future proceeds from investments may be reinvested at a potentially lower Reinvestment Risk: rate of return (i.e., interest rate). h issuer, such 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 suc 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 and bad times. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or declining market value. 16  Fixed Income Risk: Portfolios that invest in fixed income securities are subject to several general risks, including interest rate, credit, and market risk, which could reduce a client’s yield . These risks may occur from fluctuations in interest rates, a change in an issuer’s individual situation or industry, or general market events. and changes in specific of other securities involve greater Credit Risk: Changes in financial condition of an issuer or counterparty, 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 risk of default or price changes due to changes in the credit quality of the issuer. be more volatile and can perform differently region, or emerging market. than U.S. market s . Emerging to greater social, economic, regulatory, and political uncertainties and can Foreign exchange rates may also be extremely volatile. a client’s 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, Foreign markets may markets can be subject be extremely volatile. Tax Risk: Securities in the investment strategy may be bought and sold without regard to 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 is an investment strategy that actively perform as well as other styles, including those based on fundamental analysis to measure its intrinsic value by the fund to maintain a long -term goal for asset allocation). The sub -adviser’s evaluations and assumptions in may be incorrect in view of actual market countries risk profile with respect to particular asset classes, countries and regions, Tactical Asset Allocation Risk: 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 strategies using other asset management (a method of evaluating a security that entails attempting examining related economic, financial, and other factors) or strategic asset allocation (a strategy that involves periodically rebalancing This strategy may not work as intended. selecting underlying funds or individual securities 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, or regions, or industries or groups of industries that underperform other management styles. In addition, a strategy’s and industries may change at any time based on the sub -adviser’s allocation decisions. Information -dealer and a federally registered investment adviser. In the last ten years, Disciplinary TFA is both a broker TFA has had three material disciplinary events . Two of these events involve actions brought by the 17  SEC and o ne involve s an action brought by FINRA. SEC Proceedings • On March 11, 2019, the SEC signed an Order Instituting Administrative and Cease -and -Desist -and -Desist O rder (“Order”) practices and the 12b -1 conflicts of interest related to a) its 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 relating to TFA’s disclosure of its mutual fund share class selection fees TFA and its associated persons received. Specifically, the SEC alleged that TFA failed to adequately disclose in its Form ADV or elsewhere the 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. elevant period, plus interest, subject to a 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 r de minimis threshold. The foregoing is only a brief 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 -Series ® and Inc. (“F -Squared”). The models managed – Conservative, Global Tactical Allocation by AUIM were the Global – Balanced, Global Tactical and Global Tactical -Squared were the AlphaSector Rotation Index, Index. These strategies are no neither AUIM nor F - Squared currently provide model things, errors in certain models used by TFA in its Transamerica I 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, Tactical Allocation Allocation – Growth, Tactical Fixed Income, Global Tactical Income Rotation models. The models managed by F AlphaSector Premium Index and World Allocator Premium longer offered by TFA and management services to TFA. The strategies developed by AUIM and F- Squared were offered 18  - Series ® and Transamerica ® ONE programs between 2011 and by TFA in the Transamerica I 2015. -judgment interest, and to cease and n to affected investors who -Squared strategies in the Transamerica I- through June 2015. The Order an amount related to the pro rata fees 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 desist from violating certain securities laws and regulations. The disgorgement, interest and penalties were paid to a Fair Fund (“Fund”) for distributio purchased or held an interest in the AUIM and F Series ® and Transamerica ® ONE programs from July 2011 states that these investors are to receive from the Fund and commissions paid by them during that period, plus interest, subject to a de minimis threshold. controls and and that the consultant’s written findings had been received and affiliates had 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 related procedures, proposed changes implemented. The SEC also acknowledged that, in advance of receiving recommendations from the independent compliance consultant, TFA and its already begun making revisions and improvements to their compliance policies and procedures. The SEC also considered that TFA and its affiliates have retained the independent compliance consultant for further reviews. The settlement does not impose any restrictions on the business of TFA. SEC’s The foregoing is only a summary of the Order. A copy of the Order is available on the website at https://www.sec.gov . FINRA Proceedings • On December 21, 2020, TFA and FINRA entered into a Letter of Acceptance, Waiver and – variable annuities, mutual $4,354,160 in A copy of this Order is available on FINRA’s website at 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 funds and 529 Plans. TFA was censured, fined $4,400,000 and required to pay restitution to customers. www.finra.org/rules -guidance/oversight -enforcement/finra -disciplinary -actions -online . 19  inancial Group O ther Financial Industry Activities and Affiliations TFA is a member of the Transamerica group of companies. Most of TFA’s IARs, members of management, and Investment Committee members are also registered with TFA’s affiliated broker -dealer. In addition, the majority of TFA’s IARs are affiliated with World F Insurance Agency, Inc. (“WFGIA”), an affiliated insurance agency. registered issued by TFA makes available variable universal life insurance products, variable annuities, index -linked annuities, mutual funds, 529 plans, ETFs and unit investment trusts (“UITs”) companies affiliated with TFA (“Affiliated Products”). When clients purchase Affiliated Products, TFA and/or its affiliates receive additional fees or compensation that are not received for the sale as a financial incentive to recommend Affiliated of non -affiliated products. As a result, TFA h Products over similar non -affiliated products. Affiliated Products may also be accessed through third -party money managers (“TPMMs”) or model managers used in TFA advisory programs. id by clients with TFA, which TFA has contractual relationships with TPMMs that are independent investment advisers offering fee -based advisory programs. These relationships were described in Item 4. These TPMMs are not affiliated with TFA. TPMMs share a portion of the advisory fees pa creates conflict of interest because TFA has an incentive to recommend TPMMs that compensate TFA. In some cases, the cost of these arrangements may be higher than other advisory options. Affiliated Products are issued by one of our affiliated companies. In addition r our affiliates receive programs. Because TFA and/or our affiliates make -affiliated products. TFA mitigates this conflict by Some of the insurance and annuity products and mutual funds that TFA makes available are Affiliated Products. to any commission associated with purchasing the product, TFA and/o additional fees and compensation related to Affiliated Products that TFA does not receive in connection with non -affiliated products. Many of these products can be purchased by the various TPMMs or Model Managers available in TFA’s additional money when TFA and IARs sell Affiliated Products, TFA has an incentive to recommend these Affiliated Products over similar non supervising all recommendations made by IARs. clients pay to them. This is considered a with one of these TPMMs may be higher than placing the assets TFA has contracts with TPMMs offering fee -based advisory that are also investment advisers programs. These relationships were described in Item 4. These TPMMs are not affiliated with TFA, conflict of interest. and they pay TFA a portion of the fees The cost of placing client’s assets in another advisory account. TFA offers access to securities backed lending programs through third party lenders. TFA receives compensation from the lending sponsors, which creates a conflict of interest. Please refer to Item 4 for a description of these conflicts and related risks. 20  TFA offers a bank deposit sweep program as its default option for uninvested cash in your accounts. TFA receives compensation from the banks involved in the program. Please refer to Item 4 for a description of the conflicts related to this program. AEGON Ltd. Affiliates Under Common Control with TFA and the following entities are indirect, wholly owned subsidiaries of AEGON Ltd. Broker -Dealers • Transamerica Investors Securities Corporation • Transamerica Capital, LLC (“TCL”) TCL serves as principal underwriter and wholesale distributor for certain variable annuity and life insurance products issued by affiliated insurance companies. TFA receives compensation under selling agreements for these products, creating a conflict of i nterest. Investment Company • Transamerica Asset Management (“TAM”) TAM 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. Registered Investment Advisers • Transamerica Asset Management, Inc. (“TAM”) • AEGON USA Investment Management, LLC (“AUIM”) • Transamerica Retirement Advisors, Inc. (“TRA”) -dealer capacity, TFA receives revenue -sharing Other Affiliated Companies TFA has material relationships with certain product sponsors, including affiliated insurance companies and agencies. In its broker compensation when clients purchase products through these sponsors. Sponsoring Current revenue -sharing arrangements and sponsoring companies are disclosed on TFA’s website at www.tfaconnect.com under Indirect Compensation Disclosure and Companies List . • Transamerica Retirement Solutions, LLC Transamerica Retirement Solutions, LLC (“TRS”) TRS is a retirement services firm offering a range of services, including recordkeeping, participant education and communications, Plan design, Plan testing, general ERISA, and IRS compliance. 21  • WFG Securities of Canada (WFGS) WFGS offers mutual funds and referral arrangements in Canada. Affiliated insurance companies and agencies include: • Transamerica Premier Life Insurance Company • Transamerica Life Insurance Company • Transamerica Financial Life Insurance Company • World Financial Group Insurance Agency, Inc. • World Financial Group Insurance Agency of Hawaii, Inc. • World Financial Group Insurance Agency of Massachusetts, Inc. • WFG Insurance Agency of Puerto Rico, Inc. • World Financial Group Insurance Agency Canada Inc. affiliated Conflict Management The a ffiliations described above create financial incentives to recommend certain products or services. TFA addresses these conflicts through disclosure and supervisory oversight of recommendations made by its IARs. IARs may also be licensed insurance agents and offer fixed insurance products through these affiliated agencies. When clients purchase fixed insurance products, the affiliated agencies receive commission compensation. designed to ensure that TFA meets its fiduciary advisory services with the Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading TFA has adopted a Code of Ethics (“Code”) obligation to clients and our prospective clients, that TFA conducts its highest level of ethical standards, and that TFA instills a culture of compliance within our firm. ust acknowledge their the Code with annual The Code applies to TFA Access Persons, defined as TFA IARs, directors, officers, and other persons who are subject to TFA’s supervision. It is distributed to Access Persons at the time of becoming an Access Person and annually thereafter. Access Persons m understanding of and agreement to abide by the Code. TFA supplements training and ongoing monitoring of the activity of Access Persons. TFA’s Code outlines the duties of Access Persons, including requirements to: • maintain TFA’s reputation as a firm that operates with the principles of honesty, integrity, • • and professionalism; comply with applicable federal and state securities laws; read, know, understand, and follow all policies and procedures prescribed by TFA manuals, bulletins, or supervisory directives; 22  • • • cooperate with any investigation or inquiry conducted or authorized by TFA Management and/or Supervisory Personnel; follow TFA’s Privacy Policy and related procedures; and report personal securities transactions by obtaining approval for outside brokerage accounts and reporting such accounts as described in the Code. Additionally, the Code prohibits Access Persons from actions such as: • purchasing or selling securities for their own accounts or others while in the possession -public) information or of information which might be considered “insider” (material, non discussing the information with a third party; • participating in any Initial Public Offering or Private Securities Transaction; and • accepting or offering inappropriate and/or excessive gifts, favors, entertainment, special accommodations, or other things of material value. Any Access Person not complying with these guidelines may be subject to disciplinary action up to and including termination. Clients may request a complete copy of our Code by contacting TFA at the address or telephone number displayed on the cover page of this Brochure. and will contact advisory clients at least IARs and clients can access account statements, trade -mail notifications are sent to are posted to clients’ account s . If clients Review of Accounts IARs provide ongoing monitoring of client portfolios annually to determine whether the account continues to align with the client’s investment objectives and financial circumstances. confirmations , and performance reports from the Folio website. E IARs and clients when statements and confirmations wish to receive paper statements, clients can request those documents for an additional fee. account he custodian of the account to ensure In addition to account statements and transaction confirmations, clients may receive performance reports. Periodically, clients may receive Albridge Personalized Account Statements directly from their IARs. These reports and statements may include lists of holdings, including mutual funds and securities, but are not official account statements. We urge clients to compare these reports and statements to the official account statements of their account holdings provided to them at least quarterly by t that the holdings listed on these reports provided by the IAR match those reflected on the official custodial account statements. 23  C lient Referrals and O ther C ompensation -dealer. If an IAR is also a ut are not limited to, the purchase -linked Registration Arrangements Many of TFA’s IARs are also Registered Representatives of TFA’s broker TFA Registered Representative, they may recommend that clients place securities transactions through TFA’s broker -dealer. These transactions could include, b or sale of variable universal life insurance products, variable annuities, registered index annuities, mutual funds, 529 plans, ETFs, and UITs. All sales charges and expenses are disclosed in the product prospect us, which clients will receive at or before the time of the purchase of the product. e meetings. These cause TFA benefits from these contributions Marketing Compensation Arrangements Each of the TPMMs, Portfolio Managers, or other service providers may attend, contribute to, or sponsor education and training meetings for our IARs. TPMMs, Portfolio Managers, or other service providers may reimburse TFA for up to 100% of the cost of thes contributions and reimbursements create a conflict of interest because meeting sponsors have more opportunities to provide IARs with education on investments, their investment management services, industry trends, and other issues; and be and reimbursements. - e events may influence Other Compensation Arrangements If an IAR is associated with WFGIA, they are permitted to participate in award and incentive programs sponsored by WFGIA in which they could qualify to receive trips, promotions, or non cash compensation based on their volume of fixed insurance sales. Thes their decision to recommend particular fixed insurance products to clients. -cash compensation f non -cash compensation, a s to help defray these expenses. TFA does not require or Some IARs may participate in incentive trips and receive other forms of non based on the amount of their sales and services through TFA or product providers. To the extent an IAR participates in an incentive trip or receives other forms o conflict of interest exists in connection with the IAR’s recommendation of products and services for which they receive these additional economic benefits. TFA allows IARs to receive marketing reimbursements from product provider have any expectation that IARs refer clients to or place assets with such providers. TFA monitors recommendations made by its IARs to ensure that they are in each client’s best interests. -party lender when its clients engage in t which we disclose to TFA receives revenue sharing compensation from a third securities backed lending. TFA also receives fees from its arrangement with its Bank Deposit Sweep Program sponsor. Such arrangements create conflicts of interes clients and manage through TFA’s policies and procedures. 24  likely Financial Information To the best of TFA’s knowledge, TFA is not aware of any financial condition that is reasonably to impair TFA’s ability to meet contractual commitments to clients. TFA has not been the subject of a bankruptcy petition at any time, including the past ten years. 25 

1 – COVER PAGE Form ADV Part 2A March 31, 2026 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 -3271. The information in this Brochure has not been approved 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 B rochure, please contact us at (770) 248 or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about TFA is also available on the SEC ’s website at www.adviserinfo.sec.gov (s elect “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 material changes that were made to this Brochure since its last annual Item 2 provides a summary of amendment on March 28, 2025 . Below is a summary of the material change s : In the TFA 365 A dvisory Program : • TFA disclose d a securities backed lending arrangement • A default bank deposit sweep program was added became available. to all accounts w ith free cash balance s . or Transamerica ONE officially closed to new business. However, current account may add money to their , in limited circumstances, open a new Transamerica ALPHA or Transamerica Transamerica ALPHA and Transamerica ONE clients who own a Transamerica ALPHA existing account or ONE account. TFA will either send you a copy of the updated within the When TFA update s this Brochure with material changes, Brochure or offer to send you a copy (either by electronic means (email) or in hard copy form) required time frame . www.tfaconnect.com , or contact If you would like a copy of this Brochure, you may download it from the SEC’s public disclosure website (IAPD) at www.adviserinfo.sec.gov , download it from TFA’s website at 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 ................................ ................................ ................................ ..........9 ................................ ITEM 6 – PERFORMANCE -BASED FEES AND SIDE -BY -SIDE MANAGEMENT ................................ ............ 16 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 ACTIVITIES AND AFFILIATIONS ................................ 25 ................. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ................................ ................................ ................................ ................................ ................................ ............ 27 ITEM 12 – BROKERAGE PRACTICES ................................ ................................ ................................ ................................ ......... 28 ITEM 13 – REVIEW OF ACCOUNTS ................................ ................................ ................................ ................................ ............. 30 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ................................ ................................ ........... 31 ITEM 15 – CUSTODY ................................ ................................ ................................ ................................ ................................ .............. 32 ITEM 16 – INVESTMENT DISCRETION ................................ ................................ ................................ ...... 32 ................................ ITEM 17 – VOTING CLIENT SECURITIES (PROXY VOTING) ................................ ................................ 32 ...................... ITEM 18 – FINANCIAL INFORMATION ................................ ................................ ................................ ................................ ....... 33 3  ITEM 4 – ADVISORY BUSINESS er -dealer and has been a “FINRA ”) since 1984 as well as a member of the The Company Transamerica Financial Advisors, LLC (“we/our/us/TFA”) is a federally registered investment advis (“RIA”) and has been registered with the SEC since 1991. TFA is also a broker member of the Financial Industry Regulatory Authority ( Municipal Securities Rulemaking Board ( “MSRB ”). investment -related products and advisory and asset management services to the retail ” or “Financial Professionals , the fiduciary standard applicable under the Investment Advis /FPs ”) (“RRs”) respectively. When TFA capacity rather than providing ers Act of TFA offers public. TFA and some of its investment advis er representatives (“IARs -dealer and registered representatives also act in the capacity of broker or an IAR is acting in a broker -dealer or registered representative investment advisory services 1940 generally does not apply to those brokerage activities . “NYSE ”) and TFA is directly owned by AUSA Holding, LLC, which is an indirect, wholly owned subsidiary of the ultimate parent, AEGON Ltd., a publicly traded company listed on the New York Stock Exchange ( trading under the symbol AEG. clients and wrap fee programs that offer clients access to fee -based investment Advisory Services Offered In its capacity as an RIA , TFA offers access to third -party money managers who manage model portfolios on behalf of management . TFA’s advisory services are made available to clients through individuals registered with TFA as IARs. At the time of or prior to offer ing advisory services, an IAR will meet with the client to collect and analyze risk tolerance, investment financial information to determine the client ’s financial needs, time horizon, objectives, and current investment strategies, if any. The IAR will then provide the client with investment recommendations based on the analysis. TFA and its IAR s do not provide legal, tax , or accounting advice. IARs may recommend 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. Wrap fee means that clients pay a single fee for the the program, as opposed to purchasing and paying for the services separately. services provided by There are, however, other fees associated with the accounts held, which could include, but are not limited to paper statements fees, IRA fees, low balance fees, and opening and closing account fees, which are paid for outside of the wrap fee. -sharing plans, trusts, estates, charitable TFA365 is available to individuals, pension and profit organizations, corporations, and other business entities. TFA has entered into an agreement with 4  FIWA will administer and act as Platform ℠ managed Fidelity Institutional Wealth Adviser LLC (“FIWA”), whereby sponsor the TFA365 Advisory Program using the Fidelity Managed Account Xchange account platform (the “FMAX Platform” or “FMAX”). and sole responsibility to determine the services, features As named intermediatory, TFA has full discretion , and investments of TFA365. IARs may recommend to their clients: (1) the -allocated portfolios which and exchange -traded funds (“ETFs”); (2) the Separately Managed Account within one account. Within each TFA365 TFA365 consists of three different programs which Fund Strategist Portfolio Program (“FSP”), which provides access to asset invest in mutual funds 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 clients to invest in FSPs, SMAs, individually selected mutual funds, and ETFs 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. National Financial Services (“ NFS ”) is the broker -dealer and custodian for TFA365 accounts. IAR the discretionary authority to so long as the changes match the client’s risk their current Statement of Investment Selection (“SIS”) on file with TFA. Any the client’s current stated risk tolerance require a new S IS be . Clients also give FIWA and Envestnet Asset Management, Inc. (“EAM”), an , discretionary authority to conduct trading . Clients may impose an account or later by written notice to Clients who open TFA365 Advisory accounts grant TFA and their replace model portfolios, mutual funds, and ETFs tolerance noted on changes to allocations outside of completed by the client unaffiliated investment adviser reasonable limitations and restrictions at the time of opening their IAR . TFA has a securities backed lending arrangement with non-purpose loans . This arrangement allows clients to borrow against clients may be required to provide Lending Spon sor may force the sale of the securities in the account to For clients of the TFA365 Advisory Program, a third -party lender (“Lending Sponsor” ) that allows clients to use certain advisory accounts as collateral to obtain secured 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 valu e of the securities in the investment account declines, additional collateral, or the repay the loan. securities backed loan program available on The Lending Sponsor compensates TFA for making the 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 IARs and IARs do not have a direct financial incentive to 5  IARs may still be incentivized recommend the Lending Sponsor over other lenders, both TFA and its to recommend borrowing over asset liquidation. This is because maintaining account assets allows TFA and its IARs to continue earning advisory fees. Additional information about the TFA365 Advisory Program can be found in the TFA365 Advisory Program Brochure – Form ADV Part 2A Appendix 1. Bank Deposit Sweep Program” or the “Program” ). When cash is swept to a Clients may opt out of the Program Bank Deposit Sweep Program If clients hold uninvested cash in a TFA365 account, TFA in conjunction with its clearing broker, NFS, automatically transfers these amounts into interest bearing deposit accounts at participating FDIC insured banks (the “ participating bank, it is protected by FDIC insurance up to applicable limits and is no longer covered by SIPC. The Program is the default option for uninvested cash. for any non -retirement advisory program account by contacting their IAR . Program, TFA, not the participating banks, se always the highest available lects the interest rate , and the interest that could be earn ed through other available , will be , in most cases clients . As a result, returns will be lower than those available from Under the Bank Deposit Sweep clients receive. T he interest rates TFA selects are not rate earn ed will, in most cases, be lower than the returns cash options. TFA receives compensation from the participating banks that higher than the interest paid to alternative investment options. eligible investment advisory programs, they should -based s , this may reduce When clients are enrolled in one of TFA’s understand that the Program fees paid to TFA are separate from, and in addition to, the asset advisory fee paid to TFA and the IAR on the cash in an advisory program account. Because we receive two layers of fees on the same cash balances held in advisory program account overall investment return s and could result in a negative return. s paid on the cash balance in s of interest because TFA has a s create significant conflict clients’ cash in the Program. TFA addresses th -generated revenue with ese conflict s of interest TFA The revenue paid to TFA through the Program and the two layers of fee TFA365 advisory program account financial incentive to keep through disclosures regarding the Program, by not sharing Program IAR s , and by permitting certain accounts to opt out of the Program. alternative investments for is available in the Bank Deposit Sweep Disclosure document available at More information about the Program, associated conflicts of interest, and uninvested cash https://www.tfaconnect.com/disclosure . is no longer open to new Transamerica ONE Wealth Management Platform The Transamerica ONE Wealth Management Platform (“Transamerica ONE”) business. However, current clients that own a Transamerica ONE account may add money to their existing Transamerica ONE account or , in limited circumstances, open a new Transamerica ONE 6  account . Transamerica ONE is a wrap fee program that offer ed access to a fee TFA - -based TFA entered into an agreement with Goldman Sachs Group, Inc. ("Goldman Sachs"), whereby administers and sponsors Transamerica ONE using Goldman Sachs Advisor Solutions’ internet based platform. investment management program. -Series model portfolios are available within Transamerica ONE. TFA is the Model -Series portfolios. Transamerica I -Series model portfolios use rdance with particular investment Transamerica I Manager for the Transamerica I strategic, tactical, and alternative asset allocation models in acco objectives and risk targets. -Party Model Portfolios”). TFA has also retained independent firms to create model portfolios (“Third These independent asset managers are referred to as “Third -Party Model Managers ” or “TPMMs ”. TFA may, from time to time, replace existing TPMMs or hire others to create additional portfolio s , at their discretion . The TPMMs are responsible for all investment selections for the model portfolios that they manage. From time to time, TPMMs will update their model portfolios. TFA monitors the performance of TPMMs on an ongoing basis as part of our due diligence process. clients may select multiple model portfolios , allowing clients to pursue Within Transamerica ONE, 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 Investment Products in his or her account. , which is a suite of risk staying TFA also offers Transamerica Strategy Solutions -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 with their stated risk tolerance. -dealer and primary Folio Investments, Inc., a Goldman Sachs Company (“Folio”), is the broker custodian for Transamerica ONE accounts. -Series model portfolios , and Program Brochure Additional information about Transamerica ONE , Transamerica I Transamerica Strategy Solutions can be found in the Transamerica ONE Wrap Fee – Form ADV Part 2A Appendix 1. (“Transamerica ALPHA”) is no longer open to Transamerica ALPHA Digital Investment Program The Transamerica ALPHA Digital Investment Program new business. However, current clients who own a Transamerica ALPHA account may add money to . their existing accounts or, in limited circumstances , open a new Transamerica ALPHA account 7  -based platform. Betterment serves as a sub s - -based platform through which Betterment -advis er. Model portfolios and TFA. Betterment uses a strategic asset TFA entered into an agreement with Betterment LLC ("Betterment"), whereby TFA sponsor Transamerica ALPHA using Betterment’s internet advis er for the program. Betterment provides an internet provides discretionary managed account services as the program’s sub are developed and overseen by Betterment, Vanguard, allocation method for investing assets and uses ETFs as the underlying investments for client assets. -dealer and Apex Clearing Corporation accounts . Millennium Trust Company serves Betterment Securities, an affiliate of Betterment, is the broker (“Apex”) is the clearing broker for Transamerica ALPHA as the custodian for Betterment IRA accounts. found in the Transamerica ALPHA Wrap Additional information about Transamerica ALPHA can be – Form ADV Part 2A Appendix 1. Clients should review Betterment’s Form Fee Program Brochure ADV Part 2A, which contains additional information regarding Betterment’s services, processes, and policies. Program is a digital offering and that the is through the Clients should understand that the Transamerica ALPHA primary method of communicating with clients and providing clients investment advice Transamerica ALPHA website, mobile applications, or other digital interfaces that may become available in the future. IARs have access to third -party money managers model portfolios to clients who have access to a self - . Depending on the TPMM selected, the TPMM will typically utilize In some cases, TPMMs may include . Please refer to the specific TPMM’s Form ADV Part 2A or other their model activity . This program and TPMM s Third -Party Money Management Program In addition to the above Programs/Platforms, (“TPMMs”) that focus on providing managed directed brokerage account (“SDBA”) either ET Fs or mutual funds within their investment strategies. equity securities, municipal securities, US government securities, and/or other securities products within their investment strategies disclosure document for a complete listing of the types of investments it may use in portfolio s . Within each Third -Party Money Management Program, the TPMM will have discretionary authority over client account s to conduct the necessary trading are only offered to individuals through their SDBA option in their 401(k). -party investment advisers that the IAR and the third -party manager. Where we act Third -Party Referral Services TFA has entered into referral arrangements with various third participate in, manage, or sponsor different types of money management services and investment are structured in accordance with the marketing advisory programs. These referral arrangements clients the compensation we rule 206(4) -1 under the Advisers Act which requires that we disclose to receive for referring you to a third -party adviser, whether the IAR is a client of the third -party manager and any other conflicts that may exist between solely as a referrer, clients will not enter into an agreement directly with us. In such an arrangement, 8  clients will establish a direct relationship with the third -party investment adviser, and we will receive the client . This a referral fee from the adviser based on a percentage of the advisory fee they charge compensation creates a conflict of interest and serves as an incentive for the IAR 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 B rochure and any compensation disclosure statements provided. the TPMM, Portfolio Manager , or Model Manager Types of Investments Within each of the advisory services described above, decide what securities will be used in the models. their clients by explaining the investment management process, investment objectives, undertaken as part of the completing the written IARs assist any applicable securities restrictions, and the investment strategies servic es. IARs review the programs with their clients and assist their clients in or electronic materials required by each program . to determine whether the account continues to align with the client’s IARs provide ongoing monitoring of client portfolios in investment advisory programs. IARs will contact advisory clients at least annually investment objectives and financial circumstances. 1 “AUM”) Assets Under Management ( As of December 31, 2025, TFA managed approximately $1,663,100,000 of client assets on a discretionary basis and approximately $ 443,5 00,000 of client assets on a non -discretionary basis . ITEM 5 – FEES AND COMPENSATION several different methods. It is important to us that clients compensated , along with any other costs or fees associated TFA and IARs receive compensation through understand how both TFA and its IARs are with their advisory accounts. Details for each program are listed below. The fees and costs charged differ among our programs. Clients should carefully review the advisory service agreement for the advisory program they select ed . It provides greater detail with respect to the fees and costs clients will pay for the selected program . 1 With the exception of the Betterment Standard Service Model accounts . 9  Program Fees Deducted from the Account Other Expenses Charged on the Account 2 Annual Advisory Fee Account Aggregation Discount Offered Maximum Total Annual Program Fees IAR Portion of the Total Fee is Negotiable between Client and IAR Yes 2.75% TPMM Programs 3 Dependent on the TPMM program selected. 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 Yes 2.0% Transamerica ONE Monthly in arrears. Please refer to the Transamerica ONE Brochure for additional fee information. Yes Yes Transamerica ALPHA Monthly in arrears. 0.65% - 0.95% 4 Please refer to the Transamerica ALPHA Brochure for additional fee information. TFA365 Yes Yes 2.75% 5 Monthly in advance. Please refer to the TFA365 Brochure for additional fee information. 2 Clients may also incur certain charges imposed by third parties other than TFA and their IAR in connection with investments made through client’s account, including, without limitation, the following types of charges which are generally charged by mutual f unds and fully disclosed in each fund prospectus: 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 Pro gram Fee Client will pay to participate 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. Clients should carefully review the mutual fund prospectuses associated wi th recommendations made by their IAR 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 the 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) -1 fees. 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 retained by the custodian. For TFA365 accounts, the lowest cost mutual fund share class made available will be purchased. In certain instances, the shar e 10  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. Within the TPMM program, for self -directed brokerage accounts managed by The Pacific Financial Group (“TPFG”) and TFA, clients are not charged an advisory fee. Instead, TPFG’s affiliate, Pacific Financial Group, LLC (“PFG”), receives an advisor y fee from P FG Mutual Funds for providing investment advice to the Funds. In addition, for services provided by TFA and its IARs, 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 its IARs. PFG Mutual Fu nds only have one share class available; therefore, clients will invest in that share class. 3 TFA’s IARs do not establish the fee charged by the TPMM. TFA’s IARs 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 IA Rs. TFA does not mark up the fees charged by the TPMM. TPMMs will typically require that clients authorize automatic fee deductions from their advisory accounts. In many cases, the TPMM will also charge fees on cash positions held within client accounts. C lients should refer to the TPMM’s Form ADV Part 2A or other disclosure documents 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 e xpenses 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 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 register ed investment adviser such as TFA. The IAR’s portion of the client’s total fee will be in addition to the TPMM’s fee which can be found in the TPMM’s Form ADV P art 2A or other disclosure document. The total fee may be charged monthly or quarterly in arrears or in advance depending on the TP MM. 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. 4 The Total Annual Program Fee charged may be higher than the fees charged by other investment advisers for similar services. TFA reserves the right to waive or lower the fee in certain cases. 5 Fees are expressed as an annual percentage of assets under management. The Total Annual Program Fee to the client is dependent on the model portfolio(s) selected and the negotiated IAR fee. The client may also incur certain charges imposed by third parties other than by TFA and its IARs in connection with investments made through Client’s Account. For more details – Services, Fees and related to these charges, please refer to the TFA365 Brochure (Form ADV Part 2A Appendix 1), Item 4 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 dete rmined 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 fee, it will be assessed a minimum of $12.50 every month based on the average daily balance of the account during th e 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. 11  Transamerica ONE (Not open to new business) For detailed information on fees and billing, please see the Transamerica ONE Brochure . ONE, the - Depending on the account balance and/or model portfolios selected within Transamerica 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 the client . Transamerica ALPHA (Not open to new business) For detailed information on fees and billing, please see the Transamerica ALPHA Brochure . IAR a portion of the fee according to a compensation grid that may change from TFA will pay the time to time. The fees charged under certain advisory programs may be higher than those charged by other investment advisers for similar services. Fee differences may be attributable to differences in service models, account features , levels of personalization, and administrative costs. TFA365 For detailed information on fees and billing, please see the TFA365 Brochure . the same strategies or model portfolios may be available within the Third -Party Depending on the account balance and/or model portfolios selected within TFA365, investment management Money Management programs available through TFA at different pricing levels which may be more or less expensive to clients . Please refer to the account establishment paperwork for the TFA365 Advisory Program for additional details on fees and expenses. Refunds For clients with assets managed within Third-Party Money Management Programs, please refer to the the TPMM advisory service agreement, termination provisions and, if applicable, fee refund provisions in account opening paperwork, and/or Form ADV Part 2A or similar Disclosure Brochure. TFA and Goldman , nor any of the Model Managers cash, or other Upon termination of the Client Services Agreement with ONE account s will remain under the custody of Folio until ONE, the Client Services Agreement will continue in effect until For clients with assets in Transamerica the client 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 Sachs terminate. Upon termination, neither TFA, the IAR, Goldman Sachs will have any obligation to recommend or take any action regarding the securities, investments in the Transamerica ONE account. TFA, account assets held within Transamerica the client provide s the required account transfer instructions to Goldman Sachs. 12  ALPHA, the Client Services Agreement will continue in effect will remain under the custody of Betterment Securities or Millennium the client provide s the required account transfer instructions to For clients with assets in Transamerica until the client 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 its IAR , will have any obligation to recommend the Transamerica ALPHA or take any action regarding the securities, cash, or other investments in account. Upon termination of the Client Services Agreement with TFA, account assets held within the Transamerica ALPHA account Trust Company (for IRA accounts) until Betterment. its IAR , will have any obligation to the securities, cash, or other investments in the TFA365 For TFA365, the Client Services Agreement will continue in effect until the client or TFA terminates it by giving written notice pursuant to the specific terms found in the TFA365 Brochure , 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 recommend or take any action regarding Advisory Program account. the client’s under custody of NFS until the client provide s the Upon termination of the Client Services Agreement with TFA, account assets held within TFA365 Advisory Program account will remain required account transfer instructions to Fidelity. TFA may , at its discretion , communicate a change to any aspect of : (1) the IAR’s fee, (2) the Platform fee, and (3) Clients will they object to the fee change by sending written notice Brochure to Changes in Fees Upon 30 days prior notice to clients, the Total Program Fees which include three components the Portfolio Manager fee . Changes may include an increase in the fees payable by the client. be deemed to have approved a fee change unless pursuant to the Notice section in the Client Services Agreement and/or applicable Program 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 (Not open to new business) TFA and its IARs will receive a portion of the total fee for the ongoing advisory, administrative, and marketing services related to the program. 0.65% for assets 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 ALPHA by $10,000 and below (based on the combined assets in all accounts within Transamerica the client). Of the 0.65% in the Standard and Premier Service Models, TFA receive s an annualized fee receive s 0.25%. of 0.40% for its investment advisory and administrative services and Betterment 13  -to-consumer services similar to -driven, investing direct ly with Betterment or to waive or lower the fee in certain cases at its Of the 0.95% in the Premier Service Model, TFA receive s an annualized fee of 0.70% for its investment advisory and administrative services and Betterment receive s 0.25%. The Total Annual Advisory Fee charged may be higher than the fees charged by other investment advis er firms for similar services. For instance, Betterment offers direct Transamerica ALPHA. Therefore, clients would pay a lower advisory fee for algorithm automated (“Digital Advisor”) investment advisory services by other similar Digital Advisors. TFA reserves the right discretion with notice to clients as provided for in this Brochure . ONE Program and one of several Model Managers within Transamerica ONE (Not open to new business) TFA is the sponsor of the Transamerica the program . the and risk tolerance. Depending upon the model portfolios 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 client’s particular investment objectives 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, clients 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 clients in this program. TFA is the Model Manager for the Transamerica I-Series model portfolios available within -Series model portfolios use strategic, tactical, and alternative Transamerica ONE. Transamerica I asset allocation models in accordance with particular investment objectives and risk targets. Program is a program which uses strategic, the client' s stated investment objectives, time horizon and risk of investments used can consist of, TFA365 Advisory Program, clients may be or programs at a lower cost than TFA365 TFA and its IARs receive a portion of the total fee for ongoing advisory, administrative, and marketing services related to the program. TFA365 Advisory tactical, and alternative asset allocation model portfolios to establish an individualized model portfolio in accordance with tolerance. Depending upon the model portfolios selected, types but are not limited to, individual stocks, bonds, mutual funds, and ETFs (collectively “Investment Products”). Due to TFA’s advisory service fees within the able to purchase such investment products in other accounts participating in the model portfolios available to clients in this program. Transamerica Asset Management, Inc. (“TAM”), that manufacture s mutual funds. the TFA365 UMA program . TFA does not receive TAM, TFA is affiliated with These mutual funds may be made available within additional compensation for recommending affiliated products over unaffiliated products within its advisory programs, and IARs do not receive additional compensation for such recommendations. receives more overall revenue due to TFA offering its affiliated mutual fund products within the program 14  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. backed lending programs through third -party banks. These a client ’s advisory account . While TFA does not directly Sponsor t of interest exists because TFA ipate in Clients may be offered access to securities loans are collateralized by securities held in receive compensation for these loans, it does receive revenue share. The Lending compensate s 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 conflic and its IARs have an incentive to recommend such programs. Clients are not obligated to partic 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, wh ich may negatively impact the client's investment strategy. Bank Deposit If you hold uninvested cash in your account, TFA in conjunction with its clearing broker, NFS, automatically -bearing deposit accounts at participating FDIC insured banks (the transfers these amounts into interest “Bank Deposit Sweep Program” or the “Program” ). Once the cash is swept to a participating bank, it is protected by FDIC insurance up to applicable limits and is no longer covered by SIPC. The Sweep Program is the default option for uninvested cash. ses, will be higher than the the Program rather than recommending alternatives that may provide you with a IAR , and by permitting certain accounts to opt the Program , by not out of the Under the Bank Deposit Sweep Program , TFA, not the participating banks, selects the interest rate you interest rates TFA selects are not always the highest available, and the interest rate you will receive. The earn will in most cases be lower than the returns you could earn through other available cash options. TFA receives compensation from the participating banks that, in most ca interest paid to you. As a result, your returns will be lower than those available from alternative investment options. This creates a significant conflict of interest because TFA has a financial incentive to keep your cash in higher yield. TFA addresses this conflict of interest through disclosures regarding sharing Program -generated revenue with your Program. Sweep Disclosure document More information about the Bank Deposit Sweep Program, associated conflicts of interest, and alternative investments for uninvested cash is available in the Bank Deposit available at https://www.tfaconnect.com/disclosure or you can contact your IAR. an IAR acting in Sales of Other Financial Products The IAR may also offer clients fixed insurance products through his or her affiliation with World Financial Group Insurance Agency (“WFGIA”). Clients who purchase a fixed insurance policy from his or her capacity as a purchase of the policy. In these cases, WFGIA Agent, will pay a normal and customary insurance commission for the the IAR is not acting in their capacity as an IAR , but rather as an 15  IAR has an incentive to insurance agent of WFGIA and will receive a commission as an insurance agent. Such commission is paid IAR , as an insurance agent, from the issuer of the insurance product through WFGIA. to the applicable Receipt of these commission payments creates a conflict of interest. The recommend certain non -variable insurance contracts that are available through his or her affiliation with WFGIA, an affiliate of TFA, for which the IAR may receive greater compensation instead of certain investm ent advisory services through TFA that may be more suitable for the client . products to clients. The compensation paid on these individual products TFA is also registered as based securities than the compensation on investment advisory services, which creates a conflict of interest for the a broker -dealer. This allows IAR s to recommend the purchase of commission - may be greater IAR . TFA endeavors to mitigate the risks associated with these conflicts by providing training and guidance to its IARs regarding the assessment of best interest and suitability given the client’s stated investment objectives , time horizon and stated desire for on -going investment advice . compensation not affect client account s , the services . additional Additional Conflicts of Interest 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 may increase or decrease from time to time. Any additional marketing allowanc e paid by the TPMMs, Portfolio Managers, or other service providers to TFA will provided to clients , the fee for advisory services that clients pay to the TPMM, Portfolio Managers, or other service providers , or the compensation paid by TFA to its IARs. The existence of a marketing services agreement with TPMMs, Portfolio Managers, or other service providers can create a conflict of interest for TFA and /or its IARs . TFA will earn more revenue due to such marketing services agreements IARs do not receive any of this revenue directly , however, they indirectly benefit from this revenue through different educational and marketing initiatives conducted by TPMMs , Portfolio Manager s , or other service provider s . of interest because meeting TFA benefits from these Each of the TPMMs, Portfolio Managers, or other service providers that have marketing service agreements with TFA may attend, contribute to, or sponsor education and training meetings for IARs . 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 sponsors have more opportunities to provide IAR s with education on investments, their investment management services, industry trends, and other issues; and because contributions and reimbursements. ITEM 6 – PERFORMANCE -BASED FEES AND SIDE -BY -SIDE MANAGEMENT a client’s account. These fees are also called performance capital appreciation of -based fees. TFA’s TFA does not charge advisory fees based on a share of the capital gains on or funds or securities in advisory fee compensation is charged only as disclosed above in Item 5. 16  ITEM 7 – TYPES OF CLIENTS pensions , profit -sharing plans, trusts, estates, available through TFA clients’ related accounts managed by the TFA provides investment advisory services to individuals, charitable organizations , corporations and other businesses. Certain programs have minimum investment amounts based on the prog ram selected . TPMMs have discretion to waive an account minimum depending on the account program and TPMM. certain requirements for opening and maintaining advisory accounts. One of these TFA has established requirements is that advisory clients complete an investor profile. This profile provide s TFA with information such as name, address, date of birth, and other information used to identify clients . TFA may use third-party sources to verify and/or update the information provided and may also request to see a client’s driver’s license or other identifying documents. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS IARs will also explain the differences among the TPMMs available; including investment the electronic or written materials Third -Party Money Manager Programs IARs assist their clients in selecting a TPMM whose investment strategies suit their needs and financial objectives. management process, investment objectives, and the investment strategies undertaken as part of the servic e. IARs will also required by the TPMM. account continues to al review and assist the client in completing IARs will contact advisory clients at least annually to determine whether the ign with the client’s investment objectives and financial circumstances. TPMMs who are registered investment advisors based upon, but not limited to, the Investment strategy TFA selects following criteria: • Track record • • Disclosure documents, including disciplinary history The methods of analysis, sources of information , and investment strategies used by TPMMs will vary. We encourage clients to read each TPMM’s Brochure, and any other document receive d prior to entering into an agreement with a TPMM. strategies may involve reinvesting client TPMMs will exercise discretion over account assets. Certain dividends. is that past performance is not a guarantee , such TPMM has discretion to change how A risk associated with TFA’s selection criteria for TPMMs 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 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. 17  TFA365 Additional information related to the method of analysis, investment strategies, and risk of loss relevant to TFA365 can be found in the TFA365 Advisory Program Brochure – Form ADV Part 2A Appendix strategies, and risk of loss relevant Transamerica ALPHA Additional information related to the method of analysis, investment to Transamerica ALPHA Program Brochure – Form ADV Part 2A Appendix 1 . To automate rebalancing of the gy will instead seek tax efficiency by reducing trading frequency and Transamerica ALPHA Stars Strategy Transamerica® ALPHA Stars Strategy invests in a diversified portfolio of both stock and bond ETFs in between a blend that seeks to balance returns with risk. The balance between stocks and bonds and 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. 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 strate preferring long -term gains and losses over short -term gains and losses. eeded based on a review of the ETF’s ratings, 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 n returns, downside risk, daily liquidity, and other measurements. strategies, and risk of loss relevant Transamerica ONE Additional information related to the method of analysis, investment to Transamerica ONE can be found in the Program Brochure – Form ADV Part 2A Appendix 1. -Series Program (“I -Series Program”), TFA makes available its own proprietary ses such as and international and domestic , and Transamerica I-Series Program In the Transamerica I 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 clas 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 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 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. Each of these mutual funds or ETFs invests in at least 20 individual stocks, bonds, futures, or options. In consultation with the Advisor, clients may select an investment strategy that ranges from I -Series 18  -Series Aggressive, which Ultra Conservative, which is primarily invested in bond ETFs and/or funds, to I is primarily invested in stock ETFs and/or mutual funds. clients should never assume that future loss, including loss of original principal. TFA is unable to represent, guarantee, or even imply Past performance is not indicative of future results. Therefore, profitable and involves risk of performance of any specific investment or investment strategy will be loss. Further, depending on the different types of investments , there may be varying degrees of risk. Clients should be prepared to bear investment Due to the inherent risk of loss associated with investing, that TFA’s services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients 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 Brochure – Form ADV Part 2A Appendix 1 . -based allocations to strategies in the Transamerica Strategy Solutions Transamerica Strategy Solutions are a suite of risk Transamerica ONE platform. There are five allocations, one for each of the five risk categories. For more details, see the Transamerica ONE Brochure – Form ADV Part 2A Appendix 1 . model portfolios that have higher generally subject to greater risk, such as stock market volatility Material Investment Risks TFA’s advisory programs offer multiple model portfolios to satisfy a wide variety of investment and risk profiles, ranging from aggressive portfolios to conservative. In general, the advisory programs offered through TFA are subject to the risks noted below. However, concentrations in equity investments are and foreign exposure. Model portfolios that have a higher concentration in fixed income securities have credit, interest rate, and liquidity. greater exposure to risks such as their , investing in Investment Products involves a risk of loss to principal (invested Risk of Loss: Although TFA works hard to preserve client’s capital assets and help clients achieve investment objectives amount) and any unrealized profits . Certain model portfolios impose more risk than others. IARs will strive to provide investment advice for client’s assets to the best of our ability; er time. Clients should be prepared to lose money in any investment account. Clients may lose money TFA and its however, we cannot guarantee any level of performance or prevent losses in account assets. All investments in securities include a risk of loss of principal and any unrealized profits. Stock and bond markets fluctuate ov Investments are not a bank deposit and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. 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 19  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 tion to their investment strategy, and tax consequences. the potential for loss of principal, interrup -U.S. markets through either direct exposure the market may be significantly impacted Investments or accounts are also subject to volatility in non 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 by events affecting those industries or markets. In addition, investments in advisory account s may be subject to the following specific risks: Investing in Mutual Funds and ETFs: Account bears all the risk of the investment strategies employed by the account, including the risk that a mutual fund or ETF will not meet the mutual funds and ETFs held in 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. ESG investing, also known as “socially particular issuer or security, while others affirmatively select in companies that engage in , and Governance (“ESG”): Investing in Environmental, Social 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 “socially responsible” investments or screen out or exclude investments cert ain activities. This may limit the type and number of investments available in a strategy and cause without an ESG based focus or with a different type of the strategy to underperform other strategies 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. and Cybersecurity: Certain investment activities and investment strategies technologies, many of which are or critical activities of TFA on behalf of its clients, could be severely - fire or water damage, human errors in using or accessing relevant systems, It is not possible to provide fool -proof protection against all such events, and no Reliance on Technology are dependent upon various computer and telecommunications provided by or are dependent upon third parties such as data feed, data center, telecommunications, utility providers. The successful deployment, implementation, and/or operation of such activities and strategies and various other compromised by system or component failure, telecommunications failure, power loss, a software related “system crash,” unauthorized system access or use (e.g., “hacking”), computer viruses, or various other events or circumstances. assurance can be given about the ability of applicable third parties to continue providing their services. 20  of the risk of cyber ting, and/or monitoring its clients’ -attacks and harm to technology Any event that interrupts such computer and/or telecommunications systems or operations 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, liquida investments. In addition, clients should be aware infrastructure and data from misappropriation or corruption. 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, computer systems, software, and networks may be vulnerable to unauthorized and other events that could have a security access, issues, computer viruses or other malicious code, impact. (Transamerica ALPHA): Certain investment activities and investment strategies are The use of algorithms to provide investment advice carries the risk that with respect to client accounts. While this to implementation, even of assumptions, which may have inherent Algorithm Risks dependent upon algorithms. changes to algorithm’s code may not have the desired effect risk increases if changes to the algorithms are insufficiently tested prior extensively tested changes may not produce the desired effect over time. The algorithms used in the Transamerica ALPHA program are based on a number limitations and may not prove to be accurate. which stocks Investment Risk : Every mutual fund and ETF is run by a manager who is making decisions on and bonds to buy and sell. These securities can lose money causing the mutual fund or ETF to lose money. ’ operations and following the laws and or simply make bad decisions that result in higher expenses for the funds may commit fraud, ’ investors, Operation Risk : Every ETF and mutual fund are investment companies that are run by an advis er and a board of directors that is responsible for managing the funds regulations relevant to ETFs and mutual funds. The managers of the fund companies malfeasance, mistaken calculations of the funds ’ true value, or 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. For example, political, economic, and social conditions may trigger market Market Risk : The price of investments in advisory account s may drop in reaction to tangible or intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. events. Economies and financial markets throughout the world are increasingly interconnected. Economic, financial, or political events, trading and tariff arrangements, terrorism, war, global conflicts, epidemics , 21  , and other circumstances in one country pandemics , technology and data interruptions, natural disasters 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 investments are in securities of issuers to the countries directly affected, the value and liquidity of located in or with significant exposure investments may be negatively affected. Also, liquidity of individual investments, or even entire market segment s , can deteriorate rapidly, particularly during times of market turmoil , making those investments more 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 erod es 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 : Future proceeds from investments may be reinvested at a potentially lower rate of return (i.e., interest rate). To the extent a significant portion of the assets in a client’s account are , or region, the overall adverse Concentration Risk: concentrated in the securities of a single issuer, industry, sector, country impact on the client of adverse developments in the concentration area could be considerably greater than if the client did not concentrate their investments to such an extent. : These risks are associated with a particular industry or a particular company within an Business Risk industry. lt in bankruptcy and/or declining market 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 resu value. Fixed Income Risk : Portfolios that invest in fixed income securities are subject to several general risks, including interest rate, credit, and market risk , which could reduce a client’s yield . These risks may occur from fluctuations in interest rates, a change in an issuer’s individual situation or industry, or general market events . in specific risk Credit Risk: Changes in the financial condition of an issuer or counterparty and changes economic or political conditions that affect a particular type of security or issuer can increase the 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. 22  are subject to interest rate, currency exchange risks, all of which may be greater in emerging markets. These risks and can perform differently than U.S. markets. Emerging markets can be rate, economic, Foreign Risk: Foreign securities are regulatory, and political particularly significant for securities that focus on a single country, region, or emerging market. Foreign markets may be more volatile subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates may also be extremely volatile. a client to incur tax obligations that negatively affect the after . - Tax Risk: Securities may be bought and sold without regard to a client’s individual tax ramifications Therefore, portfolio turnover could cause tax return. Tactical asset allocation is an investment strategy that actively adjusts related economic, financial , es may be groups of industries that underperform other management countries and regions, Tactical Asset Allocation Risk: 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 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 securiti 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 styles. In addition, a strategy’s risk profile with respect to particular asset classes, 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 three material disciplinary events . Two events involve actions brought by the SEC and o ne involve s an action brought FINRA. SEC Proceedings • On March 11, 2019, the SEC issued an Order Instituting Administrative and Cease -and -Desist -and -Desist O rder (“Order”) relating to TFA’s disclose in its Form ADV 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 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 or elsewhere the conflicts of interest related to a) its receipt of 12b -1 fees and/or b) its selection of that pay such fees. TFA self -reported this matter to the SEC pursuant to mutual funds share classes 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 23  $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 -1 fees attributable to the investor during the that these investors are to receive from the Fund the 12b 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 -Series ® and Transamerica® ONE programs. The Order - -Squared”). The models managed by AUIM were the Global Tactical –Balanced, Globa l Tactical Allocation – Growth, egies are no longer offered by TFA and neither AUIM nor F - 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 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 Allocation – Conservative, Global Tactical Allocation 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 strat 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. -judgment interest, and to cease and desist from disgorgement, interest and penalties have been -Series® and Transamerica® ONE 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 violating certain securities laws and regulations. The 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 program s 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. nd the named affiliates had voluntarily retained a 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 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 b een 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 complianc e policies and 24  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. website at The foregoing is only a summary of the Order. A copy of the Order is available on the SEC’s www.sec.gov . FINRA Proceedings • On December 21, 2020, TFA and FINRA entered a Letter of Acceptance, Waiver and Consent in which ent A copy of this Order is available on FINRA’s 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 differ 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. website at www.finra.org/rules -guidance/oversight -enforcement/finra -disciplinary -actions -online . ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIV ITIES AND AFFILIATIONS with TFA’s affiliated broker -dealer . In addition, IA”), an TFA is a member of the Transamerica group of companies. Most of TFA’s IARs, members of management, and Investment Committee members are also registered the majority of TFA’s IARs are affiliated with World Financial Group Insurance Agency, Inc. (“WFG affiliated insurance agency. variable universal life insurance products, variable annuities, registered index - issued by companies the sale of non-affiliated on- -party money managers - These relationships were described in Item 4. These TPMMs are not affiliated conflict of TFA makes available linked annuities, mutual funds, 529 plans, ETFs and unit investment trusts (“UITs”) affiliated with TFA (“Affiliated Products”). When clients purchase Affiliated Products, TFA and/or its affiliates receive additional fees or compensation that are not received for products. As a result, TFA has a financial incentive to recommend Affiliated Products over similar n affiliated products. Affiliated Products may also be accessed through third (“TPMMs”) or model managers used in TFA advisory programs. TFA has contractual relationships with TPMMs that are independent investment advisers offering fee based advisory programs. with TFA. TPMMs share a portion of the advisory fees paid by clients with TFA, which creates interest because TFA has an incentive to recommend TPMMs that compensate TFA. In some cases, the cost of these arrangements may be higher than other advisory options. Affiliated Affiliated Products that TFA does not receive in connection with non - Some of the insurance and annuity products and mutual funds that TFA makes available are Products. Affiliated Products are issued by one of our affiliated companies. In addition to any commission associated with purchasing the product, TFA and/or our affiliates receive additional fees and compensation related to affiliated products. Many of these products can be purchased by the various TPMMs or Model Managers available in TFA’s programs. Because TFA and/or our affiliates make additional money when TFA and 25  Affiliated Products over similar IARs sell Affiliated Products, TFA has an incentive to recommend these non -affiliated products. TFA mitigates this conflict by supervising all recommendations made by IARs. cl ients pay to them. This is considered a conflict of interest. The cost of placing the assets in another advisory TFA has contracts with TPMMs that are also investment advis ers offering fee -based advisory programs. These relationships were described in Item 4. These TPMMs are not affiliated with TFA, and they pay TFA a portion of the fees client’s assets with one of these TPMMs may be higher than placing account. backed lending programs through third party lenders . TFA receives Please refer to Item 4 for TFA offers access to securities compensation from the lending sponsors, which creates a conflict of interest. a description of these conflicts and related risks. ogram. Please refer to Item 4 for a description TFA offers a bank deposit sweep program as its default option for uninvested cash in your accounts. TFA receives compensation from the banks involved in the pr of the conflicts related to this program. AEGON Ltd. Affiliates Under Common Control with TFA and the following entities are indirect, wholly owned subsidiaries of AEGON Ltd. Broker -Dealers • Transamerica Investors Securities Corporation • Transamerica Capital, LLC (“TCL”) TCL serves as principal underwriter and wholesale distributor for certain variable annuity and life insurance products issued by affiliated insurance companies. TFA receives compensation under selling agreements for these products, creating a conflict of i nterest. Investment Compan y • Transamerica Asset Management (“TAM”) TAM 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. Registered Investment Advisers • Transamerica Asset Management, Inc. (“TAM”) • AEGON USA Investment Management, LLC (“AUIM”) • Transamerica Retirement Advisors, Inc. (“TRA”) -dealer capacity, TFA receives revenue -sharing compensation Other Affiliated Companies TFA has material relationships with certain product sponsors, including affiliated insurance companies and agencies. In its broker when clients purchase products through these sponsors. 26  Current revenue -sharing arrangements and sponsoring companies are disclosed on TFA’s website at www.tfaconnect.com under Indirect Compensation Disclosure and Sponsoring Companies List . • Transamerica Retirement Solutions, LLC Transamerica Retirement Solutions, LLC (“TRS”) TRS is a retirement services firm offering a range of services, including recordkeeping, participant education and communications, Plan design, Plan testing, general ERISA, and IRS compliance. • WFG Securities of Canada WFGS offers mutual funds (“WFGS ”) and referral arrangements in Canada . Affiliated insurance companies and agencies include: • Transamerica Premier Life Insurance Company • Transamerica Life Insurance Company • Transamerica Financial Life Insurance Company • World Financial Group Insurance Agency, Inc. • World Financial Group Insurance Agency of Hawaii, Inc. • World Financial Group Insurance Agency of Massachusetts, Inc. • WFG Insurance Agency of Puerto Rico, Inc. • World Financial Group Insurance Agency Canada Inc. affiliated Conflict Management The a ffiliations described above create financial incentives to recommend certain products or services. TFA addresses these conflicts through disclosure and supervisory oversight of recommendations made by its IARs . IARs may also be licensed insurance agents and offer fixed insurance products through these affiliated agencies. When clients purchase fixed insurance products, the affiliated agencies receive commission compensation. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS , AND PERSONAL TRADING TFA has adopted a Code of Ethics (“Code”) designed to ensure that TFA meets its fiduciary obligation to clients 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. . It is distributed to Access Persons Access Persons must acknowledge their understanding of and TFA supplements the Code with annual training and ongoing monitoring The Code applies to TFA Access Person s , defined as TFA IARs, directors, officers, and other persons who at the time of becoming an Access are subject to TFA’s supervision Person and annually thereafter. agreement to abide by the Code. of the activity of Access Persons. 27  TFA’s Code outlines the duties of Access Persons, includ ing requirements to: • maintain TFA’s reputation as a firm that operates with the principles of honesty, integrity, and • • • ; and • • by obtaining approval for outside brokerage accounts professionalism; comply with applicable federal and state securities laws; read, know, understand, and follow all policies and procedures prescribed by TFA manuals, bulletins, or supervisory directives; cooperate with any investigation or inquiry conducted or authorized by TFA Management and/or ; Supervisory Personnel follow TFA’s Privacy Policy and related procedures report personal securities transactions and reporting such accounts as described in the Code . Additionally, the Code prohibits Access Persons from actions such as : • purchasing or selling securities for their own accounts or others while in the possession of -public) information or discussing information which might be considered “insider” (material, non the information with a third party; • participating in any Initial Public Offering or Private Securities Transaction • accepting or offering inappropriate and/or excessive ; and gifts , favors, entertainment , special accommodations, or other things of material value. Any Access Person not complying with these guidelines may be subject to disciplinary action up to and including termination. Clients may request a complete copy of our Code by contacting TFA at the address or telephone number displayed on the cover page of this Brochure. ITEM 12 – BROKERAGE PRACTICES -dealer will be used for the services described in s for a complete discussion of brokerage practices, trade allocation , and TFA does not have authority to determine which broker Item 4 above. TPMMs choose their own brokerage and soft -dollar practices ; clients should refer to TPMMs ’ disclosure document research or other soft -dollar benefits. -dealer and custodian for , at this firm. client account s when rebalancing is required for Transamerica I -Series ONE platform that are not affiliated with TFA will a model portfolio to adjust the weight Transamerica ONE Folio Investments, Inc., a Goldman Sachs Company (“Folio”), is the broker Transamerica ONE . Securities transactions will be executed through, and assets held TFA direct s purchases and sale transactions to Folio. Additionally, TFA will periodically direct one or more transactions for models . Model Managers on the Transamerica periodically direct one or more transactions for client account s when rebalancing is required. Rebalancing is the process of buying and selling portions of of each asset class to the original asset allocation model portfolio. 28  , however, there is no guarantee that this will be , Folio attempts to obtain the best execution accomplished. Due to this arrangement with Folio, TFA may be limited or unable to negotiate commissions, aggregate orders, or seek execution of transactions as efficiently as possible and at the best price . Clients 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. -dealer, to be cleared and settled through Apex. Betterment for clearance and -dealer may result in lower prices or more favorable Transamerica ALPHA For Transamerica ALPHA, client s have authorize d all trades to be placed with Betterment Securities, in its capacity as an introducing broker will send all trades to Betterment Securities for execution (which will use Apex settlement) even if the use of a different broker execution. -dealer and custodian securities transactions will be EAM”), an for TFA365 accounts; , NFS. Envestnet Asset Management, Inc. (“ , will be responsible for directing purchases and sale transactions to for client account s when rebalancing is a model portfolio to adjust the TFA365 NFS is the broker executed through, and assets held at unaffiliated investment adviser NFS. EAM will periodically direct one or more transactions required. Rebalancing is the process of buying and selling portions of weight of each asset class to the original asset allocation model portfolio. NFS attempts to obtain the best execution , however, there is no guarantee that this will be Due to this arrangement with NFS, TFA may be limited or unable to negotiate accomplished. commissions, aggregate orders, or seek execution of transactions as efficiently as possible and at the best price . ONE, client account s with similar may be made at different prices due to the in the transaction, will be made by Goldman Sachs in a manner 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 Goldman Sachs may aggregate securities purchases or sales orders for orders for other accounts if, in its judgment, such aggregation is reasonably likely to result in an overall economic benefit. Some of these aggregated transactions volume of securities purchased or sold. In such event, allocation of the securities to be purchased or sold, as well as the expenses incurred consistent with industry practices. ALPHA, Betterment places aggregated orders involving multiple Betterment no client is favored over any Within Transamerica accounts trading in the same securities. In conducting these transactions, other client, and each client that participates in an aggregated transaction will participate at the average share price for transactions in the aggregated order. 29  client account s with similar may be made at different prices due to the of the securities to be purchased or sold, NFS in a manner consistent with Within TFA365, NFS may aggregate securities purchases or sales orders for orders for other accounts if, in its judgment, such aggregation is reasonably likely to result in an overall economic benefit . Some of these aggregated transactions volume of securities purchased or sold. In such event, allocation as well as the expenses incurred in the transaction, will be made by industry practices and applicable disclosures . transactions. An agency cross transaction is a transaction in which advis er and broker -dealer for clients on one side of the transaction and Agency Cross Transactions TFA does not engage in agency cross TFA would act as an investment another client on the other side of the transaction. those However, TFA or any person associated with TFA may buy or sell securities identical to recommended to clients for their personal accounts. ITEM 13 – REVIEW OF ACCOUNTS IARs will contact IARs provide ongoing monitoring of client portfolios in investment advisory programs. advisory clients at least annually to determine whether the account continues to align with the client’s investment objectives and financial circumstances .6 Betterment’s algorithms continuously review client accounts on the Transamerica ALPHA platform. Clients 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 clients to carefully review these reports and compare custodial statements with performance reports , if applicable . The information in performance reports may vary from custodial statements due to accounting procedures, reporting dates, or valuation methodologies of certain securities. In the event of any discrepancies, clients should rely on the statements they receive from the custodian of the assets. We urge clients to compare these reports to the official account In addition to account statements and transaction confirmations, clients may receive performance reports. Periodically , clients may receive Albridge Personalized Account Statements directly from their IARs . These statements may include lists of account holdings, including mutual funds and securities, but are not official account statements. statements of their account holdings provided to them at least quarterly by the custodian of the account to ensure that the holdings listed on these reports provided by the IAR match those reflected on the official custodial account statements. Annually, the TFA Chief Compliance Officer , or designee, delivers TFA ’s Annual Due Diligence Questionnaire to all TPMMs and/or Model Managers with which TFA has agreements. Compliance and a designee review and score each questionnaire. Scores will be used to TFA investment committee 6 With the exception of Transamerica ALPHA Standard Service Model accounts . 30  -site visits; placement of determine such things as further requests for documentation; further action; on the firm on TFA’s watch list. Results of the reviews and scores are reported to the TFA Investment Committee. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION , they may recommend that of TFA’s broker -dealer. If an IAR is also a TFA clients place securities transactions through variable life insurance, All sales charges and expenses are disclosed in the product prospectus, registered indexed -linked annuities, ETFs, or which Registration Arrangements Many of TFA’s IARs are also Registered Representatives Registered Representative TFA’s broker -dealer. These transactions could include, but are not limited to, the purchase or sale of mutual funds, variable annuities, other financial products. clients will receive at or before the time of the purchase of the product. IARs. TPMM, Portfolio Manager, or other service provider may IARs with Marketing Compensation Arrangements Each of the TPMMs, Portfolio Managers, or other service providers may attend, contribute to, or sponsor education and training meetings for our 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 education on investments, their investment management services, industry trends, and other issues; and because TFA benefits from these contributions and reimbursements. may influence their , or non -cash compensation based on their volume of fixed particular fixed insurance decision to recommend Other Compensation Arrangements If an IAR is associated with World Financial Group Insurance Agency , Inc., they are permitted to participate in award and incentive programs sponsored by World Financial Group Insurance Agency , Inc. in which they could qualify to receive trips, promotions insurance sales. These events products to clients . -cash compensation based providers . To the extent an IAR -cash compensation, a conflict of interest IAR ’s recommendation of products and services for which they receive IAR s to receive marketing reimbursements from product FA does not requir e or have any expectation that IARs refer TFA monitors recommendations made by its IARs to Some IARs may participate in incentive trips and receive other forms of non on the amount of their sales and services through TFA or product participates in an incentive trip or receives other forms of non exists in connection with the these additional economic benefits. TFA allows providers to help defray these expenses. T clients to or place assets with such providers. ensure that they are in each client’s best interests. revenue sharing compensation from a third -party lender when its clients engage in Such arrangements create conflict s of interest, which we disclose to clients and TFA receives securities backed lending. TFA also receives fees from its arrangement with its Bank Deposit Sweep Program sponsor. manage through TFA’s compliance policies and procedures. 31  ITEM 15 – CUSTODY , and should only make them LPHA, and Goldman Sachs for Transamerica ONE . TFA urge s TFA does not take custody of client funds or securities. Client funds and securities are held with a qualified custodian. Clients should never make checks payable to their IAR payable to NFS for TFA 365, Apex for Transamerica A Clients receive account statements directly from the qualified custodian at least quarterly. clients to carefully review these statements as they are the official record of the account and assets. ITEM 16 – INVESTMENT DISCRETION would be fully disclosed IARs do not accept discretionary authority in connection with the accounts opened through its TPMM relationships. TPMMs may maintain discretionary authority, but such authority to clients in the TPMM’s Form ADV Part 2A or other disclosure documents . later by written notice to their IAR . If a requested investment restriction become TFA will notify the client that, unless the instructions are modified, TFA may reject or Clients may impose reasonable investment restrictions on the management of their accounts at the time of opening their account or is deemed to be unreasonable, or if TFA determines that a previous restriction has unreasonable, terminate the client relationship at its discretion and upon notification to the client pursuant to the notification terms in the applicable Client Services Agreement. the client grant s TFA the discretionary authority to if the changes only occur within lient also give s FIWA and EAM discretionary the account When a client open s a TFA365 Advisory account, the risk replace and update allocation weightings for Portfolio Managers tolerance noted on a c lient’s most current S IS on file with TFA. Any changes to allocations outside of the stated risk tolerance would require a new SIS . The c authority. Clients may impose reasonable limitations and restrictions at the time of opening or later by written notice to their IAR . ITEM 17 – VOTING CLIENT SECURITIES (PROXY VOTING) ’ accounts in Transamerica ONE or TFA365, including ; clients are responsible for directing the way proxies for the the account are voted. Clients should refer to the TPMM’s disclosure documents for a These documents will explain whether clients will TFA does not vote proxies on behalf of our clients those accounts managed by TPMMs securities held in complete description of their proxy voting procedures. receive proxies or other solicitations directly from the custodian or a transfer agent. Transamerica ALPHA account s delegate d to Betterment the authority to receive Clients who opened 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 tha t Betterment recommends be purchased for client accounts. Clients may request 32  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, TFA is not aware of any financial condition that is reasonably likely to impair TFA’s ability to meet contractual commitments to clients. TFA has not been the subject of a bankruptcy petition at any time, including the past ten years. 33 

Form ADV Part 2A – Appendix 1 Transamerica ALPHA Wrap Fee Brochure March 31, 2026 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 -3271. The information in This Form ADV Part 2A – Appendix 1 (“Wrap Fee Brochure” or “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 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 on the SEC’s website at 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. 2  ITEM 2 – MATERIAL CHANGES Item 2 provides a summary of material changes that were made to this Brochure since its last annual amendment on March 28, 2025. Transamerica ALPHA officially closed to new business. However, current clients who own a Transamerica ALPHA account may add money to their existing account or, in limited circumstances, open a new Transamerica ALPHA account. When TFA updates this Brochure with material changes, TFA will either send you a copy of the updated Brochure or offer to send you a copy (either by electronic means (email) or in hard copy form) within the required timeframe. or contact us at If you would like a copy of this Brochure, you may download it from the SEC’s public disclosure website (IAPD) at www.adviserinfo.sec.gov , download it from TFA’s website at www.tfaconnect.com, (770) 248 -3271. 3  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 ................................ ................................ ................................ ................................ . 5 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ................................ ................................ .. 14 ................................ ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION ................................ ................................ 15 ............................ ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ................................ ................................ .......... 17 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................ ................................ ................................ .......... 17 ITEM 9 – ADDITIONAL INFORMATION ................................ ................................ ................................ ................................ 17 ........................... 4  ITEM 4 – SERVICES, FEES, AND COMPENSATION -dealer and has been a FINRA”) since 1984 as well as a member of The Company Transamerica Financial Advisors, LLC (“we/our/us/TFA”) is a federally registered investment adviser (“RIA”) and has been registered with the SEC since 1991. TFA is also a broker member of the Financial Industry Regulatory Authority (“ the Municipal Securities Rulemaking Board (“MSRB”). -related products and advisory and asset management services to the retail ” or “Financial (“RRs”) -dealer and registered representatives -dealer or registered representative capacity TFA offers investment public. TFA and some of its investment adviser representatives (“IARs Professionals /FPs ”) also act in the capacity of broker respectively. When TFA or an IAR is acting in a broker rather than providing investment advisory services, the fiduciary standard applicable under the Investment Advisers Act of 1940 ge nerally does not apply to those brokerage activities. TFA is directly owned by AUSA Holding, LLC, which is an indirect, wholly owned subsidiary of the ultimate parent, AEGON Ltd., a publicly traded company listed on the New York Stock Exchange (“NYSE”) and trading under the symbol AEG. -party money managers who manage model -based ients through individuals Advisory Services Offered In its capacity as an RIA, TFA offers access to third portfolios on behalf of clients and wrap fee programs that offer clients access to fee investment management. TFA’s advisory services are made available to cl registered with TFA as IARs. Transamerica ALPHA is no longer open to new The information in this Wrap Fee Brochure only pertains to the Transamerica ALPHA Program (“Transamerica ALPHA” or “Digital Advice Program”). business. However, current clients who own a Transamerica ALPHA account may add money to their existing account or in limited circumstances open a new Transamerica ALPHA account. other B rochure s . For more detailed TFA IARs can offer clients other advisory services described in information about these programs, IAR s can provide clients with a copy of TFA’s Form ADV Part 2A or it can be access ed directly by visiting TFA ’s public website at www.tfaconnect.com . advisory services determine the client’s financial needs, , an IAR will meet with the client to collect and time horizon, risk tolerance, . The IAR will then provide investment At the time of or prior to offering analyze financial information to investment objectives, and current investment strategies, if any advice based on the analysis. TFA and its IRAs do not provide legal, tax or , accounting advice . TFA does not take custody of client funds or securities, including stocks or bond certificates or cash. 5  When providing funding for a client’s account, if the client is using a check, the client should only make any check payable to Apex . Clients should never make checks payable to their IAR or any entity other than Apex . and answer questions about the service. IARs will contact advisory The IAR will also explain any special instructions for the management of the assets in a Transamerica ALPHA account; the investment management process, investment objectives, investment strategies undertaken as part of the service; clients at least annually to determine whether the account continues to align with the client’s investment objectives and financial circumstances. 1 , whereby TFA sponsors Transamerica ALPHA -Advisor”), an unaffiliated using Betterment’s a digital advice program under which clients receive -advisory services to clients in Transamerica ALPHA, s for TFA has an agreement with Betterment LLC (“Betterment” or “Sub registered investment advisor internet -based platform. Transamerica ALPHA is investment portfolio recommendations and discretionary investment management of the assets held in their accounts. Betterment provides sub including t he model portfolios recommende d through the program’s website. Additionally, client delegate discretionary authority to Betterment to conduct day -to-day management and trading their account s. Clients can review Betterment’s Wrap Fee Brochure, which contains additional information regarding Betterment’s services, processes, and policies. le through the Clients should understand that Transamerica ALPHA is a digital offering and that the primary method of communication will be through the Transamerica ALPHA website and/or other digital interfaces that are available. The Transamerica ALPHA program offers clients the ability to participate in a centrally managed, goals Transamerica ALPHA web -based investment advisory program that is made availab -portal. advice to assist clients in achiev ing their investment objectives. clients p rovide through the TFA IAR s and Betterment are responsible for providing ongoing guidance and advice for the suitability of the Program. Through the Betterment website, IARs and Betterment can review clients’ investments and goals and provide The advice is limited to algorithms and is based upon the information Transamerica ALPHA web -portal. Transamerica ALPHA uses Betterment’s proprietary, automated, computer algorithms to create asset allocation portfolios for a client’s goals and to provide certain services described in this Brochure, including: • Determining the asset allocation to recommend to each client, based on the can elect to automatically update asset client information collected. Clients allocations for each goal as the goal date gets nearer. • Providing trade orders in each client’s account(s) . 1 With the exception of the Transamerica ALPHA Standard Service Model accounts. 6  ’s • Monitoring Transamerica ALPHA accounts regularly to determine whether to rebalance back to the target asset allocations based on parameters determined by Betterment in its sole discretion (current drift parameters vary based on the percentage of the client portfolio that each asset class represents); and • At a client’s election, placing trades for tax loss harvesting purposes (as further described below). The model portfolios are developed and overseen by Betterment, Vanguard, or TFA. Betterment seeks to create asset allocation s that maximize returns for given levels of risk. Betterment’s Socially Responsible model portfolios may use socially responsible exchange - traded funds (“ETFs”) for various asset classes at Betterment’s discretion. Vanguard’s model portfolios are based on a long -term static asset allocation chosen at Vanguard’s discretion. TFA will not provide or review performance information to determine or verify its accuracy and does not calculate model portfolio performance. This information will be reviewed and provided by Betterment. -bond allocations rather than active y will be periodically reviewed and replaced , if , and other metrics as Transamerica ALPHA Stars portfolios will use ETFs to gain broad market exposures to both stocks and bonds which are diversified across asset categories, industries, and countries but with a heavy weighting toward the U.S. and with a bias in growth stocks over value stocks. The ideal client prefers less trading and higher tax -efficiency (long -term capital gains/losses rather than short -term). Risk management is based solely on stock management. ETFs used in each asset categor necessary , by TFA based on risk, returns, ratings, daily liquidity, fees measured over select trailing time periods. , and Betterment collect certain demographic information, investment amounts, investment time horizon, and TFA model asset Under Transamerica ALPHA, TFA financial information, initial and ongoing investment objectives to recommend an asset allocation for the chosen model portfolio comprised of ETFs that are diversified across multiple asset classes. The model portfolios defaults to are TFA’s ALPHA Stars portfolios, which consist of a set of diversified stock and bond allocations through ETFs. Clients also have the optio n to alternatively select from Betterment Core Portfolios, Betterment Socially Responsible Portfolios , or Vanguard Portfolios. The percentage of stock and bond allocations is based on the answers to the information collected from the client. Clients have the option of accepting the model asset allocation recommended by the algorithm or adjusting the parameters for the purpose of receiving a different allocation. Adjusting the parameters may lead to an allocation that is not risk appropriate for such clients. 7  IARs are not a party To participate in the Digital Advice Program, clients must establish an account with Betterment Securities, an affiliate of Betterment. The account is a brokerage account that is opened when the client enters into a separate customer agreement with Betterment Securities to act as the introducing broker -dealer for all transactions executed under the Digital Advice Program. Please refer to “Brokerage Practices” below for additional information. TFA and its to this agreement. Assets in Transamerica ALPHA account s will be managed on a discretionary basis by Betterment in accordance with the model portfolio selected by the client. In order to permit time to ensure that the transfer of assets from a client’s existing bank, brokerage, or custodial account into a client’s account has been successfully completed and to complete any other required processing, there may be a delay of typically no more than 5 business days between the time the applicable deposit is credited to the account and the time when Betterment begins to place orders to purchase ETFs for the account. As a result, the deposit or transfer made will generally not be invested immediately upon opening an account and clients will not be subject to investment gains or losses resulting from the movement in market prices until the processing is completed. Fees are not assessed until assets are invested in the program’s model portfolios. Transamerica ALPHA reject or terminate the client relationship at its discretion and Program account to TFA requires a minimum asset value of $10.00 for a begin being managed. Note that an account will not be invested according to a model portfolio until the applicable minimum for the model portfolio and allocation has been reached. 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 upon notification to the client pursuant to the notification terms in the applicable Brochure and this Appendix. to their financial or demographic IAR can IARs will contact clients at least annually to determine whether the account Clients should notify their TFA IAR if there are changes information , financial objectives , or any other information previously provided, so that the help the client assess whether the selected model portfolio is still appropriate based on the client’s stated investment objectives, investment time horizon, risk tolerance and any other pertinent factors. continues to align with the client’s investment objectives and financial circumstances. 2 Transamerica ALPHA also offers tax -loss harvesting services to clients who opt for this service. Betterment will use algorithms to analyze tax -loss harvesting opportunities (such as gains or Standard Service Model accounts. 2 With the exception of the Transamerica ALPHA 8  losses) and wash sale management. Clients, and not TFA, are responsible for any tax consequences or tax or filing obligations resulting from the sale of securities in their account and from their election of tax -loss harvesting, if applicable. The tax -loss harvesting service does not should consult their tax advisor prior provide a comprehensive tax management solution. Clients to making any decision that may affect their tax obligations. TFA, TFA IARs , and Betterment do not provide tax advice. Within the Transamerica ALPHA program, clients will participate in a Standard or Premier Service Model . Specific features and services of each are outlined below: Features and Services Transamerica ALPHA Standard Transamerica ALPHA Premier Personal One -on-One Advice 3 Upon Request Yes Automated Rebalancing Yes Yes Automated Tax Loss Harvesting Optional Optional Optional Optional Tax Coordinated Portfolios (Auto Asset Placement) 4 Advisor Led Annual Reviews Upon Request Yes Yes Yes Yes Yes Aggregated Reporting of Held -Away Assets 5 Easy -to-Use Internet -Based Platform & Live Customer Support via Phone or Email Service Models of the Transamerica ALPHA program. If clients need s ervice model they are enrolled in would like to switch between Standard or This is not intended to represent a comprehensive list of all features and services available through the Standard or Premier clarification on which Premier, clients should contact their TFA IAR . clients have authorized all Brokerage Practices / Trade Execution In connection with the client’s participation in Transamerica ALPHA, the trades to be placed with Betterment Securities, in its capacity as an introducing broker -dealer, to be ient’s 3 Personal One -on-One advice will include, but not be limited to, advising clients on personal “What If?” scenarios, offering behavioral coaching, and providing life events consultation along with ad hoc advice. 4 Tax Coordinated Portfolios are not designed to, and do not, provide comprehensive tax advice to clients. Clients are solely responsible for the determination of whether, and when, to enable these features in their accounts, as well as any tax consequences arising from any transaction associated with these features. 5 Betterment will not base its recommendations on external accounts that clients sync to their Betterment account via Betterment’s online interface. Clients should also understand that use of this feature is not directly incorporated into a cl Transame rica ALPHA investment strategy or performance 9  through the custodian Apex Clearing Corporation (“Apex”). Millennium Trust that Betterment will send all trades to execution (which will use Apex for clearance and settlement) even if the -dealer may result in lower prices or more favorable execution. Clients will cleared and settled Company will serve as the custodian for qualified retirement accounts. Clients will bear the risks associated with these transactions and should understand Betterment Securities for use of a different broker receive the price at which such orders are executed in the marketplace. of securities in same securities for other accounts managed by net prices on the purchase and sale of securities -dealers. The ability to achieve best arrangement, he account occurs via a bundled fee urities’ execution services and Apex’s the use of Betterment Securities and Apex should not result in Each client participating in the Transamerica ALPHA Program is required to enter into a brokerage account agreement with Betterment Securities to open an account that will hold the client’s assets covered by the program. Clients also direct that all orders for the purchase or sale their accounts will be introduced to Apex by Betterment Securities and settled and cleared by Apex. By directing trades in the foregoing manner, TFA will not be able to: (i) select broker -dealers on the basis of price or other attributes; (ii) negotiate commissions or negotiate the price or quality of the custody, settlement and clearing services provided by Apex Clearing; or (iii) aggregate or “batch” orders for purposes of execution with orders for the TFA which are not executed by Betterment Securities or settled and cleared by Apex. As a result, certain transactions may result in less favorable than would be the case if TFA were able to select other broker execution may be partially or wholly limited by the nature of the directed brokerage and clients may not achieve executions of the nature, quality, speed, or price that might otherwise occur. As a result of the foregoing, a client’s account might not generate the returns it would if orders were not directed. However, since management of t arrangement that includes the costs of Betterment Sec settlement and clearance services, additional brokerage fees to a client. to reduce market impact and to obtain best execution. In position obtainable, and in some Program. Additional details about trade execution, account Clients authorize TFA and Betterment to aggregate purchase and sale orders for securities held (or to be held) in client accounts with similar orders being made on the same day for TFA’s and Betterment’s other accounts which are also custodied or cleared through Apex. Betterment may aggregate trades for clients and transmit “batched” orders some cases, aggregating orders may adversely affect the size of the cases, clients would receive better price execution if they did not participate in a batched order. Clients do not pay separate fees for trade execution, clearance, settlement, or custody services received under the Transamerica ALPHA maintenance, and asset custody may be found in Betterment’s Wrap Fee Brochure. receives deposits or withdrawals . on the same business day as it Betterment generally trades However, transactions will be subject to processing delays in certain instances. For example, orders initiated on non -business days or before/after trading hours (prior to 9:30AM EST or after 4:00PM EST) will not transact until the stock market opens (9:30A M EST) that same day or the following 10  business day. -ask spreads, and ETF market prices. team decide during their market assessment that factors in the market trading until they believe the client, delay or Each trading day, Betterment’s trading team conducts a market assessment prior to market open to review items such as, but not limited to, market volatility, bid Should Betterment’s trading are causing heightened volatility, they have discretion to not trade or halt pricing has normalized. Betterment may, at any time and without notice to TFA or manage tra ding in response to market volatility. not placing trades during approximately the first thirty also thirty minutes before the Betterment has a practice of generally minutes after the opening of any market session to avoid periods of market volatility. Betterment generally stops placing orders arising from model portfolio allocation changes (including rebalancing and increasing or decreasing the exposure to asset classes) approximately close of a market session. Betterment will continue to place orders associated with withdrawals and deposits until the market closes. Client account deposits are automatically subject to a processing period that may be up to five business days or longer. Deposit -related transactions will not occur until the next business day after this processing period is complete. Clients should refer to Betterment’s Wrap Fee Brochure for additional details regarding its portfolio management practices. , and other Fees and Compensation C lients pay an annualized wrap fee for the ongoing services of TFA and Betterment which include, but are not limited to investment advisory services, the execution of transactions administrative and custodial services. . Clients with $10,000 or less in total assets invested in the Program Two service model options are available to clients: a Standard Service Model and a Premier Service Model , each priced as follows will be placed in the Standard Service Model. 11  Client’s Total Assets Betterment’s TFA’s Portion Service Model Fees Total Fee Billed Portion of Total Fee of Total Fee (Wrap Fee) Transamerica ALPHA All Assets 0.65% 0.25% 0.40% Standard First $10,000 Transamerica ALPHA 0.40% All Assets over 0.65% - 0.95% 6 0.25% Premier 0.70% $10,000 or algorithm -driven, would not receive the personal advice provided by TFA IARs. The TFA will pay the IAR a portion of its fee according to a compensation grid that may change from time to time. The total fee charged may be higher than the fees charged by other investment adviser firms for similar services. For instance, Betterment offers direct -to-consumer services similar to Transamerica ALPHA. Therefore, clients would pay a lower advisory fee f automated (“Digital Advisor”) investment advisory services by investing directly with Betterment or other similar Digital Advisors but 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 adviser and brokerage services are purchased separately, and the size of a client’s account. charges imposed by law; and (ii) internal charges and fees, including -term trading fees, that may be imposed by any collective investment vehicles, -end funds, or exchange -traded funds (clients pay a pro -rata portion of The Wrap Fee does not include certain fees and charges associated with securities transactions, including the following: (i) redemption or short such as mutual funds, closed such fees, which are in addition to the fees paid to TFA under the program). with multiple SSNs, all accounts For clients with multiple accounts in Transamerica ALPHA, the applicable service model will be determined based on the combined assets in all accounts within Transamerica ALPHA by the client with matching social security numbers (“SSN”). For joint accounts with a matching SSN will be included as part of the combined assets calculation. For trust accounts, all accounts matching the trustee’s SSN (not the trust’s Federal tax ID number) will be included as part of the combined assets calculation. Please refer to the account establishment paperwork for Transamerica ALPHA for additional details on aggregating fees and expenses. The Wrap Fee is accrued daily in arrears by applying the applicable advisory fee rate (0.65% or 0.95%) day. to the average portfolio value of all assets of client’s account as of the close of each calendar 6 TFA’s portion of the client’s total fee within Transamerica ALPHA Premier may be negotiable. 12  ALPHA program do not have an securities will be sold monthly to pay for the Wrap Fee. In non-tax , such sales may result in a taxable event for clients. Clients are solely responsible (s). Clients should Monthly, Betterment will calculate the applicable Wrap Fee and will automatically deduct the amount due from a client’s account. The model portfolios in the Transamerica allocation to cash. Accordingly, qualified accounts for all taxes payable in connection with the sale of securities in their account consider such tax ramifications before deciding to participate in the program. time and will result in an adjustment to the Wrap Fee with Additional assets may be added at any respect to such new assets prorated from the date of the addition. Withdrawals of assets may be made at any time. The proceeds of a withdrawal will be delivered to the client after the time necessary for the resulting trades to clear and settle. Custodian Fees and Charges The custody fee charged by Betterment Securities will be paid out of the Wrap Fee. All in each ETF’s prospectus for client review. Clients should read each ETF’s Additional Fees and Charges All fees paid to TFA or Betterment are separate and distinct from the fees and expenses charged by ETFs to their shareholders. These fees and expenses are described in each ETF’s prospectus. ETFs held within the Transamerica ALPHA account have ongoing expenses that will impact the return received by the client’s account. The ongoing expenses include management fees, distribution expenses, shareholder servicing, and other similar fees and are automatically deducted by the ETF daily. The ETF’s charges and expenses are subject to change. An explanation of the ETF charges and expenses are provided prospectus carefully. Changes in Fees TFA, at its discretion, may revise TFA’s portion of the Wrap Fee with 30 days prior notice to clients which may increase the fees paid by the client. A client will be deemed to have approved a fee change unless he or she objects to the fee change by sending written notice to TFA within 30 days from the date of the fee increase notification. We also may negotiate, discount, or waive any fees associated with the Transamerica ALPHA program, at our discretion with no notice. Furthermore, TFA employees and employees of affiliates may b e entitled to fee discounts by virtue of their employment. notice, and thereby terminate an account under the Account Information Either TFA or a client may terminate the investment management agreement at any time with written notice, effective as of the date of the Transamerica ALPHA program. Upon termination of the agreement, Betterment is authorized by client via the Client Services Agreement to redeem or otherwise liquidate any investments in the account and disbu rse the proceeds to the client. Such redemption or liquidation will affect the asset allocation and/or market value of the account and may also have tax consequences. The client may 13  assets -dealer other than Betterment Securities by Betterment Securities. Certain -dealer and, therefore, may need to be - kind. Betterment and TFA shall not be liable for any losses caused alternatively request transfer of assets to a broker submitting a request to Betterment in a form determined by held in the account may not be accepted by another broker liquidated and not transferred in by the liquidation of securities pursuant to the termination of the investment management agreement, including but not li mited to any tax liabilities. Conflicts of Interest TFA and IARs will receive a portion of the Wrap Fee for ongoing advisory, administrative, and marketing services related to the program. and other services and Betterment ilar to Transamerica -to- ALPHA. Clients would pay a lower advisory fee for Two service model options are available to clients: a Standard Service Model priced at 0.65% 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 held 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, administrative, will receive 0.25%. Of the 0.95% in the Premier Service Model, TFA will receive an annualized fee of 0.70% 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, offers direct consumer services sim algorithm - driven, automated (“Digital Advisor”) investment advisory services by going direct to Betterment, or other similar Digital Advisors. TFA reserves the right to waive or lower the fee in certain case at its discretion with notice to clients as provided or in this Brochure. TFA sponsors and manages various other investment advisory programs, which provide clients with a mix of investment advisory and related services that may cost clients more than participating in the Transamerica ALPHA program. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS , and other businesses. -sharing plans, trusts, TFA provides investment advisory services to individuals, pensions, profit estates, charitable organizations, corporations The following minimum amount s are required to establish and maintain an investment in a diversified portfolio under the Transamerica ALPHA program: Service Model Investment Minimum Transamerica ALPHA – Standard $10 Transamerica ALPHA – Premier $10,000 14  which program is best for their Clients with $10,000.00 or more in investable assets are not required to select or maintain the Premier program. Such clients do have the option of selecting individual needs. investor profile . This profile provides TFA with information such as name, address, date -party sources to verify r’s license or TFA has established conditions for maintaining accounts. Specifically, advisory clients must complete an of birth, and other information used to identify clients. TFA may use third and/or update the information provided and may also request to see a client’s drive other identifying documents. date, a heavier initial weight to bonds is used The ideal client for the Transamerica ALPHA Stars strategy wishes to invest in a diversified portfolio with both equity and bond ETFs to seek a balance of returns with risk. The targeted balance between stocks and bonds (and between returns and risk) will initially be set based solely on the time remaining until the target goal date. For goals with a closer target to reduce the historically higher risk due to stocks. To automate the adjustment of the initial weights so that the portfolio is automatically rebalanced to hold more bonds and less stocks as the target date gets closer, the client must have the “Auto Update” feature turned on. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION IAR , inform Betterment of the client’s financial goals algorithm then recommends and builds a portfolio of ETFs Betterment’s Investment and the ETFs in such TFA serves as the investment advisor for the Transamerica ALPHA program. Betterment serves as the Sub -Advisor. Clients, working with their TFA and personal information and Betterment’s for each of the client’s financial goals and account types. Each portfolio is associated with a target allocation (the “Allocation”) of investment types and/or asset classes. Committee oversees this process and has approved each potential portfolio portfolio. To reduce costs in the Transamerica ALPHA program, ETFs are utilized. one or more model portfolios based on the client’s TFA IAR s assist clients with the selection of investment needs. Except for the Transamerica ALPHA Stars Strategy, Betterment is responsible for maintaining all model portfolios available through the Transamerica ALPHA program and ensuring that changes to the models are implemented appropriately for the client’s accounts, which includes taking into consideration any reasonable restrictions set forth by a client. TFA does not guarantee the performance of the model portfolios developed by Betterment. s under the Transamerica ALPHA program or participate portfolios. TFA IAR s do not exercise discretion over any client account. IAR s have an interest in or receive remuneration based on any model of its IAR s manage, control, portfolio’s supervise, or otherwise exert any TFA’s IARs do not act as portfolio manager in the design of the model Neither TFA nor its target allocation. Neither TFA nor any influence over the managers of the ETFs purchased in client accounts under the Transamerica 15  ALPHA program. due diligence for existing Sub -Advisors which is presented to the TFA Analysis TFA conducts ongoing Investment Committee. risk tolerance, time horizon, and goals. Each model Betterment uses diversified asset allocation models for the purpose of managing each client’s account. Betterment’s proprietary algorithm generates recommendations of the model portfolio based on the client’s financial circumstances, portfolio corresponds to a specific set of asset classes and allocation of ETFs among those asset classes (which may differ if the account is taxable or non -taxable). should understand that the Transamerica ALPHA program financial plan , but rather is built to assist clients provide inaccurate information, Clients, working with their TFA IAR , are free to accept Betterment’s recommended model portfolio or choose their own model portfolio within the Transamerica ALPHA program based on their own preference or risk tolerance. Clients who seek to deviate from Betterment’s recommended allocation will receive feedback from Betterment as to why the recommended allocation might better match their investment objectives/goals. Betterment manages a client’s account according to the model portfolio the client selects. Clients is not designed to provide clients with a comprehensive clients in meeting specific investment goals. The model portfolio recommendation is highly dependent on receiving accurate information from clients. If it will materially impact the quality and applicability of Betterment’s recommendation. , in the face of fluctuating market prices , each client’s d to have Betterment rebalances client portfolios so that portfolio remains within a narrow range of the recommended allocation based on the client’s stated investment goals and objectives. Clients can request that their accounts only rebalance in response to additional cash flows. To participate in the Transamerica ALPHA program, clients agree their dividends automatically reinvested in accordance with their allocation. by reducing trading frequency and 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 thro ughout a bear market and will NOT seek to reduce equity downside during such time. The strategy will instead seek tax efficiency preferring long -term gains and losses over short -term gains and losses. -term buy and hold basis to a select group of U.S. and Investments are allocated on a long international stock and bond categories. One or two ETFs are purchased and held for each category. 16  These ETFs are reviewed by TFA periodically and are replaced on an as needed based on a review of the ETF’s ratings, returns, downside risk, daily liquidity, and other measurements. Investment Strategies Model portfolios generally provide exposure to both fixed income and equity markets. More conservative model portfolios tend to have a more substantial weighting in fixed income investments, while more aggressive portfolios tend to have greater exposure to equities. Equity markets have historically provided greater potential for long -term growth but tend to be more volatile when compared to investments in fixed income. Fixed income investments have historically been less volatile than equity markets but have not historically provided greater long -term returns when compared to equity investments. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS d in recommending an asset Individual client information gathered during the establishment of the account (demographic information, financial information, initial/ongoing investment amounts, investment time horizon and investment goals) is accessible by TFA and Betterment and is use allocation to a client, however it is not used by TFA or Betterment in creating or managing the model portfolios. Client information is not provided to the Client information will be retained by TFA for us to continue to ensure that model portfolios used in client’s Transamerica ALPHA account (s) are appropriate for each client’s stated risk tolerance and investment objectives. It is important that clients notify their TFA IAR of any updates to their risk tolerance and/or investment objectives in a timely manner. Model Managers. ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Betterment www.betterment.com. Generally, clients will not have any direct contact or The services under the Transamerica ALPHA program are provided primarily through the website located at consultation with the Model Manager. ITEM 9 – ADDITIONAL INFORMATION anteed by the Federal Deposit Insurance Risks All investments in securities include a risk of loss of clients’ principal. Stock markets and bond markets fluctuate over time and clients may lose money. Clients should be prepared to lose money invested in the account. Investments are not insured or guar Corporation (“FDIC”) or any other government agency. This does not include the Betterment Everyday Checking and Betterment Everyday Cash Reserve. For more information regarding Betterment 17  Everyday Checking and Betterment Everyday Cash Reserve, please refer to Betterment’s ADV and other disclosure documents. You may lose money by investing in investment products. pose risk, and many factors or accounts that have exposure to debt are subject to risks of may be subject to the following The investment strategies utilized in the Transamerica ALPHA program affect each investment and each account’s performance. 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 prepayment or default, and ETFs that pursue strategies that concentrate in industries or are otherwise subject to segme nts of the market may be significantly impacted by events affecting those industries or segments. In addition, the investments in your account specific risks: Investing in ETFs Account bears all the risk of the investment strategies employed by the ETFs held in the account, including the risk that an ETF will not meet its investment objectives. For the specific risks associated with a particular ETF, please see its prospectus . nalysis when considering a 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 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 ments available in a strategy and cause the strategy to limit the type and number of invest underperform other strategies without a n ESG based focus or with a focus that involves a different type of focus or screening methodology. ESG strategies may underperform the market as a whole. Companies and issuers selected in a ESG based strategy may not or may not based characteristics. continue to demonstrate ESG s such as could be severely compromised by system -related “system acking”), computer viruses, or various other events or Reliance on Technology and Cybersecurity Certain investment activities and investment strategies in the Transamerica ALPHA program are dependent upon algorithms, as well as other various computer and telecommunications technologies, many of which are provided by or are dependent upon third partie Betterment and 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, or component failure, telecommunications failure, power loss, a software crash”, fire or water damage, human errors in using or accessing relevant systems, unauthorized system access or use (e.g., “h circumstances. It is not possible to provide foolproof protection against all such events, and no 18  ing preventing 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, includ Betterment from trading, modifying, liquidating, and/or monitoring its clients’ investments. In addition, clients should be aware of the risk of cyber infrastructure and data from misappropriation or corruption -attacks and harm to technology . -party vendors, central agents, -attack or other info rmation security icious code, and other events that Due to TFA’s and Betterment’s interconnectivity with third exchanges, clearing houses, and other financial institutions, TFA and Betterment could be adversely impacted if any of them is subject to a cyber event. Although TFA 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 mal could have a security impact. to implementation or are Algorithm Risk The use of algorithms to generate investment advice carries the risk that changes to an 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 insufficiently monitored, even extensively tested changes and monitoring 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 inhe rent limitations and may not prove to be accurate. The algorithms used might rebalance client accounts without regard to market conditions or on a more frequent basis than a client might expect. The algorithms also may not address prolonged changes in mark et conditions. nderlying assumptions, c lients considering an automated digital investment advisory Investor Bulletin: Robo -Advisers | Algorithms may not perform as intended for a variety of reasons, including but not limited to incorrect assumptions, changes in the market, and/or changes to data inputs. Betterment may modify periodically these algorithms, or a computer system’s code or u and these changes may have unintended consequences. Additional information regarding relevant considerations for program (sometimes referred to as “robo advisor”) is contained in the Investor Bulletin from the Securities and Exchange Commission available at Investor.gov . Investment Risk Every 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 ETF to lose money. 19  is an investment compan y that is run by an adviser and a board of directors that is Operation Risk Every ETF responsible for managing the funds’ operations and following the laws and regulations relevant to ETFs. 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, or 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. nomic, and social conditions may Market Risk The price of investments in advisory accounts may drop in reaction to tangible or intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, eco trigger market events. ral disasters, and other here in this section will likely increase. As a , making those investments more difficult, or Economies and financial markets throughout the world are increasingly interconnected. Economic, financial, or political events, trading and tariff arrangements, terrorism, war, global conflicts, epidemics, pandemics, technology and data interruptions, natu 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 elsew result, whether investments are in securities of issuers located in or with significant exposure to the countries directly affected, the value and liquidity of investments may be negatively affected. Also, li quidity of individual investments, or even entire market segments, can deteriorate rapidly, particularly during times of market turmoil 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 erod es 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 Future proceeds from investments may be reinvested at a potentially lower rate of return (i.e., 20  interest rate). Business Risk These risks are associated with a particular industry or a particular company within an industry. in bankruptcy and/or 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 declining market value. a client’s y ield. These risks may occur Fixed Income Risk Portfolios that invest in fixed income securities are subject to several general risks, including interest rate, credit, and market risk, which could reduce from fluctuations in interest rates, a change in an issuer’s individual situation or industry, or general market events. security or instrument’s credit Credit Risk Changes in the 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 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. ion, or emerging markets. Foreign than U.S. market s . Emerging markets 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, reg markets may be more volatile and can perform differently can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchan ge rates may also be extremely volatile. er strategies using egic asset allocation (a strategy that involves 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 oth 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 strat periodically rebalancing the fund in order to maintain a long -term goal for asset allocation). This 21  -adviser’s evaluations and assumptions in selecting ies. The management strategy may not work as intended. The sub underlying funds or individual securities may be incorrect in view of actual market conditions and may result in owning securities that underperform other securit 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 icular asset classes, countries and regions, and strategy’s risk profile with respect to part -adviser’s allocation decisions. industries may change at any time based on the sub 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. additional risks due to it Transamerica ALPHA Additional Risks In addition to the risks described above, Transamerica ALPHA involves automated nature and reliance on the Algorithm and technology systems: Reliance on Electronic Communications and Delivery . Services provided are primarily IARs will be available to discuss investment your account s in general in person or via telephone. As set forth f all current • online and communications concerning the program are intended to occur primarily through electronic means including but not limited to email communications or through the Transamerica ALPHA website, although TFA strategies, objectives, or in the Client Services Agreement, clients consent to the electronic delivery o and future Form ADVs, Brochure supplements, privacy notices, prospectuses and offering documents, tax forms and other legal and regulatory notices, disclosures, reports, and other communications. Third Party Account Access clients must log into their they expressly rvice can disable this • . Clients have the ability to allow the program to access information for any accounts held with third party financial institutions, such as a brokerage firm (“Third Party Account Information”). To use this feature, account. If clients authorize access to Third Party Account Information, permit TFA, their TFA IAR , and Betterment to access Third Party Account Information in connection with the services provided. Clients using the Managed Se feature and access to Third Party Account Information at any time. Limitations of Transamerica ALPHA . Advice provided by TFA, TFA IARs , and Betterment a client’s investable assets to the extent that a client has • is not intended to comprise all of investible and invested assets held in ERISA Plans, or other accounts that the client (or his or her spouse or spousal equivalent) has not transferred into the account. In addition, advice is generally limited in scope to the information that clients provide to their TFA IAR 22  financial circumstances not IAR s , and Betterment based on the questions asked at the time a IAR to and Betterment. There may be additional information or other considered by TFA, TFA client establishes their investment objective. Clients should contact their TFA discuss any such additional information or other financial circumstances that they believe may be relevant to the advice provided through the program and with any changes to information that client has previously provided. Reliance on Technology; Back r, IAR s , and Betterment on behalf of its users and clients, could be -related “system crash,” and similar foolproof ave a material etterment, hopes , regional power outage or loss es, and on the nature of the replace them. Although the siness disruption. In addition, the failure • -up Measures; Cyber Security Breaches and Identity Theft. The program’s investment activities and investment strategies are dependent upon various computer and telecommunications technologies, many of which are provided by or are dependent upon third parties such as the Aggregation Vendor, data feeds, data cente telecommunications, or utility providers. The successful deployment, implementation, and/or operation of such activities and strategies, and various other critical activities provided by TFA, TFA severely compromised, damaged, or interrupted by system, network or component failure, computer and telecommunications failure, power loss, a software unauthorized system access or use (such as “hacking”), computer viruses programs, other security breaches, fire or water damage or other catastrophic events, power outages, human errors in using or accessing relevant systems, or various other events or circumstances. It is not possible to provide comprehensive and 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 compromises, interrupts, or renders inoperable such systems or operations could h adverse effect on clients, including by preventing Betterment from trading, modifying, liquidating, and/or monitoring its clients’ investments. In the case of events that compromise, interrupt, or render inoperable systems or operations of B to resume trading, modifying, liquidating, and/or monitoring its clients’ investments relatively promptly, subject to any circumstances that are outside the control of TFA and/or Betterment. In the case of severe business disruptions (e.g. of personnel), TFA and/or Betterment may not resume such activities for one or more business days because (among other things) such resumption is dependent on other critical business constituents, such as brokers and exchang disruption. If any systems designed to manage such risks are compromised, become inoperable for extended periods of time, or cease to function properly, TFA, and/or Betterment may have to make a significant investment to fix or foregoing reflects TFA’s objectives, designs, and/or plans, no assurance can be given that these objectives, designs, and/or plans will be realized, or that TFA and/or Betterment would be able to resume operations following a bu of these systems and/or of disaster recovery plans for any reason could result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including users’ or 23  s , or Betterment, clients’ personal information. Such a failure could harm TFA, TFA Advisor subject them and their respective affiliates to legal claims and otherwise affect their business and financial performance. adviser. In the last ten years, TFA . Two events involve actions brought by the SEC and o ne Disciplinary Information TFA is both a broker -dealer and a federally registered investment has had three mater ial disciplinary events involve s an action brought by FINRA. -and -Desist the SEC alleged that TFA failed to adequately disclose in SEC Proceedings • On March 11, 2019, the SEC signed an Order Instituting Administrative and Cease 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, 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 fund 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. $5,364,292.04 were paid to a Distribution Fund (“Fund”) for distribution -1 fee paying share class mutual funds in advisory accounts -1 fees attributable to the investor during the TFA settled this matter with the SEC. TFA agreed to a censure, to pay disgorgement of plus $658,780.64 in interest, and to cease and desist from violating certain securities laws and regulations. The disgorgement and interest to investors who purchased or held 12b when a lower -cost share class of the same fund was available to the client. The Order states that these investors a re to receive from the Fund the 12b relevant period, plus interest, subject to a de minimis threshold. The foregoing is only a brief summary of the Order. A copy of the Order is available on the SEC’s website at www.sec.gov. -and -Desist proceeding -Series ® and Transamerica® ONE programs. the case were managed by an affiliate, AEGON USA Investment -Squared”). The models managed – Conservative, Global Tactical Allocation – Balanced, – Growth, Tactical Fixed Income, Global Tactical Income and Global • On August 27, 2018, the SEC settled public administrative Cease 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 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 Management, LLC (“AUIM”) and by F -Squared Investments, Inc. (“F by AUIM were the Global Tactical Allocation Glob al Tactical Allocation Tactical Rotation models. The models managed by F -Squared were the AlphaSector Rotation Index, 24  - Squared currently provide model management services to - Squared were offered by T FA in the Transamerica I - TFA settled this matter with the $800,000, to pay disgorgement of $1.7 million plus - Squared -Series® and Transamerica ONE programs from July 2011 through received an amount from the Fund related to the pro rata fees and AlphaSector Premium Index and World Allocator Premium Index. These strategies are no longer offered by TFA and neither AUIM nor F TFA. The strategies developed by AUIM and F Series® and Transamerica® ONE programs between 2011 and 2015. SEC. TFA agreed to a censure, to pay a penalty of $258,162 in pre -judgment interest, and to cease and desist from violating certain securities laws and regulations. The disgorgement, interest and penalties were paid to a Fair Fund (“Fund”) for distribution to affected investors who purchased or held an interest in the AUIM and F strategies in the Transamerica I June 2015. The investors commissions paid by them during that period, plus interest, subject to a de minimis threshold. nd the named affiliates had voluntarily een received and proposed changes implemented. The SEC also retained an 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 a 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 b 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 complianc e policies and procedures. The SEC also considered that TFA and its affiliates independent compliance consultant for further reviews. The settlement does not impose any restrictions on the business of TFA. website The foregoing is only a summary of the Order. A copy of the Order is available on the SEC’s at https://www.sec.gov. On December 21, 2020, TFA and FINRA entered into a Letter of Acceptance, Waiver and at www.finra.org/rules -guidance/oversight - FINRA Proceedings • 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’ reco mmendations 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 enforcement/finra -disciplinary -actions -online . Other Financial Industry Activities and Affiliations TFA is a member of the Transamerica group of companies. Most of TFA’s IARs, members of management, and Investment Committee members are also registered with TFA’s affiliated broker - 25  dealer. In addition, the majority of TFA’s IARs are affiliated with World Financial Group Insurance Agency, Inc. (“WFGIA”), an affiliated insurance agency. registered index - issued by - as a financial incentive to recommend Affiliated Products over -party money TFA makes available variable universal life insurance products, variable annuities, linked annuities, mutual funds, 529 plans, ETFs and unit investment trusts (“UITs”) companies affiliated with TFA (“Affiliated Products”). When clients purchase Affiliated Products, TFA and/or its affiliates receive additional fees or compensation that are not received for the sale of non affiliated products. As a result, TFA h similar non -affiliated products. Affiliated Products may also be accessed through third managers (“TPMMs”) or model managers used in TFA advisory programs. id by clients with TFA, which creates TFA has contractual relationships with TPMMs that are independent investment advisers offering fee -based advisory programs. These relationships were described in Item 4. These TPMMs are not affiliated with TFA. TPMMs share a portion of the advisory fees pa conflict of interest because TFA has an incentive to recommend TPMMs that compensate TFA. In some cases, the cost of these arrangements may be higher than other advisory options. r our affiliates receive additional fees - programs. Because TFA and/or our affiliates make additional money -affiliated products. TFA mitigates this conflict by supervising all Some of the insurance and annuity products and mutual funds that TFA makes available are Affiliated Products. Affiliated Products are issued by one of our affiliated companies. In addition to any commission associated with purchasing the product, TFA and/o and compensation related to Affiliated Products that TFA does not receive in connection with non affiliated products. Many of these products can be purchased by the various TPMMs or Model Managers available in TFA’s when TFA and IARs sell Affiliated Products, TFA has an incentive to recommend these Affiliated Products over similar non recommendations made by IARs. with one of these TPMMs may be higher than placing the assets in TFA has contracts with TPMMs offering fee -based advisory that are also investment advisers programs. These relationships were described in Item 4. These TPMMs are not affiliated with TFA, and they pay TFA a portion of the fees clients pay to them. This is considered a conflict of interest. The cost of placing client’s assets another advisory account. TFA offers access to securities backed lending programs through third party lenders. TFA receives compensation from the lending sponsors, which creates a conflict of interest. Please refer to Item 4 for a description of these conflicts and related risks. TFA offers a bank deposit sweep program as its default option for uninvested cash in your accounts. TFA receives compensation from the banks involved in the program. Please refer to Item 4 for a description of the conflicts related to this program. 26  AEGON Ltd. Affiliates Under Common Control with TFA and the following entities are indirect, wholly owned subsidiaries of AEGON Ltd. Broker -Dealers • Transamerica Investors Securities Corporation • Transamerica Capital, LLC (“TCL”) TCL serves as principal underwriter and wholesale distributor for certain variable annuity and life insurance products issued by affiliated insurance companies. TFA receives compensation under selling agreements for these products, creating a conflict of i nterest. Investment Company • Transamerica Asset Management (“TAM”) TAM 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. Registered Investment Advisers • Transamerica Asset Management, Inc. (“TAM”) • AEGON USA Investment Management, LLC (“AUIM”) • Transamerica Retirement Advisors, Inc. (“TRA”) -dealer capacity, TFA receives revenue -sharing Other Affiliated Companies TFA has material relationships with certain product sponsors, including affiliated insurance companies and agencies. In its broker compensation when clients purchase products through these sponsors. Sponsoring Current revenue -sharing arrangements and sponsoring companies are disclosed on TFA’s website at www.tfaconnect.com under Indirect Compensation Disclosure and Companies List . • Transamerica Retirement Solutions, LLC Transamerica Retirement Solutions, LLC (“TRS”) TRS is a retirement services firm offering a range of services, including recordkeeping, participant education and communications, Plan design, Plan testing, general ERISA, and IRS compliance. • WFG Securities of Canada (WFGS) WFGS offers mutual funds and referral arrangements in Canada. 27  Affiliated insurance companies and agencies include: • Transamerica Premier Life Insurance Company • Transamerica Life Insurance Company • Transamerica Financial Life Insurance Company • World Financial Group Insurance Agency, Inc. • World Financial Group Insurance Agency of Hawaii, Inc. • World Financial Group Insurance Agency of Massachusetts, Inc. • WFG Insurance Agency of Puerto Rico, Inc. • World Financial Group Insurance Agency Canada Inc. affiliated products Conflict Management The a ffiliations described above create financial incentives to recommend certain or services. TFA addresses these conflicts through disclosure and supervisory oversight of recommendations made by its IARs. IARs may also be licensed insurance agents and offer fixed insurance products through these affiliated agencies. When clients purchase fixed insurance products, the affiliated agencies receive commission compensation. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading TFA has adopted a Code of Ethics (“Code”) designed to ensure that TFA meets its fiduciary obligation to clients 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. ust acknowledge their understanding of the Code with annual training and ongoing The Code applies to TFA Access Persons, defined as TFA IARs, directors, officers, and other persons who are subject to TFA’s supervision. It is distributed to Access Persons at the time of becoming an Access Person and annually thereafter. Access Persons m and agreement to abide by the Code. TFA supplements monitoring of the activity of Access Persons. TFA’s Code outlines the duties of Access Persons, including requirements to: • maintain TFA’s reputation as a firm that operates with the principles of honesty, integrity, and • • • • • professionalism; comply with applicable federal and state securities laws; read, know, understand, and follow all policies and procedures prescribed by TFA manuals, bulletins, or supervisory directives; cooperate with any investigation or inquiry conducted or authorized by TFA Management and/or Supervisory Personnel; follow TFA’s Privacy Policy and related procedures; and report personal securities transactions by obtaining approval for outside brokerage 28  accounts and reporting such accounts as described in the Code. Additionally, the Code prohibits Access Persons from actions such as: • purchasing or selling securities for their own accounts or others while in the possession of -public) information or information which might be considered “insider” (material, non discussing the information with a third party; • participating in any Initial Public Offering or Private Securities Transaction; and • accepting or offering inappropriate and/or excessive gifts, favors, entertainment, special accommodations, or other things of material value. Any Access Person not complying with these guidelines may be subject to disciplinary action up to and including termination. Clients may request a complete copy of our Code by contacting TFA at the address or telephone number displayed on the cover page of this Brochure. tools on the Review of Accounts Transamerica ALPHA’s investment tools are designed to provide clients with continuous access to account information through Betterment’s online interface. Clients can utilize various interface to review their account and better understand their holdings and performance information. Clients also receive periodic emails from Betterment with information about their accounts as well as links to account statements. a Betterment’s algorithms continuously review clients’ accounts to ensure their portfolios are within set range of their allocation. If a client’s portfolio deviates from this range, Betterment will rebalance such portfolio back to its target allocation in certain circumstances. allocation is too Furthermore, Betterment monitors accounts to determine whether a client is on or off track to meet particular goals or whether, in Betterment’s judgment, the client’s chosen aggressive or conservative for a goal and indicates the result of that monitoring through the online interface. IARs will contact advisory clients at least annually to determine whether the account continues to align with the client’s investment objectives and financial circumstances. 7 Clients are also directed , on at least a quarterly basis , to update their information via the online interface. Client Referrals and Other Compensation 7 With the exception of Transamerica ALPHA Standard Service Model accounts. 29  -dealer. If an IAR is also a TFA insurance products, variable annuities, registered index -linked annuities, Registration Arrangements Many of TFA’s IARs are also Registered Representatives of TFA’s broker Registered Representative, they may recommend that clients place securities transactions through TFA’s broker -dealer. These transactions could include, but are not limited to, the purchase or sale of variable universal life mutual funds, 529 plans, ETFs, and UITs. All sales charges and expenses are disclosed in the product prospect us, which clients will receive at or before the time of the purchase of the product. e meetings. These contributions and Marketing Compensation Arrangements Each of the TPMMs, Portfolio Managers, or other service providers may attend, contribute to, or sponsor education and training meetings for our IARs. TPMMs, Portfolio Managers, or other service providers may reimburse TFA for up to 100% of the cost of thes reimbursements create a conflict of interest because meeting sponsors have more opportunities to provide IARs with education on investments, their investment management services, industry trends, and other issues; and be cause TFA benefits from these contributions and reimbursements. -cash e events may influence their Other Compensation Arrangements If an IAR is associated with WFGIA, they are permitted to participate in award and incentive programs sponsored by WFGIA in which they could qualify to receive trips, promotions, or non compensation based on their volume of fixed insurance sales. Thes decision to recommend particular fixed insurance products to clients. -cash compensation f non -cash compensation, a conflict of Some IARs may participate in incentive trips and receive other forms of non based on the amount of their sales and services through TFA or product providers. To the extent an IAR participates in an incentive trip or receives other forms o interest exists in connection with the IAR’s recommendation of products and services for which they receive these additional economic benefits. TFA allows IARs to receive marketing reimbursements from product provider s to help defray these expenses. TFA does not require or have any expectation that IARs refer clients to or place assets with such providers. TFA monitors recommendations made by its IARs to ensure that they are in each client’s best interests. revenue sharing compensation from a third -party lender when its clients engage in TFA receives securities backed lending. TFA also receives fees from its arrangement with its Bank Deposit Sweep Program sponsor. Such arrangements create conflicts of interest which we disclose to clients and manage through TFA’s policies and procedures. Financial Information To the best of TFA’s knowledge, TFA is not aware of any financial condition that is reasonably likely to impair TFA’s ability to meet contractual commitments to clients. TFA has not been the subject of a bankruptcy petition at any time, including the past ten years. 30