Wealthspire Advisors

WEALTHSPIRE ADVISORS LLC FORM ADV PART 2A INFORMATION 521 Fifth Avenue, 15th Floor New York, NY 10175 Phone 212.973.1200 www.wealthspire.com April 30, 2026 This Brochure provides information about the qualifications and business practices of Wealthspire Advisors LLC. If you have any questions about the contents of this Brochure, please contact us at 212.973.1200. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Wealthspire Advisors LLC is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Wealthspire Advisors LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The Firm's CRD Number is 106181. 1  Item 2 – Material Changes to this Brochure since the last update filed March 30, 2026 This publication of the Form ADV Part 2A contains highlights of the changes that have been made to this brochure since the last amendment on March 30, 2026, which may be deemed material changes from our last filing:  Updates to reflect 12.31.2025 AUM including merged entities.  Reflects that we have merged subsidiary affiliate RIAs into Wealthspire Advisors LLC.  Updated to reflect Bookkeeping and Bill Pay service offering  Added references to a Wrap Fee Program available primarily for legacy clients of certain merged entities.  Added disclosure language due to an affiliated person’s Private Funds.  Expanded fee disclosure to clarify the Firm’s fee calculation and differential practices. We strongly encourage each client to review the entire updated brochure. You may request a complete copy of our current Form ADV, Part 2A Brochure at any time by contacting us at 212.973.1200 or info@wealthspire.com. Our Brochure is also available on our website at www.wealthspire.com.  Item 3 - Table of Contents Item 1 – Cover Page Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Advisory Business Item 5 – Fees and Compensation Item 6 – Performance-Based Fees and Side-By-Side Management Item 7 – Types of Clients Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Item 9 – Disciplinary Information Item 10 – Other Financial Industry Activities and Affiliations Item 11 – Code of Ethics Item 12 – Brokerage Practices Item 13 – Review of Accounts and Reports Item 14 – Client Referrals and Other Compensation Item 15 – Custody Item 16 – Investment Discretion Item 17 – Voting Client Securities Item 18 – Financial Information About Wealthspire Advisors Privacy Policy 1 2 3 4 16 21 22 23 29 30 32 34 39 40 44 45 46 47 48  Item 4 – Advisory Business through its state-registered Investment Advisor Representatives Wealthspire Advisors LLC (“Wealthspire Advisors,” “Wealthspire,” “We,” or the “Firm”) is an SEC- registered investment adviser providing wealth management, investment advisory and financial (“Advisor consulting Representatives”) to individuals, businesses, non-profit organizations and foundations. Our role is to listen, inform and advise. We take a well-rounded, relationship-driven approach to helping our clients develop customized solutions that address a full range of financial issues. Our investment strategy is focused on each client’s investment goals and risk tolerance. Sontag Advisory LLC (“Sontag”) was founded in 1995 by Howard Sontag and became a wholly owned subsidiary of NFP Corp. (previously known as National Financial Partners, Corp.) (“NFP”) in 2015. On May 1, 2019, Sontag acquired Bronfman E.L. Rothschild, L.P., an SEC-registered investment advisor (“Bronfman Rothschild”). Bronfman Rothschild was formed in May 2013 as the successor by conversion from Baker Tilly Investment Advisors, LLC, an investment adviser providing services since August 1997. Following the acquisition, Bronfman Rothschild became a subsidiary of Sontag. Beginning in October 2019, Bronfman Rothschild was renamed Wealthspire Advisors, LP. Wealthspire Advisors, L.P. and Sontag, both separate registered investment advisers, began doing business under the common brand and trade name of Wealthspire Advisors. Wealthspire Advisors, L.P. merged with and into Sontag as of December 31, 2020, and the surviving entity was renamed Wealthspire Advisors LLC. On October 30, 2025, NFP completed the sale of five of its subsidiary businesses, including Wealthspire, to Madison Dearborn Partners, LLC (“MDP”), and the businesses became wholly-owned subsidiaries of Wealthspire, LP. A full list of Wealthspire mergers and acquisitions is available upon request. Wealthspire may have subsidiary affiliates, via acquisitions, that maintain separate client brochures until such time as the operations of Wealthspire Advisors LLC and the acquired company are sufficiently integrated to merit combined client brochures. Mike LaMena is Wealthspire, LP’s Chief Executive Officer; Eric Sontag is the Firm’s President; Channing Olson is the Firm’s Chief Operating Officer; Michael Del Priore is the Firm’s Chief Compliance Officer; and Brian Powers is the Firm’s Chief Financial Officer. Assets Under Management As of December 31, 2025, Wealthspire Advisors has the following regulatory assets under management: Discretionary Clients 9,265 Assets $33,046,513,176 Non-discretionary 708 $1,276,464,512 Total 9,973 $34,322,977,688 4  Services to Individual Clients Wealthspire Advisors offers a suite of wealth management services, which may include one or more of the following, depending on each client’s specific engagement: Investment Advisory Investment program implementation and rebalancing  Evaluation of current portfolio  Assessment of investment objectives and financial goals  Asset allocation planning  Separate Account Manager research and selection   Portfolio monitoring and risk management  Performance measurement Financial Planning and Consulting Insurance planning  Portfolio monitoring and advice regarding assets not managed by Wealthspire Advisors   Estate and wealth transfer planning  Retirement planning  Education planning  Philanthropic and charitable gift planning Comprehensive Reporting  Unique reporting service complementing standard statements provided by the account custodian  Customized periodic statements aggregating all invested (and sometimes fixed or illiquid) assets - even those not managed by Wealthspire Advisors  Portfolio performance, asset class returns, annual income and investment flows are consolidated on one easy-to-understand dashboard Tax Reporting  Tax reporting service to assist our clients’ tax professionals  Firm provides annual “tax packages” to clients and/or their accountants  Tax packages include reports and summaries detailing: cost basis, fees, gain/loss, interest, dividends, distributions and charitable contributions, among other information Bookkeeping and Bill Pay Services  Recording cash receipts/disbursements, and reconciling bank statements  Payroll and 1099 support  Cash flow and balance sheet reporting  Payment of recurring and ad hoc bills Asset Allocation and Account Customization Advisory services begin with determining each client's financial circumstances and investment objectives and are followed by continuous investment management services to the client's investment account (“Account(s)”) based on the client's needs and objectives. Wealthspire Advisors tailors its services to the individual investment needs of its clients by determining each client’s investible assets, investment experience, specific goals, objectives, risk tolerance, time horizon, investment restrictions and other considerations (collectively, “Investment Information”) that might impact the client’s investment needs. Investment Information is generally gathered via conversations with the client or an interview process. To comply with applicable laws and internal procedures when opening new Accounts, Wealthspire Advisors may request proof of identification from a prospective client and may utilize third party agencies to verify the client's identity. 5  (e.g., cash holdings, 401k balances, assets placed with other Based on this determination of a client’s Investment Information, Wealthspire Advisors generally identifies and implements an investment program grounded on one of its various portfolio guidelines and invests the Account(s) accordingly. As agreed with each client individually, this program may take into account the allocation of the client’s assets not placed under Wealthspire Advisors’ investment management advisors/managers, limited partnerships, business interests, individual securities holdings, employee stock options, real estate). Generally, Wealthspire Advisors’ intention is to manage investments to provide the client with an overall asset allocation (including assets outside Wealthspire Advisors’ investment purview, if agreed) matching as closely as possible the client’s investment goals and objectives. Wealthspire Advisors has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Wealthspire Advisors will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s Investment Information. Based upon these factors, there may be extended periods of time when Wealthspire Advisors determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Wealthspire Advisors will be profitable or equal any specific performance level(s). Investment Selection - Separate Account Managers Wealthspire Advisors may recommend the allocation of a portion of a client’s investment assets among one or more unaffiliated independent investment managers (each, a “Separate Account Manager”) in accordance with the client’s designated investment objectives. In such situations, the Separate Account Manager shall have day-to-day responsibility for the active discretionary management of the allocated assets. Wealthspire Advisors shall continue to render Investment Advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Wealthspire Advisors shall consider in recommending Separate Account Managers include the client’s designated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. Wealthspire Advisors maintains a disciplined research and due diligence process to identify Separate Account Managers suitable for client investment and also maintains ongoing annual due diligence and review over the recommended firms. Before a client establishes an account with a Separate Account Manager, the client shall also receive the Separate Account Manager’s written disclosure statement specifying its fees and services. Wealthspire Advisors maintains sub-advisory arrangements with most of the Separate Account Managers it recommends for client portfolios. This means that Wealthspire Advisors has authority to hire and/or fire the Separate Account Manager on behalf of its discretionary Clients, resulting in some operational efficiencies regarding the opening and closing of accounts as well as communicating transaction details. Separate Account Managers charge their own advisory fees, which are typically deducted directly from the Client’s custodial account at customary billing intervals, separate from Wealthspire Advisor’s fee, and do not separately pay a referral fee to Wealthspire Advisors. The assets invested with a recommended Separate Account Manager are included with the client’s other assets managed directly by Wealthspire Advisors for the purpose of calculating and billing in accordance with the client’s fee schedule. Individual Managed Accounts include the following service and fee categories: Wealthspire Advisors Wealth Management includes ongoing investment management support and typically no less than annual meetings with a service team which may consist of two or three Wealthspire Advisors employees. Wealthspire Advisors utilizes "institutional" style asset allocation based on investing principles used by the largest endowments and foundations in the world. By utilizing the methodology used by institutional money managers, Wealthspire Advisors aims to achieve consistent returns with less volatility than traditional portfolios. Once a client's allocation is 6  in place, Wealthspire Advisors employs a rigorous due diligence process to select the appropriate mutual funds, exchange-traded funds (“ETFs”), private investment funds, and/or investment managers. Wealthspire Advisors Institutional, recommended for institutions with assets under management exceeding $5,000,000, includes quarterly or semi-annual meetings with a service team which consists of three Wealthspire Advisors employees. It is managed in line with the Wealthspire Advisors Wealth Management program discussed above. Wealthspire Advisors has established account services relationships with, and typically recommends the custodial services of, Charles Schwab & Co., Fidelity Brokerage Services (“Fidelity”), and Pershing Advisor Solutions (“Pershing”), among others as individual situations dictate. These firms maintain custody of Account assets and process transactions ordered by Advisor Representatives and Separate Account Managers. Reports of Account transactions and positions are prepared and sent to each client no less than quarterly by each custodian. Wealthspire Advisors is responsible for the management of investments within client Accounts and adjusts client portfolios by buying and selling investments from time-to-time based on current investment objectives and client needs. The Firm may also manage Accounts on a non-discretionary basis from time-to-time, and, when it does so, Advisor Representatives obtain permission for Account transactions from the client prior to placing the trades. Accounts are continuously monitored, and investments are made based on changes to economic and market conditions or to realign the portfolio to be consistent with the client's investment objectives, time horizon, and risk tolerance. Clients may place reasonable restrictions or constraints on the way their Accounts are managed, where practicable, and retain the right to modify Account restrictions at any time by providing written notice of such changes to Wealthspire Advisors. Advisor Representatives will periodically request updates to a client's Investment Information to assist in managing and supervising the client's Account and to make any necessary changes to the investment decisions and recommendations being made for the client's Account. However, clients remain ultimately responsible for informing Wealthspire Advisors of material changes to Investment Information as it occurs. Clients may contact their Advisor Representative any time they wish to confer about any aspect of the Account or services being, or to be, provided. Financial Planning Wealthspire Advisors also offers comprehensive and limited financial planning and consulting services depending on each client's needs. Our comprehensive evaluation of a client's current and anticipated future financial state is accomplished by using currently known variables to assess future cash flows, asset values, and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written summary which provides the client with a detailed financial outline designed to assist the client in achieving his or her financial goals and objectives. Our limited financial planning services are based on specific recommendations outlined by our clients. Our clients will receive an appropriate evaluation based on the parameters agreed to in the services agreement. We seek to develop comprehensive or limited financial plans that include any or all of the subject areas as defined by the Certified Financial Planning Board: 7   Financial Statement Preparation and Analysis: We review family records, budgets, assets, liabilities, and cash flow to create a clear picture of the current financial status of our clients in order to determine opportunities and priorities. Specific topics that may be addressed include, but are not limited to: (i) personal financial planning; (ii) asset liability ownership; (iii) debt management/structuring; (iv) home purchase analysis; (v) analysis/comparison of debt pay-off options; (vi) cash flow; (vii) calculation of liquidity and cash reserve needs; (viii) budget monitoring; and (ix) inflation projection of living expenses.  Investment Planning: We analyze investment alternatives and their effect on the client's portfolio. We communicate our economic and investment outlook via a quarterly Investment Philosophy that is available to all advisory clients. Specific topics that may be addressed include: (i) asset allocation; (ii) retirement income strategies; (iii) education goal analysis; (iv) potential tax ramifications of various investment strategies; (v) computation of the length of time, money, or other asset will last given a specified rate of withdrawal and expected rate of return; (vi) calculation of a lump sum amount of money needed to be invested to receive a specified level of income per year for a certain number of years; and (vii) portfolio optimization/rebalancing.  Insurance Planning, Risk Management, and Employee Benefits: We analyze the impact of the client's death, disability, or incapacity on his or her financial strategy. We evaluate existing policies and determine ways to cost-effectively meet family needs that can be addressed through life, disability, and long-term care insurance. Specific topics that may be addressed include: (i) survivor income needs; (ii) capital needs; (iii) estate liquidity needs; and (iv) buy-sell analysis.  Income Tax Planning: We analyze the client's income tax history and spending patterns to plan for the current and future years then model the potential impact of various investment and financial strategies on the client's net worth and liquidity. Specific topics that may be addressed include: (i) income tax projections including general and specific techniques for reducing tax liability; (ii) tax deduction and tax credit maximization opportunities; (iii) alternative minimum tax considerations; (iv) business structure alternatives including compensation methodology; (v) intergenerational asset transfers; (vi) capital gain/loss harvesting; (vii) Roth conversion analysis; and (viii) net investment income considerations.  Retirement Planning: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. For individuals who are already retired, we analyze the impact of changing income and expense amounts and timing, gifting, and risk tolerance with the objective of maintaining financial independence. Specific topics that may be addressed include: (i) analysis of retirement needs; (ii) early retirement analysis; (iii) pension maximization; (iv) social security optimization; and (v) rollovers/transfers.  Estate Planning: We assist the client in assessing and developing long-term strategies, including (as appropriate), trusts, wills, powers of attorney, asset protection plans, and estate tax exposure. We carefully evaluate the impact of various gifting and wealth transfer strategies. Specific topics that may be addressed include: (i) estate/death tax estimate including general and specific techniques for reducing taxes, probate, and transfer costs; (ii) estate liquidity and survivor income analysis; (iii) gifting strategies; (iv) estate planning for minor children or special needs dependents; and (v) charitable planning strategies. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax circumstances, future goals, investment objectives, and attitudes towards risk. We carefully review documents supplied by the client and prepare a written report. 8  The financial plan is presented to the client as prescribed within the agreement, provided that all information needed to prepare the financial plan has been promptly provided. Should a client choose to implement the recommendations contained in the financial plan, Wealthspire Advisors suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of the recommendations contained in the financial plan is entirely at the client's discretion. To the extent that Wealthspire Advisors or an affiliate offers legal, accounting, insurance, or brokerage services recommendations, a client is not obligated to use a Wealthspire Advisors affiliate to obtain any such services. If a client chooses to use a Wealthspire Advisors affiliate for any such services, Wealthspire has a conflict of interest when evaluating product recommendations involving advisory services or products offered by the Firm or its affiliate. While certain individuals associated with Wealthspire Advisors are registered representatives of a broker-dealer and licensed as insurance agents/brokers of various insurance companies, financial plan recommendations are generally of a generic nature and do not typically involve the recommendation of specific investment products. Recommendations are not limited to any specific product or service offered by a particular broker-dealer or insurance company. Please Note: Wealthspire Advisors and its representatives do not provide legal or tax advice, and Wealthspire Advisors does not act as law, accounting, or tax firm. Our services are not intended to replace any tax, legal or accounting advice from a tax/legal/accounting professional. Family Office Services Wealthspire Advisors provides family office support services for existing clients with separate holding companies and/or family office entities. These services may include wealth strategy, family legacy planning, and collaboration with client’s outside professionals to implement and oversee the client’s family office structures, as well as additional family office-related services as necessary and appropriate. Investment Consulting Services Wealthspire Advisors assists other organizations with asset allocation strategies, investment manager research and selection, performance reporting, marketing support and other services in exchange for a fee. The representatives of the organization retain the authority to approve or reject all asset allocation strategies, investment manager recommendations or other materials that result from Wealthspire’s services. In addition, each representative of the organization retains sole responsibility for determining their needs, and in choosing which strategies or managers may be appropriate for them. Unaffiliated Private Investment Funds In certain cases, Wealthspire Advisors may recommend investment in certain unaffiliated private investment funds. Wealthspire Advisors’ role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client decides to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Wealthspire Advisors calculating its investment advisory fee. Wealthspire Advisors’ clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). All clients that determine to become investors in a fund receive an Offering Memorandum prepared by the fund sponsor (discussing the fund's investment objectives, risk factors, conflicts, etc.) and shall generally be required to enter into a subscription or other written agreement acknowledging the terms and conditions of the fund and/or venture and the corresponding risk factors, including loss of principal and liquidity constraints. Wealthspire Advisors will only recommend private funds to those 9  clients for whom it reasonably believes such an investment to be suitable, given the client’s total portfolio, risk parameters and liquidity needs. Wealthspire Advisors shall not exercise any discretion to invest in any private fund on a client’s behalf. Rather, the ultimate investment decision shall remain with the client. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Because of the above factors associated with a private fund investment, the Firm must make a determination as to whether a specific private fund is appropriate for the client. In so doing, the Firm shall consider the following factors: • The type of offering-including risks, time horizon, and liquidity issues; • The client's investment objective(s)-realizing that for certain clients, a private fund of any kind may not be suitable; • The client's current portfolio allocation; • The client’s available cash to commit to the private fund; • The private fund's investment minimum per investor; and • The client's current allocation to private investment funds. Please Note: Valuation. In the event that Wealthspire Advisors references private investment funds owned by the client on any supplemental account reports prepared by Wealthspire Advisors, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The most recently available value will continue to be reflected on this report until the fund provides a further updated value. Please Also Note: As a result of the valuation process, the report may reflect an initial purchase price or an updated value subsequent to purchase, and the current value(s) of an investor’s fund holding could be significantly more or less than the value reflected on the report. The client’s advisory fee shall be based upon the value reflected on the report. Trustee Services Certain of Wealthspire Advisors’ employees (or employees of affiliates) may, upon client request, serve as trustee for various types of trusts set up by clients. These services are available on a limited, case- by-case basis. The Firm’s trustee services include the execution of trust duties, as well as administrative functions necessary to support the fiduciary responsibilities of the trustee. This service is separate and apart from the investment advisory services and is subject to a separate fee. Client Retirement Plan Assets Wealthspire Advisors also provides investment advisory services relative to the client’s 401(k) plan assets upon request. In such event, Wealthspire Advisors shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Please Note: Wealthspire Advisors’ services shall be limited to the allocation of the client’s assets among the investment alternatives available through the plan. Wealthspire Advisors will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s 10  exclusive obligation to notify Wealthspire Advisors of any changes in investment alternatives, restrictions or other relevant or material information pertaining to the retirement account. IRA Rollovers In appropriate circumstances, Wealthspire Advisors may recommend that a client roll over an account held in a former employer's retirement plan to Individual Retirement Account ("IRA") for Wealthspire Advisors to manage. When providing investment advice to clients regarding retirement plan accounts or IRAs, Wealthspire Advisors is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Wealthspire Advisors makes money creates some conflicts with the client’s interests, so Wealthspire Advisors operates under a special rule that requires it to act in the client’s best interest and not put the Firm’s interests ahead of the clients. If the client elects to rollover assets into an IRA account subject to Wealthspire Advisors’ management, the account will be subject to Wealthspire Advisors’ advisory fee per the client’s Investment Advisory Agreement. Conflict of Interest: A financial advisor’s recommendation to roll over retirement plan assets into an IRA creates some conflict of interest because such a recommendation can create an incentive to recommend the rollover for the purpose of generating additional compensation rather than solely based on the client’s needs. When Wealthspire Advisors recommends a rollover IRA, the recommendation is given in the client’s best interest and with the client’s interests ahead of the Firm’s, and the client is never under any obligation, contractually or otherwise, to complete a rollover to have the rollover IRA assets managed by Wealthspire Advisors. Many employers permit former employees to keep their retirement assets in the company plan. Also, some retirement plans may permit current employees to move assets out of the company plan before retiring or leaving the company. In determining whether to complete an IRA rollover, and to the extent the following options are available, Wealthspire Advisors clients should consider their costs and benefits. An employee will typically have four options:  Leave the assets in the employer/former employer's plan;  Transfer the funds to a new employer’s retirement plan;  Cash out and take a taxable distribution from the plan; or  Roll the funds into an IRA account. Each of these options has advantages and disadvantages, and Wealthspire Advisors recommends that a client communicate with their CPA/tax attorney to consider them before making a change. Each client should consider the following relevant issues together with their Wealthspire Advisors advisor, as well as their tax and/or legal professional, before initiating a retirement plan rollover:  Determine whether the investment options in the employer's retirement plan address client’s needs or whether other types of investments are needed.  Employer retirement plans generally have a more limited investment menu than IRAs.  Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds.  The employer plan may have lower fees than Wealthspire Advisors’ fees.  If interested in investing only in mutual funds, client should understand the cost structure of the share classes available in employer's retirement plan compared to those available in an IRA.  Client should understand the various products and services that may be available through a Rollover IRA and the potential costs of those products and services.  Wealthspire Advisors’ recommended strategy may entail higher risk than the option(s) 11  provided in client’s plan.  Client’s current plan may also offer financial advice.  Keeping assets titled in 401k or retirement accounts may potentially delay a required minimum distribution.  For clients concerned about protecting assets from creditors, an existing 401k plan may offer more liability protection than a rollover IRA. Such legal protection varies by state.  Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there may be some exceptions to these general rules so an attorney should be consulted if concerned about protecting retirement plan assets from creditors.  Loans may be available from the employer plan (although generally not to ex-employees); no   loan available from an IRA. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless qualifying for an exception such as disability, higher education expenses or the purchase of a home. If you own company stock in your 401k plan, you may be able to liquidate those shares at a lower capital gains tax rate. Client’s existing retirement plan may allow Wealthspire Advisors to be hired as the investment manager and to keep the assets titled in the plan name. It is important that clients understand the differences between these types of accounts and to evaluate whether a rollover is best under the circumstances. Insurance While Wealthspire Advisors routinely provides insurance planning as part of a client’s financial plan, Wealthspire Advisors does not sell insurance. Wealthspire Advisors may provide Client with recommendations of licensed insurance agents (some of whom may be affiliated with Wealthspire’s former parent company NFP) for the purchase of various types of insurance. Wealthspire Advisors does not accept or receive referral compensation from any of the firms to whom it refers clients. Although Wealthspire is affiliated a licensed insurance agency, Wealthspire is not an insurance agency and does not sell fixed or general account life insurance products or annuities. Wrap Fee Program As described herein and on a limited basis, we offer our managed account clients the option to participate in our Wrap Fee Program (“Wrap Program” or “Program”). The services offered under, and the corresponding terms and conditions pertaining to, the Program are discussed in the Firm’s Wrap Fee Program Brochure, a copy of which is presented to all prospective Program participants. Under the Wrap Program, the Firm offers participants discretionary and non-discretionary investment management services for a single specified annual fee, inclusive of execution, custody, performance reporting, and our investment management fees. The Firm receives a portion of the Program fee for its services. Execution, reporting, and custodial services for the Program are generally provided by a Pershing Advisor Solutions, LLC (“Pershing”), Fidelity Investments (“Fidelity”) and/or Schwab Advisor Services, a division of Charles Schwab & Co., Inc. (“Schwab”). Additionally, Program accounts are generally maintained at Pershing, Fidelity and/or Schwab. Prior to engaging Wealthspire to provide investment management services under the Wrap Program, each client will be required to enter into an Investment Management Agreement with Wealthspire 12  setting forth the terms and conditions under which we manage such client’s assets, and a separate custodial/clearing agreement with the Program broker-dealer and custodian. The Firm has a potential disincentive to trade securities as a result of the transaction/execution costs that it is required to pay its broker-dealer and custodian for securities transactions. When beneficial to the client, as determined by Wealthspire in its sole discretion, individual equity and fixed income transactions may be effected through broker-dealers with whom Wealthspire has entered into arrangements for prime brokerage clearing services. Participation in the Wrap Program may cost more or less than purchasing such services separately. Depending upon the wrap fee charged by the Firm, the amount of portfolio activity in a client’s account, and the value of custodial and other services provided with respect to such client’s account, the wrap fee charged to such client may or may not exceed the aggregate cost of the services provided to such client if such services were provided separately or if we were to negotiate transaction fees and seek best price and execution of transactions for such client’s account. In addition, the fees charged by the Firm for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. There is no substantive difference between how we manage wrap fee accounts and how we manage other accounts. Private Fund Affiliation An acquired and merged firm, GM Advisory Group, LLC (“GMAG”), previously recommended that certain of its advisory clients invest in one or more Funds (“Funds”) managed or sponsored by GMAG Management, an investment adviser previously under common control with GMAG. In addition, certain affiliates of the Firm sponsors and serves as general partner or managing member of such Funds and, as a result, receive compensation, depending on the Fund. Frank Marzano, a Managing Director of Wealthspire, has a controlling ownership interest in GMAG Management and its affiliates that serve as general partner of the Funds. A conflict of interest exists as Mr. Marzano has a financial incentive to recommend clients retain their positions in a Fund where GMAG Management or its affiliates can earn compensation. Nonetheless, an investment in a Fund was only recommended to clients with consideration of numerous factors in mind, including but not limited to, the client’s investment objective and financial circumstances. The Funds shall continue to be operated separate and independent of Wealthspire and its parent organizations. The Funds will not be offered to Wealthspire clients. Clients may continue to own one or more of the Funds, but neither the purchase of a new Fund nor additional investment in a currently owned Fund will be permitted. Wealthspire does not, and shall not, monitor or supervise any of the Funds, nor will it supervise Mr. Marzano relative to his role with the Funds. Wealthspire does not, and shall not, receive compensation from any of the Funds. No Legal Services Certain of Wealthspire Advisors’ employees may be licensed to practice law. However, no such persons provide legal services to any of Wealthspire Advisors’ clients, and no corresponding attorney- client relationship is established. This foregoing is provided for purposes of full disclosure and to emphasize that the fact that certain of Wealthspire Advisors’ employees may be licensed to practice law is not material to Wealthspire Advisors’ investment advisory business or services. Services Offered to ERISA Plans On a limited basis, Wealthspire Advisors provides advisory services to retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), including participant- directed defined contribution plans, such as 401(k) plans, defined contribution plans that are not participant-directed and defined benefit plans (“ERISA Plan Clients”). Each ERISA Plan Client is required to enter into an investment advisory or investment management agreement with Wealthspire Advisors describing the services that Wealthspire Advisors will perform for the ERISA 13  plan and its participants (the “ERISA Plan Services Agreement”). Wealthspire Advisors provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. Please Note: As of March 2019, Wealthspire Advisors began introducing ERISA plan clients to Wealthspire Retirement, LLC dba Wealthspire Retirement Advisory (f/k/a NFP Retirement, Inc.; hereinafter, “Retirement Advisory”), an affiliated company specializing in working with plan sponsors. Wealthspire Advisors believes that, in most cases, Retirement Advisory will be better equipped to service our current and future 401k plan sponsor clients. Conflict of Interest: Retirement Advisory and Wealthspire Advisors are affiliated firms, as both are owned by Wealthspire, LP. Therefore, Wealthspire Advisors has a conflict of interest where it recommends the services of an affiliated firm. Wealthspire Advisors has addressed this conflict of interest as outlined more fully below in “Item 14-Client Referrals and Other Compensation.” Fiduciary Services for ERISA Plan Clients Wealthspire Advisors provides fiduciary services either as a discretionary investment manager or a non-discretionary investment adviser. Discretionary Investment Management Services Wealthspire Advisors provides investment management services to ERISA Plan Clients on a discretionary basis as an investment manager under ERISA Section 3(38) and in that capacity, Wealthspire Advisors’ investment decisions are made in its sole discretion without the ERISA Plan Client’s prior approval. Each ERISA Plan Client who engages Wealthspire Advisors to perform investment management services is required to enter into an investment management agreement. Wealthspire Advisors’ investment management services include developing and implementing an investment policy statement (if required by the ERISA Plan), selecting a broad range of investment options consistent with ERISA Section 404(c), making decisions about the selection, retention, removal and addition of investment options and if the ERISA Client has determined that the Plan should have a qualified default investment alternative (a “QDIA”) for participants who fail to make an investment election, selecting the investment that will serve as a QDIA. Non-Discretionary Investment Advisory Service Wealthspire Advisors also provides investment advisory services on a nondiscretionary basis and in that capacity, the ERISA Plan Client retains, and exercises, final decision-making authority and responsibility for the implementation (or rejection) of Wealthspire Advisors’ recommendations or advice. Each ERISA Plan Client who engages Wealthspire Advisors to perform nondiscretionary investment advisory services is required to enter into an investment advisory agreement. Wealthspire Advisors’ nondiscretionary investment advisory services include assisting the ERISA Plan Client in developing and implementing an investment policy statement (if required by the ERISA Plan) and assisting the ERISA Plan Client in making decisions about the selection, retention, removal and addition of investments. Non-Fiduciary Services for ERISA Plan Clients Wealthspire Advisors’ non-fiduciary services provided to ERISA Plan Clients include assisting in group enrollment meetings, educating plan participants about general investment principles and the investment alternatives under the plan and educating the ERISA Plan Client as to its fiduciary responsibilities. Wealthspire Advisors’ non-fiduciary services also include assisting the ERISA Plan Client in monitoring, selecting and supervising service vendors and performing benchmarking studies and fee analysis. For a more detailed description of Wealthspire Advisors’ services, the ERISA Plan Client should refer to the ERISA Plan Services Agreement. 14  ERISA / IRC Fiduciary Acknowledgment. If the client is: (i) a retirement plan (“Plan”) organized under ERISA; (ii) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or her Plan account or to take a distribution; (iii) the beneficial owner of an IRA acting on behalf of the IRA; or (iv) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code: then Wealthspire Advisors represents that it and its representatives are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by the Firm or its representatives or with respect to any investment recommendations regarding an ERISA Plan or participant or beneficiary account. Cash Positions All cash positions (money markets, etc.) may be included as part of assets under management for purposes of calculating Wealthspire‘s advisory fee. Please Further Note: When the account is holding cash positions, those cash positions may be subject to the same fee schedule as set forth below unless otherwise agreed upon. Third-Party Professionals financial situation or investment objectives for As an accommodation when asked, Wealthspire Advisors may recommend the services of qualified professionals for certain non-investment implementation purposes (e.g., attorneys, accountants, insurance agents). Clients are encouraged to make their own decisions and are under no obligation to engage the services of any such recommended professional. Although we have experience with these service providers, Wealthspire has not performed due diligence on these service providers and is not responsible for the services provided by these services providers. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Wealthspire and/or its representatives. Please Also Note: If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional(s), and not Wealthspire, shall be responsible for the quality and competency of the services provided. Please Further Note: Wealthspire believes that it is important for the client to address financial planning issues on an ongoing basis. Wealthspire’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Wealthspire. Please Also Note: It remains the client’s responsibility to promptly notify Wealthspire Advisors of any change in his/her/its of the purpose reviewing/evaluating/revising Wealthspire Advisors’ previous recommendations and/or services. Held Away Retirement Assets We use a third-party platform, Pontera Order Management System (“Pontera”), to facilitate management of held away retirement assets, such as 401(k) or defined contribution plan participant accounts, over which we have discretion. Pontera allows us to assist with management of our clients’ held away retirement assets without requiring direct access to Client log-in credentials to affect trades. We are not affiliated with Pontera in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to Pontera, Wealthspire will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed periodically, and allocation changes will be made as deemed necessary. 15  Item 5 – Fees and Compensation Investment Advisory Services for Individuals Wealthspire Advisors provides discretionary investment advisory services on a fee basis. The advisory fee is either an asset-based or a fixed annual fee, depending on circumstances. The proposed fee rate and method of billing is negotiable, subject to many factors. The size, complexity and scope of the engagement are among the factors considered. Generally, new clients are charged a tiered fee schedule (as an example, see below for Wealthspire’s standard fee schedule for wealth management accounts), whereby the fee reduces as certain asset thresholds are reached. As circumstances may warrant, Wealthspire Advisors may charge an asset-based fixed rate or fixed dollar investment management fee (see below). Unless otherwise dictated by Wealthspire’s written agreement with its Client, the annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by Wealthspire Advisors on the last day of the previous quarter. The Firm’s various fee arrangements may be amended from time to time upon thirty (30) day written notice to Client. Wealthspire Advisors Wealth Management Wealth Management fees are agreed upon with each client in writing, which may be amended from time to time. Wealthspire Advisors typically charges an annual percentage-based fee for investment management. We may use alternate fee arrangements, including minimum fees, based on the particular circumstances for specific clients based on, among other factors, the size and scope of the engagement, anticipated level of service and complexity of the relationship, client needs, related accounts, services required, reporting requirements, anticipated assets to be managed, and future additional assets. As a result, clients should expect to be charged different fees for similar services, and the actual advisory fee may be higher or lower than the fee charged to other clients depending on these broader considerations. If a minimum fee is charged for clients whose fee for assets under management falls below a particular threshold, such fee may exceed 1.20% on assets under management in the advisory account. Any minimum fee will be agreed to with the client. Wealthspire and its affiliates retain the right, based upon criteria (e.g., assets under management) or otherwise in their discretion, to reduce, lower or waive fees, waive minimums on fees, provide lowest available fee arrangements, or allow credits or offsets relating to certain types or specified amounts of expenses with respect to certain clients. The Firm established certain client relationships through its merger, acquisition and advisor recruiting efforts. To accommodate client transitions from prior investment advisor to Wealthspire, the fees the Firm charges are subject to the pre-existing agreement entered into with their prior investment adviser. As a result, some clients pay higher or lower rates than Wealthspire’s current advisory fee rate, and the associated billing arrangements may differ from those of Wealthspire Advisors. Wealthspire Advisors Institutional Fees are agreed upon with each client, in writing, which may be amended from time to time. We may use alternate fee arrangements, including minimum fees, based on the particular circumstances for specific clients based on, among other factors, the size and scope of the engagement, anticipated level of service and complexity of the relationship, client needs, related accounts, services required, reporting requirements, anticipated assets to be managed, and future additional assets. A minimum institution account size of $5,000,000 is recommended for this service which results in a 0.75% effective annual fee for Accounts of this size. Under certain circumstances, Wealthspire Advisors may accept institution accounts of less than $5,000,000. The fees for these Accounts may be higher than 0.75%, depending on the Account size and the final rate determined between the Firm and client. 16  Wealthspire Advisors Retirement Plan Management Service Fees are agreed upon with each client, in writing, which may be amended from time to time. We may use alternate fee arrangements, including minimum fees, based on the particular circumstances for specific clients based on, among other factors, the size and scope of the engagement, anticipated level of service and complexity of the relationship, client needs, related accounts, services required, reporting requirements, anticipated assets to be managed, and future additional assets. A minimum account size of $250,000 is recommended for this service which results in an effective annual fee of 0.50% for Accounts of this size. This minimum account size may be waived. The fees for these Accounts may be higher than 0.50%, depending on the Account size and the final rate determined between the Firm and client. Retirement Plan Clients are generally invoiced quarterly in arrears based on the value of invested assets as of the last day of the previous quarter. The fee for the quarter in which the investment advisory agreement becomes effective (as of the date the contract was signed) will be prorated for the number of days remaining in the quarter. Wealthspire Advisors may introduce ERISA plan clients to, or may service ERISA plan clients jointly with, Retirement Advisory, an affiliated company specializing in working with plan sponsors. To the extent that Wealthspire Advisors refers a plan sponsor to Retirement Advisory, Retirement Advisory will share 40% (or other agreed upon percentage as fully disclosed to the Plan Sponsor client) of the first year of its annual billable fee with Wealthspire Advisors pursuant to an agreement and full disclosure to the Plan Sponsor client. In no case will Wealthspire Advisors’ recommendation of Retirement Advisory cause a client’s fee to be increased. Prosperity Program Services For these services, the fee schedule is up to 1.25% on assets managed under Wealthspire’s Prosperity platform. The minimum account size is $100,000 although this requirement can be waived from time to time at Wealthspire’s discretion. This fee also can be different from above based on the referral arrangement discussed later in this brochure. Flat Rate or Fixed Dollar Amount Fee In some circumstances, and in Wealthspire Advisors’ sole discretion, Wealthspire Advisors may enter into a flat percentage rate investment advisory arrangement with new clients that generally will not exceed 1.20% annually of the assets under management. Alternatively, in limited circumstances and also in Wealthspire Advisors’ sole discretion, the Firm may agree upon an engagement for a fixed annual dollar fee for investment advisory or consulting services. The fee is determined on a variety of factors and is generally subject to a minimum of $5,000, depending upon the level and scope of the services required and the professional rendering the services. Fee Differentials As indicated above, Wealthspire Advisors prices its services based upon various objective and subjective factors. As a result, Wealthspire Advisors’ clients may pay diverse fees based upon the market value of their assets, the complexity of the engagement, and the level and scope of the overall financial planning, reporting and/or consulting services rendered, among many other factors. As a result of these objective and subjective factors, similarly situated clients could pay diverse fees, and the services to be provided by Wealthspire to any particular client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly. Conflict of Interest. Wealthspire shall generally compensate its representatives based upon the revenues derived from accounts that they service. The representative generally maintains 17  the authority to determine/negotiate the percentage advisory fee. Thus, a conflict of interest is presented because the higher the advisory fee, the greater the representative’s (and Wealthspire’s) compensation. Separate Account Manager Fee Schedules As described in Item 4, Wealthspire Advisors maintains a sub-advisory relationship with most of the Separate Account Managers it currently recommends for new investment. Before investing with any Separate Account Manager, clients are provided with the Separate Account Manager’s Disclosure Brochure and fee schedule. Annual fees charged by Separate Account Managers vary, but generally range from 0.10% to 0.85% of the amount under management; these fees are in addition to Wealthspire Advisors’ advisory fee and are typically debited directly by the Separate Account Manager from the client’s Account. For participants in the Firm’s Wrap Program, client assets allocated by Wealthspire to unaffiliated separate account managers shall include a separate and additional investment management fee charged by the separate account manager, in addition to Wealthspire’s investment advisory fee. Financial Planning Services Fees The fees for Financial Planning and Consulting services will typically be charged on a fixed fee basis, depending on the specific service requested, the nature and complexity of each client's circumstances, and the qualifications, training, and experience of the individuals performing the service. Up to 50% of this fee may be due upon signing the advisory services agreement with the balance due upon completion of services. Typical financial planning engagements last no longer than six months. Trustee and Trust Administration/Reporting Services As described in Item 4 above, certain Wealthspire Advisors’ employees (or employees of affiliates), upon client request, serve as trustee, POA, or Agent for various types of trusts set up by clients. The fee for trustee services is variable depending on the type of trust, the terms of the trust document, the scope of the trustee’s duties and applicable state law. Wealthspire Advisors’ fee for having one of its employees serve as trustee generally will not exceed 0.60% annually of the trust assets under management. For trusts subject to another fee arrangement, the trustee services fee is variable, but generally subject to a minimum fee of $5,000. Wealthspire Advisors’ fee for providing trust administration services is generally a fixed annual dollar fee of no less than $5,000 per annum. Wealthspire Advisors may, at its sole discretion, elect to waive any or all of these fees. Other fees for necessary and customary third-party professional services (such as legal and accounting fees) are not included and are incurred separately by the trust. Wrap Fee Program Wrap Program fees are agreed upon with each client in writing, which may be amended from time to time. For clients with a Wrap Program investment advisory agreement, Wealthspire charges up to a 2.00% fee on all assets in the Wrap Program account. Clients in the Wrap Program pay a single specified annual fee, inclusive of execution, custody, performance reporting, and our investment management fees. We incur the cost of executing securities transactions in your account. This creates a conflict of interest because the Firm is incentivized to initiate fewer trades in your account to minimize expenses. To manage this conflict of interest, we monitor account activity to help identify inactivity and ensure that trading levels are consistent with a client’s investment objectives and risk tolerance. We may engage the services of third-party investment managers to manage a portion of a client’s assets. These third-party managers 18  charge their own fees, which are in addition to the fees charged by Wealthspire. Multiple fees charged on the same investments results in layering of fees, which will reduce the rate of return that the investor will derive from the underlying investment. For fee information associated with Wrap Program client accounts, please see our Wrap Program Brochure as well as your investment advisory agreement. Fee Calculations The specific manner in which asset-based fees are charged by Wealthspire Advisors is set forth in the services agreement between each client and Wealthspire Advisors. There are some clients that may be receiving similar services under different fee schedules and billing methods due to the historical nature of their particular services agreement. Clients may elect to be billed directly for fees or may authorize Wealthspire Advisors to debit fees directly from the client's Account. All fees are rounded to the nearest whole dollar. Fees for wealth management clients are typically paid quarterly in advance, with one quarter of the fee drawn each quarter based upon the value of the Account at the close of the previous quarter. Accounts opened during a quarter where fees are calculated in advance will be charged a prorated fee based upon the number of days services are provided in the next billing cycle. Upon termination of any Account, any prepaid, unearned fees will be promptly refunded. If fees are calculated in arrears, fees will be prorated accordingly. Wealthspire Advisors may, in its discretion, combine the values of investments of related Accounts for fee calculation purposes and may amend its fee upon advance written notice to clients. Wealthspire Advisors does not independently value any private securities held in client accounts or in the hedge funds it recommends. The quarterly financial information provided by the private funds themselves will be used as the basis for client reporting and fee billing (where a client pays an asset- based fee). This valuation is determined independently of Wealthspire Advisors. As indicated above, Wealthspire Advisors, in its sole discretion, may reduce its investment management fee or reduce or waive its minimum fee requirement for any service based upon certain criteria (e.g., anticipated future earnings or asset acquisitions by a client, dollar amount of assets to be managed, related Accounts, Account investment composition, and by negotiations with the client). Please Note: Wealthspire has acquired unaffiliated registered investment advisers. Certain clients who transitioned to Wealthspire as part of this acquisition may be subject to fee arrangements (including fee timing, frequency, calculation methodology, and fee amount) that differ from those described herein. As an accommodation to such acquired clients, Wealthspire will maintain such fee arrangements, consistent with the terms of the clients’ advisory agreement until such time as the agreement has been amended. As a result, some clients may pay higher or lower rates than the current Wealthspire advisory fee rate. Clients are advised to review their advisory agreement for further details. Other Costs Wealthspire Advisors’ fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the Account. Accounts may also incur certain charges imposed by custodians, brokers, separate account managers, and other third parties, such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, variable annuities, and ETFs also charge internal management fees, which are disclosed in a fund’s prospectus. Thus, when such investments are within an Account, two levels of management fees are paid: one to the fund or annuity manager and one to Wealthspire Advisors. Wealthspire Advisors does not receive any portion of these commissions, fees, and costs. See Item 12 19  for a description of the factors Wealthspire Advisors considers in selecting or recommending broker- dealers for Account transactions and determining the reasonableness of their compensation (e.g., commissions). 20  Item 6 – Performance-Based Fees and Side-By-Side Management Wealthspire Advisors does not charge any performance-based fees, which are fees based on a share of capital gains on or capital appreciation of a client’s assets. The Firm does not conduct side-by-side management. Frank Marzano, a Managing Director of Wealthspire, receives performance-based compensation for the Funds referenced in Item 4 hereto. A conflict of interest exists as Mr. Marzano has an incentive to recommend clients retain their positions in one or more of the Funds. Nonetheless, an investment in a Fund was only recommended to clients with consideration of numerous factors in mind, including but not limited to, the client’s investment objective and financial circumstances. The Funds shall continue to be operated separate and independent of Wealthspire and its parent organizations. The Funds will not be offered to Wealthspire clients. Clients may continue to own one or more of the Funds, but neither the purchase of a new Fund or additional investment in a currently owned Fund will be permitted. Wealthspire does not, and shall not, monitor or supervise any of the Funds, nor will it supervise Mr. Marzano relative to his role with the Funds. Wealthspire does not, and shall not, receive compensation from any of the Funds. 21  Item 7 – Types of Clients Wealthspire Advisors provides investment advisory services to a wide variety of clients including individuals, high net worth individuals, corporate pension and profit-sharing plans, trusts, estates, charitable institutions, foundations, endowments, corporations, and other business entities. Wealthspire Advisors does not require minimum account sizes for its various programs but does have recommended account sizes for its various programs as noted in Item 4 above. 22  Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Investment Philosophy The Firm’s mission is to help our clients achieve their short-to-long-term financial goals. Wealthspire Advisors employs an investment team whose primary responsibility and focus is to continuously research and monitor/evaluate existing allocations and investments while also evaluating new opportunities. The Firm’s investment professionals incorporate institutional discipline into its investment and risk management processes by following a coherent and consistent investment philosophy. The key tenets of Wealthspire Advisors’ investment philosophy emphasize:  Managing risk with diversified portfolios that feature a broad range of asset classes  Utilizing an asset allocation model based on investing principals used by some of the largest endowments and foundations in the world to aid our asset allocation process  Continual evaluation of how an individual investment decision may impact a broader portfolio  Mindful of fees and taxes  Minimizing portfolio changes and turnover in any security or by following any strategy, Wealthspire Advisors does not guarantee the results of any advice given. Thus, losses can occur by investing including conservative strategies recommended or applied by Wealthspire Advisors. Key Portfolio Guidelines/Investment Strategies Wealthspire Advisors has developed a range of portfolio guidelines to fit client investment profiles varying from Ultra Conservative to Aggressive to all Equity. These portfolio guidelines have been developed to meet the needs of various types of investors having different time horizons, financial goals, investing philosophy, tax considerations, cash needs and risk appetite. Central to each portfolio guideline is that it is developed through the investment team’s comprehensive quantitative and qualitative research (described below), in keeping with the key tenets of the Firm’s investment philosophy. The primary difference between each portfolio guideline is the risk/reward profile, as determined by that portfolio guideline’s asset allocation. For instance, over sufficiently long time horizons, the Ultra Conservative portfolio is expected to have a lower volatility profile than the Aggressive Portfolio due to its higher allocation to fixed income and/or cash, and lower allocation to equities. Methods of Analysis and Investment Selection For clients in the traditional comprehensive service model: Based on the initial client portfolio analysis and the client’s investment objectives and needs, Wealthspire Advisors is granted limited discretionary authority to implement the recommended investment strategies. Unless the client and advisor agree upon exceptions, the Firm primarily recommends investing client portfolios in a mix of active and/or passive mutual funds, ETFs, Separate Account Managers, and private and/or illiquid vehicles. Investments are selected based on both quantitative and qualitative analysis. Some of the key quantitative and qualitative factors are: Quantitative Analysis  Historical return and volatility profile  Historical exposure and allocations  Fees and liquidity  The impact that changes would have on our model portfolios Qualitative Analysis  Examination of the investment approach  Assessment of potential risks to the portfolio  Review of operational practices 23  Risks of Loss Investment Risk. Investing in securities involves many inherent risks, including the risk of loss that clients should be prepared to bear. Investments managed by Wealthspire Advisors are no exception. Securities fluctuate in value, depending on many factors that are unpredictable and outside of Wealthspire Advisors’ control. There is no guarantee that the future performance of any specific investment or investment strategy recommended or undertaken by Wealthspire Advisors will be profitable or will equal any specific performance level. Asset Allocation Risk. The allocation of investments among various asset classes for client accounts is primarily invested in equities, fixed-income securities, alternatives, illiquid investments, and short- term cash equivalents. These asset classes may increase or decrease in value at different times or may all move together at any particular time. While a goal of this diversification is to reduce risk, that result is not assured. The asset allocation of your account has a significant effect on your account performance. Mutual Funds and Exchange Traded Funds (ETFs). An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per-share NAV of a mutual fund is calculated at the end of each business day. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Interest Rate Risk. Many investments are subject to interest rate risk, which is the risk that the value of a security will decline because of a change in general interest rates. Investments subject to interest rate risk will usually decrease in value when interest rates rise and rise in value when interest rates decline. Also, securities with long maturities typically experience a more pronounced change in value when interest rates change. Interest rate risk most directly affects the value of fixed income securities, but many equity securities can also change in value due to changes in interest rates. Credit Risk. Fixed income investments are subject to credit risk. An issuer’s credit quality depends on its ability to pay interest on and repay its debt and other obligations. Defaulted securities (or those expected to default) are subject to additional risks in that the securities may become subject to a plan of reorganization that can diminish or eliminate their value. The credit risk of a security may also depend on the credit quality of any bank or financial institution that provides credit enhancement for the security. 24  Inflation Risk. This is the risk that the value of assets or income from investments will be less in the future as inflation decreases the value of money. As inflation increases, the real value of your assets may decline, and income earned may have less value. Market Risk. Markets can trade in random or cyclical price patterns, and prices can fall over sustained periods of time. The value of the investments in your account will change as markets fluctuate and could decline over short- or long-term periods. Due to the structure of client portfolios, it is likely that the performance of client accounts will differ from standard published indices. Margin Risk. Generally, Wealthspire does not recommend the use of margin for investment purposes, except in limited circumstances, and does not use margin in its portfolio models. The use of margin as an investment strategy creates a high level of inherent risk. A margin transaction occurs when an investor uses borrowed assets to purchase financial instruments. The investor generally obtains the borrowed assets by using other securities as collateral for the borrowed sum. The effect of purchasing a security using margin is to magnify any gains or losses sustained by the purchase of the financial instruments on margin. Portfolio margining may increase leverage and magnify gains/losses.  Impact of Margin on Client Fees: Wealthspire generally assesses its asset-based fees on the market value of the client assets, gross of any outstanding SBL balance. Accordingly, Wealthspire has a conflict of interest in recommending that clients utilize SBLs to access cash, rather than selling assets which are included in Wealthspire’s asset-based fee calculation. Liquidity and Valuation of Investments: Private Funds (such as Limited Partnerships) may invest in securities and other financial assets that are subject to legal or other restrictions on transfer or for which no liquid market exists. The market prices, if any, for such instruments tend to be reported infrequently and can be volatile. Such securities may not be saleable when desired or may not realize the perceived fair value in the event of a sale. The sale of restricted and/or illiquid securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the over-the-counter markets. As a result, calculating the fair market value of a Private Fund’s underlying holdings may be difficult. Private investments generally have risk factors and liquidity constraints and are intended only for experienced and sophisticated investors who have the willingness and financial ability to bear the high economic risks of the investment. Before investing in any private fund, clients will be provided with the fund’s offering documents which will explain the investment in detail. Investors should carefully review these offering documents and consider the potential risks before investing. Some of these risks may include loss of all or a substantial portion of the investment due to the factors discussed above. Short-term Trading - Although we, as a general business practice, do not utilize short-term trading, there may be instances in which short-term trading may be necessary or an appropriate strategy. In this regard, please read the following: There is an inherent risk for clients who trade frequently in that high-frequency trading can create substantial transaction costs that, in the aggregation, could negatively impact account performance. Option Strategies - Various option strategies give the holder the right to acquire or sell underlying securities at the contract strike price up until expiration of the option. Typically, an options contract represents a multiple number of shares of the underlying security. Options entail greater risk but allow an investor to have market exposure to a particular security or group of securities without the same capital commitment required to purchase the underlying security group of securities. In the portfolio. addition, options allow investors to hedge security positions held in For detailed information on the use of options and option strategies, please contact the Options Clearing Corporation for the current Options Risk Disclosure Statement. 25  Wealthspire Advisors, as part of its investment strategy, may employ the following option strategies independently, or in combination with other strategies, to meet a specific objective  Long call options purchases – provides the right, but not the obligation, to the option holder to purchase the underlying asset at a predefined strike price on or before the expiration date. Owning this option provides the owner with upside participation of the underlying asset should its price rise above the option’s strike price.  Long put options purchases – provides the right, but not the obligation, to the option holder to sell the underlying asset at a predefined strike price on or before the expiration date. Owning this option provides the owner with upside participation should the underlying asset price fall below the option’s strike price.  Short call options sales – obligates the option writer (seller) to deliver the underlying asset at a predefined strike price on or before the expiration date should the asset’s price rise above the strike price, the option go in-the-money, and is exercised by the option owner. One-way short call options are used in a strategy called a covered call writing, such that the short call option is collateralized by the underlying asset. This type of transaction can be used to generate income for the option writer, allow for staged exit out of the underlying asset, or be married with other option strategies for other objectives.  Short put options sales – obligates the option writer (seller) to buy the underlying asset at a predefined strike price on or before the expiration date should the asset’s price fall below the strike price, the option go in-the-money, and is exercised by the option buyer. One-way short put options can be used in a strategy called a cash-secured put. The short put option is collateralized by enough cash necessary to purchase the underlying asset if the option is exercised. This type of transaction can be used to generate income for the option writer, allow for staged entry into the underlying asset, or be married with other option strategies for other objectives. Concentration Risk - There is an inherent risk for clients who have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one investment manager, or one type of investment instrument (equities versus fixed income). Clients, who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain but also offer the potential for significant loss. Material Risks of Investment Instruments - Wealthspire Advisors typically invests in open-end mutual funds, separate accounts, and exchange-traded funds for the vast majority of its clients. However, for certain clients, we may affect transactions in the following types of securities:  Equity securities – Investing in individual companies involves inherent risk. The major risks relate to the company's capitalization, quality of the company's management, quality and cost of the company's services, the company's ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk, and the company's ability to create shareholder value (i.e., increase the value of the company's stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk, and liquidity risk.  Mutual fund securities – Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. 26   Exchange-traded funds – Exchange-traded funds are investment companies whose shares are bought and sold on a securities exchange. Many ETFs holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETF providers include Vanguard, SPDRs®, NASDAQ 100 Index Tracking Stock ("QQQs"), and iShares®. The funds could purchase an ETF to gain exposure to a portion of the U.S. or foreign market. The funds, as a shareholder of another investment company, will bear their pro-rata portion of the other investment company's advisory fee and other expenses, in addition to their own expenses. ETFs that do not track an index are actively managed funds that seek to achieve specific investment objectives through portfolio management strategies rather than replicating the performance of a benchmark index. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral, and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price of the ETFs underlying portfolio securities, thereby causing significant price fluctuations of the ETF.  Cryptocurrency Risk – Investments in cryptocurrency exchange-traded funds (ETFs) involve significant risks, including high volatility, regulatory uncertainty, and cybersecurity threats. While cryptocurrency ETFs provide indirect exposure to digital assets, they remain subject to the price fluctuations of the underlying cryptocurrencies, which can be extreme. Additionally, regulatory developments may impact the availability and operation of cryptocurrency ETFs, potentially affecting their liquidity and valuation. Other risks include tracking errors, custodial risks, and the potential for increased fees compared to traditional ETFs. Investors should carefully consider these risks and their risk tolerance before investing in cryptocurrency ETFs.  Fixed income securities – Fixed income securities carry additional risks than those of equity securities described above. These risks include the company's ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S. or foreign), and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity, the less volatile the price swings. Foreign bonds have liquidity and currency risk.  Corporate Debt Securities, Commercial Paper, and Certificates of Deposit – Corporate Debt Securities, Commercial Paper, and Certificates of Deports carry additional risks than those of equity securities described above. The risks include the company's ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S. or foreign), and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity, the less volatile the price swings. Foreign bonds also have liquidity and currency risk. Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank, and the length of maturity. With respect to certificates of deposit, depending on the 27  length of maturity, there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity.  Municipal Securities – Municipal Securities carry additional risks than those of corporate and bank-sponsored debt securities described above. These risks include the municipality's ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax- free at the federal level but may be taxable in individual states other than the state in which both the investor and municipal issuer is domiciled.  Variable Annuities – Variable Annuities are long-term financial products designed for retirement purposes. In essence, annuities are contractual agreements in which payment(s) are made to an insurance company that agrees to pay out an income or a lump sum amount at a later date. There are contract limitations, fees, and charges associated with annuities, administrative fees, and optional benefits. They also may carry early withdrawal penalties and surrender charges and carry additional risks such as the insurance carrier's ability to pay claims. Moreover, variable annuities carry investment risk similar to mutual funds. Investors should carefully review the terms of the variable annuity contract before investing.  Private Investment Funds – Private Investment Funds generally involve risk factors and liquidity constraints, a complete discussion of which is set forth in each fund's offering documents and will be provided to each client for review and consideration. Investing in private investment funds is intended for experienced and sophisticated investors only who are willing to bear the high economic risks of the investment. Investors should carefully review and consider potential risks before investing. Some of these risks may include loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative practices; lack of liquidity because of redemption terms and conditions; and that there may not and will not be a secondary market for the fund; volatility of returns, restrictions on transferring interest in the fund; a potential lack of diversification; higher fees than mutual funds; lack of information regarding valuations and pricing; and advisor risk. Wealthspire Advisors’ recommendation of a particular fund to clients does not mitigate the risks above. Fund of Funds Risk: Clients that invest in other funds indirectly bear their proportionate share of the operating expenses and management fees of the underlying fund(s). There is risk that the fund’s performance will be adversely affected by the assets owned by the other funds in which it invests, and that the layering of expenses associated with the fund’s investment in such other funds will cost investors more than direct investments would have cost. For More Information About Risks: Current and prospective clients are encouraged to ask their advisor any questions they may have about these, or other risks, associated with investing. Asset Transition: From time-to-time, Wealthspire may acquire other advisory practices, and such practices will seek to transition their clients to Wealthspire. As part of the post-acquisition integration process, a transition to convert such client accounts to Wealthspire’s investment strategies will commence. However, for various reasons (i.e., embedded taxable gains, types of holdings, client- imposed requirements, etc.), this transition could take up to one year or more. 28  Item 9 – Disciplinary Information Wealthspire Advisors and its Advisor Representatives are required to disclose all material facts regarding any legal or disciplinary event that would be material to an evaluation of Wealthspire integrity of Wealthspire Advisors’ management team, or the Firm's Advisor Advisors, the Representatives. Wealthspire Advisors and its Advisor Representatives have no material information to report in response to this Item. 29  Item 10 – Other Financial Industry Activities and Affiliations Wealthspire Advisors’ primary business is as an investment advisor as described in this brochure. It is not a broker-dealer and none of its representatives are registered with a broker-dealer. The Firm and its representatives receive no commissions for the sale of any securities. A full list of Wealthspire mergers and acquisitions is available upon request. Wealthspire may have subsidiary affiliates, via acquisitions, that maintain separate client brochures until such time as the operations of Wealthspire Advisors LLC and the acquired company are sufficiently integrated to merit combined client brochures. The Firm is affiliated with other registered investment advisers, insurance agencies, and other product and service providers. Wealthspire Advisors is under no obligation to sell any products or recommend any services to our clients as a result of these affiliations. Wealthspire Advisors has entered into mutual referral arrangements with the following parent company-affiliated entities (“Affiliate”): Retirement Advisory, Newport Private Wealth Inc., and Fiducient Advisors LLC. As a result of these referral arrangements, the referring entity will receive a portion of the advisor's services fee received for each referred client. Clients will not pay a higher fee than they would normally, and a client is under no obligation to use the services of any Affiliate or third-party advisor that Wealthspire Advisors recommends. Wealthspire has also entered into a referral agreement with Kestra Advisory Services, LLC (“Kestra”), the Broker Dealer platform through which Retirement Advisory offers securities. Private Investment Partnerships Personnel of Wealthspire Advisors may be investors and/or partners/members in private investment partnerships, limited liability companies, or corporations that invest in securities or private equity opportunities. Certain investors in the private investment partnerships, limited liability companies, or corporations may also independently be clients of Wealthspire Advisors. Wealthspire Advisors does not act as an advisor, sponsor, or placement agent for these private investment partnerships, limited liability companies, or corporations. A client of Wealthspire Advisors also manages a private fund that has been recommended to other Wealthspire Advisors clients. Wealthspire Advisors clients do not receive any preferential treatment as investors in the fund; the manager pays usual and customary fees as a Wealthspire Advisors client. Supervised Person Outside Business Activity An acquired and merged firm, GM Advisory Group, LLC (“GMAG”), previously recommended that certain of its advisory clients invest in one or more Funds (“Funds”) managed or sponsored by GMAG Management, an investment adviser previously under common control with GMAG. In addition, certain affiliates of the Firm sponsors and serves as general partner or managing member of such Funds and, as a result, receive compensation, depending on the Fund. Frank Marzano, a Managing Director of Wealthspire, has a controlling ownership interest in GMAG Management and its affiliates that serve as general partner of the Funds. A conflict of interest exists as Mr. Marzano has a financial incentive to recommend clients retain their positions in a Fund where GMAG Management or its affiliates can earn compensation. Nonetheless, an investment in a Fund was only recommended to clients with consideration of numerous factors in mind, including but not limited to, the client’s investment objective and financial circumstances. The Funds shall continue to be operated separate and independent of Wealthspire and its parent organizations. The Funds will not be offered to Wealthspire clients. Clients may continue to own one or more of the Funds, but neither the purchase of a new Fund nor additional investment in a currently owned Fund will be permitted. Wealthspire does not, and shall not, monitor or supervise any of the Funds, nor will it supervise Mr. Marzano relative to his role with the Funds. Wealthspire does not, and shall not, receive compensation from any of the Funds. 30  Trust Protectorships Representatives of Wealthspire Advisors have, on occasion, be asked to be named as Trust Protector for a client trust. Wealthspire Advisors has offered this service to its clients on a limited basis, strictly if the powers granted to the Trust Protector are limited in scope. The Trust Protector does not act as Trustee and does not have custody of funds within the trust. The Trust Protector typically is solely granted the ability to remove or replace the trustee if the trustee is found to not be performing its duties for the benefit of the trust and its beneficiaries. The Trust Protector role is an additional layer of protection for the trust grantor's long-term financial and personal goals of the trust. Representatives of Wealthspire Advisors do not charge for this service, and it is available to all trust accounts. Wealthspire Trust LLC (“Wealthspire Trust”) and Wealthspire Advisors are separate subsidiary entities of Wealthspire, LP. Wealthspire Trust is a corporation domiciled in Tennessee, chartered pursuant to Tennessee statutes as a non-depository trust company, and regulated by the State of Tennessee Department of Financial Institutions. Wealthspire Trust was created to provide trust administrative services to clients where financial, family, or business needs require the services of a professional fiduciary and trust company. Specific services provided by Wealthspire Trust include: (1) corporate trustee services for personal trusts, (2) corporate trustee for life insurance trusts, and (3) trustee services for charitable trust accounts. Wealthspire Trust’s services include the safekeeping of all trust assets, held via segregated trust accounts at qualified third-party custodians identifying Wealthspire Trust as trustee or interested third party. Certain Wealthspire Advisors employees serve on the Board of Directors to Wealthspire Trust in addition to their Wealthspire Advisors responsibilities. Wealthspire Trust may retain the services of Wealthspire Advisors for investment advisory functions through a delegated arrangement. Fees and expenses paid by clients to Wealthspire Trust are separate from and in addition to the fees charged by Wealthspire Advisors. Because of Wealthspire Advisors’ affiliation with Wealthspire Trust, Wealthspire has a conflict of interest in recommending Wealthspire Trust to clients. Clients are not obligated to use the services of Wealthspire Trust and can establish their trust account at any custodian or trustee of their own choosing. Gifts and Entertainment Brokers, counterparties, service providers, and other third parties with whom we do business occasionally provide gifts and entertainment to our principals and employees. From time to time, we expect to enter into business transactions and relationships on behalf of a client with the donors of such gifts and entertainment. Such gifts and entertainment create a conflict of interest in our selection and retention of these donors as service providers for Clients. To address this conflict, we have adopted policies and procedures to: (1) monitor gifts and entertainment given and received by our employees; and (2) limit the value of gifts and entertainment given and received by our employees. for which Industry Events & Expense Reimbursements We will from time to time receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors underwrite the costs incurred for marketing, such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors investments recommendations have been made or are anticipated to be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of our clients. We attempt to control for this conflict by always basing investment decisions on the facts discussed in Item 8 herein. 31  Item 11 – Code of Ethics Wealthspire Advisors and its employees may buy and sell the same securities that may be recommended to clients. If the possibility of a conflict of interest occurs, the client's interest will prevail. It is the policy of Wealthspire Advisors that priority will always be given to the client's orders over the orders of an employee. To avoid any potential conflicts involving personal trades, Wealthspire Advisors has adopted a Code of Ethics which sets forth the standards of conduct which every officer, partner, Advisor Representative, and employee of Wealthspire Advisors is expected to follow. Wealthspire Advisors' fiduciary duty compels all employees to act with the utmost integrity in all dealings, which is the core principle underlying its Code of Ethics and incorporated Personal Trading Policy, and represents the expected norm of all dealings with Wealthspire Advisors clients. In connection with these expectations, Wealthspire Advisors has established principles of conduct for its employees. These standards are consistent with Wealthspire Advisors' belief that ethical conduct is premised on the fundamental principles of openness, integrity, honesty, and trust. Wealthspire Advisors maintains an investment policy relative to personal securities transactions. This investment policy is part of Wealthspire Advisors’ overall Code of Ethics, which serves to establish a standard of business conduct for all Wealthspire Advisors’ personnel that is based upon fundamental principles of openness, integrity, honesty and trust. The Firm’s policy, in accordance with Section 204A of the Investment Advisers Act of 1940, contains written policies reasonably designed to prevent the unlawful use of material non-public information by Wealthspire Advisors or any of its personnel. For example, the Firm’s Code of Ethics:  Requires certain Wealthspire Advisors’ personnel to report their personal securities holdings and obtain pre-approval of certain investments  Prohibits the misuse of material non-public information by any person associated with Wealthspire Advisors  Prohibits the recommendation, purchase or sale for client accounts any securities in which Wealthspire Advisors or any of its related persons has a material financial interest. A copy of the Firm’s Code of Ethics is available upon request. Generally, Wealthspire Advisors invests client funds in mutual funds and ETFs. Assets allocated to Separate Account Managers are invested by that manager without input from Wealthspire Advisors as to the specific securities to be purchased or sold. Wealthspire Advisors’ personnel are permitted to buy or sell securities that are also recommended to clients. Because the Firm does not generally purchase individual securities for client accounts (except for ETFs that are used as a mutual fund alternative, and when previously agreed upon), Wealthspire Advisors believes that its personnel are not in a position to potentially materially benefit from the sale or purchase of those securities, including ETFs given the underlying composition thereof (i.e., a pooled investment vehicle comprised of numerous individual securities selected at the discretion of the fund manager). Wealthspire Advisors anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which Wealthspire Advisors has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which Wealthspire Advisors, its affiliates, Advisor Representatives, and/or clients, directly or indirectly, have a position. Wealthspire Advisors employees and persons associated with Wealthspire Advisors are required to follow the Wealthspire Advisors' Code of Ethics. The Code of Ethics is designed to ensure that the personal securities transactions, activities, and interests of the employees of Wealthspire Advisors will not interfere with (i) making decisions in the best interest of advisory clients, and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions based on a determination that these would materially not interfere with the best interest of Wealthspire Advisors clients. In addition, the Code requires pre- 32  clearance of some transactions, including investment in any limited, private, or initial public offering. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between Wealthspire Advisors and its clients. The Code of Ethics also includes provisions relating to maintaining the confidentiality of client information, a prohibition on trading on inside information, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Wealthspire Advisors must acknowledge reviewing the current Code of Ethics annually. Trade Error Policy Wealthspire Advisors strives to minimize the occurrence of trade errors. In the event of a trade error, it is Wealthspire Advisors’ policy to return the client to an equivalent or comparable position had the trade error not occurred. Gifts and Entertainment Policy Wealthspire Advisors maintains a Gifts and Entertainment Policy, whereby employees are generally prohibited from receiving (or giving) any gift, gratuity, hospitality, or other offering of more than de minimis value, from (to) any person or entity doing business with the Firm. This prohibition generally excludes items or events where the employee has reason to believe there is a legitimate business purpose, such as a dinner or a sporting event, of reasonable value and frequency, where a representative of the company providing the business entertainment is present. Gifts received (or given) by employees are reported regularly and are monitored by the Firm. Wealthspire Advisors values its relationships with clients and others doing business with the Firm, including Separate Account Managers Wealthspire Advisors recommends to its clients. These relationships may result in periodic gifts provided or received by Wealthspire Advisors employees in the ordinary course of business. As a practical matter, it would be difficult to establish working relationships with clients and others without periodic gifts being exchanged. While the acceptance of any gift by a Wealthspire Advisors employee may be viewed as a conflict, the Gifts and Entertainment Policy is designed to provide reasonable assurance that gifts received are not of a material nature to impact a Wealthspire Advisors employee's judgment in working with clients and others doing business with the Firm. Wealthspire Advisors clients or prospective clients may request a complete copy of the Firm's Code of Ethics by contacting Wealthspire Advisors' Compliance Department using the telephone number on the Cover Page of this Brochure. 33  Item 12 – Brokerage Practices Unless otherwise directed by the client, Wealthspire Advisors and third-party Separate Account Managers may use any broker-dealer they deem appropriate to execute transactions on behalf of a client's Account. Clients should consult the respective Separate Account Manager's Form ADV and the Account Agreement for full details on the use of broker-dealers. In selecting or recommending broker-dealers to execute portfolio transaction for the client's account, Wealthspire Advisors may consider the quality and reliability of the brokerage services, as well as research and investment information and other services provided by the brokers or dealers. Commission rates, being a component of price, are one factor considered by Wealthspire Advisors together with other factors. Wealthspire Advisors is not obligated to seek in advance competitive bidding for the most favorable commission rate applicable to any particular transaction for the client's account or recommend any broker or dealer on the basis of its purported posted commission rate. Accordingly, recommended brokers or dealers may charge commission rates in excess of the amounts another broker or dealer would have charged for effecting transactions when Wealthspire Advisors has determined in good faith that the broker's or dealer's commission rates generally are reasonable in relation to the value of the brokerage and/or research provided by the broker or dealer. In limited instances, Wealthspire Advisors may permit clients to direct them to use a custodian broker-dealer other than with those brokers with which Wealthspire Advisors has an established relationship (see Item 4). In such instances, Wealthspire Advisors may not have the ability to negotiate commissions or obtain volume discounts (if applicable), and best execution of transactions may therefore not be achieved. In addition, a disparity in commission charges (if any) may exist between the commissions charged to other clients. Client assets are held by qualified custodians. Wealthspire Advisors may be deemed to have custody of client assets due to deducting fees directly from the Client’s account, employees who act as a trustee or hold a power of attorney over Client accounts, or for facilitating withdrawals or transfers to third party recipients (including wire transfers) (see Item 15 Custody, below). Recommended Custodian Broker-Dealers Wealthspire Advisors generally recommends that investment management accounts be maintained at Schwab, Fidelity, and/or Pershing, among others as individual situations dictate (see Item 4, above). Wealthspire Advisors is not affiliated with any of these qualified custodians, each of which is a registered broker-dealer, member SIPC and subject to the regulation and jurisdiction of the SEC and FINRA. The custodians will hold Client’s assets in a brokerage account and will purchase/sell securities when instructed to do so by Wealthspire Advisors, a Separate Account Manager, or the Client. Although we recommend that clients use one or more of these custodians and we typically assist the Client with account-opening process, the Client must authorize the opening of the account(s) directly with the custodian. Upon opening the account, Wealthspire Advisors is granted a limited power of attorney (LPOA) to effect transactions in the account and to debit its quarterly advisory fee. Any additional power over the account (e.g. appointing a Wealthspire Advisors adviser as Trustee or granting General Power of Attorney), if any, is on a case-by-case basis and must be initiated and granted directly by the Client. Each custodian has a formal process before any additional rights/power over the account can be granted to Wealthspire Advisors. How We Select Custodian Broker-Dealers Wealthspire Advisors seeks to recommend reputable custodians that will hold client assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. Wealthspire Advisors considers a range of factors, including, but not limited to: their respective historical relationship with Wealthspire Advisors, financial strength, reputation, execution capabilities, pricing competitiveness, investment research capabilities, breadth of additional financial services (e.g., mortgage, private banking, trust accounting), and client service. Each custodian enables Wealthspire Advisors to obtain for client portfolios many mutual funds without incurring transaction charges and other securities at nominal transaction charges. Although Wealthspire Advisors has generally negotiated what it believes to be 34  competitive rates offered by each custodian, the commissions and/or transaction fees charged by any particular custodian may be higher than those charged by other qualified custodian broker- dealers. Wealthspire Advisors has determined in good faith that the commission/transaction fees charged by Schwab, Fidelity and Pershing are reasonable in relation to the value of the brokerage and research services received. We believe that each firm meets the criteria of providing the best qualitative execution of client transactions, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are exclusive of, and in addition to, Wealthspire Advisors' investment management fee. Wealthspire Advisors’ best execution responsibility is satisfied if securities that it purchases for client accounts are mutual funds that trade at net asset value as determined at the daily market close. Each of the custodians that Wealthspire Advisors recommends provides Wealthspire Advisors with a dedicated team to handle daily business needs, which is a value add for Wealthspire Advisors and its clients. Research and Additional Indirect Economic Benefits Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Wealthspire Advisors will occasionally receive discounted or free support services and/or products from one or more custodians which assist Wealthspire Advisors to better service client accounts maintained at such institutions. Examples of such support services are: investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, and discounted or gratis consulting services, attendance at conferences, meetings, and other educational events. Conflict of Interest: The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services presents a conflict of interest because it creates an incentive to receive the benefits without cost to Wealthspire Advisors. As indicated above, certain of the support services and/or products may assist Wealthspire Advisors in managing and administering client accounts. Other services do not directly provide such assistance, but rather assist Wealthspire Advisors to manage and further develop its business enterprise. In any event, Wealthspire Advisors’ clients do not pay more for investment transactions effected and/or assets maintained at any of the recommended custodians as a result of any support Wealthspire Advisors may receive from those firms. Wealthspire Advisors has negotiated for clients reduced transaction fees (from published rates) with each custodian, and has access to a wide array of non-transaction fee mutual funds through each firm. Wealthspire Advisors has made no corresponding commitment to any custodian to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of any of the above arrangements. Your Brokerage and Custody Costs The custodians Wealthspire Advisors work with generally do not charge clients separately for custody services but rather are compensated by charging commissions or other fees on trades or account activity made in or that settle into client accounts. In some instances, the custodians Wealthspire Advisors work with earn interest on uninvested cash in your account or by charging you a percentage of the dollar amount of assets in the account in lieu of commissions (i.e., asset-based pricing). In addition to commissions and asset-based fees, the custodians Wealthspire Advisors works with typically charge a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we 35  have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your account. These fees are in addition to the commission or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we generally have the custodian of your account execute most trades for your account. Wealthspire Advisors has negotiated reasonable transaction fees with custodians, which also provide Wealthspire Advisors clients with access to a wide array of non-transaction fee mutual funds. We have determined that the custodians we work with meet our responsibility to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those described above (see “How we select brokers/custodians”). By using another custodian, you may pay higher transaction costs. Products and Services Provided by Custodians Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms. Fidelity Institutional Wealth Services is Fidelity's business also serving independent investment advisory firms. They provide Wealthspire Advisors and its clients with access to its institutional brokerage services -- trading, custody, reporting, and related services -- many of which are not typically available to retail customers. Schwab and Fidelity also make available various support services. Some of those services help Wealthspire Advisors manage or administer clients' accounts, while others help us manage and grow our business. These support services generally are available on an unsolicited basis and at no charge as long as Wealthspire Advisors' clients collectively maintain a total of at least $10 million (at Schwab) and $15 million (at Fidelity) of their assets under management in accounts at the respective custodians. If our clients collectively have less at either Schwab or Fidelity, then we will be charged a quarterly service fee. Schwab's and Fidelity's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab and Fidelity include some of which Wealthspire’s clients might not otherwise have access or that would require a significantly higher minimum initial investment. Schwab and Fidelity also make available other products and services that benefit Wealthspire Advisors but may not directly benefit our clients. These products and services assist us in managing and administering client accounts. They include investment research, both Schwab's and Fidelity's own, and that of third parties. Wealthspire Advisors may use this research to service all or a substantial number of its clients' accounts, including accounts not maintained at Schwab and Fidelity. In addition to investment research, Schwab and Fidelity also purchase, reimburses or make available benefits, software, and other technology that:  Provides access to client account data (such as duplicate trade confirmations and account statements)  Facilitates trade execution and allocate aggregated trade orders for multiple client accounts  Provides pricing and other market data  Generates performance reports for clients  Facilitates payment of Wealthspire Advisors' fees from client accounts  Assists with back-office functions, recordkeeping, and client reporting  Offsets transfer of account exit fees imposed on clients by other custodians  Organizes events where expert guest speakers present to our clients Schwab and Fidelity also offer other services intended to help Wealthspire Advisors manage and further develop its business enterprise. These services include:  Educational conferences and events (or sponsorship of Wealthspire Advisor-hosted educational events)  Consulting on technology, compliance, legal and business needs 36   Publications and conferences on practice management and business succession  Access to employee benefits providers, human capital consultants, and insurance providers  Marketing and consulting support Schwab and Fidelity may provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services. Schwab and Fidelity may also discount or waive their fees for some of these services or pay all or a part of a third party's fees. Schwab and Fidelity may also provide us with other benefits, such as occasional business entertainment of our personnel. the formation, compliance, technology, Schwab has agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Wealthspire Advisors’ behalf. Economic benefits received by Wealthspire Advisors, that would not be available to the Firm absent its client relationships, are designed to support investment and wealth management, communications, and operational activities of Wealthspire Advisors’ business to help better serve our current and future clients. Provision of these economic benefits to Wealthspire Advisors is not conditioned on transactions or investment decisions the Firm may make or recommend on behalf of its clients. Conflict of Interest: Clients should be aware that the receipt of any economic benefit by Wealthspire Advisors are received by the Firm at no direct cost and are used to support the Firm's operations and its ability to service clients, in and of itself, creates a conflict of interest and may directly or indirectly influence Wealthspire Advisors' recommendation of those custodians for custody and brokerage service. We believe, however, that taken in the aggregate, our recommendation of these custodians for custody and brokerage services is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of each custodian’s services (see "How we select brokers/custodians") and not those services that benefit only Wealthspire Advisors. Wealthspire Advisors does not engage in pre-arranged "soft dollar" arrangements (formal arrangements where Wealthspire Advisors specifically directs portfolio brokerage commissions to a broker-dealer in return for services and research that Wealthspire Advisors uses in making investment decisions for its clients). However, as described above, Wealthspire Advisors utilizes standard services generally available to all advisors (such as proprietary trade execution software) from broker-dealers with which Wealthspire Advisors has an established relationship. All such arrangements are informal in nature and are not the product of any formal arrangement with the broker-dealer to direct portfolio brokerage commissions in exchange for such research. Such services provided by brokers may be used in servicing any or all of the clients of Wealthspire Advisors, and such products or services may not necessarily be used by Wealthspire Advisors in connection with the accounts that paid commissions to the broker providing such products or services. Wealthspire Advisors generally expects Separate Account Managers to obtain best execution in placing Wealthspire Advisors client trades. In order to obtain best execution, Separate Account Managers may place trades through outside brokers, which may result in additional trading costs to the client. Please refer to the applicable Separate Account Managers disclosure document(s) for information on brokerage and trading practices. Aggregation and Allocation of Client Trades In general, investment opportunities are made available to clients who are eligible to participate and where such opportunities are deemed appropriate for the client's Account. For pension, profit sharing, and 401(k) clients, Wealthspire Advisors will exercise discretion to rebalance accounts and substitute positions it deems appropriate to meet client objectives. When practical, trades may be bunched in a single order (a “block”) in an effort to achieve best execution. Block orders are generally completed (or “filled”) on the same day the trade is placed. If a block order is filled (full or partial fill) at several prices through multiple trades, an average price will 37  be calculated for all trades executed, and all participants in the block trade will receive the average price. Only trades executed within the block on the single day may be combined for purposes of calculating the average price. While the occurrence of partial fills (i.e., a block order which is not fully executed within the same day) is rare, all partial fills shall be allocated to client accounts on a pro rata basis subject to minimal rounding. While this policy is consistently applied, Wealthspire Advisors may deviate from this policy if the standard method of aggregating or allocating trades would result in unfair or inequitable treatment to some or all of its clients. 38  Item 13 – Review of Accounts and Reports Wealthspire Advisors’ advisors conduct ongoing account review for Investment Advisory clients, and generally prefer to personally meet and/or correspond with clients on an as-needed basis. Clients are reminded that it remains their responsibility to advise Wealthspire Advisors of any changes in their investment objectives and/or financial situation. Clients are encouraged to review financial planning issues, investment objectives and account performance with Wealthspire Advisors on an annual basis. Wealthspire Advisors’ investment team actively monitors all of the Firm’s recommended investments and is responsible for trading client accounts. It is also conducting continuous research to find new potential investments. The Investment Committee meets once per month to discuss the Firm’s recommended investments, market issues and to make recommendations on future actions to be taken. The account custodians directly provide each client with transaction confirmation notices and regular written summary account statements directly. In addition, Wealthspire Advisors provides clients with periodic statements summarizing account activity and performance. If participating in Wealthspire Advisors’ Comprehensive Reporting service described in Item 4 above, statements provided by Wealthspire Advisors may also include some or all of their asset portfolios, including assets not managed by Wealthspire Advisors. Clients should always rely on the statement received from the custodian broker- dealer for all official valuation and tax information. A client's account custodian provides periodic transaction and position reports no less frequently than quarterly for their Investment Management Accounts. The Firm provides an Account report at least annually. The reports include information regarding transactions, cash flows, security positions, and market values. 39  Item 14 – Client Referrals and Other Compensation Recommended Custodians As described in Item 12, Wealthspire Advisors may receive an indirect economic benefit from Schwab, Fidelity and/or Pershing for recommending those firms as custodians for client accounts. These indirect benefits generally consist of discounted or free support services and/or products which help the Firm better serve clients (e.g. investment research, dedicated support team, etc.). Hard Dollars/Soft Dollars Wealthspire Advisors receives no direct economic benefit from any custodian because the Firm does not participate in any “hard dollar” or “soft dollar” programs offered by the custodians. Client Referral Arrangements Affiliates Wealthspire has mutual referral arrangements with the following Affiliates: Retirement Advisory, Newport Private Wealth Inc., and Fiducient Advisors LLC. As a result of these referral arrangements, the referring entity will receive a portion of the advisor's services fee received for each referred client. The client will not pay a higher fee than they would normally, and a client is under no obligation to use the services of any Affiliate or third-party advisor that Wealthspire Advisors recommends. Wealthspire has also entered into a referral agreement with Kestra Advisory Services, LLC (“Kestra”), the Broker Dealer platform through which Retirement Advisory offers securities. Wealthspire Advisors has partnered with Retirement Advisory to provide a more robust offering of fiduciary services to 401k plans. The firms have entered into a mutual arrangement to introduce potential clients, where appropriate, to one another. Wealthspire Advisors’ primary business is advising individual clients, while Retirement Advisory specializes in serving pension plans. Conflict of Interest: As these firms are corporate affiliates of parent company Wealthspire, LP, there is a conflict of interest when Wealthspire Advisors refers a potential client to Affiliates. Wealthspire Advisors believes it has mitigated this conflict of interest in a number of ways. Neither firm has any additional incentive to refer or accept clients from the other. Wealthspire Advisors has performed due diligence to determine that each firm is an excellent provider of services outside of our core businesses and may be better equipped to provide those services than Wealthspire Advisors in certain circumstances. In no case will Wealthspire Advisors’ recommendation of an Affiliate company cause a client’s fee to be increased. To the extent that Wealthspire Advisors refers out to the Affiliates, or in cases where Wealthspire Advisors and the Affiliates work together, the relationship between the firms will be readily apparent or fully disclosed to the client before a client agreement is signed. The advisory fee will be divided accordingly (see Items 4 and 5 above regarding services and fees offered). The client is never under any obligation to use the services of Affiliates or any other advisor(s) that Wealthspire Advisors may recommend in the future. Similarly, Wealthspire Advisors anticipates that Affiliates or Kestra will refer individual clients to Wealthspire Advisors for wealth management services. In no case will Wealthspire Advisors’ fee exceed our customary client fee arrangement. Any referral fee shall be paid solely from Wealthspire’s investment advisory fee and shall not result in any additional charge to the client. If the client is introduced to Wealthspire by Kestra or another unaffiliated party, the referring party, at the time of the solicitation, shall clearly and prominently disclose whether the referring party is or is not a current client of Wealthspire, that cash or non-cash compensation was provided for the referral, if applicable, and the material terms of such compensation arrangement, and a brief statement and description of any material conflicts of interest on the part of the referring party resulting from Wealthspire’s relationship with the referring party or the compensation arrangement. 40  Lenox Advisors, Inc. Lenox Advisors, a licensed insurance agency, is a subsidiary of former parent company NFP. Securities and investment advisory services are offered through qualified registered representatives of MML Investors Services, LLC (“MML”) and NFP. Wealthspire and Lenox Advisors have a referral arrangement whereby employees and independent contractors of Lenox Advisors make referrals to Wealthspire in their capacity as MML agents as follows:  Lenox Advisors has employees and independent contractors who are also investment adviser representatives of Lenox Advisors and can render advice regarding asset allocation and the selection of third-party wealth management programs, such as Wealthspire. Such persons are registered representatives and/or investment adviser representatives of MML.  Lenox Advisors is a licensed insurance agency. In addition, certain independent contractors of Lenox Advisors, in their individual capacities, are licensed insurance agents. Certain of these individuals are also registered representatives and/or investment adviser representatives of MML. Wealthspire anticipates that it will receive referrals from the insurance agents engaged by Lenox Advisors in their capacity of MML representatives.  When a Lenox Advisors Relationship Manager, in their capacity as an investment adviser representative of MML, refers a client to Wealthspire, Wealthspire will pay certain cash compensation to MML for the referral, and the Relationship Manager will receive a portion of this compensation. This compensation creates an incentive for MML and its investment adviser representatives to recommend that individuals enter into a relationship with Wealthspire, which creates a material conflict of interest. Wealthspire Advisors may also from time to time enter into written referral agreements with employees or other persons or organizations by which Wealthspire Advisors pays referral fees to the referring individual or organization based upon fees received by Wealthspire Advisors from the referred client relationship. Some of these organizations or persons may be affiliates of Wealthspire Advisors. Wealthspire Advisors does not charge referred clients a fee higher or lower than it charges to other similarly situated clients who were not referred. An inherent conflict of interest arises on behalf of the referring individual because it is receiving an economic benefit for the referral or recommendation of Wealthspire’s services. Wealthspire Representatives & Employees Wealthspire Advisors pays compensation to individual investment adviser representatives and employees, which may include bonuses, awards, or other things of value offered by Wealthspire Advisors. These bonuses, awards, or other things of value may be awarded as part of a program to incentivize the creation of new business, increase revenue to the Firm or its affiliates, or be based on the volume of new business generated. Any conflicts of interest created by such incentive programs are carefully monitored through supervisory reviews and approval of all new business by supervisory staff of Wealthspire Advisors who are not subject to the same incentive programs applicable to the new business being reviewed. Additional Economic Benefit Wealthspire Advisors receives economic benefit from Charles Schwab and Fidelity in the form of the support, products, and services they make available to Wealthspire Advisors and other independent investment advisors whose clients maintain accounts with these custodians. The support, products and services, how they benefit Wealthspire Advisors, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of Charles Schwab or Fidelity support, products and services to Wealthspire Advisors is not based on giving particular investment advice, such as buying particular securities for our clients. The Firm or its affiliates may receive monetary sponsorships, reimbursements, or other benefits from 41  third-party vendors, including asset managers, custodians, research providers, and technology firms. These payments may be used to support the Firm's marketing efforts, educational events, client seminars, or internal training initiatives. In some instances, a sponsor may be permitted to speak or exhibit at Firm-hosted events. These sponsorship arrangements are not contingent upon specific investment recommendations or the placement of client assets with any particular sponsor. However, these arrangements create a conflict of interest in that the Firm may have an incentive to favor sponsors or provide them with preferential access or visibility over non-sponsoring vendors. The Firm manages this conflict by requiring compliance review and approval of sponsorship arrangements, and by making investment and platform decisions independently of sponsorship relationships. The aggregate value of these arrangements is not material to the Firm's revenues. Third-Party Sponsorships Wealthspire has business relationships with unaffiliated counterparties that it may utilize in conjunction with its service offerings to clients, including custodians, brokers, investment platforms, managers and fund sponsors. From time to time, Wealthspire and certain of these counterparties will participate in joint marketing efforts, including investment symposiums and event sponsorships. In addition, Wealthspire convenes educational, training, or other events for Wealthspire employees and/or clients. Certain organizations may sponsor and cover a portion of the costs associated with these events. Not all sponsors participate at the same level and participation is voluntary. Sponsors can include custodians, investment managers and fund or product sponsors to which Wealthspire can allocate client investment assets. Sponsorship is not a commitment that Wealthspire will utilize (or continue to utilize) sponsor-related products or services. Wealthspire Advisors has a fiduciary duty to provide services consistent with the client’s best interest. However, clients should understand that the receipt of economic benefits by Wealthspire and/or its employees creates a potential conflict of interest (i.e. the receipt of the benefits could influence the selection of a sponsor’s products or services). The benefits received by Wealthspire and/or its employees through such sponsorships are not dependent upon or tied to any current and/or future relationship Wealthspire has (or anticipates having) with sponsors. Wealthspire’s representatives do not receive additional compensation for recommending or utilizing a sponsor’s products or services. Any Questions: Wealthspire’s Chief Compliance Officer remains available to address any questions regarding sponsorships. Schwab Advisor Network® Wealthspire Advisors also receives client referrals from Charles Schwab through Wealthspire Advisors' participation in Schwab Advisor Network® (“the Service”). The Service is designed to help investors find an independent investment advisor and our participation in the Service does not diminish our duty, when acting as an investment advisor for any client, to select brokers on the basis of best execution. Charles Schwab is a broker- dealer independent of and unaffiliated with Wealthspire Advisors. Charles Schwab does not supervise Wealthspire Advisors and has no responsibility for Wealthspire Advisors’ management of clients’ portfolios or their other advice or services. Wealthspire Advisors pays Charles Schwab fees to receive client referrals through the Service. Their participation in the Service may raise potential conflicts of interest described below. Wealthspire Advisors pays Charles Schwab a Participation Fee on all referred clients' accounts that are maintained in custody at Charles Schwab and a Program Transfer Fee on all accounts that are maintained at, or transferred to, another custodian. The Participation Fee paid by Wealthspire Advisors is a percentage of the fees the client owes to Wealthspire Advisors or a percentage of the value of the assets in the client's account, subject to a minimum Participation Fee. Wealthspire Advisors pays Charles Schwab the Participation Fee for so long as the referred client’s account remains in custody at Charles Schwab. The Participation Fee is billed to Wealthspire Advisors quarterly and may be increased, decreased or waived by Charles Schwab from time to time. The Participation Fee is paid by Wealthspire Advisors and not by the client. Wealthspire Advisors has agreed not to charge clients referred through the Service fees or costs greater than the fees or costs they charge clients with similar portfolios who were not referred through the Service. Wealthspire Advisors generally pays Charles Schwab a Program Transfer Fee if custody of a referred 42  client’s account is not maintained by, or assets in the account are transferred from, Charles Schwab. This Fee does not apply if the client was solely responsible for the decision not to maintain custody at Charles Schwab. The Program Transfer Fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Charles Schwab. The Program Transfer Fee is higher than the Participation Fees Wealthspire Advisors generally would pay in a single year. Thus, Wealthspire Advisors has an incentive to recommend that client accounts be held in custody at Charles Schwab. The Participation and Program Transfer Fee are based on assets in the accounts of Wealthspire Advisors who were referred by Charles Schwab and those referred clients' family members living in the same household. Thus, Wealthspire Advisors has an incentive to encourage household members of clients referred through the Service to maintain custody of their accounts and execute transactions at Charles Schwab and to instruct Charles Schwab to debit Wealthspire Advisors' fees directly from the accounts. For accounts of Wealthspire Advisors' clients maintained in custody at Charles Schwab, Charles Schwab will not charge the client separately for custody but will receive compensation from Wealthspire Advisors' clients in the form of commissions or other transaction-related compensation on security trades executed through Charles Schwab. Charles Schwab also will receive a fee (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Charles Schwab. Charles Schwab's fees for trades executed at other broker-dealers are in addition to the other broker- dealer's fees. Thus, Wealthspire Advisors has an incentive to cause trades to be executed through Charles Schwab rather than other broker-dealers. Trades for client accounts held in custody at Charles Schwab may be executed through a difference broker-dealer than trades for Wealthspire Advisors' other clients. Thus, trades for accounts custodied at Charles Schwab may be executed at different times and different prices than trades for other accounts that are executed at other broker-dealers. 43  Item 15 – Custody General Pursuant to government regulations, Wealthspire is deemed to have custody of your assets if you authorize us to instruct the custodian to deduct our advisory fees directly from your account or give you authorize Wealthspire to move your money to a third-party. The custodians, Schwab, Fidelity and/or Pershing, respectively, maintain the actual custody of your assets. Generally, the account custodian will debit Wealthspire’s fee for each client on a quarterly basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian (Schwab, Fidelity or Pershing) and/or program sponsor for the client accounts. Wealthspire provides each client with a periodic statement summarizing account activity and performance. Trustee Services When one of the Firm’s advisors acts as a trustee for client trusts, accepts an appointment as executor of an estate, acts as POA, acts as Agent, or exercises a General Power of Attorney over client accounts, Wealthspire Advisors is deemed to have custody of client funds and securities. BillPay Services The Firm is deemed to have custody of client funds if it has the ability to withdraw funds from client accounts in conjunction with its BillPay services offering. Standing Letters of Authorization or Instruction Schwab, Fidelity and Pershing have long offered clients the ability to make periodic transfers from their accounts to third parties of their choosing. The transfer instructions, which must be directed by the client pursuant to signed documentation required by the custodian, are known as “Standing Letters of Authorization” (“SLOA”) or similar terminology. The client’s authorization of a SLOA permits Wealthspire Advisors to act on client’s behalf to transfer client funds or securities to third parties (e.g. college or mortgage payments). Although the number of accounts is disclosed to the SEC in Wealthspire Advisors’ ADV Part 1 regulatory filing, per regulatory guidelines these are exempt from Wealthspire Advisors’ annual surprise CPA examination. Annual Custody Examination As a protection for clients whose assets are under Wealthspire’s custody, Rule 206(4)-2 under the Investment Advisers Act of 1940 requires the Firm to be subject to an annual surprise examination by a qualified accounting firm. Because Wealthspire Advisors has custody of client assets, Wealthspire Advisors has engaged an outside accounting firm to perform an annual Surprise Audit of the related accounts as required by the Investment Advisers Act of 1940. The report is available upon request. Custodian Statements Clients will receive, at least quarterly, statements from the broker-dealer, bank, or other qualified custodian that holds and maintains the client’s investment assets in the Account. Wealthspire Advisors urges clients to carefully review such statements and compare such custodial records to the account statements that Wealthspire Advisors may provide to clients. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Please Note: To the extent that Wealthspire Advisors provides clients with periodic account statements or reports, and clients for whom we provide billpay services, the client is urged to compare any statement or report provided by Wealthspire Advisors with the account statements received from the account custodian. Please Also Note: The account custodian does not verify the accuracy of Wealthspire Advisors’ fee calculation. 44  Item 16 – Investment Discretion Wealthspire Advisors usually receives discretionary authority in writing from each client at the outset of an advisory relationship. This authority allows the Firm to select the securities and amount of securities to be bought or sold and when to buy and sell them without advance client approval for each trade. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, Wealthspire Advisors observes the investment policies, limitations, and restrictions of the clients whose Accounts it advises. For registered investment companies, Wealthspire Advisors' authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Clients may request, in writing, a reasonable limitation on discretionary authority (e.g. limit the types/amounts of particular securities purchased for their account), which limitation will be accommodated where practicable. Wealthspire Advisors’ discretionary authority extends to the following responsibilities:  The amount and type of securities to be purchased or sold  When transactions are made  The Separate Account Managers to be utilized or discontinued Investment guidelines and restrictions must be provided to Wealthspire Advisors in writing. In the event of an order error by Wealthspire Advisors, a client’s Account is made whole, and the Firm does not retain any gain from adjusting the error. 45  Item 17 – Voting Client Securities Wealthspire does not vote proxies for its managed account clients. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Wealthspire and/or the client instruct each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. If Wealthspire inadvertently receives proxy information for a security held in a managed account client’s account, Wealthspire will immediately forward such information to the appropriate managed account client, but will not, and will not be obligated to, take further action with respect to the voting of such proxy. Upon termination of its agreement with a managed account client, Wealthspire shall make a good faith and reasonable attempt to forward proxy information received by Wealthspire on behalf of such managed account client to the forwarding address provided by such client to Wealthspire. Wealthspire affirmatively disclaims responsibility for voting (by proxies or otherwise) on, and will not take any action with regard to, all matters (other than forwarding proxies and proxy information to managed account clients) for which shareholder action is required or solicited. Class Action Lawsuits Related to Securities Owned by Clients The client shall maintain exclusive responsibility for all legal proceedings or other type events pertaining to the assets managed by Wealthspire Advisors, including, but not limited to, class action lawsuits. Wealthspire Advisors has identified an unaffiliated service provider Chicago Clearing Corp. (“CCC”) to assist the client, for a fee (generally 15% of the recovery), with class-action matters. Wealthspire Advisors shall not receive any compensation from the service provider. Please Note: The client is under no obligation to engage the service provider. Please Also Note: Wealthspire Advisors does not participate in class action proceedings on behalf of its clients. Thus, if the client chooses not to engage CCC, the client will be exclusively responsible to monitor and pursue all class action claims. 46  Item 18 – Financial Information About Wealthspire Advisors Registered investment advisors are required to provide clients with financial information or disclosures about their financial condition under circumstances that are not applicable to Wealthspire Advisors. Wealthspire Advisors is financially sound and does not have any financial condition that would impair its ability to meet contractual or fiduciary commitments to clients. Wealthspire Advisors’ Chief Compliance Officer, Michael Del Priore, is available to address any questions that a client or prospective client may have regarding the above disclosures and arrangements. 47  Privacy Policy WHAT DOES WEALTHSPIRE ADVISORS DO WITH YOUR PERSONAL INFORMATION? FACTS Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:  Social Security number and employment information  Income and investment experience  Risk tolerance and retirement assets When you are no longer our customer, we continue to share your information as described in this notice. How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Wealthspire Advisors chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Wealthspire Advisors share? Can you limit this sharing? Yes No For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus No We don’t share For our marketing purposes— to offer our products and services to you No We don’t share For joint marketing with other financial companies Yes No For our affiliates’ everyday business purposes— information about your transactions and experiences No We don’t share For our affiliates’ everyday business purposes— information about your creditworthiness No We don’t share For our affiliates to market to you No We don’t share For non-affiliates to market to you Call 212.973.1200 or go to www.wealthspire.com. Questions? 48  Who we are Who is providing this notice? Wealthspire Advisors LLC and its subsidiary companies, separate registered investment advisers. What we do How does Wealthspire Advisors protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We restrict access to your personal information to those employees who need it to perform their job responsibilities. We collect your personal information, for example, when you How does Wealthspire Advisors collect my personal information?  establish an investment advisory relationship  contract for financial planning services  open an account or deposit money with custodians  purchase or sell securities with executing broker-dealers We also collect your personal information from others, such as custodians, broker-dealers, or other companies. Federal law gives you the right to limit only Why can’t I limit all sharing?  sharing for affiliates’ everyday business purposes— information about your credit worthiness  affiliates from using your information to market to you  sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing. Definitions Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. Non-affiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. Non-affiliates we share with can include companies such as vendors, and other service providers. Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include categories of companies such as insurance companies. Other important information Wealthspire Advisors LLC and subsidiary companies are subsidiary companies of Wealthspire, LP. 49 

WEALTHSPIRE ADVISORS LLC Wrap Fee Program Brochure 521 Fifth Avenue, 15th Floor New York, NY 10175 212.973.1200 www.wealthspire.com April 30, 2026 This Wrap Fee Program Brochure (the “Wrap Brochure”) provides information about the qualifications and business practices of Wealthspire Advisors LLC. If you have any questions about the contents of this Wrap Brochure, please contact us at 212.973.1200 or email us at compliance@wealthspire.com. The information in this Wrap Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Wealthspire Advisors LLC (“Wealthspire Advisors”, “Wealthspire”, “we”, or the “Firm”) is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Wealthspire Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov. The Firm's CRD Number is 106181.  Item 2: Material Changes This is the initial filing of Wealthspire Advisors' Wrap Brochure in connection with the merger of GM Advisory Group, LLC (“GMAG”) into Wealthspire Advisors, effective April 30, 2026. GMAG previously operated this wrap fee program under its own SEC registration and provided annual brochure updates to clients through March 30, 2026. There have been no material changes to the wrap fee program as a result of the merger. Clients should review this Wrap Brochure in its entirety as it supersedes all prior brochures delivered by GMAG in connection with this program. You may request a complete copy of our current Form ADV Part 2A Brochure (“Firm Brochure”) and/or Wrap Brochure at any time by contacting us at 212.973.1200 or compliance@wealthspire.com. Our Firm Brochure and Wrap Brochure are also available on our website at www.wealthspire.com. 3  Item 3: Table of Contents 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 .................................................................................................... 7 Item 6: Portfolio Manager Selection and Evaluation ..................................................................................................... 7 Item 7: Client Information Provided to Portfolio Managers .................................................................................... 18 Item 8: Client Contact with Portfolio Managers ........................................................................................................... 19 Item 9: Additional Information .............................................................................................................................................. 19 4  Item 4: Services, Fees and Compensation Separately Managed Account Clients We provide discretionary investment management services through a wrap fee program (“Wrap Program” or the “Program”) primarily for legacy managed account clients of certain merged entities. Clients in the Program pay a single specified annual fee, inclusive of execution, custody, performance reporting, and our investment management fees. Wealthspire also offers clients participation in a non-discretionary wrap fee program. Wealthspire has personal discussions with its clients in which their investment objectives, based on their particular financial circumstances, are determined. We create and manage a portfolio based on the client’s goals and objectives, the portfolio consists of one or more of the following: individual equities, bonds, exchange traded funds (“ETFs”), no-load or load-waived mutual funds, third-party managed equity or bond strategies, or other investment vehicles (including private investment funds including hedge and private equity funds). Each client has the opportunity to place reasonable written restrictions on investing in certain securities or types of securities. These limitations or restrictions are required to be memorialized in writing. Restrictions do not have to be reflected in a client’s investment management agreement; restrictions are reflected in various forms, including but not limited to, agreed to in writing by both parties, and by email. Wrap Fee Program Fees The Firm charges an annual “wrap-fee” for participation in the Program. Fees are agreed upon with each client in writing, which may be amended from time to time. For clients with a Wrap Program investment advisory agreement, Wealthspire charges up to a 2.00% fee on all assets in the Wrap Program account. Clients in the Wrap Program pay a single specified annual fee, inclusive of execution, custody, performance reporting, and our investment management fees. We incur the cost of executing securities transactions in your account. This creates a conflict of interest because the Firm is incentivized to initiate fewer trades in your account to minimize expenses. To manage this conflict of interest, we monitor account activity to help identify inactivity and ensure that trading levels are consistent with a client’s investment objectives and risk tolerance. We may engage the services of third-party investment managers to manage a portion of a client’s assets. These third-party managers charge their own fees, which are in addition to the fees charged by Wealthspire. Multiple fees charged on the same investments results in layering of fees, which will reduce the rate of return that the investor will derive from the underlying investment. Fee Differentials In certain circumstances, Wealthspire, in its sole discretion, charges its clients a different wrap-fee (higher or lower) or flat fee based upon certain criteria (i.e., complexity of the engagement, anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). Certain Program clients are subject to a different fee schedule that was previously established. Fee Calculation The fee is not charged on the basis of a share of capital gains, capital appreciation of the funds, or any portion of the funds of an advisory client, pursuant to Section 205(a)(1) of the Investment Advisers Act of 1940, as amended (hereinafter the “Act”). Fee Payment Clients will be charged in advance, at the beginning of each calendar quarter, based upon the value (market value or fair market value in the absence of market value, plus any credit balance or minus any debit balance), of the client's account at the end of the previous quarter. Fees are prorated for accounts opened during the quarter. An additional fee for the current quarter will be assessed if assets are deposited after the beginning of the quarter. This fee is also prorated based on the number of calendar days remaining in the quarter during which the service will be in effect. No 5  portion of the fee will be credited to the client for the current calendar quarter should any withdrawals from the portfolio occur in the same calendar quarter. Termination of Advisory Relationship A client agreement may be canceled at any time, by either party, for any reason upon receipt of prior written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Mutual Fund Fees and Exchange Traded Fees and Expenses If a client invests in mutual funds or ETFs, they generally will be charged fees and expenses by such funds that are separate and distinct from the Program fee or other Wealthspire advisory fees, as specified in the pertinent Investment Management Agreement. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. Wealthspire selects mutual funds and ETFs with varying fee structures. Pershing, Schwab and/or Fidelity may elect to offer no- transaction-fee mutual funds or ETFs, as such certain fees associated with the mutual funds or ETFs selected from the no-transaction fee offerings are waived. However, Wealthspire selects mutual funds and ETFs that have transaction fees, and that do not have transaction fees. Wealthspire’s investment team selects mutual funds and ETFs based upon investment need and selection criteria, which includes various quantitative factors, such as performance, internal expense ratio, exposure and market outlook. Clients are not restricted from investing in mutual funds or ETFs directly, without the services of Wealthspire; however, in that event clients will not receive the services provided by Wealthspire, which are designed, among other things, to assist the client in determining which mutual funds or ETFs are most appropriate to each client’s financial condition and objectives. Clients should compare the fees charged by the funds (available in each fund’s prospectus) and the fees charged by Wealthspire to fully understand the total amount of fees to be paid by the client. Separate Account Manager Fees For participants in the Firm’s Wrap Program, client assets allocated by Wealthspire to unaffiliated separate account managers shall include a separate and additional investment management fee charged by the separate account manager, in addition to Wealthspire’s investment advisory fee. Miscellaneous Fees The Program fee does not include transaction costs and other fees charged by broker-dealers other than Pershing, Fidelity and Schwab. The Program Fee also does not include certain transaction costs and other fees charged by Pershing, Fidelity, Schwab, and third-party managers including, but not limited to, mark-ups and mark-downs on fixed-income transactions. Such fees and expenses are in addition to the Program’s wrap-fee. Purchasing Services Separately Execution, reporting, and custodial services for the Program are generally provided by Pershing, Fidelity and Schwab. Additionally, Program accounts are generally maintained at Pershing, Fidelity and Schwab. Prior to engaging Wealthspire to provide investment management services under the Program, each client will be required to enter into an Investment Management Agreement with Wealthspire setting forth the terms and conditions under which Wealthspire manages each client’s assets, and a separate custodial/clearing agreement with the Program broker-dealer and custodian. Wealthspire has a potential disincentive to trade securities as a result of the transaction/execution costs that it is required to pay its broker-dealer and custodian for securities transactions. When beneficial to the client, as determined by Wealthspire in its sole discretion, individual equity and fixed income transactions may be affected through broker-dealers with whom Wealthspire has entered into arrangements for prime brokerage clearing services. Participation in the Wrap Program may cost more or less than purchasing such services separately. Depending upon the wrap fee charged by Wealthspire, the amount of portfolio activity in a client’s account, and the value of custodial and other services provided with respect to such client’s 6  account, the wrap fee charged to such client may or may not exceed the aggregate cost of the services provided to such client if such services were provided separately or if Wealthspire were to negotiate transaction fees and seek best price and execution of transactions for such client’s account. In addition, the fees charged by Wealthspire for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. There is no substantive difference between how we manage wrap fee accounts and how we manage other managed accounts. Financial Planning, Consulting, and Similar Fees From time to time, Wealthspire provides certain financial planning and consulting services to its clients on non-investment related matters. Although Wealthspire generally considers these services incidental to the services it provides under its managed account services, including the Program, Wealthspire may determine to provide these services on a fixed fee basis, separate and apart from its managed account services including the Program. In that event, Wealthspire will describe these services and fees in a separate financial planning agreement or limited consulting agreement between Wealthspire and the applicable client. These services cover financial planning for a variety of client needs, including but not limited to, cash flow planning, business planning, risk management, retirement and wealth preservation planning, tax planning and analysis, charitable giving, and bill pay. Fees will be determined on a case-by-case basis depending on the needs of the client. The agreements will also include a description of the fees to be charged and when they are to be paid. If Wealthspire agrees to provide these services, Wealthspire's obligations are expressly limited to the planning and consulting services specifically requested by the client. Item 5: Account Requirements and Types of Clients Wealthspire imposes no requirements to open or maintain an account under the Program. Program clients are not required to place a minimum amount of assets with a portfolio manager, and they are not required to maintain a minimum account size. Our clients include, but are not limited to, individuals, high net worth individuals, trusts, estates, charitable organizations, and business entities. independent investment managers and/or separately managed accounts investment objective(s). In such situations, Item 6: Portfolio Manager Selection and Evaluation Wealthspire may recommend that a portion of a client’s Program assets be allocated among in unaffiliated accordance with the client’s designated the independent manager(s) or separately managed account managers shall have day-to-day responsibility for the active discretionary management of the allocated Program assets. include the client’s designated Wealthspire shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Factors which Wealthspire shall consider in recommending independent investment manager(s) or separately managed accounts investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Wealthspire acts as the portfolio manager for the Program. The amount of compensation received by Wealthspire as a result of client participation in the Program may be more than what we would receive if the client paid separately for investment advice, brokerage, and other services. Advisory Services Offered We provide discretionary and non-discretionary investment management services through separately-managed accounts. We provide discretionary investment management services through the Program primarily for legacy managed account clients of certain merged entities. Clients in the Program pay a single specified annual fee, inclusive of execution, custody, performance reporting, and investment management fees. Wealthspire also offers clients investment advisory services on a non-wrap basis, please see our Firm Brochure for more details. 7  Wealthspire has personal discussions with its clients in which their investment objectives, based on their particular financial circumstances, are determined. We create and manage a portfolio based on the client’s goals and objectives, the portfolio consists of one or more of the following: individual equities, bonds, exchange traded funds (“ETFs”), no-load or load-waived mutual funds, third-party managed equity or bond strategies, or other investment vehicles (including private investment funds including hedge and private equity funds). Each client has the opportunity to place reasonable written restrictions on investing in certain securities or types of securities. These limitations or restrictions are required to be memorialized in writing. Restrictions do not have to be reflected in a client’s investment management agreement; restrictions are reflected in various forms, including but not limited to, as agreed to in writing by both parties, and by email. As part of an overall client asset allocation strategy, Wealthspire may recommend that clients who qualify as either “accredited investors”, as defined in Rule 501 under the United States Securities Act of 1933, as amended and/or “qualified purchasers” or “knowledgeable employees” as defined in the Investment Company Act of 1940, as amended and the rules thereunder consider allocating a portion of that client's investment assets among private investment funds. If the client determines to invest in a private investment fund recommended by Wealthspire, the Firm may be compensated based upon the value of the assets placed in private investment funds in accordance with the Program fee schedule or other managed account agreement. The Program Fee or other advisory fees paid to Wealthspire are in addition to the fees paid to the private investment fund sponsors and managers, as described in the offering documents of any of those private investment funds. The decision whether to invest in a fund rests with each client after that client has received and reviewed the fund's offering documents (including, among others, a confidential private placement memorandum that details, among other items, the terms, risks and conflicts of interest pertaining to an investment in that fund). The Firm has previously recommended that certain of its advisory clients invest in one or more Funds (“Funds”) managed or sponsored by GMAG Management, an investment adviser previously under common control with an acquired and merged firm, GM Advisory Group, LLC (“GMAG”). In addition, certain affiliates of GMAG Management sponsor and serve as general partner or managing member of such Funds and, as a result, receive compensation, depending on the Fund. Frank Marzano, a Managing Director of Wealthspire, has a controlling ownership interest in GMAG Management and its affiliates that serve as general partner of the Funds. A conflict of interest exists as Mr. Marzano has a financial incentive to recommend clients retain their positions in a Fund where GMAG Management or its affiliates can earn compensation. Nonetheless, an investment in a Fund was only recommended to clients with consideration of numerous factors in mind, including but not limited to, the client’s investment objective and financial circumstances. The Funds shall continue to be operated separate and independent of Wealthspire. The Funds will not be offered to Wealthspire clients. Clients may continue to own one or more of the Funds, but neither the purchase of a new Fund nor additional investment in a currently owned Fund will be permitted. Wealthspire does not, and shall not, monitor or supervise any of the Funds, nor will it supervise Mr. Marzano relative to his role with the Funds. Wealthspire does not, and shall not, receive compensation from any of the Funds. Financial Planning and Consulting Services From time to time, Wealthspire provides certain financial planning and consulting services to its clients on non-investment related matters. Although Wealthspire generally considers these services incidental to the services it provides under its managed account services, including the Program, Wealthspire may determine to provide these services on a fixed fee basis, separate and apart from its managed account services including the Program. In that event, Wealthspire will describe these services and fees in a separate financial planning agreement or limited consulting agreement between Wealthspire and the applicable client. These services cover financial planning for a variety of client needs, including but not limited to, cash flow planning, business planning, risk management, retirement and wealth preservation planning, tax planning and analysis, charitable giving, and bill pay. Fees will be determined on a case-by-case basis depending on the needs of the 8  client. The agreements will also include a description of the fees to be charged and when they are to be paid. If Wealthspire agrees to provide these services, the Firm's obligations are expressly limited to the planning and consulting services specifically requested by the client. We may recommend the services of other professionals. Clients are under no obligation to engage the professionals we recommend. Wealthspire does not guarantee the services of any recommended professional, and we are not liable for any action, omission, recommendation, decision, or loss as a result of a client’s use of one of these recommended professionals. Customized Services Wealthspire provides customized advisory services to its managed account clients based upon each client's unique needs, objectives, and concerns. We review client investment goals and financial circumstances with clients. Following such review, we develop an investment strategy and investment guidelines for each client. Each client has the opportunity to place reasonable written restrictions on investing in certain securities or types of securities. Unless a client has advised Wealthspire in writing to the contrary, the Firm is not subject to restrictions on the discretionary management of a particular client’s managed account assets. Wrap Fee Program As described herein, we provide discretionary investment management services through our Program primarily for legacy managed account clients of certain merged entities. The services offered under, and the corresponding terms and conditions pertaining to, the Program are discussed in this Wrap Brochure, a copy of which is presented to all prospective Program participants. There is no substantive difference between how we manage investments in a wrap fee account, and how we manage other accounts. Performance Based Fees and Side-by-Side Management Wealthspire does not receive performance-based compensation for advisory services rendered to its clients. Frank Marzano, a Managing Director of Wealthspire, may receive performance-based compensation for Funds previously recommended to such clients that are managed by GMAG Management or one of its affiliates. A conflict of interest exists as Mr. Marzano has an incentive to recommend clients retain their positions in a Fund where GMAG Management or its affiliates can earn compensation. Wealthspire has adopted policies and procedures intended to address conflicts of interest relating to the allocation of investment opportunities among clients. Wealthspire reviews investment decisions to ensure that all clients with substantially similar investment objectives are treated fairly and equitably over time. We will offer clients the right to participate in all investment opportunities that we determine are appropriate for the client in view of their investment objectives, relative amounts of capital available for new investments, their investment profile, and portfolio composition. In accordance with our allocation procedures, we will endeavor to treat each of our clients in a fair and equitable manner. For example, Wealthspire determines in its sole discretion to allocate certain investment opportunities to one or more managed accounts and not to all managed accounts. The Firm also pursues and executes trades in the same or different securities for one or more managed accounts at different times. Those trades may cause two different performance results among the various managed account clients. Wealthspire may purchase securities for one or more clients at the same time as we sell securities for other clients of the Firm. Wealthspire will attempt to service the individual needs of each of its clients. Conflicts of interest between a particular client, and other clients could exist. 9  Methods of Analysis and Investment Strategy With respect to managed account clients, Wealthspire utilizes a variety of different sources of financial information in connection with its analysis of securities. Those sources include financial publications, inspections of corporate activities, research materials and reports, corporate rating services, annual reports, prospectuses, SEC filings, and company press releases. Research services are received in various forms, including, without limitation, written reports and information obtained via electronic sources including the internet. Employees of Wealthspire also attend industry conferences. Wealthspire will review each person or firm that manages a mutual or exchange traded fund, privately placed pooled investment vehicle, or other investment strategy for which an investment is being considered. They will use one or more of the following methods of due diligence: meetings/ongoing conference calls with such persons and his or her staff; verification of references; background reviews with respect to regulatory matters, education and professional history; reviews of audited financial statements; and verification of performance claims. Investment Strategies Managed Account Clients The primary investment strategy we use for client accounts is strategic asset allocation. Asset allocation is the process for determining a long-term asset allocation that is appropriate for an investor, as well as considering how each asset class will fare in the intermediate-term in relation to its long-term expectations. This determination is made by first defining which asset classes exist and how to categorize the world of investments. Asset classes must be unique, and investable for consideration. We believe there are a number of asset classes from which suitable selections can be made for clients. It is also important to classify these asset classes more broadly into groups that investors can understand. Asset classes generally serve one of three purposes: Growth, Preservation, or Inflation Protection. By using broad categories that establish a clear goal and objective, we believe investors can better determine their proper allocation, and therefore have portfolios that better fit their risk profile. The investment strategy for a specific client is based upon their investment objective and financial circumstances stated by the client during consultations. The client may change these objectives at any time. In performing our services, we are not required to verify any information received from the client or from the client's other professionals and are expressly authorized to rely on information from the client. Moreover, each client is advised that it remains their responsibility to promptly notify the Firm if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Wealthspire's previous recommendations and/or services. Material Risks of Strategies and Securities Investing in securities involves a risk of loss that clients and investors in should be prepared to bear. Investing involves risk, including the risk of loss. There can be no assurance that the investment objective of our clients and investors will be achieved and that clients and investors will not incur losses. interest rates, Subject to the Advisers Act and the terms of the applicable investment management agreement or similar agreement, Wealthspire shall have no liability for any losses in a client’s account. The price of any security can decline for a variety of reasons outside of Wealthspire’s control, including, but not limited to, changes in the macroeconomic environment, unpredictable market regulatory sentiment, forecasted or unforeseen economic developments, changes, and domestic or foreign political, demographic, or social events. There is no guarantee that Wealthspire’s judgment or investment decisions about particular securities will necessarily produce the intended results. Wealthspire’s judgment may prove to be incorrect, and a client might not achieve his or her investment objectives. High volatility and/or the lack of deep and active liquid markets for a security may prevent the Firm from selling a client’s securities at all, or at an advantageous time or price because Wealthspire and 10  the client’s broker may have difficulty finding a buyer and may be forced to sell at a significant discount to market value. Finally, performance-based fees can increase the risk of excessive trading in client accounts. Wealthspire cannot guarantee any level of performance or that any client will avoid a loss of account assets. Any investment in securities involves the possibility of financial loss that clients should be prepared to bear. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risk items, each of which may affect the probability of adverse consequences and the magnitude of any potential losses. The following risks may not be all-inclusive but should be considered carefully by a prospective client before entering the Program. These risks should be considered as possibilities, with additional regard to their actual probability of occurring and the effect on a client if there is, in fact, an occurrence. In addition to the risks listed below, clients should review the respective offering or similar documents of each mutual fund, ETF and other security or instrument in its portfolio or recommended for purchase by us for a detailed description of risk factors associated with a particular investment or portfolio. We encourage all of our clients to meet with us on regular basis to review the assets in the account and the specific risk parameters for the account. Managed Account Risks Capital values fluctuate, especially over shorter periods of time. The possibility of capital loss does exist. However, historical data suggests that the risk of principal loss can be minimized if a long-term investment mix, chosen in accordance with your risk tolerances and objectives, is maintained over the long-term. It is uncertain as to when profits, if any, will be realized. Losses on unsuccessful investments may be realized before gains are realized on successful investments. Clients may not get a return of capital or realize any gains on their investments. If they do, those returns, or gains may not occur for a substantial period of time after investing with us. Wealthspire may utilize a range of different investment strategies depending upon the investment objectives of the client. The associated risks will vary depending upon which investment products and strategies are employed. Risks associated with Wealthspire investment strategies as applicable, include, but are not limited to the considerations outlined below. Although we generally limit our investments for clients to listed securities, mutual funds and ETFs, we are not required to diversify our strategies. We may invest in a limited number of strategies or with a limited number of mutual funds and ETFs. In addition, funds that we recommend may invest in underlying funds in the same or similar securities, further limiting the diversification of managed accounts. We may invest in strategies or markets that underperform as compared to other strategies or securities markets generally. This strategy may cause client accounts to underperform as compared to other investment vehicles that invest in different asset classes. Different types of securities (for example, large-, mid- and small-capitalization stocks or growth or value stocks) tend to go through cycles of performing better or worse than the securities markets generally. Stocks of mid-cap companies tend to be more volatile than those of large-cap companies because mid-cap companies tend to be more susceptible to adverse business or economic events than larger, more established companies. During a period when large- and mid-cap U.S. stocks fall behind other types of investments, bonds or small-cap stocks, for instance, the performance of investment strategies focused on large- and/or mid-cap stocks will lag the performance of these other investments. Historically, small-cap and international stocks have been riskier than large- and mid-cap U.S. stocks. During a period when small-cap and/or international stocks fall behind other types of investments, U.S. large- and mid-cap stocks, for instance, the performance of investment strategies focused on small-cap or international stocks may lag the performance of these other investments. In the past, these periods have lasted in excess of several years. 11  We may utilize investment techniques such as leverage, margin transactions, short sales, option transactions, and forward and futures contracts. These practices can, in certain circumstances, maximize the adverse impact to client accounts. We cannot guarantee or represent that our investment strategy will be successful, and investment results may vary substantially over time. Changes in interest rates will affect the value of fixed income investments. In general, as interest rates rise, bond prices fall, and conversely, as interest rates fall, bond prices rise. Interest rate risk is generally greater for high yield securities; however, higher-rated fixed income securities are also subject to this risk. Increased interest rate risk is also a factor when investing in fixed income securities paying no current interest (such as zero-coupon securities and principal-only securities), interest-only securities and fixed income securities paying non-cash interest in the form of other securities. The trading prices of equity securities fluctuate in response to a variety of factors. These factors include events impacting a single issuer, as well as political, market and economic developments that affect specific market segments and the stock market as a whole. The value of client accounts, like stock prices generally, will fluctuate within a wide range in response to these factors. As a result, client accounts could lose value over short or even long periods. Mutual fund and/or ETF performance may not exactly match the performance of the index or market benchmark that the mutual fund and/or ETF is designed to track because 1) the mutual fund and/or ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the mutual fund and/or ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the mutual fund and/or ETF and/or for the securities held by the mutual fund and/or ETF may cause the mutual fund and/or ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the mutual fund and/or ETF. Clients should be aware that to the extent Wealthspire invests in mutual fund and/or ETF securities, they will pay two levels of compensation - fees charged by Wealthspire, plus any management fees charged by the issuer of the mutual fund and/or ETF. This scenario may cause a higher cost (and potentially lower investment returns) than if a client purchased the mutual fund and/or ETF directly. Mutual funds and ETFs typically include embedded expenses that may reduce the fund’s net asset value, and therefore directly affect the fund’s performance and indirectly affect a client’s portfolio performance or an index benchmark comparison. Expenses of the fund may include investment adviser management fees, custodian fees, brokerage commissions, and legal and accounting fees. Mutual fund and/or ETF expenses change from time to time at the sole discretion of the mutual fund and/or ETF issuer. Mutual fund and/or ETF tracking error and expenses vary. ETF investments rely on third-party management and advisers; Wealthspire is not expected to have an active role in the day-to-day management of fund investments. Carried interest and other incentive distributions to fund management may create an incentive towards more speculative investments than would otherwise have been made. The value of assets or income from investments may be less in the future as inflation decreases the value of money. As inflation increases, the value of fixed assets can decline. This risk is greater for fixed income securities with longer maturities. The issuer or guarantor of a fixed income security may be unable or unwilling to make timely payments of interest or principal. This risk is magnified for lower-rated debt securities, such as high yield securities. High yield securities are considered predominantly speculative with respect to the ability of the issuer to make timely payments of interest or principal. In addition, funds that invest in fixed income securities issued in connection with corporate restructurings by highly leveraged issuers or in fixed income securities that are in default may be subject to greater credit risk because of those investments. 12  Changes in the financial condition of an issuer or counterparty, changes in specific economic or political conditions that affect a particular type of security or issuer, and changes in general economic or political conditions can affect a security's or instrument's value. The value of securities or instruments of smaller, less well-known issuers can be more volatile than that of larger issuers. Issuer-specific events can have a negative impact on the value of client accounts. Wealthspire cannot control, and clients are exposed to, the risk that financial intermediaries or security issuers experience adverse economic consequences that may include impaired credit ratings, default, bankruptcy or insolvency, any of which may affect portfolio values or management. This risk applies to assets on deposit with any broker utilized by a client, notwithstanding asset segregation and insurance requirements that are beneficial to clients generally. In addition, exchange trading venues or trade settlement and clearing intermediaries could experience adverse events that may temporarily or permanently limit trading or adversely affect the value of securities held by clients. Finally, any issuer of securities may experience a credit event that could impair or erase the value of the issuer’s securities held by a client. Private investment funds are speculative, not suitable for all investors, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short- selling, or other speculative practices, lack of liquidity in that there may be no secondary market for the investment and none is expected to develop, volatility of returns, restrictions on transferring interests in the investment, potential lack of diversification and resulting higher risk due to concentration of trading authority depending on the numbers of advisor(s) utilized, absence of information regarding valuations and pricing, complex tax structures and delays in tax reporting, less regulation and higher fees than mutual funds, and risks associated with operations, personnel, and processes of the manager. Private investment funds may invest in a limited number of strategies, a limited number of direct investments, and with a limited number of portfolio managers. Clients must promptly apprise us of any material changes in their financial condition, or of any other change having a material effect on their investment objectives or goals. If they fail to inform us of any change and we do not modify our strategy to account for these changes, their accounts could suffer, adverse consequences. losses Managed Account Liquidity Risks We may invest our clients' assets in a blend of liquid, publicly traded mutual funds and ETFs, which may, in turn, invest in or be comprised of a variety of securities and other instruments. Certain types of securities, such as non-investment grade debt securities, small capitalization stocks, securities issued by real estate investment trusts (“REITs”), and emerging market securities are subject to the risk that the securities may not be sold at the quoted market price within a reasonable period of if time. A managed account holding these securities may experience substantial required to liquidate these holdings. The mutual funds and ETFs in which we may invest our clients' assets may, in turn, invest in non- U.S. securities and other financial instruments denominated in non-U.S. currencies. Investments in securities of non-U.S. issuers and securities denominated in non-U.S. currencies pose currency exchange risks to the extent they are not hedged. In addition, foreign securities regulators may exercise less regulatory supervision than those in the United States, and foreign governments may afford less legal protection to the pooled investment vehicles as investors than that of the U.S. government. We may invest our clients' assets in emerging or developing markets. Investments in emerging or developing markets involve exposure to economic structures that are generally less diverse and mature, and to political systems, which have less stability than those of more developed countries. Investments in securities in developing market countries are also generally more volatile and less liquid than investments in securities in markets of developed countries. Emerging market securities may be subject to currency transfer restrictions and may experience delays and disruptions in 13  securities settlement procedures. Certain emerging markets are closed in whole or part to the direct purchase of equity securities by foreigners. In addition, funds that invest in foreign securities or securities denominated in foreign currencies may be adversely affected by changes in currency exchange rates, exchange control regulations, foreign country indebtedness and indigenous economic and political developments. In addition, foreign investing may involve less publicly available information. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. We may invest our clients' assets in high yield securities. High yield securities, also known as "junk bonds," are below investment grade quality and may be considered speculative with respect to the issuer's continuing ability to make principal and interest payments. These types of securities are more susceptible to real or perceived adverse economic and competitive industry conditions than investment grade securities. Yields on high yield securities will fluctuate. The secondary markets in which lower-rated securities are traded may be less liquid than the markets for higher-rated securities. A lack of liquidity in the secondary trading markets could adversely affect the price at which clients or the funds they own could sell a particular high yield security when necessary to meet liquidity needs or in response to a specific economic event, such as a deterioration in the creditworthiness of the issuer, and could adversely affect and cause fluctuations in the value of client accounts. Adverse publicity and investor perceptions may decrease the values and liquidity of high yield securities generally. We may invest our clients' assets in REITs, which are subject to certain risks associated with the direct ownership of real property, including declines in the value of real estate, risks related to general and local economic conditions, overbuilding and increased competition, increases in property taxes and operating expenses and variations in rental income. REITs may also be subject to the risk of fluctuations in income from underlying real estate assets, poor performance by the REITs’ managers, prepayments and defaults by borrowers, adverse changes in tax laws, and, for U.S. REITs, their failure to qualify for the special tax treatment granted to REITs. We recommend private investment funds to our clients, some of which lack liquidity, in that there may be no secondary market for the investment, and none is expected to develop. Third Party Manager Risks We may engage the services of third-party investment managers to manage a portion of a client’s assets. These third-party managers charge their own fees, which are in addition to the fees charged by Wealthspire. Multiple fees charged on the same investments results in layering of fees, which will reduce the rate of return that the investor will derive from the underlying investment. Fund Risks We advise clients on investments in private investment funds, some of which are in limited partnerships, limited liability companies, corporations or other entities. Private investment funds, generally involve various risk factors and liquidity constraints, a complete discussion of which is set forth in the private investment fund offering documents. Each prospective client will be required to complete a subscription agreement to establish qualification for investing in private investment funds and also to acknowledge understanding and acceptance of the merits and risks of the investment. The performance of a private investment fund will be dependent in part upon the integrity, skill, and judgment of its portfolio managers. We conduct the amount and depth of due diligence that we believe is adequate to recommend the appropriate portfolio managers with which to invest. However, due diligence is not a guarantee and may not reveal problems associated with a particular portfolio manager or an investment. We 14  rely upon representations made by hedge fund managers, accountants, attorneys, prime brokers and other investment professionals. If any representation is misleading, incomplete, or false, it may result in the selection of portfolio managers that might otherwise have been eliminated from consideration had complete and accurate information been made available. The management fee payable to Wealthspire based upon the value of the assets placed in private investment funds in accordance with the Program fee schedule or other managed account fee schedule will result in a layering of fees, which will reduce the rate of return that the investor will derive from the underlying investments. Funds may invest in certain types of securities, such as non-investment grade debt securities, small capitalization stocks, securities issued by REITs, and emerging market securities, which are subject to the risk that the securities may not be sold at the quoted market price within a reasonable period of time. A pooled investment vehicle holding these securities may experience substantial losses if it is required to liquidate them. A portfolio manager of a private investment fund may have an inability to exit underlying funds because of, among other things, poor performance by those underlying funds, regulatory actions or complaints against those underlying funds, or volatility in the markets in which those funds invest. Underlying funds in which a portfolio manager invests have the right to defer or suspend withdrawals in the event those situations arise, or that a suspension is otherwise considered to be in the best interest of those underlying funds. The organizational documents of the underlying funds may impose additional limitations on withdrawal. Other Risks of Loss Market Risk The price of any security or the value of an entire asset class can decline for a variety of reasons outside of Wealthspire’s control, including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, or social events. If a client has a high allocation in a particular asset class it may negatively affect overall performance to the extent that the asset class underperforms relative to other market assets. Conversely, a low allocation to a particular asset class that outperforms other asset classes in a particular period will cause that client account to underperform relative to the overall market. Large Investment Risks Clients may collectively account for a large portion of the assets in certain investments. A decision by many investors to buy or sell some or all of a particular investment where clients hold a significant portion of that investment may negatively impact the value of that investment. Cryptocurrency Risk Purchasing cryptocurrencies comes with a number of risks, including volatile market price swings or flash crashes, market manipulation, and cybersecurity risks. In addition, cryptocurrency markets and exchanges are not regulated with the same controls or customer protections available in equity, option, futures, or foreign exchange investments. There is no assurance that a person who accepts a cryptocurrency as payment today will continue to do so in the future. Investors should conduct extensive research into the legitimacy of each individual cryptocurrency, including its platform, before investing. The features, functions, characteristics, operation, use and other properties of the specific cryptocurrency may be complex, technical, or difficult to understand or evaluate. The cryptocurrency may be vulnerable to attacks on the security, integrity or operation, including attacks using computing power sufficient to overwhelm the normal operation of the cryptocurrency’s blockchain or other underlying technology. Some cryptocurrency transactions will be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that a transaction may have been initiated. 15  Any individual cryptocurrency may change or otherwise cease to operate as expected due to changes made to its underlying technology, changes made using its underlying technology, or changes resulting from an attack. These changes may include, without limitation, a "fork," a "rollback," an "airdrop," or a "bootstrap." Such changes may dilute the value of an existing cryptocurrency position and/or distribute the value of an existing cryptocurrency position to another cryptocurrency. Any cryptocurrency may be cancelled, lost or double spent, or otherwise lose all or most of their value, due to forks, rollbacks, attacks, or failures to operate as intended. The nature of cryptocurrency means that any technological difficulties by digital trading platforms may prevent the access of your cryptocurrency. Any insurance or surety bonds maintained by digital trading platforms for the benefit of its customers may not be sufficient to cover all losses incurred by customers. Cryptocurrency trading can be extremely risky. Cryptocurrency trading may not generally be appropriate, particularly with funds drawn from retirement savings, student loans, mortgages, emergency funds, or funds set aside for other purposes. Cryptocurrency trading can lead to large and immediate financial losses. The volatility and unpredictability of the price of cryptocurrency relative to fiat currency may result in significant loss over a short period of time. Transactions in cryptocurrency may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable. The nature of cryptocurrency may lead to an increased risk of fraud or cyber-attack. Under certain market conditions, it may be difficult or impossible to liquidate a position quickly at a reasonable price. This can occur, for example, when the market for a particular cryptocurrency suddenly drops, or if trading is halted due to recent news events, unusual trading activity, or changes in the underlying cryptocurrency system. The greater the volatility of a particular cryptocurrency, the greater the likelihood that problems may be encountered in executing a transaction. In addition to normal market risks, you may experience losses due to one or more of the following: system failures, hardware failures, software failures, network connectivity disruptions, and data corruption. Investments in cryptocurrency exchange-traded funds (ETFs) also involve significant risks, including high volatility, regulatory uncertainty, and cybersecurity threats. While cryptocurrency ETFs provide indirect exposure to digital assets, they remain subject to the price fluctuations of the underlying cryptocurrencies, which can be extreme. Additionally, regulatory developments may impact the availability and operation of cryptocurrency ETFs, potentially affecting their liquidity and valuation. Other risks include tracking errors, custodial risks, and the potential for increased fees compared to traditional ETFs. Investors should carefully consider these risks and their risk tolerance before investing in cryptocurrency ETFs. Digital Asset Risk Investments in Digital Assets are subject to many specialized risks and considerations, including risks relating to (i) technology, (ii) security, (iii) regulation, (iv) user/market acceptance, (v) volatility and (vi) timing. Digital Assets and their networks may not experience material technological development. There can be no assurance that all material vulnerabilities in the technology associated with a particular Digital Asset and its associated networks will be identified, and exposure to such vulnerabilities may result in direct or indirect losses due to security incidents, network or smart contract failure, or losses of market confidence in the applicable Digital Asset or network. Trading Platforms continue to be especially susceptible to service interruptions or permanent cessation of operations due to many reasons, including fraud, technical glitches, hackers, malware or governmental regulation or other intervention. In particular, a breach of the security procedures used by third-party custodians, Trading Platforms or over-the-counter (“OTC”) counterparties, if any, could result in an uninsured loss of the entirety of the investment in a Digital Asset. Any failure of technologies associated with Digital Assets or their networks could have a material adverse effect on the investment. 16  Digital Assets are not legal tender in the United States, and federal, state or foreign governments may restrict the use and exchange of Digital Assets at any time. While Digital Assets generally are not currently regulated as a currency, security, commodity interest or similar asset/instrument in the United States, they have attracted the attention of U.S. regulatory agencies, the SEC has taken the position that some Digital Assets are securities. Furthermore, Digital Assets may be structured in a way that creates an intentional or unintentional security or commodity interest. Future regulatory clarity that imposes greater regulatory burdens on some participants in the crypto ecosystem is likely. To the extent that new regulations are imposed, or regulatory authorities apply existing regulations to Digital Assets investments may be materially adversely affected. Further, the taxation of Digital Assets is uncertain in many jurisdictions, and those jurisdictions that have formulated a position have reached varying (and continuously evolving) conclusions. Digital Asset values have experienced extreme price volatility that may continue in the future. The value of Digital Assets also will be affected by the worldwide acceptance or rejection of Digital Assets and Digital Asset network technology. In particular, problems with the supply of a Digital Asset, security flaws (or perceived security flaws) with the applicable network or smart contracts deployed thereon, difficulties with converting a Digital Asset to fiat currencies or other Digital Asset and concerns that Digital Assets may disproportionately facilitate criminal activities or consume excessive amounts of electricity may negatively affect the acceptance, growth and development of Digital Assets. The value of Digital Assets may be volatile and subject to impairment, and such investments may lose their entire value. Legislative and Tax Risk Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment adviser or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities and changes in the tax code that could affect interest income, income characterization, and/or tax reporting obligations. Projections Wealthspire may rely upon projections, forecasts or estimates developed by a company in which a fund is invested concerning the company’s future performance and cash flow. Projections, forecasts and estimates are forward-looking statements and are based upon certain assumptions. Actual events are difficult to predict and beyond a Wealthspire’s control. Actual events may differ from those assumed. Some important factors which could cause actual results to differ materially from those in any forward-looking statements include changes in interest rates; loan pricing; leverage levels; loan structures; credit agreement terms; prepayment rates; timing of acquiring additional assets for a client; exchange rates or default or recovery rates or timing; mismatches between the timing of accrual and receipt of proceeds from a fund’s assets; domestic and foreign business, market, financial or legal conditions; differences in the actual allocation of a fund’s investments among asset groups from that described herein; the degree to which a fund’s investments are hedged and the effectiveness of such hedges, among others. There can be no assurance that certain of a fund’s estimated returns or projections can be realized or that actual returns or results will not be materially lower than those estimated therein. Certain Operational Risks Cybersecurity Risk The information and technology systems of Wealthspire and of key service providers to Wealthspire and its clients may be vulnerable to potential damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by their respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. Although Wealthspire has implemented various measures designed to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, it may be necessary for Wealthspire to make a significant investment to fix or replace them and to seek to remedy the effect of these issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the 17  operations of Wealthspire or its client accounts and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information. Business and Regulatory Risks of Private Investment Funds Legal, tax and regulatory changes could occur that may adversely affect clients. The regulatory environment for private investment funds and their investment advisers is evolving, and changes in the regulation of private investment funds or their investment advisers may adversely affect the value of investments held by a client and the ability of a client to obtain the leverage it might otherwise obtain or to pursue its trading strategies. In addition, the securities and futures markets are subject to comprehensive statutes, regulations and margin requirements. The SEC, other regulators and self-regulatory organizations and exchanges are authorized to take extraordinary actions in the event of market emergencies. The regulation of derivatives transactions and funds that engage in such transactions is an evolving area of law and is subject to modification by government and judicial action. In addition, regulators are increasingly considering the role of non- bank lenders. There is no guarantee that laws and regulations applicable to non-bank lenders will not change in a manner that adversely affects a client, including the ability of a client to originate loans or otherwise restrict a client’s activities in this regard, or otherwise restrict or materially increase the cost of business of pursuing all potential investment strategies and options. Voting Client Securities Wealthspire does not vote proxies for its managed account clients. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Wealthspire and/or the client instruct each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. If Wealthspire inadvertently receives proxy information for a security held in a managed account client’s account, Wealthspire will immediately forward such information to the appropriate managed account client, but will not, and will not be obligated to, take further action with respect to the voting of such proxy. Upon termination of its agreement with a managed account client, Wealthspire shall make a good faith and reasonable attempt to forward proxy information received by Wealthspire on behalf of such managed account client to the forwarding address provided by such client to Wealthspire. Wealthspire affirmatively disclaims responsibility for voting (by proxies or otherwise) on, and will not take any action with regard to, all matters (other than forwarding proxies and proxy information to managed account clients) for which shareholder action is required or solicited with respect to securities beneficially held by a client’s managed account, including, without limitation, (i) all matters relating to class actions, including without limitation, matters relating to opting in or opting out of a class and approval of class settlements and (ii) all matters relating to bankruptcies or reorganizations. Item 7: Client Information Provided to Portfolio Managers Wealthspire is the Program’s portfolio manager. We provide investment advisory services specific to needs of each client. Prior to providing investment advisory services, we discuss with each client their particular investment objective(s). Wealthspire allocates each client’s investment assets consistent with their designated investment objective(s). Clients may, at any time, impose restrictions, in writing, on Wealthspire’s services. As indicated above, each client is advised that it remains their responsibility to promptly notify Wealthspire if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services. To the extent, the Program recommends or utilizes independent manager(s), Wealthspire shall provide the independent manager(s) with each client’s particular investment objective(s). Any changes in the client’s financial situation or investment objectives reported by the client to Wealthspire shall be communicated to the independent manager(s) within a reasonable period of time. 18  Item 8: Client Contact with Portfolio Managers The client shall have, without restriction, reasonable access to the Program’s portfolio manager. Item 9: Additional Information Disciplinary Information Neither we nor any of our management personnel are subject to or have in the past been subject to any criminal or civil action in any domestic or foreign court, and neither we nor any of our management personnel have been subject to any administrative proceedings before the SEC or any other state, federal or foreign financial regulatory authority. Other Financial Industry Activities and Affiliations Frank Marzano’s Ownership of Unaffiliated Private Investment Funds Frank Marzano, a Managing Director of Wealthspire, directly or indirectly owns a majority interest in GMAG Management and various of its affiliates, which sponsor and manage the Funds. A conflict of interest exists as Frank Marzano has a financial incentive to recommend clients retain their positions in a Fund where he can earn compensation. Nonetheless, an investment in a Fund was only recommended to clients with consideration of numerous factors in mind, including but not limited to, the client’s investment objective and financial circumstances. The Funds shall continue to be operated separate and independent of Wealthspire. The Funds will not be offered to Wealthspire clients. Clients may continue to own one or more of the Funds, but neither the purchase of a new Fund nor additional investment in a currently owned Fund will be permitted. Wealthspire does not, and shall not, monitor or supervise any of the Funds, nor will it supervise Mr. Marzano relative to his role with the Funds. Wealthspire does not, and shall not, receive compensation from any of the Funds. Affiliate Companies Wealthspire Advisors’ primary business is as an investment advisor as described in its Firm Brochure and this Wrap Brochure. It is not a broker-dealer and none of its representatives are registered with a broker-dealer. The Firm and its representatives receive no commissions for the sale of any securities. A full list of Wealthspire mergers and acquisitions is available upon request. Wealthspire may have subsidiary affiliates, via acquisitions, that maintain separate client brochures until such time as the operations of Wealthspire Advisors LLC and the acquired company are sufficiently integrated to merit combined client brochures. The Firm is affiliated with other registered investment advisers, insurance agencies, and other product and service providers. Wealthspire Advisors is under no obligation to sell any products or recommend any services to our clients as a result of these affiliations. Wealthspire Advisors has entered into mutual referral arrangements with the following parent company-affiliated entities (“Affiliate”): Wealthspire Retirement Advisory (“Retirement Advisory”), Newport Private Wealth Inc., and Fiducient Advisors LLC. As a result of these referral arrangements, the referring entity will receive a portion of the advisor's services fee received for each referred client. Clients will not pay a higher fee than they would normally, and a client is under no obligation to use the services of any Affiliate or third-party advisor that Wealthspire Advisors recommends. Wealthspire has also entered into a referral agreement with Kestra Advisory Services, LLC (“Kestra”), the Broker Dealer platform through which Retirement Advisory offers securities. 19  Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Wealthspire Advisors and its employees may buy and sell the same securities that may be recommended to clients. If the possibility of a conflict of interest occurs, the client's interest will prevail. It is the policy of Wealthspire Advisors that priority will always be given to the client's orders over the orders of an employee. To avoid any potential conflicts involving personal trades, Wealthspire Advisors has adopted a Code of Ethics which sets forth the standards of conduct which every officer, partner, Advisor Representative, and employee of Wealthspire Advisors is expected to follow. Wealthspire Advisors' fiduciary duty compels all employees to act with the utmost integrity in all dealings, which is the core principle underlying its Code of Ethics and incorporated Personal Trading Policy, and represents the expected norm of all dealings with Wealthspire Advisors clients. In connection with these expectations, Wealthspire Advisors has established principles of conduct for its employees. These standards are consistent with Wealthspire Advisors' belief that ethical conduct is premised on the fundamental principles of openness, integrity, honesty, and trust. Wealthspire Advisors maintains an investment policy relative to personal securities transactions. This investment policy is part of Wealthspire Advisors’ overall Code of Ethics, which serves to establish a standard of business conduct for all of Wealthspire Advisors’ personnel that is based upon fundamental principles of openness, integrity, honesty and trust. The Firm’s policy, in accordance with Section 204A of the Investment Advisers Act of 1940, contains written policies reasonably designed to prevent the unlawful use of material non-public information by Wealthspire Advisors or any of its personnel. For example, the Firm’s Code of Ethics:  Requires certain Wealthspire Advisors’ personnel to report their personal securities holdings and obtain pre-approval of certain investments  Prohibits the misuse of material non-public information by any person associated with Wealthspire Advisors  Prohibits the recommendation, purchase or sale for client accounts any securities in which Wealthspire Advisors or any of its related persons has a material financial interest. A copy of the Firm’s Code of Ethics is available upon request. Generally, Wealthspire Advisors invests client funds in mutual funds and ETFs. Assets allocated to Separate Account Managers are invested by that manager without input from Wealthspire Advisors as to the specific securities to be purchased or sold. Wealthspire Advisors’ personnel are permitted to buy or sell securities that are also recommended to clients. Because the Firm does not generally purchase individual securities for client accounts (except for ETFs that are used as a mutual fund alternative, and when previously agreed upon), Wealthspire Advisors believes that its personnel are not in a position to potentially materially benefit from the sale or purchase of those securities, including ETFs given the underlying composition thereof (i.e., a pooled investment vehicle comprised of numerous individual securities selected at the discretion of the fund manager). Wealthspire Advisors anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which Wealthspire Advisors has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which Wealthspire Advisors, its affiliates, Advisor Representatives, and/or clients, directly or indirectly, have a position. Wealthspire Advisors employees and persons associated with Wealthspire Advisors are required to follow the Wealthspire Advisors' Code of Ethics. The Code of Ethics is designed to ensure that the personal securities transactions, activities, and interests of the employees of Wealthspire Advisors will not interfere with (i) making decisions in the best interest of advisory clients, and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions based on a determination that these would materially not interfere with the best interest of Wealthspire Advisors clients. In addition, the Code requires pre- clearance of some transactions, including investment in any limited, private, or initial public offering. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest 20  in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between Wealthspire Advisors and its clients. The Code of Ethics also includes provisions relating to maintaining the confidentiality of client information, a prohibition on trading on inside information, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Wealthspire Advisors must acknowledge reviewing the current Code of Ethics annually. Trade Error Policy Wealthspire Advisors strives to minimize the occurrence of trade errors. In the event of a trade error, it is Wealthspire Advisors’ policy to return the client to an equivalent or comparable position had the trade error not occurred. Gifts and Entertainment Policy Wealthspire Advisors maintains a Gifts and Entertainment Policy, whereby employees are generally prohibited from receiving (or giving) any gift, gratuity, hospitality, or other offering of more than de minimis value, from (to) any person or entity doing business with the Firm. This prohibition generally excludes items or events where the employee has reason to believe there is a legitimate business purpose, such as a dinner or a sporting event, of reasonable value and frequency, where a representative of the company providing the business entertainment is present. Gifts received (or given) by employees are reported regularly and are monitored by the Firm. Wealthspire Advisors values its relationships with clients and others doing business with the Firm, including Separate Account Managers Wealthspire Advisors recommends to its clients. These relationships may result in periodic gifts provided or received by Wealthspire Advisors employees in the ordinary course of business. As a practical matter, it would be difficult to establish working relationships with clients and others without periodic gifts being exchanged. While the acceptance of any gift by a Wealthspire Advisors employee may be viewed as a conflict, the Gifts and Entertainment Policy is designed to provide reasonable assurance that gifts received are not of a material nature to impact a Wealthspire Advisors employee's judgment in working with clients and others doing business with the Firm. Wealthspire Advisors clients or prospective clients may request a complete copy of the Firm's Code of Ethics by contacting Wealthspire Advisors' Compliance Department using the telephone number on the Cover Page of this Wrap Brochure. Review of Accounts and Reporting Client accounts are reviewed by Private Wealth Advisors assigned to each client account. Wealthspire monitors the investments in your account continuously, and specifically reviews your account to make sure the investments Wealthspire recommends to you are meeting your financial goals. Reviews may also be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. We advise all of our managed account clients that it is their responsibility to advise us of any changes in their investment objectives or financial situation. We ask all of our managed account clients to review financial planning issues (to the extent applicable), investment objectives, and account performance, with us on an annual basis. The broker-dealer/custodian provides managed account clients with transaction confirmation notices and regular summary account statements directly. We provide performance reports for each client’s account, at least annually. Performance reports for funds are provided in accordance with the terms set forth in each Fund’s Offering Documents. Clients are encouraged to compare account statements received from its custodian with reports received from Wealthspire. Clients are 21  also encouraged to contact Wealthspire to discuss ongoing access to account information for their accounts. Client Referrals and Other Compensation Wealthspire compensates certain third parties for client referrals to the Firm. Such referral fees are negotiated on a case-by-case basis with the individuals providing the referrals and disclosed to the referred client as required under SEC rules and regulations. Additionally, we provide compensation to Wealthspire personnel and affiliates for client referrals. Among other things, Wealthspire has compensation structures that are associated with sourcing clients, including client referral bonuses, which are based on the number of clients introduced to Wealthspire and the annualized revenue generated by such clients. In addition, as part of Wealthspire’s incentive compensation bonus plan, a pool of funds is allocated to employees on an annual basis based on the Firm’s profitability. Firm employees may also receive more compensation for recommending that clients participate in the Program as opposed to receiving advisory services outside of the Program. As a result, a conflict of interest exists as such employees have an incentive to recommend that clients participate in the Program. Financial Information Wealthspire does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to Clients and have not been the subject of a bankruptcy proceeding. 22