Overview

Assets Under Management: $197.4 billion
Headquarters: ST. LOUIS, MO
High-Net-Worth Clients: 192,216
Average Client Assets: $725,327

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (WFAFN - PART 2A - RETIREMENT PLAN CONSULTING)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.10%
$1,000,001 $5,000,000 0.80%
$5,000,001 $10,000,000 0.60%
$10,000,001 $25,000,000 0.35%
$25,000,001 and above Negotiable
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $11,000 1.10%
$5 million $43,000 0.86%
$10 million $73,000 0.73%
$50 million Negotiable Negotiable
$100 million Negotiable Negotiable

Clients

Number of High-Net-Worth Clients: 192,216
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 70.64
Average High-Net-Worth Client Assets: $725,327
Total Client Accounts: 401,726
Discretionary Accounts: 319,858
Non-Discretionary Accounts: 81,868

Regulatory Filings

CRD Number: 11025
Filing ID: 2009081
Last Filing Date: 2025-08-12 13:53:00
Website: https://wellsfargo.com

Form ADV Documents

Additional Brochure: WFAFN - PART 2A - RETIREMENT PLAN CONSULTING (2025-09-22)

View Document Text
Part 2A of Form ADV Firm Brochure for: Retirement Plan Consulting 801-57434 Investment Advisory Services of Wells Fargo Advisors Financial Network, LLC Revised September 2025 Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, separate registered broker-dealers and non-bank affiliates of Wells Fargo & Company. One North Jefferson, St. Louis, MO 63103 Phone (314) 875-3000 www.wellsfargoadvisors.com This brochure provides information about the qualifications and business practices of Wells Fargo Advisors Financial Network, LLC and our Retirement Plan Consulting Program. This information should be considered before becoming a Client. If you have any questions about these services or the contents of this brochure, please contact us at the telephone number above. This information has not been approved or verified by United States Securities and Exchange Commission or by any state securities authority. Additional Information about Wells Fargo Advisors Financial Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. Please note that registration as an investment adviser does not imply a certain level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involve risk, including the possible loss of principal. 589130 (Rev 27 - 09/25) Page 1 of 13 Summary of Material Changes Material Changes to the Firm Brochure for Retirement Plan Consulting since March 31, 2025: • The following language has been added to the document: Advisory Earnings Sharing Arrangement Certain financial advisors have entered into an earnings sharing arrangement with a private entity that creates an incentive to recommend advisory accounts and services, including recommending that you contribute additional assets to your advisory accounts. Specifically, certain Financial Advisers have agreed to contribute a portion of their advisory earnings to the private entity, in exchange for which they will receive cash consideration and equity ownership interests in the private entity or a related entity. These cash payments and equity ownership interests, for certain Financial Advisers, are subject to a hurdle, whereby if they reach a certain earnings threshold, these incentives are increased. Separately, Financial Advisors could have an incentive to recommend advisory accounts/trades over brokerage if they believe that, by doing so, they can receive additional equity ownership interests or other consideration from the private entity. The arrangements described above create a conflict of interest for the financial adviser, and in turn, the firm, as the result will be additional revenue. We mitigate this conflict of interest by enforcing and supervising policies and procedures that require recommendations regarding account types and in respect of the provision of advisory services to be made in the client's best interest. 589130 (Rev 27 - 09/25) Page 2 of 13 Table of Contents Page 2 Summary of Material Changes ............................................................................................................................. 4 Advisory Business ................................................................................................................................................ Firm Description and Ownership .......................................................................................................................... 4 Types of Advisory Services ................................................................................................................................... 4 Retirement Plan Consulting .................................................................................................................................. 4 Non-Discretionary Services .................................................................................................................................... 4 Discretionary Services ............................................................................................................................................ 5 Services Tailored to Individual Client Needs ......................................................................................................... 6 Portfolio Management Services ............................................................................................................................ 6 Assets Under Management .................................................................................................................................. 6 6 Fees and Compensation ....................................................................................................................................... Performance-Based Fees and Side-By-Side Management ................................................................................. 7 7 Types of Clients ..................................................................................................................................................... 7 Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 8 Disciplinary Information ........................................................................................................................................ 9 Other Financial Industry Activities and Affiliations ............................................................................................ Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................. 11 Brokerage Practices .............................................................................................................................................. 12 Review of Accounts ............................................................................................................................................... 12 Client Referrals and Other Compensation ........................................................................................................... 12 Custody ................................................................................................................................................................... 12 Investment Discretion ............................................................................................................................................ 13 Voting Client Securities ......................................................................................................................................... 13 Financial Information ............................................................................................................................................ 13 589130 (Rev 27 - 09/25) Page 3 of 13 Advisory Business Firm Description and Ownership Wells Fargo Advisors Financial Network, LLC ("WFAFN"), is a broker-dealer and investment advisory firm providing investment and other financial services to individual, corporate, and institutional clients through a network of independent contractor representatives. It is a non-bank affiliate of Wells Fargo & Company ("Wells Fargo"), a financial holding company and bank holding company founded in 1852 and publicly held company (NYSE: WFC). Wells Fargo and its Affiliates are engaged in a number of financial businesses, including retail brokerage and investment advisory services. WFAFN is affiliated with Wells Fargo Clearing Services, LLC (WFCS), a broker-dealer and investment adviser that also provides advisory and brokerage services as well as securities-execution and brokerage-clearance services to WFAFN, and other retail securities firms throughout the United States. WFCS operates under the trade name Wells Fargo Advisors ("WFA") in providing advisory and brokerage services. WFAFN is also affiliated with Wells Fargo Investment Institute, Inc ("WFII"), a registered investment adviser that provides advisory services and research to WFAFN and WFA. WFAFN has entered into an agreement with WFA, a non-bank affiliate of WFAFN, pursuant to which WFA will act as sub-adviser and/or service provider to WFAFN with respect to the advisory programs and services offered by the Firm. WFA is a member of the New York Stock Exchange, Inc. ("NYSE") and the principal stock exchanges in the nation, as well as FINRA and SIPC. The terms "Client," "you," and "your" are used throughout this document to refer to the person(s) or organization(s) who contract with us for the services described here. "WFAFN," "we," "our," and "us" refer to WFAFN together with our Affiliates, including but not limited to, Wells Fargo & Company and its agents with respect to any services provided by those agents. "Affiliate" means any entity that is controlled by, controls or is under common control with WFAFN. Each Affiliate is a separate legal entity, none of which is responsible for the obligations of the other. Types of Advisory Services We sponsor a number of wrap fee advisory programs ("Wrap Fee Programs") that are designed to help Clients meet their investment objectives and goals. They include Unified and Separately Managed Account Programs, Mutual Fund Advisory Programs, Financial Advisor-Directed Programs and Non-Discretionary Advisory Programs ("Programs"). We also offer Consulting and Financial Planning advisory services. This Disclosure Document is being provided pursuant to Section 204 of the Investment Advisers Act of 1940 and deals solely with our Retirement Plan Consulting Program. Descriptions of the services and fees for the other programs and services we offer can be found in separate disclosure documents, copies of which are available upon request. Retirement Plan Consulting The Retirement Plan Consulting Program is a service in which Financial Advisors ("FAs") provide consulting services to retirement plans for a fee. We offer both non-discretionary and discretionary services. For non-discretionary services, your FA cannot choose and will not take any actions without your direction. The final decisions are yours. You may choose to act upon any or all of the information provided to you. FAs are required to meet additional Firm established criteria to be eligible to offer discretionary services. For discretionary service, your FA has the authority to create and maintain the plan's investment menu on your behalf and without your approval. We are fiduciaries within the meaning of ERISA and/or the Internal Revenue Code, as applicable, when we provide "investment advice," as defined under Title 1 ERISA, to you regarding your plan. The services to the plan for which we are a fiduciary are intended to be limited to those investment-related services that constitute investment advice under Section 3(21) of ERISA. The way we make money creates some conflicts with your interests, so when we operate as a fiduciary for your plan we operate under a special rule, Prohibited Transaction Exemption 2020-02, that requires us to act in your best interest and not put out interest ahead of yours. To the extent that particular communications to you or services are considered "investment education" or otherwise nonfiduciary under ERISA, we expressly disclaim that we have any fiduciary duties or obligations in connection with such communications or Services. The Retirement Plan Consulting Program offers one or more of the following services: Non-Discretionary Services Investment Policy Statement: We will assist you in preparing an Investment Policy Statement ("IPS") that identifies the objectives, risk tolerance and constraints for the management of the investments. The development of the IPS will be based on information provided by you and is designed to outline the investment philosophy, and establish the management procedures for use by you and the investment manager(s) for the effective management of the investments. Periodically, in the future, we will review the IPS with you on an agreed upon basis. Our IPS services do not include any recommendations as to the management of the plan's investments or specific recommendations regarding specific securities or other investment vehicles, unless you specifically and separately select investment search and recommendation. You shall be responsible for review and final approval of the IPS. No assurance has been or can be given that the investment objectives reflected in your IPS will be achieved. 589130 (Rev 27 - 09/25) Page 4 of 13 Investment Search and Recommendation: Upon your request, we will provide an Investment Search Report (options may include money market, collective investment trusts, mutual funds or group annuity contracts) to you. In this report, we will provide you with investments or investment managers for consideration whose investment philosophies and policies are, in our judgment, compatible with your plan. While WFA will recommend an investment option or option(s) and investment managers, as appropriate, the decision to invest with or retain any particular manager or investment, or offer any investment to participants as an investment option rests with you. You understand that the investment options that we will consider for recommendation to the plan will be limited to the investment options on the plan's custodian's platform. With respect to our investment manager search and recommendation, we cannot guarantee that the investment manager we recommend will ultimately agree to serve as an investment manager to your plan. You also understand that we make no representations concerning any investment option or manager chosen by you without or contrary to our recommendation, nor shall we assume any liability for any loss, claim, damage or expense attributable to your selection of any manager that has not been profiled, reviewed or approved by us. If requested by you, we will also provide a diversification review designed to identify particular asset classes that we feel should be included in the plan's list of investments options made available to the participants based on the plan's IPS. This information is based on modern portfolio theory and other general diversification philosophies. Based on our review, we may recommend to you additional asset classes to complement the plan's existing investment options. Performance Reporting: On an agreed upon basis, we will provide periodic Performance Reports to assist you in evaluating your Plan's designated investment options (options may include money market, collective investment trusts, mutual funds or group annuity contracts) and the performance of the plan’s portfolio over various time periods, as well as comparing various aspects of such performance to benchmarks identified in the IPS. The investments will be analyzed based on their investment philosophies, policies, risk level, and performance as they relate to the investment and diversification objectives, policies, constraints, and risk tolerance, as specified in the investment policy statement and/or you. These reports may include a combination of: market commentary; plan asset allocation summary; risk and return analysis; investment cost analysis; investment research; and overall review for comparison to the IPS. Account data will be derived from trust or custodial statements for each period. We will not be responsible for verification of the information supplied by the custodian or trustee. While we are not responsible for and will not separately monitor the investments in your plan, we will provide you with Performance Reports on an agreed upon periodic basis so that you can monitor such investments. Service Provider Search: We will request retirement plan proposals from a group of record keeping platforms based on stated goals, objectives and demographics of the plan, and subsequently prepare a report to summarize the results. The summary report is designed to provide comparison of the features, benefits, available investment options and fees of a specific recordkeeper product that can be analyzed in comparison to the stated criteria. This search process may be performed on an as-needed basis for your fiduciary due diligence or upon request to provide you information to support your decisions on product solution decisions. Plan Benchmarking: We will provide plan benchmarking reports that identify and compare specific plan-design elements such as: plan features; investment-related information; participant behaviors, plan oversight as well as plan-related fees with other plans in similar industries, or with similar plan size and/or demographics. The benchmarking report may be comprehensive and include all elements or a summary of specific items and fees. These reports will be prepared on an as-needed basis or as part of the overall annual review. Employee Education: We will provide investment education to and for the benefit of employees of your company. The parties agree that the education services are not intended to include personal investment advice and are limited to providing Investment Education or general information as described in Department of Labor ("DOL") Interpretive Bulletin 96-1, 29 C.F.R. Section 2510.3-21 or any successor DOL regulations describing the scope of non-fiduciary participant education. Plan Fiduciary Meeting Support: We will attend plan fiduciary meetings to deliver various non-discretionary services. We will provide general summary reports and statistical updates to the plan committee(s) or other fiduciaries. These may include: participation and demographic reports; a review of goals and results of the education policy statement; updates on participant meetings, regulatory updates and market updates. Unless you specifically and separately select investment services, our plan meeting support will not include investment search and recommendation. Discretionary Services Plan Level Investment Selection 3(38): When we perform discretionary plan level Investment Search and Selection and/or Performance Reporting services hereunder, we are an "investment manager" as such terms are defined in Section 3(38) of the Employee Retirement Income Security Act of 1974 ("Investment Manager"), as amended and the regulations promulgated thereunder ("ERISA") and acknowledge our fiduciary status as such. Investment Search and Selection: We will review the investment options available to you and provide you with advice regarding Designated Investment Alternatives (“DIAs”) based on your Investment Policy Statement. Plans with existing assets will be mapped and moved into the DIAs, which will include both the asset movement of current balances and the future investment elections of each participant in the plan. Once our initial investment advice has been implemented, we will monitor the DIAs and will instruct your recordkeeper directly to remove and replace investments that no longer meet the IPS criteria. We will communicate any changes to you reasonably in advance of a proposed change. You understand that the investment options that we will consider for selection for the plan will be limited to the investment options on the plan's custodian's platform. You understand and agree that declining our investment advice or investment decisions may cause the termination of our services to you. DIAs may include money market mutual funds, collective investment trusts, mutual funds or group annuity contracts. We will not be responsible for selection or monitoring, and will not make any advice or make decisions to retain or remove, employer stock, guaranteed 589130 (Rev 27 - 09/25) Page 5 of 13 investment contracts, participant loans, or investment options beyond the DIAs (i.e., investments in self-directed brokerage windows, managed accounts, and other investments that we may restrict from time to time). You also agree that we will not determine for you or recommend to you a Qualified Default Investment Alternative as defined under ERISA. Although we will not have discretion over the following, if mutually agreed upon, we may provide investment advice recommendations on the following: stable value funds, and guaranteed investment contracts. Performance Reporting: On an agreed upon basis, but no less frequently than annually, we will provide periodic Performance Reports to assist you in evaluating your plan’s DIAs and the performance of the plan’s portfolio over various time periods, as well as comparing various aspects of such performance to benchmarks identified in the IPS. The investments will be analyzed based on their investment philosophies, policies, risk level, and performance as they relate to the investment and diversification objectives, policies, constraints, and risk tolerance, as specified in the investment policy statement and/or you. These Performance Reports may include a combination of: market commentary; plan asset allocation summary; risk and return analysis; investment cost analysis; investment research; and overall review for comparison to the IPS. Account data will be derived from trust or custodial statements for each period. We will not be responsible for verification of the information supplied by the custodian or trustee. Additional Plan Services: In addition to investment-related Services, periodically in the future and as mutually agreed upon, we will provide additional non-discretionary services, as defined above. Services Tailored to Individual Client Needs Each of the advisory services we offer is tailored to you and designed to meet the plan's investment objectives, financial needs and tolerance of risk. They are drawn from research and analysis we believe to be reliable and appropriate to your financial circumstances. Portfolio Management Services We act as portfolio manager for certain Wrap Fee Programs that we offer to Clients and collect a fee for performing that service. We do not act as a portfolio manager for any Retirement Plan Consulting Program services. Assets Under Management As of December 31, 2024, we manage $148,645,897,854 of Client assets on a discretionary basis and $48,714,298,766 of Client assets on a non-discretionary basis. Fees and Compensation Fees for services are described below and are guidelines which may vary due to the complexity and size of the plan, and are therefore subject to negotiation. You can choose to pay for services either as a flat annual fee, a percentage of assets, or, for some services, as a one-time service. Generally, ongoing fees are paid on a quarterly basis unless otherwise agreed upon. Plan Size AUM Ongoing % (bps) Min Fee Ongoing % (bps) Max Fee Ongoing Dollar Min $ Fee Ongoing Dollar Max $ Fee $0 -$1M 0.1 1 $500 $10,000 $1M - $5M 0.1 0.7 $1,000 $30,000 $5M - $10M 0.1 0.5 $3,500 $40,000 $10M - $25M 0.01 0.25 $5,000 $100,000 The fee for the Plan Level Investment Selection 3(38) service is as follows: Plan Level Investment Selection 3(38) Fee Range 5 to 10 bps per year in addition to the fee range shown in the chart above. Costs for travel, incidental expenses and materials incurred during the provision of Employee Education services will be charged separately. We reserve the right to negotiate fee rates published above on a case-by-case basis. Frequency and Method of Payment Fees for one-time services are payable immediately after services are provided. Fees for ongoing services are assessed quarterly in arrears. Clients may choose to pay fees by invoice to the plan or plan sponsor, or to instruct us to send the invoice to the plan's provider/recordkeeper. Termination In the event the Client Agreement is terminated, you shall have no obligation to make additional payments that would otherwise be required to be made, but we may submit to you an accounting of the services theretofore provide to you (which may include an accounting of our preparations to provide services that would have been provided by us but for such termination) and you shall be liable to us for the amount set forth thereon (which amount will not exceed the total amount of our compensation as agreed to by you and us in the Client Agreement( (the "Termination Obligation"). In the event you have paid any payments prior to such termination: if the amount of such payments exceeds the Termination Obligation, you shall be entitled to a refund of such excess, 589130 (Rev 27 - 09/25) Page 6 of 13 and we shall be entitled to retain the remainder in full satisfaction of the Termination Obligation; and if the Termination Obligation exceeds the amount of such payments, and you shall promptly pay the amount of such excess in order to satisfy the Termination Obligation. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees in any of our investment advisory programs. We do not have any side-by-side management situations. Types of Clients We offer the Retirement Plan Consulting Program to both qualified plans subject to ERISA and non-qualified deferred compensation plans not subject to ERISA. Methods of Analysis, Investment Strategies and Risk of Loss Under our Retirement Plan Consulting Program, we render services to both retirement plans subject to ERISA and retirement plans not subject to ERISA. Our specific recommendations may vary based on the scope of the services for which we are engaged to advise upon. At all times, our investment philosophy will reflect our duty to act with respect to the plan solely in the interests of participants and beneficiaries as well as within the principles of prudence and diversification of plan assets. For plans subject to ERISA, we will carry out our duties and responsibilities in accordance with ERISA as it applies to the services we are rendering. To the extent not contrary to ERISA, we will take into consideration the goals and objectives as provided and/or communicated by the plan. If in our view, any investment instruction, guideline or requirement received from a plan fiduciary is inconsistent with or contrary to ERISA, we will disregard such provision or instruction when carrying out our duties and will act in accordance with our responsibilities under ERISA and the regulations promulgated thereunder. For the purposes of our non-discretionary service of providing Investment Search and Recommendation services to plans subject to ERISA, if the plan does not provide written investment instructions or objectives such as an IPS, we will focus on identifying a menu of diversified investment options, each with differing risk and return characteristics appropriate for a plan participant or beneficiary. The investment options we recommend could include active and passive investment vehicles, as well as target-date investment options. When we are engaged to provide discretionary services to plans subject to ERISA, we will use the IPS and the investment philosophy outlined therein in providing investment advice. If the plan is not subject to ERISA and we are hired to provide Investment Search and Recommendation—we will recommend a menu of investment options for the plan that provides plan participants a diversified set of investment options—ranging from conservative to aggressive growth investment choices. We could include active and passive investment vehicles in our recommendations, as well as target-date investment options. When we are hired to provide Investment Search and Recommendation Service for plans not subject to ERISA, we seek to identify and recommend one (or more when appropriate) investment managers to manage a plan’s assets—either in their entirety or a portion thereof. In doing so, we will recommend investment manager(s) that we believe are capable of adding value on a risk-adjusted basis. When reviewing potential investment managers, we take into consideration the overall stated objectives of the assets which will vary based on: plan type; and whether the investment manager’s mandate will be limited to a specific asset class or investment category within a broader pool of assets. We do not provide investment advice in a discretionary manner to plans not subject to ERISA. Methods of Analysis In performing the investment advisory services, our analyses and recommendations are based on modern portfolio theory and other general diversification philosophies. WFAFN makes available to its financial advisers: reports and analyses on investment products and asset managers from WFAFN’s affiliate investment adviser Wells Fargo Investment Institute, Inc. (Wells Fargo Investment Institute, Inc. is an investment adviser registered with the Securities and Exchange Commission. It is a subsidiary of Wells Fargo Bank, N.A. Registration as an investment adviser does not imply a certain level of skill or training. Wells Fargo Investment Institute, Inc. and Wells Fargo Bank, N.A. are subject to the control of Wells Fargo & Company (NYSE: WFC), a financial holding company.); and third-party databases, analytics tools and presentation tools. These resources are used individually or in combination in both initial investment product and investment manager selection. They are also used in the periodic review or, in the case of our 3(38) services, the monitoring of recommended investment products and investment managers. When evaluating and recommending investment options or investment managers to manage the plan’s assets, WFAFN generally considers the following (List includes common relevant considerations but is not intended to be exhaustive; nor will all be necessarily relevant to a particular plan’s needs.): • General principles of diversification of assets and modern portfolio theory • Legal and regulatory considerations • Plan imposed restrictions • Time horizons • Need for current income • Investment objectives • Management fees • Shareholder fees • Asset class • Performance 589130 (Rev 27 - 09/25) Page 7 of 13 Investing carries risk of loss. Separately managed accounts managed by investment managers, mutual funds and exchange-traded funds, and individual securities are all subject to risk of loss. With respect to an investment manager that we may recommend to a plan, each manager will have investor materials addressing the risks associated with the particular manager’s strategies. Investment Strategies When we provide Plan Level Investment Selection services, we do not provide personalized investment advice to plan participants. When we provide Investment Manager Search and Recommendation Services, information regarding the investment strategies (generally investment risks, investment methods of analysis, and types of securities used) offered by the investment manager that we recommend to the plan will be contained in each manager’s Form ADV Part 2A, or similar document, other informational materials of the manager. Risk of Loss All investments shall be at your risk exclusively, and you must understand that we do not guarantee any return on the investments recommended or advised upon and may not be responsible for losses resulting from such trading or for any transactions that we have not recommended to you. Disciplinary Information We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of the broker-dealer, investment adviser or predecessor firms. For more information on broker/dealer related disciplinary events you may visit: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/. Our investment advisory disciplinary history is available by going to: http://www.adviserinfo.sec.gov/. In January 2025, WFCS and WFAFN agreed to a settlement with the SEC regarding allegations that they failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to their cash sweep program, specifically, their use of a bank deposit sweep program. The order found that WFCS and WFAFN did not adopt and implement reasonably designed policies and procedures that considered the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; or addressed the duties of WFCS and WFAFN financial advisors in managing client cash in advisory accounts, in willful violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. WFCS and WFAFN, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28 million by WFCS and $7 million by WFAFN. In August 2023, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC (collectively, the "Firm") agreed to a settlement with the SEC regarding allegations that from at least 2002 through December 2022, the Firm and its predecessor firms overcharged approximately 10,945 accounts of advisory clients, for accounts opened through 2014, for more than $26.8 million in advisory fees and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the over billing in willful violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells Fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells Fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the Firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected account holders. Without admitting or denying the findings, the Firm consented to a settlement that included a cease and desist order, censure and civil money penalty of $35,000,000. In December 2021, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti-money laundering Customer Identification Program (CIP) in the required non-erasable and non-writable “Write Once, Read Many” (WORM) format in violation of Exchange Act Rule 17A-4(F)(2)(II) (A) and failed to notify FINRA prior to using the non-WORM compliant storage platform in violation of Exchange Act rules 17A-4(F) (3)(V) and 17A-4(F)(2)(I). Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine, jointly and severally, of $2,250,000. On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, following the Firms' offers of settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds ("ETFs") without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The Commission found that the Firms willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 203(e)(6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained in the Order, to: cease and desist from committing or causing 589130 (Rev 27 - 09/25) Page 8 of 13 any violations and any future violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; be censured; and jointly and severally pay a civil monetary penalty in the amount of $35,000,000. In 2018, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC elected to participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative ("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling $17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms self-reported. On December 21, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also found that the Firms failed to implement an audit system for those records, failed to provide its third party vendors full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce written procedures. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,500,000. The Firms also consented to a review of its policies and procedures. On December 5, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through available applications. The findings stated that these applications allowed the Firms' representatives to manually enter information regarding customers' external accounts, assets and liabilities into a centralized table which the Firms maintained. This information would then be used to populate reports, including those that would be sent to the Firms' customers. FINRA found that the Firms did not have systems in place to review the contents of the reports, including information about customer holdings away from the Firms. In addition, the Firms' supervisory systems and procedures were inadequate because there was no mechanism allowing representatives to designate which reports were actually provided to customers and the system could not distinguish between draft reports and completed reports that were sent to customers, which should have been subject to the Firms' supervisory systems designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,000,000. Other Financial Industry Activities and Affiliations WFAFN is a national securities firm providing investment and other financial services to individual, corporate and institutional Clients. We are a registered broker-dealer and investment adviser. Accounts are carried by WFCS, a qualified custodian. WFCS is an affiliate owned indirectly by Wells Fargo. WFAFN and WFCS are members of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). WFCS may also route transactions through its affiliate, Wells Fargo Securities, LLC. Unless otherwise stated as the case, the investment advisory services offered and the underlying stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not insured or otherwise protected by the Federal Deposit Insurance Corporation ("FDIC") or another government agency. They are not obligations of any bank or any affiliate of us; are not endorsed or guaranteed by Wells Fargo, WFAFN, or any bank or any affiliate of us; and involve investment risk including possible loss of principal. Cash balances in Client Accounts may be held in a depository product sponsored by Wells Fargo Bank, N.A. Wells Fargo Advisors Financial Network, LLC is not an FDIC- insured depository institution; FDIC deposit insurance only protects against the failure of an insured depository institution. Banking products and services provided by Wells Fargo Bank, N.A. Member FDIC. Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible for securities we sell or purchase. As a general matter, unless otherwise stated, we may be a principal or engaged in underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to issuers whose securities may be sold to you. From time to time, a bank or thrift affiliated with us may lend money to an issuer of securities underwritten or privately placed by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will disclose to the extent required by applicable securities laws: the existence of any material lending relationship by any affiliate of ours with such an issuer; and whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding indebtedness to any of our affiliates. 589130 (Rev 27 - 09/25) Page 9 of 13 We have a number of related persons who may provide investment management and related financial services to our Clients. The advisory services these investment advisers offer are described more fully in their Disclosure Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services follows. • Wells Fargo also provides retail brokerage and investment advisory services through Wells Fargo Advisors ("WFA"). • Wells Fargo Investment Institute, Inc. ("WFII") (known prior to November 1, 2014 as Alternative Strategies Group, Inc. and before that as Wachovia Alternatives Strategies, Inc.) is a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA and WFAFN. We and our affiliates may give advice and take action in the performance of our duties to you that differs from advice given, or the timing and nature of action taken, with respect to other advisory Clients and/or Clients in other advisory programs. Additionally, we and our affiliates, from time to time, may not be free to divulge or act upon certain information in our possession on behalf of investment banking or other Clients. We will not sell your information to other companies for marketing purposes. We employ strict security standards and safeguards to protect your personal information and prevent fraud. In addition, we will continue to protect your privacy even if you are no longer our Client. Consistent with our privacy policies and applicable law, WFAFN and its affiliates may provide access to Client personal information to affiliated and third party service providers throughout the world. When Client information is accessed, we maintain protective measures as described in our privacy policies and notices. For more information, please see our Privacy Statement. For more information, please read our Privacy Statement, visit a WFAFN office or call your Financial Advisor. With your written permission, obtained via Client Agreement or other written communication, we may provide your information electronically to your investment adviser and/or agent of such adviser. We reserve the right, at our discretion, to refuse to provide such requested information. Furthermore, in compliance with our Privacy Policy, we accept your instructions to discontinue providing such information. Material Relationships with Allspring Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners renamed the business Allspring Global Investments. The Wells Fargo Asset Management business was wholly owned by Wells Fargo prior to the transaction and included the following companies: Wells Capital Management Incorporated; Wells Fargo Funds Management, LLC; Wells Fargo Asset Management (International), LLC; Wells Fargo Funds Distributor, LLC; and, Galliard Capital Management, Inc. These companies, which are no longer related persons of WFAFN, served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the companies managed separately managed account strategies offered through WFAFN. Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings, LLC. This group of companies includes Allspring Funds Management, investment adviser to mutual funds within the Allspring family of funds, Allspring Funds Distributor, LLC, the principal underwriter of Allspring mutual funds, and Allspring Global Investments, LLC, a model portfolio strategy provider and an investment adviser to pooled investment vehicles and separately managed accounts. Wells Fargo has no role in the management of Allspring. However, Wells Fargo retains less than a 10% equity ownership interest in Allspring and has continued to provide certain non-advisory transition services to Allspring for a fee since the close of the sale. WFCS also receives compensation from Allspring for the distribution, administrative and operational services that we provide to the Allspring mutual funds. Although Allspring is not a related person of WFAFN, WFAFN and its related persons continue to benefit from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a similar financial interest. Wells Fargo’s equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services to Allspring for a fee provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account or model portfolio strategies. WFII charges Allspring research access fees for investment research services that WFII provides to Allspring. Allspring manages the Managed DSIP, Managed DSIP II, ESG Managed DSIP, Current Equity Income, and Income Multi Asset Portfolio strategies offered through WFA’s Personalized Unified Managed Account advisory program (collectively, the “Equity Income Strategies”) utilizing information derived, in part, from certain of the research services. The research access fees are calculated based on the assets invested in the strategies, meaning that WFII earns more money when more assets are invested in the strategies. The research access fees are assessed at rates that result in WFII receiving fees that are equivalent to substantially all of the Manager fees assessed in conjunction with the Income Multi Asset Portfolio, the Current Equity Income Strategy, and the Managed DSIP strategy, and approximately half or greater of the Manager fees assessed for the Managed DSIP II strategy and the ESG Managed DSIP strategy. The fee paid to WFII is for research services WFII provides to Allspring, including: investment research that WFII provides to Allspring; and access to certain WFII research analyst teams, strategists, and associates to discuss the research and/ or obtain additional research commentary on covered names, insights into sectors, etc. (collectively “Research Services”). While WFII does not provide the Research Services to other third-party Managers for utilization in managing strategies, WFII does provide the Research Services to its affiliates, WFCS and WFAFN, who in turn, may utilize the Research Services to manage strategies and who provide the investment research at no cost to WFCS and WFAFN advisory clients, WFCS and WFAFN brokerage customers, and prospective clients and customers for their individual use. As such, investors in the Equity Income 589130 (Rev 27 - 09/25) Page 10 of 13 Strategies are indirectly paying for investment research that others receive at no cost, and that those same investors could receive from WFCS or WFAFN for their individual use outside of the Equity Income Strategies at no cost under other circumstances. Similar investment research may be available in the marketplace at no cost or for materially lower fees than are being charged to Allspring in conjunction with the Equity Income Strategies. WFII’s receipt of a research access fee in conjunction with the Equity Income Strategies creates a material conflict of interest since it results in WFII, an affiliate of WFAFN, earning more revenue when investors follow a WFAFN recommendation to invest in the Equity Income Strategies than WFAFN, WFII or their affiliates would earn if investors followed a recommendation from WFAFN to invest in any of the other Model Manager strategies available through the Personalized UMA Program as WFAFN and its affiliates earn no comparable additional revenue for investments in other Model Manager strategies. WFAFN seeks to mitigate this conflict and its associated implications through disclosure, management of the financial incentive for financial advisors to recommend the Equity Income Strategies, and evaluation of the total costs of investing in the Equity Income Strategies relative to other Model Manager strategies. You should carefully consider the research access fee that is retained by WFII and our related conflict of interest when evaluating whether to invest in the Equity Income Strategies. The Equity Income Strategies are available through Wells Fargo Bank, N.A., including through Wealth & Investment Management Trust Services, and no research access fee is applied to assets invested in the Equity Income Strategies when the assets are custodied at Wells Fargo Bank, N.A. The research access fee is also not applied to assets invested in ERISA accounts. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our Associates are subject to a Code of Ethics that is designed to ensure our business activities are performed with the highest possible standards of ethics and business conduct, and to comply with all applicable laws, rules, and regulations that govern our businesses. Key requirements of our Code of Ethics are summarized below, and you may obtain a complete copy through your Financial Advisor. • Conduct all aspects of Wells Fargo's business activities in an honest, ethical, and legal manner, and in accordance with all applicable laws, rules, and regulations and our policies and procedures. • Provide accurate and complete information in dealings with Clients and others, including disclosure of conflicts of interest when they exist. • Prepare and maintain accurate business records. • Refrain from improper disclosure or misuse of confidential Client information and material, non-public information. Wells Fargo protects the private, personal, and proprietary information of Clients and others. • Avoid conflicts of interest in personal and business activities. • Rules specific to personal trading. Participation or Interest in Client Transactions Under the Wrap Fee Programs, we are generally appointed as sole and exclusive broker by you with respect to the referenced Account for the execution of transactions. Our Wrap Fee Program fee covers transaction costs when transactions are executed through us. On occasion, you may designate, or the law may require, the use of other brokers. Investment advisers may also elect to execute transactions with other firms as they deem appropriate, taking into account a number of factors such as best execution, research services and other qualitative factors. When transactions are executed with other firms, including transactions executed through our affiliates, there are additional trading costs in executing the transaction that are embedded into the price of the security. Any imbedded execution costs on trades done away from us are in addition to our Program Fee. In connection with these transactions, we act as agent or, where permitted by law, principal (including instances wherein we are acting as underwriter or selling group members). You authorize that we effect and execute brokerage transactions, including on a national exchange, as permitted by current provisions of Section 11(a) of the Securities Exchange Act of 1934, as amended (the "Exchange Act") and rules promulgated thereunder including any future amendments or changes to such statutes and rules. With respect to cash sweep vehicles investments, you receive disclosures about our affiliates and the advisory and other fees paid to affiliates by such cash sweep vehicles. These disclosures are contained in the prospectuses for the money market funds in which you invest and in our Disclosure Documents, and Client Agreements, as applicable. We or our affiliates maintain investment banking or other relationships with certain publicly traded companies. These relationships may from time to time require us to restrict trading in the securities of these companies. As a result of these investment banking or other activities, our affiliates acquire confidential or material non-public information that prevents us or our affiliates, for a period of time, from purchasing, selling or recommending particular securities for your account. We and our affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. Additionally, we may be restricted or limited in our ability to purchase or sell particular securities or make investment recommendations as a result of these affiliated activities. We have certain restrictions, internal procedures and Client disclosures regarding conflicts of interest that we may have with respect to our participation or interest in Client transactions. We communicate our policies and procedures related to participation in Client transactions to our Associates through our compliance policies and procedure manuals and program-specific policy guidelines. 589130 (Rev 27 - 09/25) Page 11 of 13 Personal Trading We maintain policies and procedures to mitigate conflicts of interest between transactions in our Associates' personal investment accounts, including accounts of their immediate family members and transactions in our Clients' accounts. To ensure Associate trading requirements are observed, certain Associate trading activity is subject to pre-approval. All Associates are subject to regular review by their supervisors, independent oversight by our Compliance Department, and systemic controls that automatically restrict entry of certain orders and generate related surveillance reporting. Brokerage Practices We do not provide any brokerage services as part of our Retirement Plan Consulting Program. Assets are all held away from us with a third-party custodian. Review of Accounts The FA provides the services agreed to in the contract. Client Referrals and Other Compensation From time to time, we initiate incentive programs for our Associates, including FAs. Incentive programs compensate our Associates and FAs for attracting new assets and Clients, referring business to our affiliates (such as referrals for banking services and accounts, mortgages, lending, trusts, or insurance services) or other FAs, promoting investment advisory services and promoting green initiatives (such as raising Client awareness of paperless options). We may also initiate programs that reward Financial Advisors who meet total production criteria, length of service requirements, participate in advanced training and improve Client service. Financial Advisors who participate in these incentive programs may be rewarded with cash and/or non-cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. Portions of these programs may be subsidized by external vendors and/or our affiliates, such as mutual fund companies, insurance carriers, or investment advisers. Therefore, Financial Advisors and other Associates have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services we offer. We may also enter into arrangements with other persons to whom we pay compensation for referrals to our advisory Programs. This compensation is generally in the form of a percentage of the fees described in the Program contracts. The details of such arrangements and the amount of compensation will be described in a separate disclosure provided at the time of such referrals. From time to time, we compensate Associates other than Financial Advisors for referrals of possible Clients to the Programs. Our Financial Advisors, not the referring Associate, will make the actual presentation and solicitation of these services. The referral compensation takes the form of a payment to the Associate of a percentage of the fees described in the Programs contracts and results in no additional fees to you or other Clients. Wells Fargo & Company is a full-service financial services firm with many affiliates. Wells Fargo & Company encourages its subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual business planning, business with our affiliates is included in establishing our sales goals. As a result, we may have an incentive to hire affiliate service providers for our advisory programs. We may recommend affiliated mutual funds to our Clients, and may hire other affiliates to provide trade execution, clearing, and platform administration services for our programs. We intend, however, to make all recommendations independent of any such goals and based solely on our obligations to consider your objectives and needs. Advisory Earnings Sharing Arrangement Certain financial advisors have entered into an earnings sharing arrangement with a private entity that creates an incentive to recommend advisory accounts and services, including recommending that you contribute additional assets to your advisory accounts. Specifically, certain Financial Advisers have agreed to contribute a portion of their advisory earnings to the private entity, in exchange for which they will receive cash consideration and equity ownership interests in the private entity or a related entity. These cash payments and equity ownership interests, for certain Financial Advisers, are subject to a hurdle, whereby if they reach a certain earnings threshold, these incentives are increased. Separately, Financial Advisors could have an incentive to recommend advisory accounts/trades over brokerage if they believe that, by doing so, they can receive additional equity ownership interests or other consideration from the private entity. The arrangements described above create a conflict of interest for the financial adviser, and in turn, the firm, as the result will be additional revenue. We mitigate this conflict of interest by enforcing and supervising policies and procedures that require recommendations regarding account types and in respect of the provision of advisory services to be made in the client's best interest. Custody In the Retirement Plan Consulting Program, we do not have custody of your funds or securities. Once the vendor is chosen for the retirement plan, you will receive quarterly, or more frequent, account statements directly from the vendor and/or the custodian, which may or may not include WFAFN or an affiliate. You should carefully review these statements for accuracy. 589130 (Rev 27 - 09/25) Page 12 of 13 Investment Discretion Except when providing the Plan Level Investment Selection 3(38) service, we do not have investment discretion when providing services to Retirement Plan Consulting Program Clients. Voting Client Securities We do not accept authority to vote Client securities subject to our Retirement Plan Consulting Program services. Financial Information We have no financial condition that is likely to impair our ability to meet our contractual commitments to you. 589130 (Rev 27 - 09/25) Page 13 of 13

Additional Brochure: WFAFN - WRAP FEE BROCHURE ADVISORY PROGRAMS (2025-09-22)

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Wells Fargo Advisors Financial Network Wrap Fee Brochure for Advisory Program Services 801-57434 Investment Advisory Services of Wells Fargo Advisors Financial Network, LLC Revised September 2025 One North Jefferson, St. Louis, MO 63103 Phone (314) 875-3000 www.wellsfargoadvisors.com This wrap fee brochure provides information about the qualifications and business practices of Wells Fargo Advisors Financial Network, LLC, and FundSource®, CustomChoice, Private Investment Management, Fundamental Choice, Asset Advisor, Personalized Unified Managed Account, Private Advisor Network and Customized Portfolios (the “Programs”). This information should be considered before becoming a Client of one of these Programs. If you have any questions about the Programs or the contents of this brochure, please contact us at the telephone number above. This information has not been approved or verified by United States Securities and Exchange Commission or by any state securities authority. Additional Information about Wells Fargo Advisors Financial Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. Please note that registration as an investment adviser does not imply a certain level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involve risk, including the possible loss of principal. Investment and Insurance Products are: • Not Insured by the FDIC or Any Federal Government Agency • Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate • Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, Members SIPC, separate registered broker-dealers and non-bank affiliates of Wells Fargo & Company. 556430 (Rev 70 - 09/25) Page 1 of 13 Summary of Material Changes Please refer to the Wells Fargo Advisors Wrap Fee Brochures for details on any material changes to the Programs offered. Material Changes to the Wrap Fee Brochure for Advisory Program Services since March 31, 2025: • The following language has been added to the document: Advisory Earnings Sharing Arrangement Certain financial advisors have entered into an earnings sharing arrangement with a private entity that creates an incentive to recommend advisory accounts and services, including recommending that you contribute additional assets to your advisory accounts. Specifically, certain Financial Advisers have agreed to contribute a portion of their advisory earnings to the private entity, in exchange for which they will receive cash consideration and equity ownership interests in the private entity or a related entity. These cash payments and equity ownership interests, for certain Financial Advisers, are subject to a hurdle, whereby if they reach a certain earnings threshold, these incentives are increased. Separately, Financial Advisors could have an incentive to recommend advisory accounts/trades over brokerage if they believe that, by doing so, they can receive additional equity ownership interests or other consideration from the private entity. The arrangements described above create a conflict of interest for the financial adviser, and in turn, the firm, as the result will be additional revenue. We mitigate this conflict of interest by enforcing and supervising policies and procedures that require recommendations regarding account types and in respect of the provision of advisory services to be made in the client’s best interest. 556430 (Rev 70 - 09/25) Page 2 of 13 Table of Contents Page Summary of Material Changes ......................................................................................................................... 2 Services, Fees and Compensation ................................................................................................................... 4 Advisory Programs ......................................................................................................................................... 4 Fees and Compensation ................................................................................................................................. 5 Account Termination ....................................................................................................................................... 7 Account Requirements and Types of Clients ................................................................................................... 7 Types of Clients .............................................................................................................................................. 8 Portfolio Manager Selection and Evaluation .................................................................................................... 8 Services Tailored to Individual Client Needs ..................................................................................................... 8 Client Restrictions and Instructions ................................................................................................................. 9 Performance-Based Fees and Side-By-Side Management ............................................................................... 9 Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................... 9 Proxy and Reorganizations ............................................................................................................................. 9 Client Information Provided to Portfolio Managers ......................................................................................... 9 Client Contact with Portfolio Managers ........................................................................................................... 9 Additional Information ..................................................................................................................................... 9 Disciplinary Information .................................................................................................................................. 9 Other Financial Industry Activities and Affiliations ............................................................................................. 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................... 12 Review of Accounts........................................................................................................................................ 13 Prospectus Delivery ....................................................................................................................................... 13 Client Referrals and Other Compensation........................................................................................................ 13 Brokerage Practices ....................................................................................................................................... 13 Accounts Held at Unaffiliated Custodians and Broker-Dealers........................................................................... 13 Financial Information ...................................................................................................................................... 13 556430 (Rev 70 - 09/25) Page 3 of 13 Wells Fargo Advisors Financial Network, LLC ("WFAFN"), is a broker-dealer and investment advisory Firm providing investment and other financial services to individual, corporate, and institutional Clients through a network of independent contractor representatives. It is a non-bank affiliate of Wells Fargo & Company ("Wells Fargo"), a financial holding company and bank holding company founded in 1852 and publicly held company (NYSE: WFC). Wells Fargo and its Affiliates are engaged in a number of financial businesses, including retail brokerage and investment advisory services. WFAFN is affiliated with Wells Fargo Clearing Services, LLC ("WFCS"), a broker-dealer and investment adviser that also provides advisory and brokerage services as well as securities-execution and brokerage-clearance services to WFAFN, and other retail securities firms throughout the United States. WFCS operates under the trade name Wells Fargo Advisors ("WFA") in providing advisory and brokerage services. WFAFN has entered into an agreement with WFA, a non-bank affiliate of WFAFN, pursuant to which WFA will act as sub-adviser and/or service provider to WFAFN with respect to the advisory Programs and services offered by the Firm. WFA is a member of the New York Stock Exchange, Inc. ("NYSE") and the principal stock exchanges in the nation, as well as FINRA and SIPC. References are made herein to the Program Wrap Fee Brochures. The services provided under the Programs are the same in all material respects as the services provided under the Programs with the same names described in the WFA Wrap Fee Brochures, except that WFAFN will be acting as the investment adviser under the Programs rather than WFA, and WFAFN's fee structure could vary from those described in WFA's Wrap Fee Brochures. Clients should refer to this Wrap Fee Brochure rather than WFA's Wrap Fee Brochure for Program-specific information regarding the fee structure and minimum Account size that applies to Wells Fargo Advisors Financial Network, LLC Client Accounts. The terms "Client," "you," and "your" are used throughout this document to refer to the person(s) or organization(s) who contract with us for the services described here. "WFAFN," "we," "our," and "us" refer to WFAFN together with our Affiliates, including but not limited to, Wells Fargo & Company and its agents with respect to any services provided by those agents. "Affiliate" means any entity that is controlled by, controls or is under common control with WFAFN. Each Affiliate is a separate legal entity, none of which is responsible for the obligations of the other. "Account" means collectively or individually any brokerage Account and/or any Advisory Program Account you have with us, including any and all funds, money, securities and/or other property you have deposited with us. "Securities and/or Other Property" means, but is not limited to, money, securities, financial instruments and commodities of every kind and nature and related contracts and options, distributions, proceeds, products and accessions of all property. Services, Fees and Compensation Types of Advisory Services FundSource®, CustomChoice, Private Investment Management, Fundamental Choice, Asset Advisor, Personalized Unified Managed Account (“Personalized UMA”), Private Advisor Network and Customized Portfolios (collectively, the "Programs") are investment advisory Programs offered by WFAFN, as the investment adviser. Other advisory services include Financial Planning, Institutional Consulting and Retirement Plan Consulting Services. Please contact a Financial Advisor for information regarding these services. Advisory Programs As stated earlier, WFAFN has entered into an agreement with WFA, pursuant to which WFA will provide access to its advisory Programs to WFAFN and WFA will act as sub-adviser and/or service provider to WFAFN with respect to the Programs. Regardless of which Program you select, you will retain the right to: withdraw securities or cash; vote on shareholder proposals of beneficially owned security issues, or delegate the authority to vote on shareholder proposals to another person; be provided in a timely manner with a written confirmation or other notification of each securities transaction, and all other documents required by law to be provided to security holders; and proceed directly as a security holder against the issuer of any security in your Account and not be obligated to join any person involved in the operation of the applicable Program, or any other Client of the applicable Program, as a condition precedent to initiating such proceeding. Our Program services encompass: exchange listed securities; over the counter and foreign securities; rights and warrants; corporate, municipal and U.S. Government debt securities; securities options and futures; partnership interests involving real estate, oil and gas investments; real estate investment trusts ("REITS"), mortgage backed securities; certificates of deposit; commodities and related option and futures contracts including financial futures; commercial paper; advisory annuities; exchange- traded fund shares; closed-end mutual funds shares; open-end mutual fund shares, including load-waived mutual funds, money market funds and, with respect to the Asset Advisor Program and effective in the first quarter of 2025 with respect to the Personalized Unified Managed Account Program, alternative investments. Alternative Investments include alternative investment vehicles that require execution by the client of either certain third-party fund documentation or other documentation to direct a specific investment (such as hedge funds, certain real estate funds, private equity funds, certain credit funds, certain interval funds, exchange funds that provide exposure to a diversified portfolio of securities in exchange for contributions of restricted securities, certain tender offer funds, as well as co-investments, special purpose vehicles, and other fund structures that provide exposure to private company securities and real estate) ("Alternative Investments"). 556430 (Rev 70 - 09/25) Page 4 of 13 As a minimum criterion for providing advisory services, we typically require a college degree or satisfactory past business experience, plus the required industry examinations and registrations, if any. Unless they possess equivalent satisfactory portfolio management experience, PIM and FC Financial Advisors must attain established firm or industry experience levels, and complete independent specialized portfolio management training. As described below in the "Other Financial Industry Activities and Affiliations" section, we are engaged in a wide range of securities services. The advice given and action taken in the performance of our duties to you could differ from advice given, or the timing and nature of action taken, with respect to other Program Clients and/or Clients in other advisory Programs. Additionally, there are times that we are limited in our ability to divulge or act upon certain information we possess as a result of investment banking activities or other confidential sources. Fees and Compensation FundSource® Program Please see the WFA Program Wrap Fee Brochure for a description of the services and additional fee information applicable to FundSource Program Accounts. The current WFAFN Program Fee for the FundSource Program, which is negotiable, is shown below. Some Accounts opened prior to June 9, 2017 are subject to a different fee schedule. Please consult your Client Agreement. Program Fee (annualized, calculated on your Account Value) 2.00% CustomChoice Program Please see the WFA Program Wrap Fee Brochure for a description of the services and additional fee information applicable to CustomChoice Program Accounts. The current WFAFN Program Fee for the CustomChoice Program, which is negotiable, is shown below. Some Accounts opened prior to June 9, 2017 are subject to a different fee schedule. Please consult your Client Agreement. Program Fee (annualized, calculated on your Account Value) 2.00% Private Investment Management and Fundamental Choice Programs Please see the WFA Program Wrap Fee Brochure for a description of the services applicable to PIM and Fundamental Choice Programs. The current WFAFN Program Fee for the PIM and Fundamental Choice Programs, which is negotiable, is shown below. Some Accounts opened prior to June 9, 2017 are subject to a different fee schedule. Please consult your Client Agreement. Program Fee (annualized, calculated on your Account Value) 2.00% Asset Advisor Program Please see the WFA Program Wrap Fee Brochure for a description of the services and additional fee information applicable to Asset Advisor Accounts. The current WFAFN Program Fee for the Asset Advisor Program, which is negotiable, is shown below. Some Accounts opened prior to June 9, 2017 are subject to a different fee schedule. Please consult your Client Agreement. Program Fee (annualized, calculated on your Account Value) 2.00% 556430 (Rev 70 - 09/25) Page 5 of 13 Personalized UMA Program Please see the WFA Program Wrap Fee Brochure for a description of the services and additional fee information applicable to Personalized UMA Accounts. For the services provided to your Advisory Program Account, you will be charged an advisory fee (“Advisory Fee”) plus Manager Fee(s) for each Manager selected within your Advisory Program Account (“Manager Fee”). The Advisory Fee is charged for the services we provide, including our investment advisory, execution, consulting and custodial services. The Manager Fee is charged for the advisory services provided by the Managers or Model Managers. We negotiate the Manager Fee with each Manager or Model Manager based on a variety of factors, including the nature and quality of the services to be provided by the Manager or Model Manager. Manager Fees generally range from 0.0% to 0.50%. Different Managers have different Manager Fees. Each Manager’s fee may change at any time. Manager Fee information is updated periodically and is available at https://www.wellsfargoadvisors.com/pdf/third-party-ext-mgr-fee-schedule.pdf or anytime upon request to your Financial Advisor. In a Multi Strategy Account, the applicable Manager Fee rate applies to the assets within each respective strategy. The Advisory Fee for the Personalized UMA Program, which is negotiable, is shown below. Some Accounts opened prior to September 15, 2018 are subject to a different Program Fee. Please consult the Program Features and Fee Schedule of your Client Agreement. Advisory Fee (annualized, calculated on your Account Value) 2.00% Private Advisor Network Program Please see the WFA Program Wrap Fee Brochure for a description of the services and additional fee information applicable to Network Accounts. For this Program, the Client either compensates WFAFN for its services by selecting an Execution Schedule (the Client pays a commission or markup/markdown for each trade executed in his/her Account) or a Program Fee. In addition to the Private Advisor Network charges, Clients pay for the services of the investment adviser separately. The current WFAFN Program Fee for the Private Advisor Network Program, which is negotiable, is shown below. Some accounts opened prior to June 9, 2017 may be subject to a different fee schedule. Please consult your Client Agreement. Program Fee (annualized, calculated on your Account Value) 2.00% For Clients wishing to utilize the selection or evaluation monitoring services of the Private Advisor Network without any execution service, the fees for such accounts, payment schedules and refunds thereof are negotiated on a case-by-case basis and may be determined as a percentage of assets under management, an annual fee, or a consideration of other factors. Customized Portfolios Please see the WFA Program Wrap Fee Brochure for a description of the services and additional fee information applicable to Customized Portfolios Accounts. The current WFAFN Program Fee for the Customized Portfolios Program, which is negotiable, is shown below. Some accounts opened prior to June 9, 2017 may be subject to a different fee schedule. Please consult your Client Agreement. Program Fee (annualized, calculated on your Account Value) 2.00% Platform Fee and Advisory Account Credit A Platform Fee of 0.050% will apply to certain Program Accounts ("Participating Accounts") that will help offset the costs to operate our advisory Programs. Participating Accounts that are charged the Platform Fee will be eligible to receive a credit ("Advisory Account Credit") that is calculated based on compensation we receive for networking and omnibus platform services and revenue sharing payments ("Platform Support") from mutual funds and actively managed ETFs available through the Programs. Please see the WFA Program Wrap Fee Brochure for additional information about the Platform Fee and Advisory Account Credit, Participating Accounts, and the related conflicts of interest. 556430 (Rev 70 - 09/25) Page 6 of 13 Other Account Fees and Conflicts of Interest For additional information about other fees not covered by the Program Fee as well as conflicts of interest that exist for Program Accounts, such as when investing in mutual funds and exchange traded funds in Advisory Programs, please see the WFA Program Wrap Fee Brochure. Account Termination You or we may terminate an Advisory Program Account by notifying the other party in writing of the Advisory Program Account to be terminated and termination will become effective upon the receipt of the notice. If an Advisory Program Account is terminated, we will make a pro-rata refund to you of fees paid to us pursuant to the Agreement for the period after the date of effectiveness of such termination through the end of the then current fee period. The Platform Fee is charged in arrears and will not be refunded. Client Agreements terminated prior to the application date of any Advisory Account Credit will not be entitled to any portion of such credit (nor shall such account be subject to the Platform Fee for such quarter). If you choose to terminate your Agreement with any of our investment advisory Programs, we can liquidate your Account if you instruct us to do so. If so instructed we will liquidate your Account in an orderly and efficient manner. We do not charge for such redemption; however, you should be aware that certain mutual funds impose redemption fees as stated in their fund prospectus. For taxable Accounts, you should also keep in mind that the decision to liquidate security issues or mutual funds will result in tax consequences that should be discussed with your tax advisor. We will not be responsible for market fluctuations in your Account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Factors that affect the orderly and efficient liquidation of an Account might be size and types of issues, liquidity of the markets, and market makers' abilities. Should the necessary securities' markets be unavailable and trading suspended, efforts to trade will be done as soon as possible following their reopening. Due to the administrative processing time needed to terminate an advisory Account, termination orders cannot be considered market orders. It could take up to several business days under normal market conditions to process your request. If a Program Account is terminated, but you maintain a brokerage Account with us, the money market fund used in a sweep arrangement could be changed and/or your shares exchanged for shares of another series of the same fund. You will bear a proportionate share of the money market fund's fees and expenses. You are subject to the customary brokerage charges for any securities positions sold in your Account after the termination of Program services. Class Action Services Beginning January 2025, all WFAFN accounts will be automatically enrolled in the Class Action Service also described in the Client Agreement. The Class Action Service authorizes WFAFN to automatically file a claim on your behalf if WFAFN receives notice of a class action lawsuit that impacts securities purchased in your Account. The terms of the Class Action Service apply to your Account unless you have opted out. You are not obligated to continue to use the Class Action Service and you may opt out at any time by notifying your Financial Advisor. The Class Action Service is a separate administrative service, is not part of the advisory services included in any Advisory Program and WFAFN does not act in an advisory capacity when making this service available to you. WFAFN will not provide legal advice regarding your participation in any class action. Broadridge Investor Communication Solutions, Inc. ("Broadridge") administers the Class Action Service and, in exchange for administering the Class Action Service, Broadridge will retain ten percent (10%) from any class action settlement payment received on your behalf. The remainder of the class action settlement payment will be credited to your Account and will be subject to the fees described in your Client Agreement and the Program Features and Fee Schedule incorporated into your Client Agreement. In cases where WFAFN elects not to submit a claim for any class action for which you are otherwise entitled to submit a claim, WFAFN will notify you in writing in advance of the submission deadline and provide you with the individual class action notice so you may submit a claim directly to the claims administrator if you so choose. You are encouraged to carefully review the complete terms and conditions of the Class Action Service, which can be found in the Client Agreement, or to contact us should you have questions. Account Requirements and Types of Clients The minimum initial Account values for the Programs described in this document are listed below. We have the right to terminate Client Accounts with written notice if they fall below minimum Account value guidelines established by us. At our discretion, we can choose to waive the minimum Account size. 556430 (Rev 70 - 09/25) Page 7 of 13 FundSource FundSource Optimal Blend FundSource Customized Blend FundSource Foundations Optimal Blend Minimum Account Size $25,000 $25,000 $10,000 CustomChoice CustomChoice Minimum Account Size $25,000 Private Investment Management Private Investment Management Minimum Account Size $50,000 Fundamental Choice Fundamental Choice Minimum Account Size $50,000 Asset Advisor Asset Advisor Minimum Account Size $25,000 Minimum Account Size Personalized UMA Multi Strategy Optimal Blend Custom Blend $200,000 or portfolio minimum $10,000 subject to investment minimum Personalized UMA Single Strategy SMA Strategies FundSource Optimal Blend FundSource Foundations Optimal Blend Minimum Account Size $50,000 subject to Manager's minimum $25,000 $10,000 Minimum Account Size $10,000 $25,000 Personalized UMA Single Strategy-Allocation Advisors strategies ESG Aware, Tactical Active/Passive and Intuitive Investor ETF Strategic ETF, Active/Passive, Morningstar Strategic ETF, Morningstar ETF CAAP Plus and Tactical ETF $50,000 Minimum Account Size Personalized UMA Single Strategy-Wells Fargo Compass Asset Allocation strategies Conservative Growth & Income $250,000 Moderate Growth & Income $250,000 Aggressive Growth & Income $250,000 Conservative Growth $250,000 Moderate Growth $250,000 Aggressive Growth $150,000 Private Advisor Network Private Advisor Network Minimum Account Size $100,000 subject to Manager's minimum Minimum Account Size Customized Portfolios Custom Option Portfolio $1,000,000 Types of Clients We provide the advisory services described in this brochure to individuals, pension or profit sharing plans, trusts, estates or charitable organizations, corporations or other business entities, governmental entities and educational institutions, as well as banks or thrift institutions. Portfolio Manager Selection and Evaluation The WFA Wrap Fee Brochures describe the Portfolio Manager Selection and Evaluation in connection with the Programs. WFAFN's practice in this area is the same as that applicable to WFA. Services Tailored to Individual Client Needs All of our investment recommendations for Program Accounts are based on an analysis of your individual financial needs. They are drawn from research and analysis we believe to be reliable and appropriate to your financial circumstances. Each of the advisory services we offer is tailored to a specific type of investor and designed to meet their individual investment objectives, financial needs and tolerance of risk. 556430 (Rev 70 - 09/25) Page 8 of 13 Client Restrictions and Instructions We will comply with any reasonable instructions and/or restrictions you give us when making recommendations for your Account. Reasonable instructions generally include the designation of particular securities or types of securities that should not be purchased for the Account. If your restrictions are unreasonable or if we or your Financial Advisor believe that the restrictions are inappropriate, we will notify you that, unless they are modified, we will remove your Account from the Program. You will not be able to provide instructions that prohibit or restrict the investment advisor of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund or ETF. Our policy is generally to liquidate your pre-existing securities portfolio immediately and bring the Account into conformity with your target allocations. If you wish to hold certain positions for tax or investment purposes, you should consider holding these positions in a separate Account. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees in any of our investment advisory Programs. We do not have any side-by-side management situations. Methods of Analysis, Investment Strategies and Risk of Loss The advisers selected by you in Personalized UMA and Private Advisor Network employ similar methods of analysis that are described to Clients both by us and in each such adviser's Disclosure Document. The Program Managers, including WFA, each employ a variety of investment strategies depending on the Client and the Client's objectives. Such strategies ordinarily include long or short-term purchase of securities and, depending on the Client objectives and adviser's style, supplemental covered option writing. However, we also offer certain strategies that also include margin transactions, other option or trading strategies or short- sale transactions. The PIM and FC Portfolio Managers generally rely on fundamental securities analysis with some emphasis on utilizing charting or cyclical analysis. Some PIM Portfolio Managers rely on quantitative analysis. Portfolio Managers typically develop a specific investment philosophy that will detail the mix of these analysis methods. All investment recommendations for Program Clients, including Asset Advisor, are based on an analysis of the Client's individual needs, and are drawn from research and analysis we believe reliable. Investment decisions for Allocation Advisors and Wells Fargo Compass Advisory Clients are derived from disciplined model portfolios based on established guidelines as modified to satisfy the individual investment objectives and needs of each Client. Additional information can be found in the WFA Wrap Fee Brochure for each Program. Risk of Loss All investments shall be at your risk exclusively, and you must understand that we do not guarantee any return on the investments recommended or advised upon and will not be responsible for losses resulting from such trading or for any transactions that we have not recommended to you. Proxy and Reorganizations The WFA Program Wrap Fee Brochure describes procedures used by us for Client proxy and reorganizations. Our practice in this area is the same as that applicable to WFA. Client Information Provided to Portfolio Managers All Clients must provide information on their investment objectives, financial circumstances, risk tolerance and any restrictions they wish to impose on investment activities. We will notify you in writing at least annually to update your information and indicate if there have been any changes in your financial situation, investment objectives or instructions; and you agree to inform us in writing of any material change in your financial circumstances that might affect the manner in which your assets should be invested. Your Financial Advisor will be reasonably available to you for consultation on these matters, and will act on any changes deemed to be material or appropriate as soon as practical after we become aware of the change. Client Contact with Portfolio Managers Your contact for information and consultation regarding your Program Accounts is generally your Financial Advisor. In certain instances, your Financial Advisor will coordinate their response with the Portfolio Manager (if applicable) or arrange for you to consult directly with the Portfolio Manager. Additional Information Disciplinary Information We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of the broker-dealer, investment advisor or predecessor firms. 556430 (Rev 70 - 09/25) Page 9 of 13 For more information on broker/dealer related disciplinary events, please visit: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/. Our investment advisory disciplinary history is available by going to: http://www.adviserinfo.sec.gov/. In January 2025, WFCS and WFAFN agreed to a settlement with the SEC regarding allegations that they failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to their cash sweep program, specifically, their use of a bank deposit sweep program. The order found that WFCS and WFAFN did not adopt and implement reasonably designed policies and procedures that considered the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; or addressed the duties of WFCS and WFAFN financial advisors in managing client cash in advisory accounts, in willful violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. WFCS and WFAFN, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28 million by WFCS and $7 million by WFAFN. In August 2023, WFCS and WFAFN (collectively, the "Firm") agreed to a settlement with the SEC regarding allegations that from at least 2002 through December 2022, the Firm and its predecessor firms overcharged approximately 10,945 accounts of advisory clients, for accounts opened through 2014, for more than $26.8 million in advisory fees and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the over billing in willful violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells Fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells Fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the Firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected account holders. Without admitting or denying the findings, the Firm consented to a settlement that included a cease and desist order, censure and civil money penalty of $35,000,000. In December 2021, WFCS and WFAFN agreed to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti- money laundering Customer Identification Program (CIP) in the required non-erasable and non-writable “Write Once, Read Many” (WORM) format in violation of Exchange Act Rule 17A-4(F)(2)(II)(A) and failed to notify FINRA prior to using the non- WORM compliant storage platform in violation of Exchange Act rules 17A-4(F)(3)(V) and 17A-4(F)(2)(I). Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine, jointly and severally, of $2,250,000. On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against WFCS and WFAFN, following the Firms' offers of settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds ("ETFs") without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The Commission found that the Firms willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 203(e)(6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained in the Order, to: cease and desist from committing or causing any violations and any future violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; be censured, and; jointly and severally pay a civil monetary penalty in the amount of $35,000,000. In 2018, WFCS and WFAFN elected to participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative ("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling $17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms self-reported. 556430 (Rev 70 - 09/25) Page 10 of 13 On December 21, 2016, WFCS and WFAFN agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also found that the Firms failed to implement an audit system for those records, failed to provide its third party vendors full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce written procedures. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,500,000. The Firms also consented to a review of its policies and procedures. On December 5, 2016, WFCS and WFAFN agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through available applications. The findings stated that these applications allowed the Firm's representatives to manually enter information regarding customers' external accounts, assets and liabilities into a centralized table which the Firms maintained. This information would then be used to populate reports, including those that would be sent to the Firms' customers. FINRA found that the Firms did not have systems in place to review the contents of the reports, including information about customer holdings away from the Firms. In addition, the Firms supervisory systems and procedures were inadequate because there was no mechanism allowing representatives to designate which reports were actually provided to customers and the system could not distinguish between draft reports and completed reports that were sent to customers, which should have been subject to the Firms' supervisory systems designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,000,000. Other Financial Industry Activities and Affiliations WFAFN is a national securities firm providing investment and other financial services to individual, corporate and institutional Clients. We are a registered broker-dealer and investment adviser. Accounts are carried by WFCS, a qualified custodian. WFCS is an affiliate owned indirectly by Wells Fargo. WFAFN and WFCS are members of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). Unless otherwise stated as the case, the investment advisory services offered and the underlying stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not insured or otherwise protected by the Federal Deposit Insurance Corporation ("FDIC") or another government agency. They are not obligations of any bank or any affiliate of us; are not endorsed or guaranteed by Wells Fargo, WFAFN, or any bank or any affiliate of us; and involve investment risk including possible loss of principal. Cash balances in Client Accounts may be held in a depository product sponsored by Wells Fargo Bank, N.A. Wells Fargo Advisors Financial Network, LLC is not an FDIC- insured depository institution; FDIC deposit insurance only protects against the failure of an insured depository institution. Banking products and services provided by Wells Fargo Bank, N.A. Member FDIC. Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible for securities we sell or purchase. As a general matter, unless otherwise stated, we may be a principal or engaged in underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to issuers whose securities may be sold to you. From time to time, a bank or thrift affiliated with us lends money to an issuer of securities underwritten or privately placed by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will disclose to the extent required by applicable securities laws: the existence of any material lending relationship by any affiliate of ours with such an issuer, and; whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding indebtedness to any of our affiliates. We have a number of related persons who provide investment management and related financial services to our Program Clients. The advisory services these investment advisers offer are described more fully in their Disclosure Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services follows. • Wells Fargo also provides retail brokerage and investment advisory services through WFCS. • WFII is a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA and WFAFN. WFII also provides research and strategy recommendations to other affiliates of WFAFN. While all the affiliates have similar access to the research, due to operational differences and manner and size of the advisory programs, certain affiliates could have the ability to implement and trade on these recommendations prior to another affiliate. The ability to implement and trade on these recommendations first gives the clients of one affiliate an advantage over clients of other affiliates. Certain cash sweep vehicles that we offer as part of our Cash Sweep Program may also be used by our affiliates. The rate of return paid when invested in these cash sweep vehicles with our affiliates could be greater than the rate of return paid when invested in these cash sweep vehicles with WFA. 556430 (Rev 70 - 09/25) Page 11 of 13 Material Relationships with Allspring Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners renamed the business Allspring Global Investments. The Wells Fargo Asset Management business was wholly owned by Wells Fargo prior to the transaction and included the following companies: Wells Capital Management Incorporated; Wells Fargo Funds Management, LLC; Wells Fargo Asset Management (International), LLC; Wells Fargo Funds Distributor, LLC; and, Galliard Capital Management, Inc. These companies, which are no longer related persons of WFAFN, served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the companies managed separately managed account strategies offered through WFAFN. Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings, LLC. This group of companies includes Allspring Funds Management, investment adviser to mutual funds within the Allspring family of funds, Allspring Funds Distributor, LLC, the principal underwriter of Allspring mutual funds, and Allspring Global Investments, LLC, a model portfolio strategy provider and an investment adviser to pooled investment vehicles and separately managed accounts. Wells Fargo has no role in the management of Allspring. However, Wells Fargo retains less than a 10% equity ownership interest in Allspring and has continued to provide certain non-advisory transition services to Allspring for a fee since the close of the sale. WFCS also receives compensation from Allspring for the distribution, administrative and operational services that we provide to the Allspring mutual funds. Although Allspring is not a related person of WFAFN, WFAFN and its related persons continue to benefit from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a similar financial interest. Wells Fargo’s equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services to Allspring for a fee provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account or model portfolio strategies. WFII charges Allspring research access fees for investment research services that WFII provides to Allspring. Allspring manages the Managed DSIP, Managed DSIP II, ESG Managed DSIP, Current Equity Income, and Income Multi Asset Portfolio strategies offered through the Personalized Unified Managed Account advisory program (collectively, the “Equity Income Strategies”) utilizing information derived, in part, from certain of the research services. The research access fees are calculated based on the assets invested in the strategies, meaning that WFII earns more money when more assets are invested in the strategies. The research access fees are assessed at rates that result in WFII receiving fees that are equivalent to substantially all of the Manager fees assessed in conjunction with the Income Multi Asset Portfolio, the Current Equity Income Strategy, and the Managed DSIP strategy, and approximately half or greater of the Manager fees assessed for the Managed DSIP II strategy and the ESG Managed DSIP strategy. The fee paid to WFII is for research services WFII provides to Allspring, including: investment research that WFII provides to Allspring; and access to certain WFII research analyst teams, strategists, and associates to discuss the research and/ or obtain additional research commentary on covered names, insights into sectors, etc. (collectively “Research Services”). While WFII does not provide the Research Services to other third-party Managers for utilization in managing strategies, WFII does provide the Research Services to its affiliates, WFCS and WFAFN, who in turn, may utilize the Research Services to manage strategies and who provide the investment research at no cost to WFCS and WFAFN advisory clients, WFCS and WFAFN brokerage customers, and prospective clients and customers for their individual use. As such, investors in the Equity Income Strategies are indirectly paying for investment research that others receive at no cost, and that those same investors could receive from WFCS or WFAFN for their individual use outside of the Equity Income Strategies at no cost under other circumstances. Similar investment research may be available in the marketplace at no cost or for materially lower fees than are being charged to Allspring in conjunction with the Equity Income Strategies. WFII’s receipt of a research access fee in conjunction with the Equity Income Strategies creates a material conflict of interest since it results in WFII, an affiliate of WFAFN, earning more revenue when investors follow a WFAFN recommendation to invest in the Equity Income Strategies than WFAFN, WFII or their affiliates would earn if investors followed a recommendation from WFAFN to invest in any of the other Model Manager strategies available through the Personalized UMA Program as WFAFN and its affiliates earn no comparable additional revenue for investments in other Model Manager strategies. WFAFN seeks to mitigate this conflict and its associated implications through disclosure, management of the financial incentive for financial advisors to recommend the Equity Income Strategies, and evaluation of the total costs of investing in the Equity Income Strategies relative to other Model Manager strategies. You should carefully consider the research access fee that is retained by WFII and our related conflict of interest when evaluating whether to invest in the Equity Income Strategies. The Equity Income Strategies are available through Wells Fargo Bank N.A., including through Wealth & Investment Management Trust Services, and no research access fee is applied to assets invested in the Equity Income Strategies when the assets are custodied at Wells Fargo Bank N.A. The research access fee is also not applied to assets invested in ERISA accounts. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading The WFA Wrap Fee Brochures describe the Code of Ethics, Participation or Interest in Client Transactions and Personal Trading in connection with the Programs. WFAFN's practice in this area is the same as that applicable to WFA. 556430 (Rev 70 - 09/25) Page 12 of 13 Review of Accounts The WFA Wrap Fee Brochures describe the review of Accounts and reports that you receive in connection with the Programs. WFAFN's practice in this area is the same as that applicable to WFA. Prospectus Delivery WFA Wrap Fee Program Brochures describe circumstances pursuant to which a prospectus may not be delivered directly to accountholders if such a practice could be applicable to the Programs covered by the brochure. WFAFN's practice in this area is the same as that applicable to WFA. Client Referrals and Other Compensation The WFA Wrap Fee Brochures describe the payment of referral compensation in connection with the Programs. WFAFN's practice in this area is the same as that applicable to WFA. Advisory Earnings Sharing Arrangement Certain financial advisors have entered into an earnings sharing arrangement with a private entity that creates an incentive to recommend advisory accounts and services, including recommending that you contribute additional assets to your advisory accounts. Specifically, certain Financial Advisers have agreed to contribute a portion of their advisory earnings to the private entity, in exchange for which they will receive cash consideration and equity ownership interests in the private entity or a related entity. These cash payments and equity ownership interests, for certain Financial Advisers, are subject to a hurdle, whereby if they reach a certain earnings threshold, these incentives are increased. Separately, Financial Advisors could have an incentive to recommend advisory accounts/trades over brokerage if they believe that, by doing so, they can receive additional equity ownership interests or other consideration from the private entity. The arrangements described above create a conflict of interest for the financial adviser, and in turn, the firm, as the result will be additional revenue. We mitigate this conflict of interest by enforcing and supervising policies and procedures that require recommendations regarding account types and in respect of the provision of advisory services to be made in the client's best interest. Brokerage Practices The WFA Wrap Fee Brochures describe the brokerage practices in connection with the Programs. WFAFN's practice in this area is the same as that applicable to WFA. We will not sell your information to other companies for marketing purposes. We employ strict security standards and safeguards to protect your personal information and prevent fraud. In addition, we will continue to protect your privacy even if they cease being our Client. Consistent with our privacy policies and applicable law, WFAFN and its affiliates provide access to Client personal information to affiliated and third party service providers throughout the world. When Client information is accessed, we maintain protective measures as described in our privacy policies and notices. For more information, please see our Privacy Statement. For more information, please read our Privacy Statement, visit a WFAFN office or call your Financial Advisor. With your written permission, obtained via your Client Agreement or other written communication, we have the right to provide your information electronically to your Manager and/or agent of your Manager. We reserve the right, at our discretion, to refuse to provide such requested information. Furthermore, in compliance with our Privacy Policy, we accept your instructions to discontinue providing such information. Accounts Held at Unaffiliated Custodians and Broker-Dealers In certain cases, Clients may choose to custody their Account assets at a financial institution unaffiliated with WFCS. Generally, these custodial arrangements take the form of a delivery-versus-payment account ("DVP Account") or a brokerage account held at an unaffiliated broker-dealer ("Held-Away Account"). The WFA Wrap Fee Program Brochure contains important information specific to DVP Account and Held-Away Account arrangements. You should review this section of the WFA Wrap Fee Program Brochure when considering these types of Account arrangements. Financial Information We have no financial condition that is likely to impair our ability to meet our contractual commitments to you. 556430 (Rev 70 - 09/25) Page 13 of 13