Introduction Stratos Investment Management, LLC (“SIM”) is wholly owned by Stratos Intermediate Holdco LLC within the Stratos Wealth Holdings, LLC family of companies and has been a registered investment adviser since 2016. Stratos Intermediate Holdco LLC is a holding company which owns the following registered investment advisers and a limited purpose broker-dealer. 1. Stratos Wealth Partners, Ltd. (“SWP”), a retail investment firm offering advice primarily through Investment Advisor Representatives (“IARs”) who are securities licensed through LPL Financial Corporation (“LPL Financial”), Member FINRA/SIPC. 2. Stratos Wealth Advisors, LLC (“SWA”), a retail investment firm offering advice primarily through IARs who are not securities licensed. 3. Stratos Wealth Securities, LLC (“SWS”), a limited purpose broker-dealer, Member FINRA/SIPC. SWS does not process securities transactions or maintain client accounts. 4. Renaissance Investment Group, a retail investment firm offering advice through IARs who are not securities licensed. Please see Item 10 for more information. Overview SIM acts as portfolio manager for wrap fee programs sponsored by its affiliated registered investment advisers, SWP and SWA. SIM also provides subadvisory services to IARs of SWP and SWA on a non-wrap fee basis. Finally, Stratos Investment Management provides subadvisory services to IARs of Lineweaver Wealth Advisors, LLC on a non-wrap fee basis. SIM offers ongoing portfolio management based on the individual goals, objectives, time horizon, and risk tolerance of each client. The wrap fee program allows the client to pay one stated fee that includes management fees and transaction costs. SIM also provides its services on a non-wrap fee basis generally in situations where wrap fee programs are not permitted or economically unfeasible. Clients may end up paying more or less in a wrap fee program than in a non-wrap fee program. SIM primarily acts as a subadviser to IARs. Its portfolio management services include, but are not limited to, the following:
• Investment strategy
• Asset allocation
• Portfolio construction
• Risk tolerance
• Regular portfolio monitoring 5 | P a g e SIM will typically require discretionary authority in order to select securities and execute transactions without permission from the client prior to each transaction. As of December 31, 2022, SIM had approximately $1,521,000,000 in assets under management on a discretionary basis and $0 in assets under management on a non-discretionary basis. SIM’s investment decisions are driven by the Investment Policy Statement (“IPS”) for each Strategy. Tax considerations are secondary to asset allocation decisions. SIM has agreements with the following broker-dealer custodians:
• Fidelity Brokerage Services, LLC and National Financial services, LLC, Member FINRA/SIPC;
• Charles Schwab, Member FINRA/SIPC; and
• LPL Financial, Member FINRA/SIPC. The choice of custodian is determined by the primary advisor and/or client. SIM seeks to provide investment decisions that are made in accordance with the fiduciary duties owed to its accounts and without consideration of SIM’s economic, investment or other financial interests. To meet its fiduciary obligations, SIM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios. It is SIM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis to avoid favoring one client over another over time. Clients should refer to below for further details regarding SIM’s model portfolios. Description of Model Portfolios SIM Tactical Models Accounts managed based on a SIM Tactical Model Portfolio will be managed similar to other clients utilizing this model. There are no guarantees a portfolio managed based on a model will ensure positive results. Past performance is no guarantee of future results. Further, any model account assembled based on prior performance analysis has the benefit of having knowledge of all facts of the market and performance of securities after the fact. SIM provides portfolio management services for the Tactical Models on both a wrap and a non-wrap fee basis.
• The Tactical Conservative Composite contains all discretionary portfolios managed to the SIM Tactical Conservative strategy. This composite is a Tactical Conservative strategy consisting of primarily mutual funds and exchange traded products, but can include closed end funds and individual securities (equities or bonds). The benchmark for this strategy is a 35%/65% mix of the MSCI All Country World Investable Market Index Net Return and the Barclays Capital US 6 | P a g e Aggregate Bond Total Return index. Its inception year is 2011, and the account minimum is $100,000.
• The Tactical Moderate Composite contains all discretionary portfolios managed to the SIM Tactical Moderate strategy. This composite is a Tactical Moderate strategy consisting of primarily mutual funds and exchange traded products but can include closed end funds and individual securities (bonds or equities). The benchmark for this strategy is a 55%/45% mix of MSCI All Country World Investable Market Index Net Return and the Barclays Capital US Aggregate Bond Total Return index. Its inception year is 2011, and the account minimum is $100,000.
• The Tactical Growth Composite contains all discretionary portfolios managed to the SIM Tactical Growth strategy. This composite is a Tactical Growth strategy consisting of primarily mutual funds and exchange traded products but can include closed end funds and individual securities (bonds or equities). The benchmark for this strategy is a 70%/30% mix of the MSCI All Country World Investable Market Index Net Return and the Barclays Capital US Aggregate Bond Total Return Index. Its inception year is 2011, and the account minimum is $100,000.
• The Tactical Aggressive Growth Composite contains all discretionary portfolios managed to the SIM Tactical Aggressive Growth strategy. This composite is a Tactical Aggressive Growth strategy consisting of primarily mutual funds and exchange traded products but can include closed end funds and individual securities (bonds or equities). The benchmark for this strategy is a 85%/15% mix of the MSCI All Country World Investable Market Index Net Return and the Barclays Capital US Aggregate Bond Total Return Index. Its inception year is 2023, and the account minimum is $100,000.
• The Tactical Diversified Income Composite contains all discretionary portfolios managed to the SIM Tactical Diversified Income strategy. This strategy is a Tactical Diversified Income strategy consisting of primarily mutual funds and exchange traded products but can include closed end funds and individual securities (bonds or equities). The benchmark for this strategy is 60% MSCI World High Dividend Index and 40% Bloomberg Barclays US Aggregate Bond Total Return Index. Its inception year is 2011, and the account minimum is $100,000.
• The Tactical Low Duration Income Composite contains all discretionary portfolios managed to the SIM Ultra Low Duration strategy. This composite is a Tactical Ultra Low Duration strategy consisting of primarily mutual funds and exchange traded products but can include closed end funds and individual securities (bonds or equities). The benchmark for this strategy is a 50%/50% mix 7 | P a g e of the Bloomberg Barclays US 1-5 Year Government Credit Float Adjusted Total Return Index and the Bank of America Merrill Lynch US Treasuries 1-3 Year Total Return Index. Its inception year is 2017, and the account minimum is $100,000.
• The SIM Barnwood MidCap Composite contains all discretionary portfolios managed to the SIM Barnwood MidCap strategy. This strategy consists of individual equities whose market capitalization lie between $1 billion and $15 billion. The benchmark for this strategy is the S&P 400 index. The inception year is 2024, and the account minimum is $100,000.
• The SIM Barnwood Small Cap Composite contains all discretionary portfolios managed to the SIM Barnwood Small Cap strategy. This strategy consists of individual equities whose market capitalization lie below $2 billion. The benchmark for this strategy is the Russell 2000 index. The inception year is 2024, and the account minimum is $100,000. SIM Strategic Models Accounts managed based on a SIM Strategic Model will be managed similar to other clients utilizing this model. There are no guarantees a portfolio managed based on a model will ensure positive results. Past performance is no guarantee of future results. Further, any model account assembled based on prior performance analysis has the benefit of having knowledge of all facts of the market and performance of securities after the fact. SIM provides portfolio management services for the Strategic Models on a wrap and a non-wrap fee basis.
• The Strategic Conservative Composite contains all discretionary portfolios managed to the SIM Strategic Conservative strategy. The benchmark for this strategy is a 35%/65% mix of the MSCI All Country World Investable Market Index Net Return and the Barclays Capital US Aggregate Bond Total Return Index. The inception year is 2015, and the account minimum is $10,000.
• The Strategic Moderate Composite contains all discretionary portfolios managed to the SIM Strategic Moderate strategy. Its inception year is 2012. The benchmark for this strategy is a 55%/45% mix of MSCI All Country World Investable Market Index Net Return and the Barclays Capital US Aggregate Bond Total Return indices. Composite minimum is $10,000.
• The Strategic Growth Composite contains all discretionary portfolios managed to the SIM Strategic Growth strategy. Its inception year is 2012. The benchmark for this strategy is a 70%/30% mix of the MSCI All Country World Investable Market Index Net Return and the Barclays Capital US Aggregate Bond Total Return index. Composite minimum is $10,000. 8 | P a g e SIM Enhanced Index Models Accounts managed based on a SIM Enhanced Index Model will be managed similar to other clients utilizing this model. There are no guarantees a portfolio managed based on a model will ensure positive results. Past performance is no guarantee of future results. Further, any model account assembled based on prior performance analysis has the benefit of having knowledge of all facts of the market and performance of securities after the fact. SIM provides portfolio management services for the Enhanced Index Models on both a wrap and a non-wrap fee basis.
• The Enhanced Index Conservative Composite contains all discretionary portfolios managed to the SIM Enhanced Index Conservative strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is as follows: 35% Barclays Capital US Aggregate Bond Total Return Index; 29% BofA US Treasury 1 Year Total Return Index; 16% Citi World Govt Bond Total Return Index; and 20% MSCI All Country World Investable Market Index Net Return.

The inception year is 2017, and the account minimum is $100,000.
• The Enhanced Index Moderate Conservative Composite contains all discretionary portfolios managed to the SIM Enhanced Index Moderate Conservative strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is as follows: 26% Barclays Capital US Aggregate Bond Total Return Index, 22% BofA US Treasury 1 Year Total Return Index, 12% Citi World Govt Bond Total Return Index and 40% MSCI All Country World Investable Market Index Net Return. The inception year is 2017, and the account minimum is $100,000.
• The Enhanced Index Moderate Composite contains all discretionary portfolios managed to the SIM Enhanced Index Moderate strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is as follows: 29% Barclays Capital US Aggregate Bond Total Return Index; 3% BofA US Treasury 1 Year Total Return Index; 8% Citi World Govt Bond Total Return Index; and 60% MSCI All Country World Investable Market Index Net Return. The inception year is 2017, and the account minimum is $100,000.
• The Enhanced Index Growth Composite contains all discretionary portfolios managed to the SIM Enhanced Index Growth strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is as follows: 13% Barclays Capital US Aggregate Bond Total Return Index; 3% BofA US Treasury 1 Year Total Return Index; 4% Citi World Govt Bond Total Return Index; and 80% MSCI All Country World Investable Market Index Net Return. The inception year is 2017, and the account minimum is $100,000. 9 | P a g e
• The Enhanced Index Aggressive Composite contains all discretionary portfolios managed to the SIM Enhanced Index Aggressive strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is the MSCI All Country World Investable Market Index Net Return. The inception year is 2017, and the account minimum is $100,000.
• The Enhanced Index Moderate-US Only Composite contains all discretionary portfolios managed to the SIM Enhanced Index Moderate-US Only strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is as follows: 37% Barclays Capital US Aggregate Bond Total Return Index; 3% BofA US Treasury 1 Year Total Return Index; and 60% Russell 3000 Total Return Index. The inception year is 2017, and the account minimum is $100,000.
• The Enhanced Index Aggressive-US Only Composite contains all discretionary portfolios managed to the SIM Enhanced Index Aggressive-US Only strategy. This strategy consists of ETFs funds and mutual funds. The benchmark for this strategy is the Russell 3000 Total Return Index. The inception year is 2017, and the account minimum is $100,000.
• The Enhanced Index Focused Conservative Composite contains all discretionary portfolios managed to the SIM Enhanced Index Focused Conservative strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is as follows: 35% Barclays Capital US Aggregate Bond Total Return index, 29% BofA US Treasury 1 Year Total Return Index, 16% Citi World Govt Bond Total Return Index and 20% MSCI All Country World Investable Market Index Net Return. The inception year is 2017, and the account minimum is $10,000.
• The Enhanced Index Focused Moderate Composite contains all discretionary portfolios managed to the SIM Enhanced Index Focused Moderate strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is as follows: 29% Barclays Capital US Aggregate Bond Total Return Index; 3% BofA US Treasury 1 Year Total Return Index; 8% Citi World Govt Bond Total Return Index; and 60% MSCI All Country World Investable Market Index Net Return. The inception year is 2017, and the account minimum is $10,000.
• The Enhanced Index Focused Growth Composite contains all discretionary portfolios managed to the SIM Enhanced Index Focused Growth strategy. This strategy consists of ETFs and mutual funds. The benchmark for this strategy is as follows: 13% Barclays Capital US Aggregate Bond Total Return Index; 3% BofA US Treasury 1 Year Total Return Index; 4% Citi World Govt Bond Total Return Index; and 80% MSCI All Country World Investable Market Index Net Return. The inception year is 2017, and the account minimum is $10,000. 10 | P a g e SIM Global Individual Equity Model Accounts managed based on the SIM Global Individual Equity Model will be managed similar to other clients utilizing this model. There are no guarantees a portfolio managed based on a model will ensure positive results. Past performance is no guarantee of future results. Further, any model account assembled based on prior performance analysis has the benefit of having knowledge of all facts of the market and performance of securities after the fact. SIM provides portfolio management services for the Global Individual Equity Model on both a wrap and a non-wrap fee basis.
• The Global Individual Equity Composite contains all discretionary portfolios managed to the SIM Global Individual Equity strategy. This strategy consists of individual equities and may include ETFs and mutual funds at modest levels. The benchmark for this strategy is the S&P 500 Total Return Index. The inception year is 2017, and the account minimum is $100,000. The SIM ESG USA No Energy Model Accounts managed based on the SIM ESG USA No Energy Model will be managed similar to other clients utilizing this model. There are no guarantees a portfolio managed based on a model will ensure positive results. Past performance is no guarantee of future results. Further, any model account assembled based on prior performance analysis has the benefit of having knowledge of all facts of the market and performance of securities after the fact. SIM provides portfolio management services for the SIM ESG USA No Energy Model on both a wrap and a non-wrap fee basis.
• The ESG USA No Energy Composite contains all discretionary portfolios managed to the SIM ESG USA No Energy strategy. This strategy consists of selected individual equities that are held in the benchmark. The benchmark for this strategy is the MSCI USA Extended ESG Focus GR Index. The inception year is 2019, and the account minimum is $100,000. The SIM Dividend Growth Strategy Accounts managed based on the SIM Dividend Growth Strategy will be managed similar to other clients utilizing this model. There are no guarantees a portfolio managed based on a model will ensure positive results. Past performance is no guarantee of future results. Further, any model account assembled based on prior performance analysis has the benefit of having knowledge of all facts of the market and performance of securities after the fact. SIM provides portfolio management services for the Dividend Growth Strategy on both a wrap and a non-wrap fee basis.
• The Dividend Growth Composite contains all discretionary portfolios managed to the SIM Dividend Growth strategy. This strategy consists of individual equities and may include ETFs and mutual funds at modest levels. The 11 | P a g e benchmark for this strategy is the Morningstar U.S. Dividend Growth Index. The inception year is 2020, and the account minimum is $100,000. The SIM Multi Asset Strategies Accounts managed based on a SIM Multi Asset Strategy will be managed similar to other clients utilizing this model. There are no guarantees a portfolio managed based on a model will ensure positive results. Past performance is no guarantee of future results. Further, any model account assembled based on prior performance analysis has the benefit of having knowledge of all facts of the market and performance of securities after the fact. SIM provides portfolio management services for the Multi Asset Strategies on both a wrap and a non-wrap fee basis.
• The Multi Asset Municipals Composite contains all discretionary portfolios managed to the SIM Multi Asset Municipals strategy and offers of multiple equities/fixed income asset allocations. This strategy consists of individual stocks, bonds, mutual funds and exchange traded products. The benchmark for the equity portion of this composite is the MSCI All Country World IMI Net Return, and the benchmark for the fixed income portion of this composite is the Bloomberg Barclays Municipal Bond 5 Year, rebalanced annually. The inception year is 2019, and the account minimum is $250,000.
• The Multi Asset Taxable Composite contains all discretionary portfolios managed to the SIM Multi Asset Taxable Strategy and offers multiple equities/fixed income asset allocations. This strategy consists of individual stocks, bonds, mutual funds and exchange traded products. The benchmark for the equity portion of this composite is the MSCI All Country World IMI Net Return, and the benchmark for the fixed income portion of this composite is the Bloomberg Barclays US Aggregate Municipal Bond, rebalanced annually. The inception year is 2019, and the account minimum is $250,000. The SIM custom indexing model Accounts managed based on the SIM Custom Indexing Model will be managed similar to other clients utilizing this model. There are no guarantees a portfolio managed based on a model will ensure positive results. Past performance is no guarantee of future results. Further, any model account assembled based on prior performance analysis has the benefit of having knowledge of all facts of the market and performance of securities after the fact. SIM provides portfolio management services for the SIM Custom Indexing Model on both a wrap and a non-wrap fee basis.
• SIM has established agreements to work with a third-party investment adviser in a sub-advisory capacity. The sub-advisor is responsible for all investment-related decisions and trading in the client accounts. The sub-advisor may be limited to only manage assets through specific custodians. For more information about what 12 | P a g e custodians a specific sub-advisor is authorized to offer services through, please refer to the sub-advisor’s ADV. SIM retains the authority to hire and fire sub- advisors at our discretion. The account minimum size is $100,000. Custom Strategies SIM also offers two types of Custom Strategies, as described below. Custom Strategies may not be available to all clients, new clients, all primary advisors, and/or at all custodians. Each Custom Strategy is approved separately by SIM on a case-by-case basis and may be offered on both a wrap and non-wrap fee basis.
• Client Specific Constraints – Strategies designed and monitored specifically for one client or household.
• Advisor Specific Constraints – Strategies designed and monitored in conjunction with the client’s primary advisor. For every approved Custom Strategy, an Investment Policy Statement is created and approved by either the client (for Client Specific Constraints) or the primary advisor (for Adviser Specific Constraints). SIM may utilize third party research to assist in analyzing investment opportunities; SIM will then choose how to act on that information in executing its analysis and investment strategies.