Services Siebert AdvisorNXT, Inc. is an SEC registered investment advisor with its headquarters in New Jersey which began conducting business in 2017. The firm provides clients with investment strategies for all market conditions through various distribution channels. As a firm, Siebert AdvisorNXT (“Siebert”) has several different distinct lines of services. Under the Siebert umbrella, there is the AdvisorNXT web- based advisory program (“AdvisorNXT”), a third-party investment Managers, and Investment Supervisory Services. Clients can engage Siebert AdvisorNXT to manage all or a portion of their assets on a discretionary or non- discretionary basis. With regard to portfolio management services, Siebert offers its primary services pursuant to two types of investment strategies: fundamental and technical analysis (as described further in item 6). Siebert primarily provides its services to individuals. Siebert offers to its clients a number of asset management programs (“Managed Programs”) consisting of asset allocation, flexible asset management and focused or completion strategies where Financial Advisors will assist each client in reviewing information about the programs, completing a client questionnaire to determine the client’s risk tolerance, financial situation and investment objectives and selecting an investment strategy. Siebert contracts with and selects other investment advisors to act as either the portfolio manager or sub-advisor on behalf of its clients. Siebert may have representatives act as portfolio managers as well. Siebert (as further discussed in Item 6) primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), individual securities, and Independent Managers, in accordance with the investment objectives of the client. Siebert also provides advice about any type of investment held in clients’ portfolios. Siebert tailors its services to the individual needs of clients. Siebert consults with clients initially and has periodic follow-up contact (generally no less than annually) to determine and/or update risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Clients are advised to notify Siebert if there are changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon Siebert’s management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in Siebert’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. It is the clients’ ongoing responsibility to timely communicate with the Advisor, any changes to their financial situation or status, which may affect the appropriateness of the client’s particular portfolio. Siebert will devote its best efforts with respect to its management of its client accounts. AdvisorNXT The AdvisorNXT platform provides clients with a web-based, cost-efficient, competitively priced, easy to use automated wealth management solution intended to maximize portfolio returns based on a client’s specific risk tolerance. Upon signing up for the AdvisorNXT platform, you will be provided with a risk Page 4 of 25 tolerance questionnaire, that will help the robo-advisor determine the ideal portfolio for your specific investing needs. AdvisorNXT offers you the choice on which Investment Plan would best support your needs. Under the Personal Plan, you will have unlimited phone access to our reliable client support team, have simple to use investment tools, and be provided with automated rebalancing of your portfolio. The Professional Plan offers you everything provided under the Personal Plan, with the addition of having unlimited access to our team of Licensed Representatives for guidance. The Premiere Plan is our most comprehensive, offering you a dedicated wealth manager who will work with you on a regular basis to address your specific needs, and will also offer you in-depth advice of services and products offered outside of AdvisorNXT. See section “Investment Management Fee,” for an in- depth description of each service line. The AdvisorNXT Platform utilizes Nobel Prize winning Modern Portfolio Theory techniques to create optimal portfolios for each client. It is intended that clients utilizing the AdvisorNXT platform will also have access to traditional wealth managers to either enhance or replace the AdvisorNXT platform. Modern Portfolio Theory seeks to optimize expected portfolio returns for specific levels of risk. The technique is referred to as Mean Variance Optimization (MVO) and it requires a series of highly complicated calculations in which all possible combinations of the potential asset classes are evaluated to determine the optimal blend of allocations for each individual client. AdvisorNXT selects low-cost, well-managed exchange traded funds (ETFs) and exchange traded notes (ETNs) that represent the asset classes that we believe will provide our clients the necessary risk- adjusted exposure given current market conditions. In order to determine a client’s risk tolerance, a prospective client answers a series of objective questions posed in the form of an interactive digital interview. Once a client’s risk tolerance is determined, the AdvisorNXT algorithm will utilize “Modern Portfolio Theory” to create an optimized allocation across a diverse selection of asset classes, thus tailoring a portfolio to a client’s specific investment objectives and risk tolerance. The AdvisorNXT program will continuously monitor client accounts and periodically adjust portfolios to address changes in market and economic conditions. Envestnet Siebert offers its clients access to investment managers and advisory services of Envestnet Asset Management, Inc. Envestnet is registered with the SEC as an investment advisor and provides investment advisory services, technology services, and products to our advisory clients. Upon contracting to an Investment Strategy Proposal, clients grant full discretionary authority to Envestnet to determine the securities to be bought and sold, and the amount and time of those transactions. When creating a proposal for a client, Siebert uses Envestnet’s Asset Managers and clients grant full trading discretion to the money manager. Upon beginning an advisory relationship and/or with subsequent amendments to Envestnet’s Brochure, you will also receive Envestnet’s updated Brochure. While the portfolio managers offered through Envestnet’s Asset Managers may act on a discretionary basis, clients may at any time place restrictions on certain types of investments, certain asset managers, or other restrictions. Siebert may, at its own discretion, terminate an advisory relationship if it determines that a clients’ restrictions are not feasible through the advisory platform and/or prohibitive based on the services offered. FMAX Platform The FMAX Platform provides access to a wide range of investment strategies (“Strategies”) provided by professional investment managers (“Investment Managers”), including FIWA (“Fidelity Institutional Wealth Adviser LLC”). Investment Managers may be affiliated or unaffiliated with FIWA or the Intermediary. FIWA has contracted with Investment Managers to provide these Strategies to the Intermediary for use with Your Program Assets. The FMAX Platform also provides access to a wide range of actively managed, passively managed, and liquid alternative mutual funds and ETPs (mutual funds and ETPs, when discussed together, are hereinafter referred to as “Funds”) that are managed by the Investment Managers.
Page 5 of 25 Fees and Compensation Our annual fees for Investment Supervisory Services are based upon a percentage of assets under management and generally range from .25% to 2.5%. A minimum of $25,000 of assets under management is typically required for this service. This account size may be negotiable under certain circumstances. Siebert AdvisorNXT may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Limited Negotiability of Advisory Fees: Siebert AdvisorNXT has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the Investment Management Agreement (IMA) between the adviser and each client. IARs may in their separate capacity may be licensed as registered representatives of Muriel Siebert & Co., Inc, an affiliated broker-dealer and/or licensed as insurance agents or brokers. These individuals are able to implement investment recommendations for clients for separate and typical compensation (i.e., commissions, 12b-1 fees or other sales-related forms of compensation). This presents a conflict of interest to the extent that these individuals recommend that a client invest in a security which results in a commission being paid to the individuals. Siebert AdvisorNXT does not charge advisory fees in addition to commissions or mark ups when one of its IARs sells securities products through Muriel Siebert & Co., Inc. Clients are not under any obligation to engage these individuals when considering implementation of advisory recommendations and clients have the option to purchase investment products that our IARs recommend through other brokers or agents that are not affiliated with us. The implementation of any or all recommendations is solely at the discretion of the client. AdvisorNXT The AdvisorNXT program is a wrap fee program sponsored by Siebert. This portion of the Wrap Fee Brochure describes the business of Siebert as it relates to clients receiving services through the AdvisorNXT Program. Certain sections also describe the activities of the Firm’s Supervised Persons, which refer to any officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or other persons who provide investment advice on behalf of AdvisorNXT. The Program includes discretionary investment advice offered by AdvisorNXT through one of three levels of service: AdvisorNXT Personal offers you a self-directed service that provides risk-based investment advice based on certain information you provide via the website. After filling out an online questionnaire, AdvisorNXT then provides investment advice in the form of an optimized portfolio allocation across a diverse selection of asset classes tailored to a client’s specific investment objectives and risk tolerance. AdvisorNXT’s advice for each of your goals is based on AdvisorNXT’s investment methodology regarding risk-based asset allocation strategies and certain information and preferences requested by AdvisorNXT and provided by you. The AdvisorNXT algorithms will also continuously monitor client accounts and periodically adjust portfolios to address changes in market and economic conditions. You will not have access to an Investment Advisor Representative, and you must be willing to receive investment advice over the internet in order to use the services provided. AdvisorNXT, however, provides customer support over the telephone and internet for purposes of technical support, but such support is educational in nature only. The fee for Personal Service is 0.25%.
Page 6 of 25 AdvisorNXT Professional offers you access to support from a pool of qualified Investment Advisor Representatives in addition to the AdvisorNXT Personal Service. The AdvisorNXT Professional Service uses a team-based approach, and you are likely to interact with multiple financial consultants. The fee for Professional Service is 0.50%. AdvisorNXT Premiere offers you access to an assigned, dedicated, qualified Investment Advisor Representative who will interact with the client on a regular basis and will be responsible for managing clients’ investment needs, in addition to everything that is offered under the Professional Service. The fee for Premiere Service is negotiated between the client and representative and will fall between .25% and 2.50%. Participation in the AdvisorNXT Professional and Premiere Plans will entitle clients to an unlimited number of telephone consultations per year with a Siebert financial consultant, subject to the availability of such financial consultants. Telephone consultations will be scheduled on Business Days during Siebert’s normal business hours, as described on the website. Please note, however, that the financial consultant is not an attorney or accountant, and no advice given to you through the Siebert AdvisorNXT Services should be interpreted as tax or legal advice. Any tax information provided by Siebert is not a substitute for the advice of a qualified tax advisor. Clients should consult a third-party advisor to discuss tax-related concerns. The annual fee includes all brokerage commissions, transaction fees, and other related costs and expenses except those inherent in a particular investment vehicle. The annual investment advisory fee is prorated and charged quarterly, in advance, based upon the market value of the assets under management as of the last day of the previous quarter. AdvisorNXT may change the fee at any time by giving 30 days’ prior written notice. General AdvisorNXT Robo Management Fee Program AdvisorNXT offers you a dedicated Investment Advisor for support and guidance with other investments outside the three levels of service offered by the AdvisorNXT Program. Participation in this more personalized management fee program may incur an annual fee up to 1.50%. Investment Advisory Fees are negotiated with the client The Fee Schedule above is the starting point of the negotiation. As such, Siebert negotiates fees with the client(s) and may charge a lesser management fee than is what is listed in the Fee Schedule immediately above. Clients provide written authorization either as part of the Investment Advisory Agreement, or separately, authorizing the Firm to deduct a client’s fees directly from the client’s account. Investment Advisory Fees can also be paid by check. Any Investment Advisory Fee deducted from the client’s account will appear on the client’s account statement from their custodian. In addition, at the client’s request the Firm will provide the Client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. It is the responsibility of the client to verify the accuracy of these fees as

listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Page 7 of 25 Fees for Management during Partial Quarters of Service Investment Advisory Fees for the initial period or the first quarter of service are calculated on a pro rata basis from the inception date of the account to the end of the first quarter. We use an asset evaluation method in which asset value is computed as the average of ending asset market values for each day in the billing period of the previous quarter. Contribution and Withdrawal bills will not be generated when ADB is used since these flows are factored into the calculated ADB. The Agreement between the Firm and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. The Firm’s fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. Clients may make additions to and withdrawals from their account on notice to Siebert subject to the usual and customary securities settlement procedures, and subject to Siebert’s right to terminate an account. Additions may be in cash or securities provided that Siebert reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Siebert designs certain of its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Siebert may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. Contingent deferred sales charge) and/or tax ramifications. Siebert prohibits clients from self- directing trading in their managed account. Fees Charged by Financial Institutions The Firm generally recommends that clients utilize the brokerage and clearing services of either National Financial Services LLC (“NFS”) or Muriel Siebert & Co., Inc. for investment management accounts. The Firm may only implement its investment management recommendations after the client has arranged for and furnished with all information and authorization regarding accounts with appropriate financial institutions. Financial institutions include, but are not limited to, NFS or any other broker dealer recommended by Siebert, broker-dealer directed by the client, trust companies, banks, etc. (collectively referred to herein as the “Financial Institutions”). Siebert AdvisorNXT or its affiliates may receive compensation in connection with the purchase and/or ongoing maintenance of positions in certain mutual funds in your account. This compensation may take the form of the receipt of 12b-1 fees or other revenue sharing payments. Such fees and revenue would be paid to Muriel Siebert & Co., Inc. 12b-1 fees are considered to be an operational expense and as such is included in a funds expense ratio. It is generally between 0.25 and 1% of a fund’s net assets. For additional information on a mutual fund payment and compensation practices, review the applicable prospectus or offering statements. Such fees may create a conflict of interest because many mutual funds offer a variety of share classes, including some that pay 12b-1 fees and others that do not. When there is a lower cost share class available that does not charge a 12b-1 fee or charges a lower 12b-1 fee it may be in the best interest for the client to invest in the lower cost alternative share class so as to not reduce investment returns. The Siebert AdvisorNXT robo-platform does not participate in any 12b-1 fees or any revenue sharing arrangements. Siebert also offers its clients access to investment managers and advisory services through Envestnet, a Sub-Advisor. Envestnet has developed a method of screening and selecting mutual funds by performance and risk characteristics, asset class, minimum fund size, inception date, manager tenure, load fees and security holdings. Envestnet will pass to Siebert all 12b-1 fees or other revenue sharing that it may receive. Page 8 of 25 Brokerage Fees and Commissions As described above, clients do not pay brokerage commissions or other fees to their Custodian in connection with the AdvisorNXT Program. The Custodian may, however, receive other revenues in connection with the Wealth Management Program. Brokerage arrangements are further described below. In addition, you may incur charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, step-out fees, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap fee you are charged by the Firm. Account Additions and Withdrawals Clients make additions to and withdrawals from their account at any time, subject to the Firm’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to AdvisorNXT, subject to the usual and customary securities settlement procedures. However, AdvisorNXT designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a client’s investment objectives. AdvisorNXT may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fess assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. Envestnet Siebert offers wrap fee programs through Envestnet. There are no differences in how we manage the wrap fee services and other accounts. Siebert may receive a portion of the wrap fee for our services. Compensation Siebert’s standard advisory fees are negotiated at the time of account opening. Siebert’s management fees, inclusive of platform and advisor fees, and typically will not exceed 3% of assets under management. When an Envestnet advisor is selected, Siebert receives a portion of the fee charged to the client while Envestnet receives a platform and advisory fee. All fees are negotiated at the time of the contract and total fees typically will not exceed 3% of assets under management. The fee will be stated in the client’s agreement. Fees are payable quarterly, on the first business day of the quarter. Lower fees for comparable services may be available from other sources. Forms of Payment Client authorizes Advisor to bill the Custodian and to authorize the Custodian to pay Advisor directly the fees described above. The Custodian has agreed to send to Client at least quarterly a statement indicating all amounts disbursed from the Account, including the amount of fees paid directly to Advisor. Page 9 of 25 Other Fees and Expenses Siebert may charge other fees for services not included in the advisory relationship such as wire fees, transfer fees, and other administrative fees. What is a “Wrap Fee” Program? A wrap fee program allows our clients to pay a specified fee for investment advisory services and the execution of transactions. The advisory services include portfolio management, and the fee is not based directly upon transactions in your account. Your fee is bundled with our costs for executing transactions in your account(s) this results in a higher advisory fee to you. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. By participating in a wrap fee program, you may end up paying more or less than you would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to you by the executing broker. Portfolio Management For services provided by Siebert, Investment Advisory Fees are on a negotiated basis and are paid quarterly in advance on the last day of the previous quarter end pursuant to the terms of the Investment Advisory Agreement. Investment Advisory Fees are based on the market value of the assets under management at the end of each calendar quarter and the fees are negotiated with the client. Lower fees for comparable services are available from other sources. The Investment Advisory Fee schedule is the starting point for the client to negotiate from and typically is as follows: 2.0% on the first $500,000 1.50% on the next $500,000 1.25% on the next $1,000,000 1.00% on the next $3,000,000 0.75% on assets in excess of $5,000,000 Investment Advisory Fees are negotiated with the Client The Fee Schedule above is the starting point of the negotiation. As such, Siebert negotiates fees with the client(s) and may charge a lesser management fee than is what is listed in the Fee Schedule immediately above. Clients provide written authorization either as part of the Investment Advisory Agreement, or separately, permitting Siebert, the independent manager or third-party manager provider or their custodian to deduct Siebert and client’s manager’s fees directly from the client’s account and remit to the respective parties. Investment Advisory Fees can also be paid by check. The amount due is calculated by applying the quarterly rate to the total assets under management with Siebert at the end of the prior quarter. The Client’s fees will take into consideration the aggregate assets under management with the advisor. Any Investment Advisory Fee deducted from the clients account will appear on the clients account statement from NFS, Muriel Siebert & Co., Inc. or other custodian. In addition, at the client’s request Siebert will provide the client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. It is the responsibility of the client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Page 10 of 25 Fees for Management during Partial Quarters of Service Investment Advisory Fees for the initial period or the first quarter of service are calculated on a pro rata basis from the inception date of the account after the inception of a quarter, the fee payable with respect to such assets may be adjusted on a pro rata basis for deposits and/or withdrawals occurring within such quarter and will be calculated in accordance with the advisory agreement based on the days remaining in the quarter. The agreement between Siebert and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. Siebert’s fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. Clients may make additions to and withdrawals from their account on notice to Siebert subject to the usual and customary securities settlement procedures, and subject to Siebert’s right to terminate the account. Additions may be in cash or securities provided that Siebert reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Siebert designs certain of its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Siebert may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. Siebert prohibits clients from self-directing trading in their managed accounts. Fees Charged by Financial Institutions As further discussed in response to Item 9 below, Siebert generally recommends that clients utilize the brokerage and clearing services of National Financial Services LLC (“NFS”) or Muriel Siebert & Co., Inc. for investment management accounts. Siebert may only implement its investment management recommendations after the client has arranged for and furnished Siebert with all information and authorization regarding accounts with appropriate financial institutions. Financial institutions include, but are not limited to, NFS, Muriel Siebert & Co., Inc., or any other broker dealer recommended by Siebert, broker dealer directed by the client, trust companies, banks, etc. (collectively referred to herein as the “Financial Institutions”). Clients may incur certain charges imposed by the Financial Institutions and other third parties such as fees charged by Independent Managers, custodial fees, charges imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfers and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee programs, clients may incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to Siebert’s fee. In addition to the transactional charges described above, clients may also pay the following separately incurred expenses, which we do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). Clients should review the ADV brochures of any third-party managers for details about any additional fees they charge. Performance-Based Fees and Side-By-Side Management Siebert does not have any performance-based fee arrangements. “Side by Side Management” refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time manages other accounts for which fees are assessed on a performance fee basis. Because Siebert has no performance-based fee accounts, it has no side-by-side management. Page 11 of 25