Diversified, LLC ("Diversified" or "the firm") is an investment advisor domiciled in the State of Delaware. Diversified was founded in 1982 and became a registered investment advisor in 1994. In 2006, the Limited Liability Company, Diversified Financial Consultants, LLC was formed and that entity became the registered investment advisor. The legal name of the firm was changed to Diversified, LLC in January 2019. Diversified's direct owners with equal ownership are David Levy and Andrew Rosen, and the firm's main office is located in Wilmington, Delaware. Investment advisory services are offered by the firm's registered investment advisory representatives ("Diversified Associates" or "Associates").
Financial Planning Services Diversified offers comprehensive Financial Planning Services to its clients typically in a two-phase process. The phases of the financial planning process are as follows: Phase One In Phase One, Diversified performs the on-boarding financial planning phase. This includes, but is not limited to, Cash Flow Management; College Planning; Tax Planning; Debt Ratios and Refinancing; Insurance matters (business, group and personal); Company Benefit Analysis; Retirement Planning; other Business Matters; Estate Planning; Social Security Planning; Investment Planning; Charitable/Legacy Planning; Family Budgeting and Asset Allocation. Diversified reviews a client's overall financial situation and makes observations and recommendations concerning past, present, and future placement of monies into investments, savings, and insurance, based on the individual needs of the client.
Phase Two In Phase Two, Diversified implements the recommendations made in Phase One, described above, and provides on-going financial planning services which includes all matters previously mentioned in Phase One, as well as asset management services, if selected by the client. Diversified provides on-going financial planning advice on a retainer and/or asset management fee basis. On-going financial planning services include, at minimum, a yearly review of the client's financial plan, with adjustments based on changes in the client's situation.
Clients have the option of choosing from two levels of financial planning services, each of which incorporates the Phase One and Phase Two planning described above. Clients may select either of the two levels described below:
•Platinum Financial Planning Clients are those clients who desire an integrated comprehensive financial plan, which includes an interactive planning forecast and a cash-flow analysis. Diversified will prepare a personalized financial plan, using a web-based platform, with unlimited meetings and advice. After the first year, Client receives unlimited advice and planning forecast in addition to access to Diversified's network of professionals for a fee.
•Gold Financial Planning Clients are those clients who do not desire an integrated comprehensive financial plan, which includes an interactive planning forecast and a cash-flow analysis but do desire a comprehensive review of their entire financial situation. After the first year, Client receives unlimited advice and access to Diversified's network of professionals for a fee. Financial plans are based on a client's financial situation at the time we present the plan, and on the financial information the client provides to us. Clients must promptly notify our firm if their financial situation, goals, objectives, or needs change. Clients are under no obligation to act on our financial planning recommendations. Should a client choose to act on any of our recommendations, the client is not obligated to implement the financial plan through Diversified Associates. Moreover, a client may act on our recommendations by placing securities transactions with any brokerage firm. Clients who come to Diversified from another investment adviser may receive financial planning services consistent with a delivery model originally contracted at the prior firm. 4 Elite Services In addition to the Gold and Platinum offerings described above, clients may elect to add an Elite bundle add on which bundles one or more advanced-planning services that may include additional estate planning or tax planning services, asset management, 401k management, retirement plan advisory services, and/or any of the other advisory services offered by Diversified. With Elite services, clients have the option of receiving advanced financial planning services for a bundled fee, which could include the development of comprehensive estate planning documents (trusts, wills, power of attorneys, advance medical directives, etc.) prepared by an attorney with whom Diversified has a relationship, advanced tax planning including preparation of tax returns by an accountant associated with a firm affiliated with Diversified, or other advanced financial planning services. The Elite bundled services may also include asset management, 401k plan management, retirement plan advisory services, among other things. Each service selected by a client as part of an Elite bundled services package will be specified in the Elite Services Agreement a client signs with our firm. Clients engage affiliated and unaffiliated service providers separately and in their sole discretion.
Financial Consulting Services In some cases, clients may choose to engage Diversified for more limited financial consulting services. These services typically involve consultation on a specific or isolated area of concern, such as estate planning, retirement planning, or any other specific area of financial planning. Consulting services will generally not include the development of a written plan and will be more limited in focus based on a client's specific need.
Asset Management Services Diversified offers regular and continuous individualized asset management (portfolio managment) services to its clients either as part of the Phase Two financial planning services or as a stand-alone offering. In the case of a stand-alone offering, limited financial planning services (not including the comprehensive financial planning services described above) may be included as part of the fee charged for this service. These asset management services are offered on both a discretionary and non-discretionary basis. Through personal consultations with the client, Diversified gathers specific financial data to develop a client's personalized profile, which includes, but is not limited to, their investment objectives, current financial position, risk profile, investment time horizon, tax situation and liquidity needs. Diversified reviews the client's personalized profile and based upon this review, determines an appropriate portfolio management strategy, which may or may not include asset management offered by a third-party advisor. In some cases, asset management services will include management of a client's employer-sponsored 401k or other accounts held at custodians other than those recommended by Diversified ("outside account"). Such management may be on a discretionary or non-discretionary basis, as agreed to by the client and Diversified. If a client participates in our discretionary portfolio management services, we ask clients to grant our firm discretionary authority to manage the account. Discretionary authorization will allow us to determine the specific securities and the amount of securities to be purchased or sold for the account, or the third-party manager to manage the account, without the client's specific approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement the client signs with our firm and the appropriate trading authorization forms. Clients may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for the account) by providing our firm with their restrictions and guidelines in writing.
As part of Diversified's discretionary or non-discretionary asset management services, clients may engage us to provide advice related to held-away retirement assets, such as 401k plan assets. Diversified uses a third-party platform to faciliate the discretionary or non-discretionary management of these assets. The platform allows Diversified to avoid being deemed to have custody of these assets since neither Diversified nor a person associated with Diversified, has direct access to client log-in credentials to affect trades in these held-away accounts. Diversified is not affiliated with the platform in any way and is not compensated by the platform for use of their services. In order to establish access to the held-away accounts for discretionary or non-discretionary 5 management, a link is provided to the client allowing them to connect a held-away account to the platform. Once this connection is established, Diversified will review a client's investment allocations and will rebalance an account, as needed or recommended, consistent with a client's investment goals, risk tolerance, and objectives. Discretionary authority to manage these held-away assets is granted to Diversified through an agreement executed by the client. For non-discretionary management, a client must give explicit approval for Diversified to affect transactions in the client's account.
If a client enters into non-discretionary arrangements with our firm, we must obtain the client's approval prior to executing any transactions on behalf of the client's account. Non-discretionary clients have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
Third-Party Advisory Programs/Sub-Advisor Programs Diversified has relationships with third-party advisors which allow Diversified to refer clients to these investment advisors for individual asset management, separate accounts, or other programs as described in the third-party advisor's disclosure brochure. Diversified may also establish sub-advisor relationships with other third-party advisors, on a case-by-case basis. If Diversified has been

granted discretionary authority by a client, Diversified will determine if a relationship with a third-party advisor/sub-advisor is appropriate for the client, and will select the third-party advisor for the client. If Diversified is providing asset management services on a non-discretionary basis, Diversified may recommend the services of a third-party advisor, and the client will determine if that strategy is appropriate. Clients are given disclosure materials for the third-party investment advisor, if applicable, which include a description of the program being recommended. Clients may be required to enter into an Agreement with the third-party advisor, which in some cases may grant discretionary trading authority to the third-party advisor.
Retirement Plan Advisory Services Diversified offers retirement plan advisory services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary in the advisory agreement. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These retirement plan advisory services will be non-discretionary and advisory in nature as a 3(21) ERISA fiduciary, and will be specified in the Retirement Plan Agreement. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
Diversified may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification;
•Asset allocation;
•Risk tolerance; and
•Time horizon Educational seminars may include other investment-related topics specific to the particular plan.
Diversified may also provide additional types of retirement plan advisory services to plans on an individually negotiated basis and as specified in the advisory agreement. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents.
6 Either party to the Retirement Plan Agreement may terminate the agreement upon notice to the other party in accordance with the terms of the agreement for services. The retirement plan advisory fees will be prorated for the billing period in which the termination notice is given and any unearned fees, if any, will be refunded to the client.
Wrap Fee Program Diversified is a portfolio manager to and sponsor of a wrap fee program, which is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee that includes administrative fees, management fees, and commissions. If a client participates in our wrap fee program, the client will pay our firm a single fee, which includes our money management fees, certain transaction costs, and custodial and administrative costs. We receive a portion of the wrap fee for our services. The overall cost a client will incur in our wrap fee program may be higher or lower than might be incurred by separately purchasing the types of securities available in the program.
Transactions for a wrap account must be executed byCharles Schwab & Co. ("Schwab"), a registered broker/dealer and member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, clients should consider the frequency of trading activity associated with our investment strategies and the brokerage commissions charged by Schwab or other broker-dealers, and the advisory fees charged by investment advisers. For more information concerning the Wrap Fee Program, see Appendix 1 to this Brochure.
Financial Institution Consulting Services Diversified provides investment consulting services to certain broker/dealers' customers ("Brokerage Customers") who provide written consent requesting to receive Diversified's consulting services. Brokerage Customers have entered into a written agreement with Diversified. Such contractual engagements do not include assuming discretionary authority over brokerage accounts or the monitoring of securities positions. Services offered to Brokerage Customers may include a general review of client investments holdings, which may or may not result in Diversified Associates making specific securities recommendations or offering general investment advice.
Adviser to a Private Fund Diversified serves as investment adviser to an unaffiliated private limited partnership (the "Limited Partnership"), which invests primarily in fixed-income securities and obligations of the US Government and its agencies. Diversified is not the General Partner or a Limited Partner of the Limited Partnership. As the adviser to the Limited Partnership, Diversified develops a portfolio strategy and selects and monitors investments or portfolio managers and provides general investment advice to the Limited Partnership. No Diversified client or Associated Person is an investor in the Limited Partnership, and Diversified does not market, recommend or solicit investors for the Limited Partnership.
Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, Diversified is providing the following acknowledgment. When our firm provides investment advice regarding a client's retirement plan account or individual retirement account, Diversified is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Diversified makes money creates some conflicts with a client's interests, so Diversified operates under a special rule that requires our firm to act in our client's best interest and not put our interest ahead of a client. Under this special rule's provisions, Diversified must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of clients when making recommendations (give loyal advice); 7
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that Diversified gives advice that is in our client's best interest;
•Charge no more than is reasonable for our services; and
•Give clients basic information about conflicts of interest. Diversified benefits financially from the rollover of client assets from a retirement account to an account that our firm manages or provides investment advice, because the assets increase Diversified's assets under management and, in turn, our advisory fees. As a fiduciary, Diversified only recommends a rollover when we believe it is in a client's best interest.
General Information Related to Financial Planning and Investment Recommendations Diversified does not limit its investment advice to any specific type of product or security. In addition, some clients may receive different services ("legacy services") as disclosed in their executed investment advisory agreement. Such legacy services may have been negotiated by a firm from which Diversified has acquired client engagement through an agreed-upon assignment of an investment advisory contract or through the transfer of an investment adviser representative. Legacy services will be maintained by Diversified until and unless a new investment advisory agreement is executed by the client. A client's individual needs and objectives are analyzed to determine appropriate financial planning needs, and investment recommendations and asset management services are tailored to the individual client's needs. Clients are free to impose reasonable restrictions as to the types of securities recommended by Diversified, and for non-discretionary asset management, all investment decisions are the sole decision of the client. Since different types of investments typically involve different types of risk, Diversified conducts a risk analysis for the client and his/her overall portfolio before recommending a certain investment. In general, the firm provides advice on equity investments in individual stocks, no-load or load-waived mutual funds, exchange traded funds, and limited partnerships. Diversified also provides recommendations on fixed income investments, including individual bond positions, bond mutual funds, certificates of deposit, and fixed income exchange traded funds. Diversified may also provide advice on other types of investments, including non-securities products, that the firm feels are suitable for the client. As an investment advisor that offers financial planning services, a conflict may exist between the interests of the investment advisor and the interests of the client. Clients are under no obligation to act upon Diversified's recommendations, and should a client choose to act on any of the recommendations made by Diversified, the client is under no obligation to effect transactions through Diversified unless a separate asset management agreement is executed.
Assets Under Management Diversified provides regular and continuous asset management services to $1,553,774,222 in assets as of December 31, 2023. Of that amount, Diversified provides discretionary regular and continuous asset management services to $1,446,509,912 in assets, and non-discretionary regular and continuous asset management services to $107,264,310 in assets as of December 31, 2023.