Commonwealth Financial Services, LLC (“CFS”) is registered as an investment adviser with the Securities and Exchange Commission (“SEC”) in order to offer investment advisory products and services to its advisory clients. Advisory products and services are offered through Financial Advisers (“FAs”) who have registered as Investment Adviser Representatives (“Advisory Representative”). Registration does not imply a certain level of skill or training. CFS is owned by Michael Seese, Todd Kimpel, and Daniel Spurgeon. CFS will henceforth be referred to as “we”, “us”, “our” or the “Firm”. We have been an SEC Registered Investment Adviser since 2023 and manage, as of December 31, 2023, $649,546,505 of assets on a discretionary basis and $0 on a non-discretionary basis. Except as discussed below, each of our Advisory Representatives is permitted to offer all or any combination of the advisory programs described below to our clients ("you” or “your”). ASSET MANAGEMENT SERVICES PROGRAM The Asset Management Services Program provides comprehensive investment management of your assets through highly customized and individualized investment strategies crafted to focus on your specific goals and objectives. We provide this investment management service through accounts maintained through Schwab Advisor Services (“Schwab”) and Fidelity Institutional Wealth Services (“Fidelity/IWS”). The Asset Management Service Program is a program where the Advisory Representative is the portfolio manager. Your Advisory Representative has the option to allocate your portfolio amongst a mix of stocks, bonds, options, exchange- traded funds, mutual funds and other securities (“Program Investments”) which are based on your investment goals, objectives, and risk tolerance. Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. For further Asset Management Services Program details, please see the Asset Management Services Program Brochure. We provide this brochure to you prior to or concurrent with your enrollment in the Asset Management Services Program. Please read it thoroughly before investing. PARTICIPANT RETIREMENT PROGRAM Through the Participant Retirement Program, CFS and Advisory Representatives offer investment advisory services to participants in tax-exempt retirement account assets in employer sponsored retirement plans (“Plan”). Under the Participant Retirement Program, you elect to have your Advisory Representative manage your contributions to the Plan, any contributions by your employer or Plan sponsor on your behalf and any other additions to the Plan on behalf of or attributable to you (collectively, “Plan Assets”). Through your Advisory Representative, CFS provides advice with respect to Plan Assets in your account only including additions, substitutions, and proceeds. CFS is not responsible for the actions or non-actions of predecessor investment advisors, managing any assets other than the Plan Assets allocated to your account or administration of the Plan. In managing your account, CFS will, but is not required to, consider any other securities, cash or other investments owned by you. You maintain the ability to impose reasonable restrictions on management of your account, including the ability to instruct us not to purchase certain investments or securities. Your Advisory Representative will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance, investment objectives, investment time horizon or restrictions you may wish to impose on the account. At no time will CFS act as custodian of the Plan or have direct access to the Plan’s funds and/or securities. Custody of Plan Assets is maintained with Fidelity/IWS or American Funds and the Custodian firm will process the orders for securities transactions in your account in its broker-dealer capacity when your Advisory Representative enters such orders. Participant Account Management We use a third-party platform (Pontera) to facilitate management of some held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. THIRD PARTY ADVISORY SERVICES CFS offers you the services of various third-party money managers (“Third Party Money Managers” or “TPMMs”) for the provision of certain investment advisory programs including mutual fund wrap and separately managed account programs. In doing so, we act in a “co-advisory” or “solicitor” capacity. TPMMs typically maintain their own custodial relationships and do not leverage the custodial relationship CFS has with Schwab or Fidelity except for certain TPMMs detailed below. Third-party money managers have differing minimum account requirements and a variety of fee ranges. Each manager’s advisory services, fees and expenses, program termination and other information is set forth in their disclosure brochures, client agreements, account opening documents and applicable fund prospectuses. Your Advisory Representative will assist you in opening an account and, when doing so, you will execute an agreement directly with the selected money manager. Most third-party money managers assume limited discretionary authority over your account, meaning that the selected manager has the authority to purchase and sell securities in your account without contacting you first. Some third-party managers may allow you to impose restrictions on investing in specified securities or types of securities. When acting in a co-advisory capacity, CFS and the Third Party Money Manager are jointly responsible for the ongoing management of your account. In connection with this agreement, your Advisory Representative will provide assistance in the selection and ongoing monitoring of a particular Third Party Money Manager. Factors we consider in the selection of a particular Third Party Money Manager include, but are not limited to: i. Our assessment of a particular Third-Party Money Manager; ii. Your risk tolerance, goals, objectives, and restrictions, as well as investment experience; and iii. The assets you have available for investment. In some instances, your Advisory Representative has discretion to act as the portfolio manager for your account. If you are interested in learning more about these services, please note that a complete description of the programs, services, fees, payment structure and termination features are available via the applicable Third Party Money Manager’s disclosure brochures, investment advisory contracts, and account opening documents. You should know that the services provided by us through the use of Third-party Money Managers are under certain conditions directly offered by them to you. The fees charged by Third Party Money Managers who offer their programs directly to you may be more or less than the combined fees charged by the Third Party Money Manager and us for our participation in the investment programs. Your Advisory Representative can also act purely in a solicitor capacity when referring you to a TPMM. When acting as a solicitor for the TPMM program, the Firm and your Advisory Representative do not provide advisory services in relation to the TPMM program. Instead, your Advisory Representative will assist you in selecting one or more TPMM programs believed to be suitable for you based on your stated financial situation, investment objectives, and financial goals. The TPMM will be responsible for assessing the suitability of their investment recommendations against your risk profile and we are compensated for referring you to the TPMM program. This compensation generally takes the form of the TPMM sharing a percentage of the advisory fee you pay to the TPMM. When we act as a solicitor for a TPMM program, you will receive a written solicitor disclosure statement describing the nature of our relationship with the TPMM program, if any; the terms of our compensation arrangement with the TPMM program, including a description of the compensation that we will receive for referring you to the TPMM program. Please consult the applicable Third Party Money Manager’s agreement for further information. The amount of compensation received by our firm and your Advisory Representative from a particular money manager could be higher than the compensation received from another money manager. This is because compensation structures vary by product type as well as manager programs provided. This results in a conflict of interest because your Advisory Representative has a financial incentive to recommend one money manager over another in order to receive greater compensation. There can be other suitable money managers that are more or less costly. Trading by third-party money managers can trigger wash sale rule implications. A wash sale occurs when a security is sold at a loss and then the same or substantially identical security is repurchased within a short time period. The third- party money manager cannot necessarily manage accounts in a manner to avoid wash sale implications. You are encouraged to consult with a tax advisor to discuss any tax implications involving your portfolios in these and in all advisory programs. FINANCIAL PLANNING AND FINANCIAL PLANNING CONSULTATION SERVICES Commonwealth Financial Services and your Advisory Representative offer advice through the presentation of financial plans. Clients using these services can receive a written financial plan providing them with a financial blueprint designed to achieve their stated financial goals and objectives. Plans can be comprehensive or focus only on specific areas of concern to you. In general, a financial plan can address any or all of the following areas:
• Cash management
• Insurance coverage
• Death and disability planning
• Divorce planning
• College planning
• Investment portfolio review
• Estate and retirement planning
• Income distribution In addition, Commonwealth Financial Services and your Advisory Representative provide financial planning consultation services on specific areas of concern to you. These services can also include retirement plan consulting services provided to the plan sponsor or to individuals wanting advice on how their plan investments should be allocated. Additionally, CFS and your Advisory

Representative can provide financial planning services to business entities and groups requesting educational services and financial planning seminars or individual consulting and planning services for employees or members. If individual planning or consulting services are provided, each participating employee or member will be required to execute a separate agreement with us. These services will be advice-only services; CFS and your Advisory Representative will not implement transactions on your behalf as part of these services. If you want CFS or your Advisory Representative to implement transactions on your behalf, you need to contract with CFS and your Advisory Representative for our investment management services described elsewhere in this section. You are under no obligation to act upon CFS’s or your Advisory Representative’s recommendations, and you have sole discretion whether to implement any recommendations. If you elect to act on any of the recommendations, you are under no obligation to effect transactions through CFS or the Broker/Dealer of CFS’ Custodian(s). When providing financial planning and financial planning consultation services, your Advisory Representative gathers information through interviews concerning your current financial status, goals and objectives, risk tolerance and time horizon. We may also request that you complete a questionnaire and provide additional documentation. Depending on the level of services requested, your Advisory Representative can prepare a written report. Implementing any recommendation can require you to work closely with your attorney, accountant and/or insurance agent. Implementation is entirely at your discretion. Your Advisory Representative can also provide advice on non- securities matters. Generally, this is in connection with rendering estate planning, college planning and insurance and/or annuity advice. Some states preclude your Advisory Representative and CFS from receiving a financial planning fee for services customarily associated with soliciting insurance sales or servicing an insurance contract. Other states permit your Advisory Representative and CFS to receive an insurance financial planning fee and an insurance commission provided certain conditions are met, such as written disclosure about the services and compensation. Please consult with your Advisory Representative if you have questions about which regulations govern you and your account. Financial planning services can be terminated at any time upon written notice of either CFS, its Advisory Representative or the client. Upon termination, clients are entitled to a refund of all deposits not already earned. Clients can terminate services within 5 business days from the date of executing the agreement for services and receive a refund of no less than one-half of the retainer or any unearned portion of the retainer, whichever is greater. If clients do not receive CFS’s written disclosure brochure at least 48 hours prior to executing the agreement for services, they have 5 days from the engagement date to cancel with a full refund of any fee or retainer. RETIREMENT PLAN ADVISORY SERVICES Our Advisory Representatives provide qualified retirement plans with investment advisory services that can be fiduciary and/or non-fiduciary in nature. Fiduciary services include plan review (e.g., design, operations, documentation and benchmarking plan expenses) and recommendations (regarding the investment policy statement, investment options and/or investment managers). Non-fiduciary services include participant education and communication. Services are provided on a discretionary basis. For all services provided, the plan’s named fiduciary retains sole decision-making authority and responsibility for the plan’s investment policy statement, selecting and maintaining investment alternatives available under the plan and implementing any plan, advice or strategy provided by CFS and/or its Advisory Representative. Under the Retirement Plan Advisory Agreement, the plan sponsor authorizes and engages CFS and its Advisory Representative to provide services to the plan. When providing these services, CFS and its Advisory Representative can rely on information provided by independent third parties. These third parties are believed to be reliable, but CFS and its Advisory Representative have no obligation to independently verify the information provided by them. The name fiduciary acknowledges that CFS and its Advisory Representative can rely on such third-party information while providing any requested services and will have no liability for the accuracy or consistency of such information or for any loss caused by such information. CFS and its Advisory Representative can also rely on material and pertinent information provided by the named fiduciary about the plan, its participants, and beneficiaries. The advisor has no obligation to verify the information provided by the named fiduciary and will have no liability for any loss caused by errors in such information. Your Advisory Representative can provide any of the following services as selected by the plan sponsor and named fiduciary: FIDUCIARY SERVICES I. Discretionary Advisory Services Discretionary Investment Manager. The plan trustee can appoint CFS and its Advisory Representative as an “investment manager.” To the extent CFS and its Advisory Representative provide discretionary advisory services under the Retirement Plan Advisory Agreement, they acknowledge their status as “investment manager” for purposes of ERISA Section 3(38). CFS and its Advisory Representative can maintain investment portfolio(s) on a discretionary basis, including investing, rebalancing assets, changing asset allocations, or changing underlying model portfolios. The advisor and its Advisory Representative exercise this authority in accordance with the objectives set forth by the named fiduciary, as may be amended from time to time, and in accordance with any additional written guidelines and/or investment policies provided by the named fiduciary. CFS and its Advisory Representative will communicate their decisions to the named fiduciary on a reasonable basis. NON-FIDUCIARY SERVICES Participant Education and Communication. Your Advisory Representative can provide educational, and investment related information, materials and software as allowed by rule or regulation as long as the information does not constitute giving fiduciary investment advice. This can include:
• Conducting periodic group enrollment and education meetings with employees and educational meetings with plan participants and beneficiaries.
• Providing information and materials informing plan participants, employees, or beneficiaries about the benefits of plan participation, the benefits of increasing contributions, the impact of pre - retirement withdrawals, the terms of the plan or operations of DIAs. The information provided can include interactive investment materials to assist with future retirement income needs and the impact of different asset allocations on retirement income.
• Providing retirement readiness consulting, which can include third party software to assess a "gap" analysis to determine sufficient retirement income. Additionally, participant education can extend to analyzing plan expenses and fees. The Advisory Representative will not render individualized investment advice to participants and will not be held to a fiduciary standard for the non-fiduciary services rendered. Covered Service Provider Disclosures for ERISA Plans As a covered service provider to ERISA plans, CFS will comply with the U.S. Department of Labor regulations on fee disclosures. CFS and your Advisory Representative will disclose (i) direct compensation received from ERISA clients, (ii) indirect compensation received from third parties and (iii) transaction -based compensation (e.g., commissions) or other similar compensation shared with related parties servicing the ERISA plan. These fee disclosures will be made reasonably in advance of entering into, renewing, or extending the advisory service agreement with the ERISA client. In some instances, CFS and your Advisory Representative will be providing certain services to the plan in a fiduciary capacity while providing other services that are not fiduciary in nature. The Retirement Program Advisory Agreement executed between CFS, and the plan will specifically state whether or not the Advisory Representative is acting in a fiduciary capacity when providing the services. Schedule A of the Retirement Program Advisory Agreement discloses the scope of services that are being provided to the plan. Such services are disclosed as “fiduciary” or “non-fiduciary.” “Fiduciary” services are disclosed as discretionary. Fees for retirement plan advisory services are charged on either an asset based or flat fee basis, although some legacy accounts can have advisory fees or level commissions charged instead. The Retirement Plan Advisory Agreement will disclose the fees to be charged, as well as other compensation received by CFS, your Advisory Representative or their affiliates in connection with providing services to your plan or any other charges (e.g., transaction fee charges) applying to plan accounts. Services can be terminated by the plan’s named fiduciary without penalty within 5 days of executing the client agreement. After that, the client agreement can be terminated by CFS or the named fiduciary at any time with 60 days’ prior written notice. The agreement will not terminate if it is assigned to a different Advisory Representative. LENDING SERVICES Securities Backed Line of Credit (SBLOC) / Non-Purpose Loans The Firm offers you SBLOCs offered through participating third party banks. SBLOCs are loans whereby an investor borrows against the assets in his or her investment portfolio without having to liquidate these securities. These loans require monthly interest-only payments, and the loan remains outstanding until it is re-paid. SBLOCs are non- purpose loans, which means the loan proceeds can be used for almost anything except the proceeds may not be used to purchase or trade securities. An SBLOC allows you the opportunity to avoid potential capital gains taxes because you don’t have to liquidate securities for access to funds. You might also be able to continue to receive the benefits of your holdings, like dividends, interest, and appreciation. However, as with virtually every financial product, SBLOCs have risks and downsides. For instance, if the value of the securities you pledge as collateral decreases, you may need to come up with extra money fast, or your positions could be liquidated. Prior to establishing a SBLOC, you should carefully review the disclosure form provided by the Firm. CONSULTING SERVICES Financial Institution Consulting Services CFS provides investment consulting services to certain Broker/Dealers’ customers ("Brokerage Customers”) who provide written consent requesting to receive CFS’ consulting services. Brokerage Customers have entered into a written advisory agreement with CFS.