ABOUT LFS LFS was incorporated in 1969 and has been registered with the SEC as an investment adviser since 1985. LFS is a wholly- owned subsidiary of Osaic Holdings, Inc., which is owned by a consortium of investors primarily through RCP Artemis Co- Invest, L.P. and RCP Harvest Co-Invest, L.P., investment funds affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2006 Trust. As of December 31, 2023, LFS managed approximately $3.2428 billion of client assets on a non-discretionary basis and approximately $1.2404 billion of client assets on a discretionary basis. LFS offers a wide variety of investment advisory programs and services. Certain of LFS’s IARs market their practices using marketing names that differ from the name under which LFS primarily conducts its advisory business. In these circumstances, clients should be aware that all investment advisory services described herein are provided by IARs through and on behalf of LFS, not the marketing names that IARs use to market their practices. LFS’s IARs assist clients in pursuing their financial goals by providing personalized financial planning services and investment solutions. The investment advisory programs and services described in this Brochure may also be offered by certain independently registered investment advisers, who are also registered representatives of LFS in its capacity as a registered broker-dealer (each, an “RIA”). References in this Brochure to the products and services offered by the IARs include the RIAs. This Brochure provides an overview of the investment advisory programs sponsored by third parties that are offered through LFS, LFS’s financial planning services, LFS’s retirement plan consulting program, and certain other advisory services. Any information you receive from LFS or the IARs relating to the tax considerations affecting your financial arrangements or transactions is not intended to be tax advice and you should not rely upon it as tax advice. Neither LFS nor the IARs provide tax, legal, or accounting advice. In addition to the advisory programs and services described in this Brochure, LFS also offers the following advisory programs and services, which are described in separate Forms ADV, Part 2A:  Lincoln WealthLincSM Platform (which includes the Lincoln WealthLinc Access Program and the Lincoln WealthLinc Alliance Program) (“WealthLinc”);  Custom Wealth Advantage Choice Wealth Management Program (the “CWA Choice Program”); and  Custom Wealth Advantage Program (which includes the Custom Wealth Advantage Separately Managed Accounts Program, Custom Wealth Advantage Unified Portfolio, the PMC Strategist Program, and the Custom Wealth Advantage Strategist Program) (the “CWA Program”). For a detailed discussion of each of the advisory programs and services listed above, including the fees and expenses you will pay, the compensation LFS and the IARs will receive, and LFS’s and the IARs’ conflicts of interest in connection with them, you should refer to the Form ADV, Part 2A for the particular advisory program or service, which is available on our website at www.lfsecurities.com under My accounts—Disclosures or at www.lfg.com/public/individual/adv, and on the SEC’s website at www.adviserinfo.sec.gov. These Forms ADV, Part 2A may also be requested by contacting LFS at (800) 237-3813 or LFNAdvisoryServices@lfg.com. AVAILABLE ACCOUNTS AND RELATIONSHIP TYPES When you choose to purchase products and services through LFS and work with an LFS financial professional, you have the option of investing through a transaction-based account, such as a brokerage account, a fee-based investment advisory program, or both. It is important for you to understand the services you will receive, the fees, costs, and expenses you will pay, and LFS’s and your LFS financial professional’s conflicts of interest in connection with each of these different types of accounts and relationships with LFS and your LFS financial professional. These services, fees, costs, expenses, and conflicts of interest are summarized below and described in much greater detail in LFS’s Form CRS, Regulation Best Interest (“Reg BI”) Disclosure Document, and Forms ADV, Part 2A, as applicable, which are available on LFS’s website at www.lfsecurities.com under My accounts―Disclosures. Transaction-Based Account, Such as a Brokerage Account With a transaction-based account, such as a brokerage account, you will pay commissions and other charges (such as sales loads on mutual funds and other securities and investment products) at the time of each transaction, such as the purchase or sale of a mutual fund, stock, bond, option, AI (as defined below), or other security or investment product. These commissions and other charges are LFS’s and your LFS financial professional’s primary source of compensation for the transaction-based advice your LFS financial professional provides when recommending such transactions. When serving as your broker, your LFS financial professional can make recommendations and provide guidance to you in selecting securities, other investment products, and services. Your LFS financial professional may also provide investment education and research services, which are incidental to the brokerage services LFS provides. A transaction-based account can potentially be more appropriate for you than a fee-based investment advisory account if you do not want ongoing investment advice on assets held in your account, or ongoing management of your account, and instead want only periodic or on-demand advice and recommendations specific to the purchase and sale of securities and other investment products. Additionally, this type of account can potentially result in lower costs for you if you expect to trade on an infrequent or occasional basis. When LFS and your LFS financial professional make securities and investment strategy recommendations to you as broker- dealer for your transaction-based account, such as a brokerage account, LFS and your LFS financial professional will be acting in their broker-dealer capacities for such account and are required to act in your best interest, without placing their financial or other interests ahead of your interests. Additionally, when LFS and your LFS financial professional provide investment advice to you on a regular basis regarding your Employee Retirement Income Security Act of 1974, as amended (“ERISA”), retirement plan account or individual retirement account (“IRA”), LFS and your LFS financial professional are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”), as applicable, which are laws governing retirement accounts. You should be aware that LFS and your LFS financial professional are subject to various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles LFS and your LFS financial professional play in a transaction, LFS’s and your LFS financial professional’s compensation arrangements, and LFS’s financial and other arrangements with custodians, clearing firms, other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in LFS’s Form CRS and Reg BI Disclosure Document, as well in the other important client disclosures available on LFS’s website, www.lfsecurities.com. For additional information on LFS’s broker-dealer services and transaction-based account offerings, please see LFS’s Form CRS and Reg BI Disclosure Document, which are available on LFS’s website at www.lfsecurities.com under My accounts―Disclosures. LFS’s Form CRS and Reg BI Disclosure Document may also be requested by contacting LFS at (800) 237-3813 or LFNAdvisoryServices@lfg.com. For detailed information regarding the commissions, trading/execution fees, and brokerage service charges that LFS establishes, controls, and charges clients when serving as broker-dealer of record for transaction-based accounts held with National Financial Services LLC (“NFS”), please see LFS’s Fee and Commission Schedule for Accounts with NFS (the “LFS Fee Schedule”), which is provided to you at account opening, will change over time, and can be found on LFS’s website at www.lfsecurities.com under My accounts—Cost. Before consenting to any broker-dealer relationship with LFS or an LFS financial professional, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation LFS and its financial professionals will receive, and LFS’s and its financial professionals’ conflicts of interest. After reviewing these disclosures, please address any questions you may have with your LFS financial professional. Fee-Based Investment Advisory Program A fee-based investment advisory program, sometimes called a “managed account,” can potentially be more appropriate for you than a transaction-based account, such as a brokerage account, if you want ongoing investment advice and management of your account. LFS offers a number of different investment advisory programs and services and acts as the sponsor and broker-dealer in connection with some of those programs and services. With a fee-based investment advisory account, you will pay an ongoing investment advisory fee based on the value of the assets held in your account in exchange for ongoing investment advice and management of your account and related services. This asset-based fee is LFS’s and your IAR’s primary source of compensation for the ongoing investment advice provided by your IAR. You generally will not be charged commissions for each purchase or sale of a security or other investment product in a fee-based investment advisory account; however, you will be charged for (1) any transaction, trading, and execution charges that are applicable to trades and other transactions (including, but not limited to, “step-out” trades) occurring within your account and (2) other fees, costs, and expenses applicable to your account, the brokerage and other services provided to you and your account, and the securities and other investment products purchased, held, and sold in your account, in each case as described in your account-opening documentation and in the prospectuses and other disclosure documents for the securities and other investment products you purchase, hold, and sell. Transaction, trading, and execution charges you pay are not used to compensate your IAR for their services in this type of account. Certain investment advisory programs that LFS offers charge an “all-inclusive” bundled fee based on the value of the assets in your account. This bundled fee usually includes a portfolio management fee, transaction, trading, and execution costs, and investment advice and is sometimes referred to as a “wrap fee.” However, this bundled fee does not include costs associated with transactions that are executed at broker-dealers other than the one at which your account is held. Transactions executed at broker-dealers other than the one at which your account is held are sometimes called “step-out” trades and are described further in Items 5 and 12 below. Fees vary depending on which LFS advisory programs and services you use. LFS’s advisory program fees are billed either in arrears (i.e., following the completion of the applicable billing period) or in advance (i.e., at the beginning of the applicable billing period) depending on the program you select, and your billing methodology (i.e., in arrears or in advance) will be specified in your client service agreement, Statement of Investment Selection or Statement of Insurance Selection, as applicable (“SIS”), or other account-opening documentation. Fees are charged either monthly or quarterly, as specified in your client service agreement, SIS, or other account-opening documentation, based on the assets held within your account for services including, but not limited to, ongoing investment advice, investment selection and recommendations, asset allocation, execution of transactions (depending on the program you are in), custody of securities, and account reporting services. Please see your client service agreement, SIS, and other account-opening documentation for additional information. After reviewing these documents, please address any questions you may have with your IAR. LFS permits certain alternative or non-traditional investments, including, but not limited to, non-traded real estate investment trusts, oil and gas programs, managed futures funds, interval funds, hedge funds, funds of hedge funds, private equity funds, and other limited partnerships, private placements, and non-traded investment programs (collectively, “AIs”), to be held within WealthLinc and Custom Wealth Advantage Wealth Management Program (“CWA”) accounts as “supervised” assets. The AIs LFS permits to be held within WealthLinc and CWA accounts as supervised assets generally will be in a share class designed or intended to be used in connection with a fee-based account. In these cases, LFS and its IARs will serve in an investment advisory capacity with respect to the supervised AI, LFS and its IARs will provide investment advisory services and oversight on the supervised AI as they would with other supervised assets maintained in the WealthLinc or CWA account, and the supervised AI will be included in the calculation of the WealthLinc or CWA account’s advisory fee and performance. If these circumstances are applicable to your AI, the AI Worksheet you complete in connection with your AI investment or your other account documentation will inform you of the fact that your AI will be a supervised asset included in the calculation of your WealthLinc or CWA account’s advisory fee and performance. Additionally, the quarterly performance reports you receive from LFS in connection with your WealthLinc or CWA account will reflect your AI as a supervised asset included in the calculation of your WealthLinc or CWA account’s advisory fee and performance. In some TAMP (as defined below) programs described in this Brochure, the third-party investment managers use AIs in the management of client accounts and include AI assets in their, LFS’s, and the IAR’s fee calculations and in their account performance calculations. Please see your account-opening documentation for additional information. Alternatively, certain AIs may only be held in WealthLinc and CWA accounts as “unsupervised” assets for consolidated reporting purposes and convenience (e.g., in certain cases where the AI was purchased on a commission basis outside of the WealthLinc or CWA account and is later transferred to the WealthLinc or CWA account). In these cases, LFS and its IARs will not serve in an investment advisory capacity with respect to the unsupervised AI, LFS and its IARs will not provide investment advisory services or oversight on the unsupervised AI, and the unsupervised AI will be excluded from the calculation of the WealthLinc or CWA account’s advisory fee and performance. If these circumstances are applicable to your AI, the quarterly performance reports you receive from LFS in connection with your WealthLinc or CWA account will reflect your AI as an unsupervised asset that is not included in the calculation of your WealthLinc or CWA account’s advisory fee and performance. While unsupervised AIs are not included in the calculation of WealthLinc or CWA account advisory fees, clients’ unsupervised AIs are subject to all other applicable fees as described in the transaction, trading, execution, and brokerage service fee schedules and other documentation applicable to their WealthLinc or CWA account, including, but not limited to, AI annual custody and valuation fees. Clients should carefully consider the investment objectives, risks, costs, and expenses of an AI and particular AI share class before investing. This and other important information is available in each AI’s prospectus, private placement memorandum, or other offering documents, which can be obtained from your IAR. Clients should be aware that investing in AIs involves material risks, including illiquidity risks, risks related to the difficulty in valuing certain AIs as a result of the assets in which they invest, risks related to the inability to obtain daily or otherwise current valuations for certain AIs, and other special risks, and that clients could lose all or portion of their AI investment. Additionally, clients should be aware that AI investments will in certain circumstances involve additional fees and expenses, including, but not limited to, fees imposed by AI platforms and investment vehicles through which LFS makes certain AIs available to clients. LFS’s advisory fees generally are negotiable. Some programs, like the CWA Choice Program, charge separately for asset management services, ongoing investment advice, and transaction costs. In such programs, you will be charged for any transaction, trading, and execution fees, costs, and expenses that are applicable to trades and other transactions occurring within your account, as described in your account-opening documentation, in addition to your asset-based advisory fees. Applicable transaction, trading, execution, and other fees, costs, and expenses are described in detail in the applicable program’s client service agreement; SIS; transaction, trading, execution, and brokerage service fee schedules; other account- opening documentation; and Form ADV, Part 2A. When LFS and your LFS financial professional serve as investment adviser for your fee-based account, LFS and your LFS financial professional will be acting in their investment advisory capacities for such account and are required to act in your best interest, without placing their financial or other interests ahead of your interests. Additionally, when LFS and your LFS financial professional provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA, LFS and your LFS financial professional are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. You should be aware that LFS and your LFS financial professional are subject to various conflicts of interest in connection with the investment advice and other services they provide to you in connection with your fee-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles LFS and your LFS financial professional play in a transaction, LFS’s and your LFS financial professional’s compensation arrangements, and LFS’s financial and other arrangements with custodians, clearing firms, other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in LFS’s Form CRS and Forms ADV, Part 2A, as well in the other important client disclosures available on LFS’s website, www.lfsecurities.com. For additional information on LFS’s investment advisory programs and services, please see LFS’s Form CRS and Forms ADV, Part 2A, which are available through our website at www.lfsecurities.com under My accounts— Disclosures or at www.lfg.com/public/individual/adv, and through the SEC’s website at www.adviserinfo.sec.gov. LFS’s Form CRS and Forms ADV, Part 2A may also be requested by contacting LFS at (800) 237-3813 or LFNAdvisoryServices@lfg.com. For detailed information regarding the trading/execution fees and brokerage service charges that LFS establishes, controls, and charges clients when serving as broker-dealer of record for WealthLinc and CWA accounts held with NFS, please see the LFS Fee Schedule, which is provided to you at account opening, will change over time, and can be found on LFS’s website at www.lfsecurities.com under My accounts— Cost. Before consenting to any investment advisory relationship with LFS or an LFS financial professional, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation LFS and its financial professionals will receive, and LFS’s and its financial professionals’ conflicts of interest. After reviewing these disclosures, please address any questions you may have with your LFS financial professional. THIRD-PARTY INVESTMENT ADVISORY PROGRAMS LFS offers clients access to several investment advisory and asset allocation programs sponsored by third-party asset management firms, which are sometimes referred to as turn-key asset management programs (“TAMPs”). TAMP programs allow clients to choose from a variety of professional investment managers. TAMPs offer clients different model portfolios associated with different levels of risk. LFS generally does not provide asset management or portfolio management functions for client accounts held in TAMP programs, as the assets and portfolios are managed by the TAMP sponsor and/or one or more investment managers made available through the TAMP program. Client accounts in TAMP programs may be invested in a number of different securities and other investment products, including, but not limited to, stocks, bonds, mutual funds, options, annuity contracts, AIs, and exchange-traded funds (“ETFs”). LFS is generally not responsible for the selection of any securities or other investment products purchased, held, sold, or otherwise chosen as investments in client accounts that are invested through TAMP programs, including, but not limited to, any illiquid investments, AIs, specific mutual funds, or particular share classes. The specific services offered by TAMPs, the fees, costs, and expenses associated with those services, and the TAMP sponsor’s and applicable investment managers’ conflicts of interest are detailed in the applicable TAMP sponsor’s disclosure brochure and in the account-opening paperwork and client agreements that a client completes prior to or in connection with entering into a TAMP program. The following description provides an overview of the different TAMP programs offered through LFS. Please refer to the relevant Form ADV, Part 2A for each TAMP or TAMP program (other than the SEI Mutual Fund Asset Allocation Program) for a detailed explanation of each of the TAMP programs offered through LFS. In each of the TAMP programs described below, LFS provides advisory services that include assisting clients in completing a program questionnaire or similar client profiling tool to gather information about the client’s financial circumstances, investment objectives, goals, risk tolerance, investment time horizon, and other pertinent information. After analyzing this information, the IAR will assist clients by providing ongoing investment advice in connection with the selection and, if necessary, replacement, of TAMP programs, asset allocation strategies, model portfolios, or other investment strategies based on the client’s specific financial circumstances, needs, and goals. Any client information collected through this process will be shared among LFS, the IAR, the TAMP sponsor, the investment managers selected, the custodian, and the other parties performing services in connection with the client’s TAMP account. LFS researches, selects, and periodically reviews the TAMP programs that it offers to clients. In conducting TAMP evaluations and oversight, LFS uses information provided by TAMP program sponsors and may also use independent data sources. While LFS periodically reviews the performance and other characteristics of the TAMP programs that it offers, clients should understand that, like any investment strategy, asset allocation, model portfolio, or investment portfolio, the past performance of TAMP programs is no guarantee of the TAMP programs’ future performance. Additionally, forecasts of future performance of financial markets or specific TAMP programs may prove to be incorrect for various reasons. Further, clients should understand that while diversification can potentially help spread risk throughout an investment portfolio, diversification alone does not guarantee a profit or protect against a loss. Finally, clients should understand that different asset classes have different risk and potential return profiles and will perform differently in different market conditions. When a client is considering a TAMP program, their IAR will typically present them with an investment strategy report, proposal, or other documentation that summarizes the TAMP program’s recommendations based on the financial and other information provided by the client. The IAR may, if appropriate and permitted under the relevant program, suggest modifications to the program’s recommendations to address client-specific needs. Additionally, the client has the ability to place reasonable restrictions on the management of their TAMP accounts. Once a client has selected a TAMP program in consultation with their IAR, the particular asset allocation strategy, model portfolio, or investment strategy that the client has selected will be implemented using the mutual funds and/or other securities and investment products offered through the relevant program. The client will typically appoint the TAMP program sponsor and/or the investment managers they have selected as their attorney-in-fact and delegate discretionary trading authority to those parties. This delegation of discretionary trading authority allows the TAMP program sponsor and/or the selected investment managers to buy and sell securities in the client’s account without the client’s prior approval for each transaction. Unless otherwise agreed to by LFS, the IAR, and the client, LFS and the IAR generally will not have any responsibility or authority to buy or sell securities in client accounts held in TAMP programs, to choose the initial or ongoing allocation of client assets held in TAMP programs, or to select TAMP sponsors and/or investment managers. The duties of all parties, including the client, LFS, the IAR, the TAMP sponsor, and applicable investment managers, are described in detail in your client agreement and other account- opening documentation and the Forms ADV, Part 2A of the TAMP program sponsor and applicable third-party investment managers. Clients should review these documents carefully and address any questions they may have with their IAR before opening an account with any TAMP sponsor. If the client’s investment objectives or financial situation change after their TAMP account is opened, or the client would like to impose reasonable restrictions on the management of their TAMP account (or modify reasonable restrictions, if any, previously placed on their TAMP account), the client should promptly notify their IAR, who will notify the TAMP program sponsor. The TAMP program sponsor, third-party investment managers selected, and/or their affiliates and service providers are responsible for creating and sending reports to clients, including transaction reports, performance reports, and tax reports. LFS and its IARs do not independently audit TAMP program performance information to determine or verify its accuracy and do not calculate or audit the performance or other reports that TAMP program sponsors send to clients. Clients are strongly encouraged to carefully review the TAMP sponsor’s and third-party investment managers’ disclosures regarding prior performance with their IAR to determine the relevance of the prior performance to the client’s account. LFS also strongly encourages clients to review the account statements provided by their custodian and compare those statements to any reports or statements provided by the TAMP program. After reviewing these statements and reports, clients should address any questions they may have with their IAR. Solicitor Programs While LFS has generally stopped offering TAMP programs to new clients through “solicitor” arrangements where LFS acts as a solicitor and refers clients to a TAMP, LFS does refer clients to certain TAMPs and third-party investment managers through solicitor or similar referral arrangements in very limited circumstances. Additionally, certain client accounts previously referred to TAMPs and third-party investment managers under now terminated solicitor arrangements remain active. In a solicitor arrangement, a TAMP sponsor or investment manager agrees to compensate LFS for providing them with client referrals. In these cases, LFS and the IAR receive referral fees for making the referral, which are generally referred to as “Solicitor Fees.” In most cases, Solicitor Fees are calculated as a percentage of the client assets that the TAMP sponsor and/or third-party investment manager manages; however, there are instances where Solicitor Fees are paid under alternative arrangements. Solicitor Fees are disclosed to clients and prospective clients as and when required by the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and the rules and regulations thereunder. In many cases, LFS and the IAR maintain an ongoing relationship with referred clients and may meet with referred clients periodically to assist them in reviewing the accounts managed by the TAMP or investment manager and to discuss other relevant financial matters. It is important for clients to understand that when LFS acts as a solicitor by referring clients to TAMPs or third- party investment managers, LFS does not provide investment advice to the client and does not act in a fiduciary or investment advisory capacity with respect to the referred client’s accounts with the TAMP or investment manager. For information regarding the conflicts of interest that LFS and its IARs have in connection with “solicitor” and other referral programs, please see Item 14, Client Referrals and Other Compensation, below. Co-Advisory Programs Except in the very limited circumstances described above under the heading “Solicitor Programs,” LFS offers only co- advisory TAMP programs to new clients. When LFS and a TAMP sponsor have a co-advisory agreement, each party acts in an investment advisory and fiduciary capacity to the client. In these programs, LFS and the IAR are responsible for recommending a TAMP program and investment strategy that are suitable for and in the best interest of the client based upon their review of the client’s financial situation, investment objectives, investment time horizon, risk tolerance, and other relevant information. The TAMP sponsor (or its selected investment managers or sub-advisers) generally is responsible for implementing and managing the client’s portfolio in accordance with the selected investment strategy, including by selecting securities and other investment products for the client’s account. The responsibilities of all parties, including the client, LFS, the IAR, the TAMP sponsor, and applicable investment managers, are described in detail in your client agreement and other account-opening documentation and the Forms ADV, Part 2A of the TAMP program sponsor and applicable third-party investment managers. Clients should review these documents carefully and address any questions they may have with their IAR before opening an account with any TAMP sponsor. The following are brief descriptions of the co-advisory TAMP programs currently being offered to LFS clients. These brief descriptions are provided for informational purposes only and are not intended to replace or fully summarize the detailed information provided in your TAMP program’s Form ADV, Part 2A, client agreement, and other account-opening documents, which provide detailed information regarding the services offered through the TAMP program, each party’s responsibilities in connection with the TAMP program, applicable investment minimums, the investment advisory and other fees, costs, and expenses you will incur, the TAMP sponsor’s and investment managers’ conflicts of interest, and other important matters. As such, you should rely on the detailed information provided in your TAMP program’s Form ADV, Part 2A, client agreement, and other account-opening documents when deciding whether to participate in a TAMP program offered through LFS, and you should address any questions you may have with your IAR before proceeding. Each TAMP program’s Form ADV, Part 2A is available from your IAR and on the SEC’s website at www.adviserinfo.sec.gov, and will be provided to you at or before account opening. SEI Investments Management Corporation LFS has an agreement with SEI Investments Management Corporation (“SIMC”), SEI Private Trust Company, and SEI Global Services, Inc. (collectively, “SEI”) under which LFS offers various asset allocation and investment advisory programs sponsored by SEI. SEI offers an investment management approach that uses actively managed asset allocation to help meet the client’s objectives. SEI offers a style-specific, multi-manager investment approach to pursue less volatile long-term performance and attempt to reduce risk. In addition, SEI monitors for style drift that might generate uncompensated risk. Client portfolios are designed with a diversified asset allocation to provide flexibility to address client needs. SEI provides clients with a monthly consolidated statement, quarterly performance reports, and an annual tax report. SEI’s programs may use global diversification and tax-efficient strategies to help reduce realized capital gains and tax liability. SEI imposes minimum investment requirements for its programs and those minimum investment requirements may be modified, waived, or negotiated at SEI’s discretion. In addition to the various SEI programs that LFS offers through a co-adviser model, LFS also offers clients access to the SEI Mutual Fund Asset Allocation Program. This program offers clients access to actively managed asset allocation portfolios comprised exclusively of no-load mutual funds advised by SIMC (“SEI Funds”). The asset allocation portfolios are constructed and maintained by SIMC based on its capital market assumptions and other criteria SIMC, in its sole discretion, determines is relevant. The IARs assist clients in selecting a specific asset allocation portfolio that is appropriate for the client based on information the client supplies in response to an investment questionnaire. The client directs the IAR to instruct SEI to purchase and sell SEI Funds pursuant to the asset allocation portfolio and rebalancing parameters selected by the client. In this program, SEI does not serve in a co-adviser capacity with LFS and LFS serves as the sole investment adviser to your account. AssetMark, Inc. LFS offers the following asset allocation and other advisory services sponsored by AssetMark, Inc. (“AssetMark”). AssetMark’s Asset Allocation System LFS and the IARs offer AssetMark’s asset allocation system, in which clients are introduced to investment managers who provide discretionary management of individual portfolios of equity and/or fixed-income securities. Clients may also invest in model portfolios of mutual funds, ETFs, and variable annuity sub-accounts created and maintained by institutional investment strategists. AssetMark imposes minimum investment requirements for its programs and those minimum investment requirements may be modified, waived, or negotiated at AssetMark’s discretion. LFS and the IARs do not have any responsibility or authority to determine the investment managers made available through the AssetMark platform or to add or remove investment managers from AssetMark’s platform. In addition, LFS and the IARs have no responsibility to determine how AssetMark or the investment managers allocate client assets, to buy or sell securities or other investment products for client accounts, or to select broker-dealers with which transactions will be effected. All decisions with respect to the availability of investment managers and other service providers are made by AssetMark. The selection of specific investment managers and broker-dealers used in connection with a specific client account will be made by the client during the account-opening process or by subsequently providing authorization of any such selection to LFS, the IAR, and/or AssetMark. Trading authorization will be granted by client to AssetMark or another investment manager under the terms of the investment advisory agreement governing the AssetMark program. AssetMark’s Retirement Services LFS and the IARs also offer AssetMark’s retirement services through which AssetMark’s Retirement Services division provides investment advisory services to employer-sponsored retirement plans. AssetMark’s investment advisory services include the development of investment alternatives, including individual mutual funds, ETFs, and managed account solutions, that retirement plan sponsors can include in their employer-sponsored retirement plans. These services are offered in connection with various retirement plan recordkeeping services and custodians with which AssetMark has developed connectivity to deliver its services. LFS, through its IARs, will assist the retirement plan sponsor in selecting AssetMark to provide investment advisory services, and may perform one or more of the following services with respect to the retirement plan: educating and supporting the responsible plan fiduciary; periodic review of the plan’s investment policy statement; review of the plan’s investment product section, the plan’s designated investment alternatives, and/or the plan’s qualified default investment alternative; assisting with plan service provider evaluation, selection, and oversight processes; review of third-party investment managers and investment advice providers; facilitating group enrollment meetings and participant investment education; and assisting participants with financial wellness education, retirement readiness, and gap analyses. The respective roles and responsibilities of all parties, including acknowledgements of fiduciary status under ERISA, as applicable, are set forth in the service agreements and related documents executed by clients electing these services, including the AssetMark Retirement Services Division Client Services Agreement and Application. AssetMark also offers asset allocation and related investment advisory services to retirement plan participants of 403(b) plans for which Fidelity Institutional Wealth Services or TIAA CREF is an authorized provider under the participant’s retirement plan. AssetMark’s asset allocation and related investment advisory services are limited to the investment options that are made available in the participant’s retirement plan by the plan sponsor. LFS, through its IARs, will assist the retirement plan participant in selecting AssetMark to provide investment advisory services, and in determining which, if any, of the asset allocation models provided by AssetMark are appropriate in light of the plan participant’s financial goals, risk tolerance, and investment time horizon, and other relevant factors. The respective roles and responsibilities of all parties, including acknowledgements of fiduciary status under ERISA, as applicable, are set forth in the service agreements and related documents executed by clients electing these services, including the AssetMark Retirement Services Division Client Services Agreement and Application. Additional information regarding the services that AssetMark provides through its Retirement Services division, including important information about fees, risks, and conflicts of interest, can be found in the AssetMark Retirement Services Form ADV, Part 2A, which is available on the SEC’s website at www.adviserinfo.sec.gov. Clients interested in these services are encouraged to review the AssetMark Retirement Services Form ADV, Part 2A, the AssetMark Retirement Services Division Client Services Agreement and Application, and all other service agreements and related documents and disclosures in detail before making any investment decisions. Morningstar Investment Services LLC LFS offers clients the Morningstar® Managed PortfoliosSM Program sponsored by Morningstar Investment Services, LLC (“MIS”). This investment advisory program includes access to mutual fund asset allocation and focused strategy portfolios (“Mutual Fund Portfolios”), ETF strategy portfolios (“ETF Portfolios”), and select stock basket strategy portfolios (“Stock Portfolios”). MIS imposes minimum investment requirements for its programs and those minimum investment requirements may be modified, waived, or negotiated at MIS’s discretion. Clients will sign an investment management agreement giving MIS discretionary authority to buy and sell mutual funds, ETFs, stocks, and other securities, as appropriate, in order to invest and manage the client’s assets based on the client’s selected portfolio and any restrictions. Rebalancing will typically occur quarterly and reallocation will occur as frequently as MIS considers necessary. Orion Portfolio Solutions, LLC (d/b/a Brinker Capital Investments) Orion Portfolio Solutions, LLC (“Orion”) provides discretionary and non-discretionary investment management services to meet the needs of individual clients. Orion offers various model portfolio and asset allocation programs that utilize various investment vehicles, including separate account managers, stocks, bonds, mutual funds (including both Orion-affiliated and unaffiliated mutual funds), ETFs, real estate investment trusts, master limited partnerships, variable annuity subaccounts, and/or other securities and investment products. Additionally, Orion offers a customized separately managed account platform, which may also include privately placed or publicly traded pooled investment vehicles (such as hedge funds, mutual funds, and exchange-traded products). Orion imposes minimum investment requirements for its programs and those minimum investment requirements may be modified, waived, or negotiated at Orion’s discretion. Symmetry Partners, LLC Symmetry Partners, LLC (“Symmetry”) provides discretionary investment management services to meet the needs of individual clients. Symmetry creates and maintains model portfolios using mutual funds and/or ETFs. Symmetry imposes minimum investment requirements for its programs and those minimum investment requirements may be modified, waived, or negotiated at Symmetry’s discretion. City National Rochdale, LLC City National Rochdale, LLC (“City National Rochdale”) provides discretionary investment management services to meet the needs of individual clients with portfolios of $1 million and above. City National Rochdale creates

model portfolios or provides individualized management services utilizing stocks, bonds, options, mutual funds, ETFs, and other securities. City National Rochdale imposes minimum investment requirements for its programs and those minimum investment requirements may be modified, waived, or negotiated at City National Rochdale’s discretion. Flexible Plan Investments, Ltd. Flexible Plan Investments, Ltd. (“Flexible Plan”) provides discretionary investment management services to meet the needs of individual clients. Flexible Plan’s services encompass various strategies with differing objectives to enable clients to receive personalized investment management utilizing mutual funds, ETFs, and/or variable annuity subaccounts. Flexible Plan imposes minimum investment requirements for its programs and those minimum investment requirements may be modified, waived, or negotiated at Flexible Plan’s discretion. The Pacific Financial Group, Inc. The Pacific Financial Group, Inc. (“Pacific”) provides discretionary and non-discretionary investment management services to meet the needs of individual clients. Pacific offers and maintains model portfolios containing mutual funds and ETFs, and/or Pacific’s separately managed accounts. Pacific imposes minimum investment requirements for its programs and those minimum investment requirements may be modified, waived, or negotiated at Pacific’s discretion. Limited Arrangements LFS offers other TAMP or asset management programs in addition to those listed above on a limited basis. This may occur when a financial professional joins LFS and was using another firm for asset management services at their prior firm, or where there is another unique need that isn’t met by the other TAMP programs that LFS offers. This may also occur when LFS has historical or legacy TAMP or asset manager arrangements but has not yet closed the programs and required clients to move to new programs. For detailed information on each of these TAMP programs, including detailed information regarding the services offered through the TAMP program, each party’s responsibilities in connection with the TAMP program, applicable investment minimums, the investment advisory and other fees, costs, and expenses you will incur, the TAMP sponsor’s and investment managers’ conflicts of interest, and other important matters, please refer to your account-opening documentation (including your client agreement) and the applicable investment adviser’s or TAMP program’s Form ADV, Part 2A, which is available from your IAR and on the SEC’s website at www.adviserinfo.sec.gov, and will be provided to you at or before account opening. FINANCIAL PLANNING SERVICES IARs provide financial planning services through a written financial planning agreement. Planning is focused on specific areas and is based upon each client’s individual financial situation and personal and/or business objectives. The degree of detail and sophistication of the financial planning services provided varies according to the individual client’s circumstances. Each client is provided with a written summary of the work undertaken in electronic or hard copy format. Plans are usually completed within six months of the agreement date, though more complex planning work may take longer to complete. LFS’s planning services are advisory only. Any information you receive from LFS or the IARs relating to the tax considerations affecting your financial arrangements or transactions is not intended to be tax advice and you should not rely upon it as tax advice. Neither LFS nor the IARs provide tax, legal, or accounting advice, or other professional services. Through meetings and discussions with your IAR, your IAR will gather the information necessary to understand your financial situation and objectives. The information gathered will include, among other things, your current financial status, future goals and objectives, and attitudes towards risk. Once this information, any requested financial records, and other relevant documents are received, your IAR will analyze your financial data and make observations based upon your current financial circumstances. Your IAR will identify financial challenges you may be facing, recommend specific financial planning strategies for your consideration, and summarize those observations and recommendations in an electronic or hard copy written report. Your financial plan will address one or more of the following areas: Personal Financial Planning  Estate Planning Strategies. Your IAR will provide advice to enable you to make informed decisions with respect to property ownership, distribution of assets, estate tax reduction strategies, tax payment, and related matters. Based on your current situation and your future goals, your IAR will review your estate plan, discuss planning techniques, and suggest alternative strategies when appropriate. Where relevant, the planning process will include a discussion of gifting, trust implementation, wills, the disposition of business interests, and related matters. Tax consequences and their implications are also identified and evaluated; however, clients should consult with their tax advisors to discuss the tax consequences of any estate planning strategy they intend to implement.  Retirement Planning. The retirement planning process includes an analysis of your current situation, a written discussion about alternative retirement planning strategies, and techniques that can be used to assist you in accumulating wealth for retirement income, or in the appropriate distribution of assets following retirement. Tax consequences and their implications are also identified and evaluated; however, clients should consult with their tax advisors to discuss the tax consequences of any retirement planning strategy they intend to implement.  Investment Planning. During the investment planning process, your IAR evaluates your existing investments, analyzes your current economic circumstances and tax characteristics, and reviews your risk tolerance. This process includes an analysis of your current asset allocation and investment income. Tax consequences and their implications are also identified and evaluated; however, clients should consult with their tax advisors to discuss the tax consequences of any investment planning strategy they intend to implement. Once your current situation has been reviewed, your IAR will recommend strategies and investment techniques for your consideration. The strategies and techniques recommended are designed to assist you with the selection of an appropriate asset allocation and investment strategy in light of your investment objectives. The strategies and techniques outlined in your financial plan are designed to assist you in pursuing your stated investment goals at an appropriate risk level for you.  Education Planning. The education planning process includes a definition of your objectives for family educational needs and a written analysis of potential ways to help fund those objectives. This includes strategies designed to help minimize negative tax implications, not only in the accumulation phase, but also in the distribution phase; however, clients should consult with their tax advisors to discuss the tax consequences of any education planning strategy they intend to implement.  Risk Management. The risk management planning process includes an evaluation of the impact of a potential premature death, disability, or long-term care event on your family’s financial situation. A written analysis defining your objectives, as well as the potential financial implications of adverse circumstances, is provided, along with recommendations of techniques that may help you meet your objectives while mitigating risk. This may include not only planning strategies, but product type/class considerations as well. Business Owner Financial Planning  Business Succession Planning. The business succession planning process includes an analysis of the current state of your business, as well as your goals for the future of your business. Once the current state of your business and your future goals are determined, your IAR will provide alternatives and strategies addressing the continuity or disposition of your business upon your retirement, death, disability, or decision to sell. Tax consequences and their implications are also identified and evaluated; however, clients should consult with their tax advisors to discuss the tax consequences of any business succession planning strategy they intend to implement.  Executive Compensation Planning. The focus of executive compensation planning is the analysis and recommendation of various compensation strategies to attract, retain, and reward key employees of the business. This planning may also include the business owner. Objectives of the business owner and the financial structure of the business will be reviewed and considered in the analysis and recommendations. Tax consequences and their implications are also identified and evaluated; however, clients should consult with their tax advisors to discuss the tax consequences of any executive compensation planning strategy they intend to implement.  Entity Planning. The entity planning process begins with a review of the type(s) of entity(ies) you have elected for your business operations, including sole proprietorships. Understanding your short-, mid-, and long-term goals for the business and your succession or exit goals are an important factor as well. Together with your other advisors, your IAR will provide alternatives that may help you achieve your goals more effectively than your current situation, or they may confirm that your current elections are most appropriate. Tax consequences and their implications may also be identified and evaluated; however, clients should consult with their tax advisors to discuss the tax consequences of any entity planning strategy they intend to implement.  Employee Benefits Planning. The employee benefits planning process begins with a review of your current benefit offerings to your key people, executives, and/or your entire employee population. Understanding your short-, mid- and long-term goals for the business and your succession or exit goals are an important factor as well. Your business cash flow, ability to maintain certain funding requirements, and other factors will be evaluated. Together with your other advisors, your IAR will provide alternatives that may help you achieve your goals more effectively than your current situation, or they may confirm that your current plans are most appropriate. Tax consequences and their implications may also be identified and evaluated; however, clients should consult with their tax advisors to discuss the tax consequences of any employee benefits planning strategy they intend to implement.  Executive Financial Planning. LFS enters into agreements with businesses and other associations to provide financial planning services to their executives, partners, members, directors, and other personnel. In these instances, each individual will be provided with a personal financial plan as described above. Fees charged are calculated based on the same criteria as the personal financial planning fees described in the Financial Planning Fees section below. Fees generally are paid by the business or association on behalf of its personnel.  Nonqualified Deferred Compensation Financial Planning. LFS also offers nonqualified deferred compensation financial planning services. For a nonqualified deferred compensation program, the analysis contains alternative methods to informally “fund” the program, including an overview of the accounting treatment of these methods, and a recommendation on the appropriate method of “funding” the program. The plan will be summarized in a written document delivered to you in electronic or hard copy format and will reflect your current situation and an analysis of alternative ways to accomplish your objectives. Clients should consult with their tax advisors to discuss the tax consequences of any nonqualified deferred compensation planning strategy they intend to implement. LFS, through the IARs, will deliver a written financial analysis and plan to the client in hard copy or electronic format and will contact the client for a review of the plan. After this review, LFS’s and its IARs’ obligations and responsibilities as it relates to the financial planning services being provided to the client shall terminate. Any necessary updates to the financial analysis and plan, or execution or implementation of the recommendations made in the plan, shall be at the sole discretion of the client. LFS and its IARs will be under no obligation to update the financial analysis and plan or to monitor changes in the client’s financial circumstances, investments, or insurance in connection with the financial analysis and plan services unless the client renews their financial planning agreement as described below. Renewal Plans After your initial financial planning agreement with LFs is completed, you may request, or your IAR may suggest, that your planning agreement be renewed for purposes of updating your financial plan, in whole or in part. The type of financial planning to be done in connection with any renewal will be agreed upon at the time of the renewal and will be memorialized in the renewal invoice and/or other documentation you receive from LFS and your IAR in connection with your renewal. The areas to be covered in any renewal may or may not be the same as the areas covered in your initial financial plan. In connection with renewals, your IAR will analyze current data you provide, prepare an updated written summary (in electronic or hard copy format) reflecting your current financial circumstances, and, where appropriate, recommend updated strategies for your consideration. Other Types of Planning Services Client Consultation Services Consultation services are more limited than the services included with a full financial plan and may be limited to an isolated issue or specific area of concern. Consultation services are offered to clients who want general investment advice or guidance, including advice or guidance relating to one or more of the following areas:  A review of the client’s current investment portfolio and a discussion of a generic asset allocation not involving any specific investment recommendations; or  A review of a new or current issue regarding one or more of the following areas: estate planning strategies, retirement planning, investment planning, business succession planning, education planning, or risk management. Your IAR will carefully review all relevant materials pertaining to your specific consultation. Your IAR will then provide a consultation that reflects your current financial circumstances, financial outlook, and personal and/or business objectives. The consultation services provided by your IAR are limited to the advice given and the information discussed during the single consultation and any related follow up, and do not require your IAR to develop or provide an in-depth financial plan. If you would like a detailed financial plan, you should consider entering into a financial planning relationship with LFS as described above. Executive Consulting Services LFS enters into agreements with businesses and other associations to provide consultation services to their executives, partners, members, directors, and other personnel. In these instances, each individual will be provided with a consultation as described above. Fees charged are calculated based on the same criteria as the client consultation fees described in the Consultation Fees section below. Fees generally are paid by the business or association on behalf of its personnel. Consulting Subscription Services Consulting subscription services are more limited than the services included with a full financial plan. With consulting subscription services, clients have the ability to engage LFS and its IARs to provide general investment advice and guidance regarding estate planning strategies, investment planning, retirement planning, risk management, education planning, business succession planning, and/or other financial matters, as applicable, over the course of a set subscription term of up to 24 months. During the term of a subscription agreement, clients will receive a minimum of two substantive consultations during each 12-month period of the term of their subscription agreement (the minimum substantive consultation obligations will be prorated for subscription periods of less than 12 months) that will allow LFS and its IARs to, among other things: (i) ensure they understand the client’s current financial circumstances, objectives, and needs and, if necessary, obtain any relevant documentation; (ii) provide general investment advice and guidance regarding key financial matters the client would like to address during the term of their subscription agreement; and (iii) provide timely investment advice and guidance regarding current matters impacting the client’s financial life. Additionally, all consulting subscription clients have reasonable access to their IAR throughout the term of their subscription agreement that will allow them to seek additional timely investment advice and guidance from their IAR regarding significant financial decisions, significant life events, financial concerns, or other important matters impacting their financial life. The terms of subscription agreements entered into prior to the date of this Brochure will in certain circumstances vary from the information described above. Existing consulting subscription clients should refer to their subscription agreements for definitive information regarding the terms of their consulting subscriptions. The consulting subscription services provided by your IAR are limited to the general investment advice and guidance given during each consultation conducted during the term of your subscription agreement and do not require your IAR to develop or provide an in-depth financial plan. If you would like a detailed financial plan, you should consider entering into a financial planning relationship with LFS as described above. Additionally, subscription agreements do not require LFS or your IAR to continuously monitor your financial circumstances, objectives, or needs; your accounts with LFS or other financial services firms; or the securities and other products you purchase and hold in such accounts. Further, subscription agreements do not require LFS or your IAR to provide any other oversight or ongoing asset management or portfolio management services, including security or other investment product recommendations or selections, with respect to your accounts with LFS or other financial services firms or the securities and other products you purchase and hold in any such accounts. If you would like LFS to provide you with account monitoring, account oversight, or ongoing asset management or portfolio management services, you should speak with your IAR regarding LFS’s fee-based investment advisory programs and services. Seminars LFS provides seminars to groups of employees and associates and other organized groups. The seminars focus on various areas of financial planning, such as estate planning strategies, investment planning, retirement planning, business succession planning, education planning, and risk management. Seminars are held on a negotiated fee basis. The generalized investment information provided during seminars is not intended to meet the objectives of any individual client or seminar attendee. Implementation of Financial Planning Advice The services included in the planning and consultation processes are limited to recommending strategies for the client to consider. Clients are in no way obligated to implement any recommendations and are not obligated to do so through LFS or an IAR. The implementation of any recommended strategies is entirely at the client’s discretion. The recommendations provided by IARs may be implemented through LFS, its affiliates, or other financial services providers. We cannot guarantee future financial results or the achievement of your financial goals through implementation of recommendations provided to you. LFS does not monitor the day-to-day performance of your specific investments as part of its financial planning or consultation services. Before implementing any recommendations, you should carefully consider the risks, costs, and potential benefits of purchasing particular products or services, and you are encouraged to seek further advice from your attorney, tax specialist, accountant, and other professional advisors, particularly in connection with estate planning strategies, tax matters, and business owner planning issues. In addition to providing financial planning and consultation services to clients, IARs separately offer securities, insurance products, and other investment products and services issued or managed by LFS affiliates, as well as securities, insurance products, and other investment products and services of unaffiliated firms. To minimize conflicts of interest between the IARs’ roles in the sale of securities, insurance products, and other investment products and services, financial plans and client consultations contain only generic recommendations regarding general types of securities, insurance products, and other investment products. In the financial planning and consultation processes, IARs do not make recommendations regarding the purchase or use of specific securities, insurance products, or other investment products or services. If a client chooses to implement the advice they receive in a financial plan or consultation through LFS, the client’s LFS financial professional will be acting as a salesperson in the sale of securities, insurance products, and other investment products and may provide separate investment advisory services in connection with the management of client assets. A client who makes the decision to implement planning or consultation recommendations through LFS and its financial professionals will have access to a broad portfolio of securities, insurance products, and other investment products. Securities and other investment products accessible through LFS and its financial professionals are restricted to products approved for sale by LFS. LFS, in its role as a registered investment adviser, also offers a variety of asset management programs and services. RETIREMENT PLAN CONSULTING PROGRAM LFS offers various retirement plan consulting services that are designed to assist sponsors (“Sponsors”) of employer- sponsored retirement plans (“Plans”) and Plan participants and beneficiaries (collectively, “Retirement Plan Services”). LFS provides Retirement Plan Services through IARs and charges fees for Retirement Plan Services as described in this Brochure and LFS’s Retirement Plan Consulting Agreement (the “Agreement”). LFS provides Retirement Plan Services through both transaction-based client engagements and fee-based client engagements. For transaction-based client engagements, IARs only provide point-in-time recommendations on the sale of retirement plan products and other point-in-time services. For fee-based client engagements, IARs may offer ERISA fiduciary investment advice regarding the Plan’s Designated Investment Alternatives (“DIAs” or more commonly known as the Plan’s “fund lineup”) and Qualified Default Investment Alternative (“QDIA”), along with other services to Plans, Sponsors, and Plan participants. In certain limited arrangements as agreed to in writing between a Sponsor and LFS, LFS may also provide Plan participants with limited point-in-time advice. When providing Retirement Plan Services to a Plan and/or Sponsor, LFS will solely be making recommendations to the Sponsor and the Sponsor retains full discretionary authority and control over the Plan’s assets. When providing Retirement Plan Services to a Plan participant, LFS will solely be making recommendations to participant and participant retains full discretionary authority and control over assets of the participant’s account. Sponsor may engage LFS to perform Retirement Plan Services by providing information about the Plan, including, but not limited to, the Plan design, Plan objectives, investment objectives, investment risk tolerance, demographics about Plan participants, and information about the Plan’s third-party service providers, and by executing an Agreement. LFS will provide Sponsor a current copy of this Brochure and the Agreement for review. The Agreement describes the terms of the arrangement between LFS and Sponsor, including a description of the Retirement Plan Services to be provided and the fees to be charged by LFS. By signing the Agreement, Sponsor represents that Sponsor has received sufficient information and determined that the Retirement Plan Services selected are: (i) necessary for the operation of the Plan and (ii) reasonable and appropriate taking into account the compensation to be paid to LFS and IARs for the Retirement Plan Services and their related conflicts of interest. Sponsor must sign and submit the Agreement to LFS before LFS performs any Retirement Plan Services. When LFS and your LFS financial professional provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA, LFS and your LFS financial professional are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. LFS currently offers the following Retirement Plan Services: Sponsor Services Educating and Supporting Plan Fiduciary/Committee. IAR will educate the Sponsor or other applicable plan fiduciary (the “Plan Fiduciary”) on considerations relevant to reviewing and/or establishing the Plan committee and/or protocols designed to help the Plan Fiduciary establish processes and governance to prudently manage and administer the Plan. The Plan Fiduciary is solely responsible for appointing or removing Plan committee members and for determining the policies and procedures for management and oversight of the Plan. IARs may provide training to Plan Fiduciary and/or Plan committee members about their fiduciary duties upon reasonable request and help the Plan committee coordinate regular meetings. Upon reasonable request, IARs may educate the Plan Fiduciary and Plan committee regarding the Plan’s structure, metrics, services, and expenses as compared to similar retirement plans (e.g., participation rates, employer contributions, vesting time frames, loan availability, etc.). The Plan Fiduciary will retain decision-making authority with respect to the structure and features of the Plan. IARs may also update the Plan Fiduciary about current and proposed regulatory and legislative initiatives, and the potential impact to the existing procedures for the operation and oversight of the Plan. Periodic Review of the Plan’s Investment Policy Statement (“IPS”). IAR will periodically review the Plan’s IPS as provided by the Plan Fiduciary in the context of Plan objectives. IAR will assist the Plan Fiduciary in establishing governance related to the Plan’s investment policies and IPS. IAR may educate the Plan Fiduciary about investment theories including investment objectives, risk return characteristics, historical return, and prospectus information on investment alternatives available through the Plan’s provider, which the Plan Fiduciary may use in developing and/or updating the Plan’s IPS. The Plan Fiduciary retains decision-making authority with respect to the terms and conditions of the IPS. Advice Regarding the Plan’s DIAs and QDIA. Based on the Plan’s IPS or other guidelines established by the Plan, IAR will review the investment options available to the Plan and will make recommendations to assist the Plan Fiduciary with respect to selecting the DIAs to be offered to Plan participants, and with respect to selecting or replacing the QDIA. Once the Plan Fiduciary selects the DIAs and QDIA, IAR will, on a periodic basis and/or upon reasonable request, provide reports, information, and recommendations to assist the Plan Fiduciary in fulfilling the Plan Fiduciary’s duty to monitor the Plan’s investments. If the Plan Fiduciary elects to remove a DIA, IAR will provide information, analysis, and recommendations to assist the Plan Fiduciary with the evaluation of replacement investment alternatives. The Plan Fiduciary retains decision- making authority to select, remove, and/or replace Plan investments. Point-in-Time Review and Monitoring Support of the Plan’s Investment Product Selection, DIAs, and/or QDIA. Based on the Plan’s IPS or other guidelines established by the Plan as provided to the IAR, the IAR will review the investment product(s) available to the Plan and may make one-time, point-in-time recommendations to the Plan Fiduciary with respect to selecting the investment product(s). The IAR may also provide one-time, point-in-time assistance to the Plan Fiduciary in selecting the initial list of DIAs (commonly referred to as the Plan’s investment lineup) to be offered to Plan participants, and the selection of the QDIA. Once the Plan Fiduciary selects the investment product(s), DIAs, and QDIA, IAR may, on a periodic basis and/or upon reasonable request, provide reports and information to assist the Plan Fiduciary with monitoring the DIAs. The Plan Fiduciary retains decision-making authority to select, remove, and/or replace Plan investment products, DIAs, and the QDIA. Assisting With Plan Service Provider Evaluation, Selection, and Oversight Processes. IAR may assist the Plan Fiduciary with establishing a process to evaluate, select, and monitor the Plan’s service providers. IAR may use third-party tools and publicly available data to assist the Plan Fiduciary with benchmarking the fees charged by a service provider. The Plan Fiduciary retains decision-making authority to select, remove, and/or replace the Plan’s service providers. These services may include any of the following:  IAR may assist the Plan Fiduciary in establishing procedures to track the receipt of and evaluate disclosures provided by “covered” service providers under Section 408(b)(2) of ERISA;  IAR may assist the Plan Fiduciary with creating formal requests for proposals from prospective service providers; collecting, evaluating, and analyzing the responses; and coordinating final interviews and presentations;  IAR may assist Plan Fiduciary with converting, dissolving, or merging Plans, or changing one or more service providers with respect to a Plan; and/or  IAR may act as a liaison with the Plan’s third-party service providers on behalf of Plan Fiduciary. Point-in-Time Review and Monitoring Support of Third-Party Investment Managers and Investment Advice Providers. Based on the Plan’s IPS or other investment guidelines established by the Plan and provided to the IAR, the IAR will review the third-party investment managers and investment advice providers, including service providers designated as “3(21)” and “3(38)” fiduciary service providers, available to the Plan and may provide point-in-time assistance to the Plan Fiduciary in selecting a third-party adviser or investment manager to advise on and/or manage some or all of the Plan’s DIAs, QDIA, or other Plan investments. Once the Plan Fiduciary selects one or more investment managers or investment advisers, IAR may provide reports and information, on a periodic basis or upon reasonable request, to assist the Plan Fiduciary with monitoring the third-party advisers or investment managers. The Plan Fiduciary will retain final decision-making authority with respect to the third-party advisers and investment managers used in connection with the Plan. Participant Services Facilitate Group Enrollment Meetings and Participant Investment Education. IAR will conduct periodic group enrollment and educational meetings with employees and educational meetings with Plan participants and beneficiaries. IAR may provide information and materials that inform a participant or beneficiary about the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan, including the Plan’s service fees and expenses, or the operation of the Plan. IAR may also provide educational information concerning the Plan’s DIAs (the Plan’s investment lineup), such as general descriptions of various asset classes, investment objectives and philosophies, risk and return characteristics, historical return information, and may refer the participants and beneficiaries to the prospectuses of the Plan’s DIAs. IAR may also provide information and materials that inform a Plan participant or beneficiary about: (i) general financial and investment concepts, such as risk and return, diversification, dollar cost averaging, compounded return, and tax deferred investment; (ii) historical differences in rates of return between different asset classes (e.g., equities, bonds, or cash) based on standard market indices; (iii) effects of inflation; (iv) estimating future retirement income needs; (v) determining investment time horizons; and (vi) assessing risk tolerance. The information and materials described above relate to the Plan and Plan participation, without reference to the appropriateness of any specific DIA for a particular participant or beneficiary under the Plan or are general financial and investment information that have no direct relationship to the Plan’s DIAs. In conducting this service, IARs will not provide Plan participants or beneficiaries with “investment advice” as that term is defined under ERISA. Assist Participants with Financial Wellness Education, Retirement Readiness, and/or Gap Analysis. IAR may conduct group meetings with Plan participants and beneficiaries to provide information about how to assess their retirement income needs. Using tools available through the Plan or approved third parties, IAR will help Plan participants and beneficiaries conduct “gap” analyses to determine whether their current investment objectives and savings rates are sufficient to provide for future income needs during retirement. IAR may help Plan participants and beneficiaries create retirement income plans. The information and materials described above relate to the Plan and Plan participation, without reference to the appropriateness of any specific DIA for a particular participant or beneficiary under the Plan or are general financial and investment information that have no direct relationship to the Plan’s DIAs. Participant Investment Advice. IAR will meet individually with a Plan participant upon reasonable request by such Plan participant to collect information necessary to identify the participant’s investment objectives, risk tolerance, time horizon, and other pertinent information. IAR will provide investment advice to assist the participant with investing the participant’s assets held in the Plan, using the investment products available to the Plan, the Plan’s DIAs, model portfolios available in the Plan, if any, or in selecting one or more investment managers available through the Plan. Unless otherwise agreed upon in writing, all investment advice will be as of the point in time at which such investment advice is given, and the IAR will have no ongoing duty or obligation to monitor the participant’s account. Unless the participant grants trading authority to IAR, an investment manager, or another party through a separate written document, participant will retain sole discretion over the investment of participant’s account. Potential Additional Retirement Services Provided Outside of the Agreement with the Sponsor In providing Retirement Plan Services, LFS and its IARs may establish a client relationship with one or more Plan participants or beneficiaries. Such client relationships develop in various ways, including, without limitation: (i) as a result of a decision by the participant or beneficiary to purchase services from LFS not involving the use of Plan assets; (ii) as part of an individual or family financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relate exclusively to assets held outside of the Plan; or (iii) through an IRA rollover. If LFS is providing Retirement Plan Services to a Plan, IARs may, when requested by a Plan participant or beneficiary, arrange to provide services to that participant or beneficiary through a separate agreement that excludes any investment advice on Plan assets (but may consider the participant’s or beneficiary’s interest in the Plan in providing that service). If a Plan participant or beneficiary desires to effect an IRA rollover, LFS may provide the participant or beneficiary with a written explanation of the options available to the Plan participant or beneficiary. Any final decision to effect the IRA rollover or about what to do with the IRA rollover assets remains that of the participant or beneficiary. LFS and its affiliates provide securities brokerage and other Retirement Plan Services to Plans and receive variable compensation for those services. LFS has a conflict of interest when it recommends its Retirement Plan Services and those of its affiliates because LFS, its employees, and its IARs benefit from the compensation paid to LFS and directly or indirectly receive all or a portion of the fees and other compensation paid by Retirement Plan Services clients. Those clients may also use other products and services available from or through LFS and in such cases will pay additional compensation, which is shared between LFS and the IARs. This practice creates a conflict of interest that gives LFS and its IARs a financial incentive to recommend Retirement Plan Services based on the compensation they receive, rather than on a client’s needs. Additionally, fees and commissions are higher for some products, services, accounts, and Retirement Plan Services, and the compensation and profitability to LFS, its IARs, and their affiliates from some products, services, accounts, and Retirement Plan Services are greater than the compensation and profitability resulting from other available products, services, accounts, and Retirement Plan Services. This creates a conflict of interest for LFS and its IARs given their financial incentive to recommend that clients use the products, services, accounts, and Retirement Plan Services that generate the highest rate and amount of compensation and profitability to them, rather than other available products, services, accounts, and Retirement Plan Services that generate relatively lower or no compensation and profitability for them. LFS addresses these conflicts of interest by, among other things, disclosing them to you. As part of LFS’s service of providing recommendations regarding the selection and monitoring of investment managers, QDIAs, or DIAs, LFS may provide a Sponsor with a list of investments, including mutual funds, to consider as options for the Plan, and may provide a list of investment managers to manage the assets of the Plan. The Sponsor retains full decision- making authority with respect to the selection of all Plan investments and investment managers. LFS will consider information provided by the Sponsor about the Plan when assisting with or making recommendations about the Plan’s IPS. It is important that information provided by Sponsor be complete, accurate, and current. Changes in the information will impact what assistance or recommendations may be made, so it is important that LFS and IARs be accurately and timely informed of any information that may be relevant to the Plan, as well as changes to previously provided information. All investments involve material risk and investment performance can never be predicted or guaranteed. The values of Plan accounts will fluctuate (perhaps significantly) due to market conditions, manager performance, and various other factors. Using any benchmark or index in connection with the Retirement Plan Services is no promise or guarantee that the performance of the Plan’s particular investments will experience the same results, including the results shown on the various reports that are delivered as part of the Retirement Plan Services. The Sponsor or Plan participants and beneficiaries retain all investment discretion over Plan assets. Each is free to make their own investment decisions. No one is required to accept any assistance or follow any recommendations provided by LFS or IARs as part of the Retirement Plan Services. If the Plan adopts LFS’s and its IARs’ recommendations regarding the allocation or rebalancing among model portfolios or recommendations of investment managers, the responsible Sponsor or Plan participant or beneficiary can freely change allocations or managers. LFS uses and may provide to Sponsor data or information provided by third parties when providing Retirement Plan Services. While LFS reasonably believes that the information or data it receives from these third parties is reliable, it does not promise that it is accurate, current, or consistently available. Sponsor is responsible for all tax liabilities arising from any transactions, including any liabilities arising from the failure to maintain the qualified status of a Plan receiving Retirement Plan Services. Any report containing a proposed asset allocation model is based upon a number of factors, which may include the demographics of Plan participants, current asset allocations, and the value of the assets. LFS may change asset allocations and investment options within the model portfolios and has no obligation to revise the report or otherwise advise Sponsor if a model or any of LFS’s assumptions change in the future. The analyses and suggested asset allocations contained in the reports may be based on historical financial data, assumptions about future financial trends (including market appreciation or decline, rates of return and risks for various asset classes), assumptions about applicable laws and regulations, and appropriate financial planning strategies. Any analyses or other information contained in or with the reports regarding various investment outcomes are not guarantees of future results. The reports do not provide advice regarding the Plan’s specific securities or other investments. Therefore, it is important for the Sponsor to monitor current events, such as changes in tax laws and in the financial markets, which may affect the Sponsor’s decisions about the Plan. The return rates and dollar figures contained in reports may not include all applicable investment or other fees, costs, or expenses; thus, any results shown will be reduced by such fees, costs, and expenses. Also, assumptions as to federal income tax rates, state income tax rates, and estate taxes reflected in reports are general estimates, unless otherwise indicated.