Who We Are Avantax Advisory Services, Inc. (“AAS” or “Firm”), also doing business as Avantax Advisory ServicesSM and Avantax Wealth Management®, was established in 19871 and is an investment adviser registered with the Securities and Exchange Commission (“SEC”) that offers a variety of investment advisory services primarily to individuals, pension and profit-sharing plans, and businesses, as more fully described in this Wrap Fee Program Brochure. The Firm conducts business throughout the United States through its investment adviser representatives (each an “Advisor” and collectively, “Advisors”), who are primarily independent contractors registered with the Firm, their personnel, and AAS’ employees (collectively, “Supervised Persons”) to provide investment advisory services to you (the “client” or “prospective client”). As of December 31, 2023, AAS had $41,695,726,722 in regulatory assets under management, of which $33,736,705,893 was managed on a discretionary basis and $7,959,020,829 was managed on a non-discretionary basis. AAS is an affiliate of Avantax Investment Services, Inc. (“AIS”), a broker-dealer and government securities dealer or broker registered with the SEC and a member of FINRA/SIPC. For most of AAS’ clients, AIS provides brokerage, custody and execution services through its clearing arrangement with National Financial Services LLC (“NFS” or “Custodian”), a non- affiliated firm, member NYSE, SIPC and a Fidelity Investments® Company. AAS is also affiliated with Avantax Insurance AgencySM and Avantax Insurance ServicesSM (collectively, “Avantax Insurance”) and Avantax Planning Partners, Inc. (“APP”), an affiliated investment adviser registered with the SEC. AAS is wholly-owned by Avantax Wealth Management, Inc. ("Avantax Wealth Management”). Avantax Wealth Management is directly owned by Avantax WM Holdings, Inc. that is wholly owned by Project Baseball Sub, Inc., that is directly owned by Avantax Holdings, LLC. Avantax Holdings, LLC is directly owned by Avantax, Inc. that is directly owned by Aretec Group, Inc. DBA Cetera Holdings (“Aretec”). Aretec is a wholly-owned subsidiary of GC Two Intermediate Holdings, Inc., and an indirect wholly-owned subsidiary of GC Three Holdings, Inc. Through common ownership by Aretec, AAS is affiliated with Cetera Financial Group, Inc. (“Cetera Financial Group”). For more information on AAS’ other financial industry activities and affiliations, see Item 9. An Overview of Investment Advisory Services Most advisory relationships begin with an initial client meeting between you and your Advisor. The purpose of this initial meeting is to discuss your investment history, goals, objectives, and risk tolerance and determine the investment advisory services that will meet your needs. For more information about the relationship with your Advisor, see Item 8. Prior to engaging your Advisor to provide AAS investment advisory services, each client will be required to enter into a written agreement setting forth the terms and conditions of services, including client specific fee information. For AAS’ Investment Management Solutions (IMS) platform, advisory accounts are required to be established and held through AAS’ affiliated broker-dealer, AIS. AIS provides brokerage, custody and execution services through its clearing arrangement with National Financial Services LLC (“NFS” or “Custodian”), a non- affiliated firm, member NYSE, SIPC and a Fidelity Investments® Company. AAS selected AIS primarily due to its affiliation and AIS’ relationship with NFS. As part of this relationship, AAS’ receives substantial economic and non-economic benefits from NFS, including but not limited to, access to the Bank Deposit Sweep Program (as detailed in Item 4 and Item 9), accessibility to dedicated service personnel, electronic and institutional trading, third-party research and technology, technical and operational support, advisory fee processing, and electronic communications and reporting to clients. AAS’ and AIS’ affiliation creates conflicts of interest and, in many cases, incentivizes AAS and its Advisors to recommend an affiliate’s products and/or services versus other, similar, non-affiliated providers. Additionally, many of AAS’ Advisors serve in multiple capacities and may be incentivized to recommend products or services that create the greatest compensation for the Advisor. For additional information, see Item 9. 1 Avantax Advisory Services, Inc. was formerly known as 1st Global Advisory Services (“1st Global”) and H.D. Vest Advisory Services, Inc. (“HD Vest”). March 28, 2024 Wrap Fee Program Brochure Page 6 of 34 AAS and its Advisors offer investment advisory services through various programs, as described in AAS’ Brochure and this Wrap Fee Program Brochure. AAS is the sponsor and investment adviser for the wrap-fee programs described under this Wrap Fee Program Brochure. Under a “wrap fee” program the client pays a single fee, based on a percentage of the managed assets, for investment advisory, portfolio management and trade execution. Depending upon the investments, investment strategy, trading activity, and other factors, you (the client) may pay more or less in fees and expenses in a wrap fee program compared to a non-wrap fee program. In addition to AAS’ and your Advisor’s fees, all clients will incur underlying investment expenses and, depending upon the investments, services, and negotiated agreement, may also incur other fees and expenses (e.g., third-party investment manager’s fees and costs). AAS and its Advisors price services based upon various objective and subjective factors. As a result, AAS’ clients will pay diverse fees and costs based upon, among other things, the complexity of the engagement, type of service(s), investment products used, investment program and strategies employed, and other third-party-specific costs. Clients may inquire at any time with their Advisor as to client-specific fees and costs. The information contained in this Wrap Fee Program Brochure cannot disclose every possible fee, expense and cost that a client may incur and is not intended to be an exhaustive list. Rather, this section provides a description of the most commonly incurred fees, expenses and costs associated with AAS’ wrap fee programs. An Advisor or AAS, at the Advisor’s or AAS’ sole discretion, may pay any of these fees, expenses and costs or AAS, in its sole judgment, can choose to waive or reduce the minimum initial investment amount or account minimums for its programs. AAS and your Advisor are compensated in several ways, as described in this Wrap Fee Program Brochure. Clients should be aware that the receipt of economic and/or other benefits by AAS and its Advisors creates a conflict of interest and may influence AAS’ choices for and your Advisor’s recommendations of investments, services, third- party investment managers and TAMPs. Therefore, it is important that you understand how AAS and your Advisor are compensated, as well as the other costs and conflicts of interest associated with the investments and services provided to you through AAS and its Advisors. Generally, AAS’ and your Advisor’s fees are negotiable on a client-by-client, account-by-account basis, subject to applicable maximum fees as outlined in this Wrap Fee Program Brochure. AAS and its Advisors offer a variety of services and manage a broad range of client accounts with different mandates, fee structures and expenses. AAS’ Advisors charge differing investment advisory fees based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). This is also a conflict of interest, as it creates a financial incentive for AAS’ Advisors to provide preferential treatment to one account over others in terms of allocation of management time, resources, and investment opportunities. As more fully described in Item 9, many of AAS’ Advisors are also registered representatives of AAS’ affiliated broker- dealer, AIS, and/or licensed insurance agents with Avantax Insurance. Brokerage services, insurance services and investment advisory services are different, and the fees charged for those services are often separate. For example, your Advisor will earn investment advisory fees on an account managed under a written agreement through AAS and, if applicable, in the capacity as a registered representative with AIS, earn transaction-based compensation or commissions on brokerage services at AIS or insurance services through Avantax Insurance. If your Advisor serves in multiple capacities, your Advisor has an incentive to recommend investment products or services that create the greatest compensation for your Advisor. In addition to disclosing these conflicts of interest, AAS has created and implemented a compliance and supervisory program to mitigate such conflicts through the oversight of client accounts and investment advisory activities. AAS mitigates these conflicts of interest, in part, by endeavoring to act in each client’s best interest and through the adoption and implementation of a Code of Ethics and other policies and procedures. See Item 9 for additional information. For example, if you purchased investments through an AIS brokerage account held at AAS’ custodian (NFS) or through a direct-to-mutual fund purchase within one year of transferring the investments to an AAS advisory account, the amount of commission you paid that exceeds an average advisory fee of 1.30% is refunded directly to your account. If the purchase was within thirty (30) days of transferring to an advisory account, the full amount of your commission is refunded directly to your advisory account. To determine whether your Advisor earns compensation in multiple capacities, review your Advisor’s Form ADV 2B Brochure Supplement. If a client has not received a copy of that document, the client should contact the Firm, using the information on the cover page of this Wrap Fee Program Brochure. AAS’ clients are not under any obligation to enter into an agreement with and receive investment advisory products and services through AAS and its Affiliates, and many of these investment products and services are available March 28, 2024 Wrap Fee Program Brochure Page 7 of 34 through other investment advisers, broker-dealers, custodians, or other financial institutions. Clients may inquire at any time with their Advisor as to any client-specific products, services, fees and costs. AAS encourages all clients and prospective clients to read this Wrap Fee Program Brochure, all relevant Wrap Fee Program Brochure Supplements, and any documentation for the specific advisory programs, products and/or services, and ask any corresponding questions, prior to participation in any advisory program, product or service provided through AAS. IMS Platform and Program Descriptions AAS’ Investment Management Solutions (IMS) platform provides you and your Advisor a multitude of investment advisory program options (individually, “IMS Program” and collectively, “IMS Platform”), including access to a wide variety of mutual funds, exchange-traded funds (ETFs) and a selection of third-party investment managers. Some of the IMS Programs allow for the inclusion of stock, bonds, and alternative/complex products. Prior to participating in any of the IMS Programs, the client and Advisor complete a Statement of Investment Selection (“SIS”), that includes a Risk Tolerance Questionnaire (“RTQ”), in order to determine the client’s (or investor) risk profile. Your risk tolerance is scored based on three factors: 1) time horizon; 2) long-term goals and objectives; and 3) short-term risk attitudes. Using a weighted average, an overall risk tolerance score is generated and mapped to one of five (5) possible risk profiles:
• Ultra-Conservative
• Conservative
• Moderate
• Growth
• Aggressive Growth The five possible risk profiles represent a theoretical risk spectrum from least risk to most risk. The recommended IMS Program (and the investments selected for your account) is constructed to represent the risk-return characteristics of your client risk profile. There is no guarantee that the risk tolerance generated from your answers accurately assesses your tolerance for risk, nor is there any guarantee that the asset mix or recommended IMS Program appropriately reflects your ability to withstand investment risk. See Item 6 for additional information on risks. The purpose of this Statement of Investment Selection ("SIS") is to establish an understanding between you and your Advisor regarding your investment objectives, goals, and investment management account guidelines. The SIS is considered a dynamic document that changes over time to reflect your changing life circumstances. Such changes naturally affect your goals, objectives, time horizon and feelings about risk in your account. Your Advisor will meet with you to review your SIS at least annually. See Item 9 for additional information on review of accounts. Retirement Investors: When we (AAS and your Advisor) provide investment advice to you (the client)regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code, as amended (“IRC”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests. We have a conflict of interest with you when we recommend a rollover / transfer of retirement assets and receive more compensation as a result. We mitigate this conflict of interest by providing you with relevant information, reviewing that information with you, answering your questions, and recommending only alternatives that we believe are in your best interest. We have provided you with other required disclosures, along with your account terms and conditions and/or advisory agreement that describe the specific services we will perform and/or terms and conditions of our relationship with you. This is important information so please read it carefully. Additional information about each IMS program, including the types of portfolio management services, wrap fee charges, discretionary authorities, and additional program costs, is provided below. For a more detailed description of each IMS program, contact your Advisor.  IMS Access Under AAS’ IMS Access program, AAS has retained Envestnet Asset Management, Inc., a registered investment adviser ("Envestnet"), to provide access to third-party investment managers (or SMA Managers). This is a discretionary program and AAS, Envestnet, and the selected SMA Manager have trading discretionary authority for your account. Your Advisor may select a SMA Manager, but does not have trading discretionary authority. AAS and Envestnet subsequently delegate the discretionary investment authority to the selected SMA Manager to directly March 29, 2024 Wrap Fee Program Brochure Page 8 of 34 manage the account per the selected investment strategy. AAS has a co-advisory relationship with the SMA Manager through Envestnet and AAS is responsible for selection, monitoring and termination of SMA Managers used under this program. Margin is available under this IMS program. The IMS Access program minimum account size is $100,000 and is subject to AAS’ maximum annual Program Fee of 2.3%. Additional information regarding program fees and costs is provided below.  IMS Flex Choice AAS’ IMS Flex Choice program provides you and your Advisor access to a wide variety of mutual funds, exchange- traded funds (ETFs) and also allows for the inclusion of stock, bonds, and alternative/complex products. In an IMS Flex Choice program, your Advisor will monitor your account and evaluate its performance in relation to your long- term goals and objectives. Your Advisor will also monitor the relative performance of your account in relation to the economy, capital markets and widely followed indices. The IMS Flex Choice (wrap) program minimum account size is $15,000 and is subject to AAS’ maximum annual Program Fee of 2.3%. Additional information regarding program fees and costs is provided below. AAS’ IMS Flex Choice program is available through a discretionary or non-discretionary arrangement. If you’ve granted your Advisor discretionary authority, your Advisor serves as the portfolio manager, will transact in your account and also rebalance investments consistent with the target investment allocations established for each particular risk profile. Each Advisor uses differing methods of analysis and investment strategies in formulating investment advice or managing assets and those assets may be subject to differing or additional risks. Advisors’ investment strategies are based on the client’s specific situation, including the client’s designated investment objective(s), risk tolerance(s), investment time horizon, and investment restrictions (if any). AAS encourages you to discuss this with your Advisor. Some investments, such as alternative and complex products, have liquidity or other restrictions that may limit the amount and/or timing of rebalancing such investments. Margin is also available under this IMS program. See Item 6 for additional information on risks. If you’re invested through a non-discretionary arrangement, your Advisor will be unable to affect any investment transactions without first obtaining your consent. AAS offers the IMS Flex Choice program on a discretionary and non-discretionary basis and also offers this program under a wrap and non-wrap fee advisory arrangement. Depending upon the investments, investment strategy, trading activity, and other factors, you (the client) may pay more or less in fees and expenses. Refer to AAS’ Brochure for a complete description of AAS’ non-wrap fee programs, including fees, costs and risks, as those are not described in this Wrap Fee Program Brochure. AAS encourages you to discuss these differences with your Advisor.  IMS Gateway AAS’ IMS Gateway program provides you access to a wide variety of mutual funds, cash and/or cash equivalents. Your Advisor will select the investments and monitor your account and evaluate its performance in relation to your long-term goals and objectives; however, your Advisor does not retain discretionary trading authority. AAS retains discretionary trading authority in the IMS Gateway program, monitors the relative performance of your account in relation to the economy, capital markets and widely followed indices and will automatically rebalance the account, as needed, on a periodic schedule chosen by the client from options provided by AAS. The IMS Gateway program minimum account size is $1,000 and is subject to AAS’ maximum annual Program Fee of 0.35% - 1.0% based on the account size, as follows: IMS Gateway Maximum Annual (Incremental) Fee Schedule: Account Size* Maximum Annual Program Fee ≤ $100,000 1.00% $100,000 - $250,000 0.50% $250,001 - $1,000,000 0.40% +$1,000,001 0.35% * based on Billable Account Value Additional information regarding program fees and costs is provided below. March 29, 2024 Wrap Fee Program Brochure Page 9 of 34  IMS Portfolio Choice Under AAS’ IMS Portfolio Choice program, AAS has retained Envestnet to provide access to unaffiliated third-party Fund Strategist Portfolio models ("FSP Models"). FSP Models include a wide array of investments, including mutual funds, equities, bonds, exchange-traded funds (ETFs) and alternative/complex products and investment strategies, including AAS’ IMS Select Model Portfolio Strategies (as described below under IMS Select). Your Advisor selects the FSP Model, but does not have trading discretionary authority. AAS retains discretionary trading authority and provides overlay management services to accounts participating in the IMS Portfolio Choice Program. AAS will make investment changes, as needed, to keep the account in line with the selected FSP Model. The IMS Portfolio Choice program minimum account size is $25,000, is subject to AAS’ maximum annual Program Fee of 2.3% and the client incurs additional costs for the selected FSP model(s). Additional information regarding program fees and costs is provided below.
• IMS Select Portfolio Franklin Templeton Strategy is a unique sleeve-based investment solution built using the Franklin Templeton family of mutual funds. The strategy consists of four distinct sleeve portfolios: Domestic, International, Balanced Income and Taxable Fixed Income – all of which can be used on a standalone basis or in combination to create a diversified portfolio. The Franklin Templeton Strategy is only available through the IMS Portfolio Choice Program. AAS determines the asset allocation for the individual sleeves and is responsible for fund selection and ongoing monitoring.  IMS Prime AAS’ Prime program provides you access to a wide variety of exchange-traded funds (“ETFs”), cash and/or cash equivalents. Depending upon your Advisor’s securities licenses, your Advisor will either 1) select a risk-based asset allocation with ETFs, as established by AAS, or 2) develop an asset allocation and choose the ETFs to align with that allocation. Under either, your Advisor will monitor your account and evaluate its performance in relation to your long-term goals and objectives; however, your Advisor does not retain discretionary trading authority. AAS retains discretionary trading authority in the IMS Prime program, monitors the relative performance of your account in relation to the economy, capital markets and widely followed indices and will automatically rebalance the account annually, or as needed. The IMS Prime program minimum account size is $5,000 and is subject to AAS’ maximum annual Program Fee of 2.3%. Additional information regarding program fees and costs is provided below.  IMS Select The IMS Select program currently offers eleven (11) portfolio strategies (each an “IMS Select Portfolio Strategy”) managed by AAS on a discretionary basis. Strategies may be added or removed at AAS’ sole discretion. Your Advisor selects the strategy and AAS retains discretionary trading authority in the IMS Select program, monitors the relative performance of your account in relation to the economy, capital markets and widely followed indices and will automatically rebalance the account, as needed, based on the selected IMS Select Portfolio Strategy. The IMS Select program minimum account size is $25,000 and is subject to AAS’ maximum annual Program Fee of 2.3%. Additional information regarding program fees and costs is provided below. Each IMS Select Portfolio Strategy has a unique mandate, utilizing mutual funds and exchange-traded funds (“ETFs”), as further described below (in alphabetical order):
• IMS Select Portfolio Blended Strategy uses an “active” and “passive” investment management approach by investing in active mutual funds, active ETFs, or factor-based (commonly referred to as “smart beta”) ETFs, and low cost, market-cap weighted ETFs within the portfolio’s strategic asset allocation established by AAS. This strategy is meant to generate capital appreciation over the long term within the risk profile chosen by the client (through the SIS).
• IMS Select Portfolio Dimensional Strategy seeks to deliver the performance of capital markets and increase returns, within the risk profile chosen by the client (through the SIS), through state-of-the-art portfolio design and trading techniques using a select group of Dimensional Fund Advisors (DFA) mutual funds. AAS is responsible for the strategic asset allocation, fund selection and fund weighting within this strategy.
• IMS Select Portfolio Dimensional Environmental, Social, and Governance (“ESG”) Strategy uses a select group of Dimensional “sustainability” mutual funds that take into consideration the impact companies may March 29, 2024 Wrap Fee Program Brochure Page 10 of 34 have on the environment, excluding or underweighting securities of companies whose environmental footprint could be detrimental to society as compared to other companies in the mutual fund’s investment universe. AAS is responsible for the strategic asset allocation, fund selection and fund weighting within this strategy.
• IMS Select Portfolio Dimensional Socially Responsible Investing (SRI) Strategy uses a select group of Dimensional “socially responsible” mutual funds that apply a screening methodology that reflects a broad set of investors’ social concerns. AAS is responsible for the strategic asset allocation, fund selection and fund weighting within this strategy.
• IMS Select Portfolio Franklin Templeton Strategy is only available through the IMS Portfolio Choice Program, as described above.
• IMS Select Portfolio Global Strategy offers exposure to both U.S. and International markets, utilizing active, passive, or “smart beta” mutual funds and ETFs. This strategy seeks to take advantage of unique opportunities in the current economic environment and, as such, there may be notable tilts within assets classes and sectors relative to the benchmark that may also result in higher turnover (i.e., more frequent trading activity).
• IMS Select Portfolio Income Strategy is specifically designed for those seeking current income with capital preservation and/or total return as secondary objectives and is only available under three risk profiles: ultra conservative, conservative and moderate. This strategy assumes that the client will be taking all income produced by the underlying mutual funds and ETFs, rather than reinvesting income and distributions. Therefore, as markets fluctuate, so will the account, more so than a traditional total return portfolio in which the client is reinvesting income.
• IMS Select Portfolio Passive Strategy uses a “passive” investment management approach by investing in low cost, market-cap weighted ETFs within the portfolio’s strategic asset allocation (“SAA”) that is designed to track the movements of a specific market index. This strategy is meant to generate capital appreciation over the long term within the risk profile chosen by the client (through the SIS).
• IMS Select Portfolio Russell Investments Tax-Managed Strategy uses a select group of Russell Investments mutual funds that use a technique that Russell Investment Management (“RIM”) calls “total portfolio management,” whereby multiple active manager positions are held in a single custody account with trades implemented by RIM with a focus on tax efficiency. This tax-managed strategy seeks to minimize capital gains and other fund distributions in order to mitigate the tax drag on portfolio performance. AAS is responsible for the strategic asset allocation, fund selection and fund weighting within this strategy.
• IMS Select Portfolio Tax-Smart Strategy focuses on tax-efficient investments, seeking equity exposure through ETFs, that may be “active,” “passive” (market-Cap weighted) or factor-based, and fixed income exposure through mutual funds or ETFs that contain underlying municipal bond exposures. This strategy is meant to generate capital appreciation over the long term within the risk profile chosen by the client (through the SIS).
• IMS Select Portfolio U.S. Only Strategy offers exposure to U.S. markets, utilizing active, passive, or “smart beta” mutual funds and ETFs. This strategy seeks to take advantage of unique opportunities in the current economic environment and, as such, there may be notable tilts within assets classes and sectors relative to the benchmark that may also result in higher turnover (i.e., more frequent trading activity). Under the IMS Select program, if elected by the client and/or Advisor, a tax-intelligent investment strategy (also referred to as a tax-managed investment strategy or tax overlay strategy) may be applied to a taxable account. A tax-managed investment strategy considers tax implications related to after-tax returns while staying as consistent as possible with the risk/return characteristics of the selected investment strategy. There are no guarantees as to the effectiveness of the tax-managed investing strategy and clients will be impacted differently. AAS does not (itself) provide legal or tax advice and clients should discuss any questions with or request further information from the Advisor and/or legal and tax professionals prior to engaging in a tax overlay strategy. The client is solely responsible for ensuring that all positions and tax lots in the account have complete and accurate cost basis March 29, 2024 Wrap Fee Program Brochure Page 11 of 34 information at all times.
• Advisor-Directed Tax Overlay services may be available through your Advisor. Advisors apply various techniques, such as tax-loss harvesting, long-term and short-term capital gain management, asset allocation and investment selections, when implementing a tax-managed investment strategy, primarily with respect to determining when assets in an advisory account should be bought or sold. Additionally, various methodologies and assumptions are used in determining the tax-implications relative to the strategy.
• IMS Select Tax Managed (TM) services are provided through Envestnet. The client authorizes Envestnet to exercise discretion to manage the account to client's specified tax sensitivity level, in an effort to help improve after-tax returns and also help reduce the client's tax burden. This service includes funding the account with legacy positions — both strategy and not-in-strategy — and optimizing the portfolio to the new IMS Select Portfolio Strategy. The service also includes ongoing tax management in the form of tax- loss harvesting, holding alternative positions, potential capital gains deferrals, tax-sensitive withdrawals and tax-sensitive rebalancing of the portfolio. An additional fee of 0.08%, or at a minimum $40, is charged to the client, and is included in AAS’ and the Advisor’s Program Fee and the minimum account size to participate in this service is $75,000.
• IMS Select Tax-Loss Harvesting (TLH) services is an automated loss-harvesting program managed by AAS, whereby an account in an IMS Select Portfolio Strategy with $5,000 or more in losses (on a month-over- month basis) will be automatically loss-harvested each month. While AAS plans to perform tax loss harvesting on a monthly basis, as described, AAS retains the right to perform tax loss harvesting at any time. Additionally, a portion of an account managed under the IMS Select program may be separately invested, from the chosen IMS Select Portfolio Strategy, in structured products. This portion of the account ("Structured Products Account") will be managed on a non-discretionary basis by your Advisor and may only include structured products as available and approved for the IMS Select program and as determined by your Advisor.  IMS Unified Choice Under AAS’ IMS Unified Choice program, AAS has retained Envestnet Asset Management, Inc., a registered investment adviser ("Envestnet"), to provide 1) overlay management services whereby Envestnet performs overlay management services of program accounts for third-party model providers, implementing portfolio changes pursuant to an investment

model updated by the model provider and/or 2) access to third-party investment managers (or Sub-Managers). This is a discretionary program and AAS, Envestnet, and/or the selected Sub-Manager have trading discretionary authority for your account. Your Advisor selects the strategy/strategies, but does not have trading discretionary authority. For certain investment strategies, the Sub-Manager manages the program account directly (without Envestnet's overlay services). In such instances, Envestnet delegates its discretionary trading authority to the Sub-Managers. AAS has a co-advisory relationship with the Sub-Manager through Envestnet and AAS is responsible for selection, monitoring and termination of SMA Managers used under this program. The minimum investment in the IMS Unified Choice program is $500,000 and the minimum investment for each single asset class fixed income portfolio is $250,000. The IMS Unified Choice program is subject to AAS’ maximum annual Program Fee of 3.0% and the client incurs additional costs for the selected third-party model provider(s) and/or Sub-Managers. Additional information regarding program fees and costs is provided below. Under the IMS Unified Choice program, if elected by the client and/or Advisor, a tax-intelligent investment strategy (also referred to as a tax-managed investment strategy or tax overlay strategy) may be applied to a taxable account. A tax-managed investment strategy considers tax implications related to after-tax returns while staying as consistent as possible with the risk/return characteristics of the selected investment strategy. There are no guarantees as to the effectiveness of the tax-managed investing strategy and clients will be impacted differently. AAS does not (itself) provide legal or tax advice and clients should discuss any questions with or request further information from the Advisor and/or legal and tax professionals prior to engaging in a tax overlay strategy. The client is solely responsible for ensuring that all positions and tax lots in the account have complete and accurate cost basis information at all times.
• Advisor-Directed Tax Overlay services may be available through your Advisor. Advisors apply various techniques, such as tax-loss harvesting, long-term and short-term capital gain management, asset March 29, 2024 Wrap Fee Program Brochure Page 12 of 34 allocation and investment selections, when implementing a tax-managed investment strategy, primarily with respect to determining when assets in an advisory account should be bought or sold. Additionally, various methodologies and assumptions are used in determining the tax-implications relative to the strategy.
• Tax-Loss Harvesting services are provided through Envestnet. The client authorizes Envestnet to exercise discretion to manage the account to client's specified tax sensitivity level, in an effort to help improve after- tax returns and also help reduce the client's tax burden. This service includes funding the account with legacy positions — both strategy and not-in-strategy — and optimizing the portfolio to the new IMS Select Portfolio Strategy. The service also includes ongoing tax management in the form of tax-loss harvesting, holding alternative positions, potential capital gains deferrals, tax-sensitive withdrawals and tax-sensitive rebalancing of the portfolio. An annual fee of 0.05% - 0.08% (or 8 basis points), based on the account’s asset size, is charged to the client and is in addition to AAS’ and the Advisor’s Program Fee. Trading and Brokerage Practices Generally, the Firm does not accept directed brokerage arrangements, which is where a client requires that account transactions be affected through a specific client directed broker-dealer. Client transactions are executed through the designated custodian(s), third-party investment manager(s) and/or TAMP(s). Clients should be aware that some third-party investment managers and/or TAMPs execute trades away from the custodian. For more information about the brokerage practices of any Platform Provider, third-party investment manager or TAMP, clients should refer to the information provided by the Advisor, including, but not limited to, the applicable disclosure(s) and applicable agreement(s). For AAS’ Investment Management Solutions (IMS) platform, advisory accounts are required to be established and held through AAS’ affiliated broker-dealer, AIS. AIS provides brokerage, custody and execution services through its clearing arrangement with National Financial Services LLC (“NFS” or “Custodian”), a non- affiliated firm, member NYSE, SIPC and a Fidelity Investments® Company. AAS selected AIS primarily due to its affiliation and AIS’ relationship with NFS. As part of this relationship, AAS’ receives substantial economic and non-economic benefits from NFS, including but not limited to, access to the Bank Deposit Sweep Program (as detailed in Item 4 and Item 9), accessibility to dedicated service personnel, electronic and institutional trading, third-party research and technology, technical and operational support, advisory fee processing, and electronic communications and reporting to clients. AAS’ and AIS’ affiliation creates conflicts of interest and, in many cases, incentivizes AAS and its Advisors to recommend an affiliate’s products and/or services versus other, similar, non-affiliated providers. Additionally, many of AAS’ Advisors serve in multiple capacities and may be incentivized to recommend products or services that create the greatest compensation for the Advisor. For additional information about AIS’ order execution and routing practices, visit https://www.avantax.com/disclosures/order-execution-routing or contact the Firm using the information on the cover page of this Brochure. AAS is obligated to seek best execution for all trades, regardless of program; however, in seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a services. While AAS reviews the accuracy, timeliness and execution of trades processed through the designated custodians, AAS cannot guarantee that a client will receive the most favorable execution of trades, which in turn may cost clients more money. Periodically, AAS reviews the custodial services provided by other qualified custodians in comparison to those provided by AIS and NFS. AAS and its Advisors have the ability to aggregate, “bunch,” or “block” client transactions. If elected, advisory accounts included in the bunched trade will receive an average price, if the entire order is not filled at a single price. Average pricing only occurs for trades in the same security entered at the same time by the same Advisor and not among different Advisors and only for stocks and ETFs. It is possible that there will be two or more aggregate trades for the same security for the same Advisor on the same day (e.g., one bunched trade is entered in the morning and one or more are entered later that same day). AAS does not generally do an average price calculation across multiple aggregate trades (either among the same or different Advisors). If the order does not execute in its entirety, the shares are allocated on a pro rata basis based on the original aggregated trade. There can be occasions where the pro rata allocation is increased or decreased to avoid holding odd lot or small numbers of shares, especially for smaller accounts. This allocation is determined in good faith in an attempt to be fair and equitable. March 29, 2024 Wrap Fee Program Brochure Page 13 of 34 Trades for tax-managed investing accounts may be processed separately from non-tax managed investing accounts. Therefore, same-day or multi-day trade timing differences can occur between the processing, submission and the execution of securities transactions, resulting in execution price differences between accounts and clients. AAS does not engage in cross trading and principal trading. A cross trade occurs when an investment adviser causes a trade to occur between two or more of its advisory clients’ accounts. A principal trade takes place when an adviser arranges for a security to be purchased from or sold to a client from its own account (which can include a fund in which the adviser or its personnel have a substantial ownership interest). IMS Platform and Program Fees and Costs Your Advisor and AAS will typically earn compensation for wealth management advisory services by charging an asset-based Program Fee that includes investment advisory, portfolio management, periodic reporting, and administration. All clients will incur underlying investment expenses. Furthermore, depending upon the investments, services, and negotiated agreement, clients will also incur other fees and expenses. This information is documented in the agreement (via the SIS) and the custodial agreement. Additional information about these fees and expenses is described in the section entitled Other Expenses, Fees and Costs. The Program Fee is negotiated between you and your Advisor (on an account-by-account, client-by-client basis) and is subject to AAS’ maximum annual Program Fee, as follows: Program Name Minimum Account Size* Maximum Annual Program Fee Additional Program Costs IMS Access $100,000 2.3% IMS Flex Choice $15,000 2.3% IMS Gateway $1,000 0.35% - 1.0% IMS Portfolio Choice $25,000 2.3% Third-party manager fee(s) IMS Prime $5,000 2.3% IMS Select $25,000 2.3% Tax-overlay services (optional) IMS Unified Choice $500,000 3.0% Third-party manager fee(s) * based on Billable Account Value The Program Fee is reflected in the client agreement (via the SIS) as a flat, tiered or incremental annual percentage, that is calculated on the Billable Account Value, billed quarterly in advance (January, April, July and October), directly debited from the client’s account, and reflected on the custodial account statement. The Program Fee may be flat, tiered or incremental annual percentage, as further described below: Flat Fee Schedule: A Program Fee based on a flat percentage would apply the applicable Program Fee rate (%) based on the applicable Billable Account Value, regardless of the amount. For example, under a flat fee schedule, if an account has a Billable Account Value of $1,500,000, the entire $1,500,000 would be charged a Program Fee rate of 1.25% (annually). Tiered Fee Schedule: A Program Fee based on a tiered percentage would apply the applicable Program Fee rate (%) based on the applicable Billable Account Value (assets) that fell within each tier, subject to the maximum annual program fee. For example, From $0 to $1,000,000 , the fee is 1.25% From $1,000,001 to $2,000,000 , the fee is 1.00% From $2,000,001 to $5,000,000 , the fee is 0.75% Over $5,000,000+ , the fee is 0.60% Under the illustrative tiered fee schedule, if an account has a Billable Account Value of $1,500,000, the first $1,000,000 would be charged at a Program Fee rate of 1.25% and the remaining $500,000 would be charged at a Program Fee rate of 1.00% (annually). March 29, 2024 Wrap Fee Program Brochure Page 14 of 34 Incremental Fee Schedule: The IMS Gateway Program Fee is based on an incremental schedule, whereby the Program Fee rate (%) is based on the total Billable Account Value. The fee changes once the Billable Account Value reaches the next fee increment. For example, if an account has a Billable Account Value of $1,000,000, the Program Fee rate would be 0.40% (annually). If during the next billing cycle, the account’s Billable Account Value is $1,500,000, the Program Fee rate would be 0.35% (annually). NOTE: AAS and its Advisors price services based upon various objective and subjective factors. As a result, AAS’ clients will pay diverse fees and costs based upon, among other things, the complexity of the engagement, type of service(s), investment products used, investment program and strategies employed, and other third-party-specific costs. Clients may inquire at any time with their Advisor as to client-specific fees and costs. The Program Fee is calculated by taking the Program Fee percentage (%), divided by the number of days in the calendar year (i.e., 365 or 366 for leap years), then multiplying the quotient by the number of days in the billable calendar quarter (i.e., 90, 91 or 92 depending on the quarter and year), and multiplying that quotient by the Billable Account Value ($). The sum (i.e., quarterly Program Fee) is the amount that is directly debited from the client’s account, unless otherwise agreed to in writing, and reflected on the custodial account statement in January, April, July and October. Subject to variances outlined below, the "Billable Account Value" is equal to the market value of all assets, including cash and cash equivalents, and less the market value of any excluded assets. The market value of all assets and the calculation of the Program Fee is provided through a third-party portfolio accounting system that receives information from AAS’ custodian. The market value information provided by the third-party portfolio accounting system is as of the close of business on the last business day of the billable calendar quarter. However, these quarter- end market valuations may be different from the market valuations provided by the custodian due to timing of corporate actions, accrued interest, and trade settlements. Excluded assets are determined in the sole discretion of AAS or as requested by an Advisor and approved by AAS. For more information about AAS’ fee billing process, contact your Advisor or the Firm using the information on the front of this Wrap Fee Program Brochure. The Program Fee includes AAS’ administrative fee, which ranges from 0.012% to 0.35% based upon your Advisor’s total advisory assets under management through AAS. You (the client) are charged and debited the agreed upon Program Fee from which AAS’ administrative fee is deducted and the remaining portion is distributed to your Advisor. The following Program Fee variances apply: Initial Program Fee: The initial Program Fee, or Inception Fee, is calculated as of the date the Billable Account Value is funded or, if applicable, reaches the Program’s minimum amount (“Inception Date”) and is prorated for the balance of calendar days remaining in the calendar quarter. The initial Program Fee is billed the month following the Inception Date. Interim Program Fee Adjustments: In the event any deposits and/or withdrawals (netted) equal or exceed $10,000 (in market value on an absolute basis) on any business day in an account, an interim, prorated Program Fee will be charged or refunded (as applicable) to the account. This is commonly referred to as flow or interim billing and is only applicable on an account-by-account basis (not aggregated with other related accounts). Each interim, prorated Program Fee is assessed in the month following the receipt/payment of the deposits/withdrawals (netted) and is based on the number of days remaining in the current billing period. Bank Deposit Sweep Program Adjustments: Any cash balances held in the Bank Deposit Sweep Program exceeding 25% of an advisory account’s assets, calculated from the end of the prior billing period to the end of the current billing period, will be excluded from the Billable Account Value. For example, if an advisory account has 26% of its assets in cash held in the Bank Deposit Sweep Program as of June 30th and as of September 30th, the market value of 1% of those assets will be excluded from the Billable Account Value for September 30th. Additional information about cash and cash equivalents, including related conflicts of interest, is described in the section entitled Other Expenses, Fees and Costs. Related Account(s): Upon a client’s request, as negotiated with the Advisor, and as accepted by AAS in AAS’ sole discretionary, advisory accounts may be associated or linked together (“Related Accounts”) for tiered- March 29, 2024 Wrap Fee Program Brochure Page 15 of 34 fee billing purposes and may allow the Related Accounts (in aggregate) to achieve a lower-cost, tiered billing rate. For additional information, contact your Advisor. Program Fee Changes: AAS reserves the right to modify or change the Program Fee after thirty (30) days of written notice to the client. You and your Advisor may renegotiate a Program Fee at any time and, an increase in a Program Fee will require a new client agreement and SIS; however, a decrease in a Program Fee requires only a notification by your Advisor to AAS. Program Fee changes will become effective at the beginning of the next billing period (i.e., start of each calendar quarter). Ineligibility: In the event an account is deemed ineligible for a program, such as no longer meeting a program’s minimum requirements or not funding an account (minimum size) within 90 days of opening an account, the advisory account will automatically be moved to a retail, brokerage account with AAS’ affiliated broker-dealer, AIS. Wealth management advisory services will be discontinued and the related Program Fee will be terminated in accordance with AAS’ policies (e.g., never charged or refunded). AAS and your Advisor will no longer be obligated to provide on-going advice and any trading will be done at your request (non- discretionary) and subject to retail commissions on a trade-by-trade basis. Termination Refunds: Wealth Management Advisory Services may be terminated via notice at any time by either the client or AAS and, following the receipt of a notice of termination, the client will be issued a prorated refund of paid Program Fees, based upon the number of days from the termination date through the end of the then-current fee period. A refund, if any, is paid the month following the termination date. Third-Parties AAS offers advisory services by referring clients to unaffiliated third-parties, including but not limited to investment managers and Turnkey Asset Management Platforms (“TAMPs”). These third-parties may charge a minimum fee, and clients should be aware that the imposition of minimum fees by another entity will result in a higher fee being charged than is described in this Wrap Fee Program Brochure. Clients may authorize the deduction of a third-party’s fees from the client’s custodial account(s). These additional fees and charges will be set forth in the information provided by the Advisor, including, but not limited to, the applicable third-party’s disclosure(s) or the applicable agreement(s). Other Expenses, Fees and Costs All clients will incur underlying investment expenses and, depending upon the investments, services, and negotiated agreement may also pay other fees and expenses, as described below. Clients may inquire at any time with their Advisor as to client-specific fees and costs. Additional information about other expenses, fees and costs typically associated with AAS’ advisory services is provided below.
• Underlying Investment Expenses for Mutual Funds and ETFs: Mutual funds and/or exchange traded funds (“ETFs”) pass along costs to investors by imposing fees and expenses, such as shareholder fees, operating expenses and/or transaction costs. These costs reduce the returns on mutual funds and ETFs. Therefore, clients should fully understand the costs incurred through these investments, as fully described in the mutual fund or ETF prospectus that is available upon request from your Advisor, and fully discuss these costs with your Advisor. For example, a client invested in a mutual fund or ETF through an AAS advisory program will pay at least two layers of fees. The client will pay the mutual fund or ETF underlying investment management fees and will also pay AAS’ Program Fee. Clients may invest in many of the ETFs and mutual funds that AAS makes available through another broker-dealer, custodian, investment adviser or another financial institution and, as a result the client’s fees may be higher or lower than those charged by AAS and your Advisor. o Share Class Costs and Fees: Mutual funds and ETFs have different share classes with different fee structures and costs. Some share classes of a fund charge higher internal expenses, whereas other share classes of a fund charge lower internal expenses. Institutional and advisory share classes typically have lower expense ratios and are less costly for a client to hold than Class A shares or other share classes that are eligible for purchase in an advisory account. In some instances, a mutual fund offers only Class A Shares, but another similar mutual fund may be available that offers institutional shares. Some share classes incur a ticket charge (commonly described as TF shares). Other share classes incur no ticket charges (commonly described as NTF shares), but usually have higher underlying costs, and the associated costs would ultimately be incurred by the client. March 29, 2024 Wrap Fee Program Brochure Page 16 of 34  While AAS strives to utilize the lowest cost share class available (without a surcharge) through its custodians, there may be other less costly share classes offered by a fund that are 1) not available for use by AAS due to constraints imposed by the terms of the fund’s prospectus, 2) not available on the custodial platform, and/or 3) subject to other conditions or restrictions that make utilizing such share class unreasonable, costly or prohibitive. A conflict of interest exists in those limited situations in which AAS elects to utilize a share class more costly to the client, than the lowest cost share class available at the custodian, in order to avoid a custodian-imposed surcharge. o 12b-1 Fees and Revenue Share: Some mutual funds charge “12b-1 fees” to cover the costs of marketing and selling fund shares (distribution) and providing shareholder services. Distribution fees include fees to compensate brokers and others who sell fund shares and to pay for advertising, the printing and mailing of prospectuses to new investors, and the printing and mailing of sales literature. Shareholder service fees are fees paid to persons to respond to investor inquiries and provide investors with information about the mutual fund. Shareholder service fees can also be paid outside of 12b-1 Fees (“Revenue Share”). Certain mutual fund companies pay AAS’ affiliate, AIS, to provide shareholder liaison services to investors. These fees are classified as shareholder servicing fees and generally include responding to investor inquiries and providing information on mutual fund investments.  While AAS does not directly receive this revenue, a conflict of interest exists because AAS indirectly benefits from its affiliates’ profitability and growth. Specifically, AAS’ affiliated broker-dealer, AIS, receives these shareholder service fees from certain mutual funds based on AAS’ advisory assets invested in a particular mutual fund. o Sales Charges, Redemption Fees, and Other Restrictions: If a client transfers a previously purchased mutual fund, and there is an applicable contingent deferred sales charge on the fund, the client will pay that charge when the mutual fund is sold. If the account is invested in a mutual fund that charges a fee if a redemption is made within a specific time period after the investment, the client will be charged a redemption fee. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or tax-loss harvesting).  Clients have the ability to retain the higher cost share class until any contingent or deferred sales loads have passed before including such positions in an AAS account. See Item 6 for additional information on risks, including mutual fund and ETF risks.
• Advisory Fees on Cash Assets and the Bank Deposit Sweep Program: AAS, by and through its affiliate, AIS, makes available a Bank Deposit Sweep Program to its clients. AAS calculates asset-based fees (e.g., Program Fees and Asset Management Fees) on assets placed under its management, including cash, cash equivalents, money market funds, and assets held in the Bank Deposit Sweep Program. This creates several conflicts of interest and potentially additional costs to you. Depending on the client’s investment objective and/or strategy, these cash balances could be relatively high and represent a material portion of the overall account. Clients should understand that the asset-based fees charged on these balances may exceed the returns provided by cash, cash equivalents, money market funds and/or Bank Deposit Sweep Program, especially in low interest rate environments. Furthermore, AAS’ affiliate, AIS, and the custodian, NFS, receive revenue share from the Bank Deposit Sweep Program. Any fees earned from the Bank Sweep Program are not shared with your Advisor; however, the returns on the Bank Deposit Sweep Program may be less than you would earn through other similar programs and/or other investments. Furthermore, the more assets that are held in the Bank Sweep Program and/or as interest rates increase, the revenue share increases. Such increases do not directly correlate to increased returns for clients invested in the Bank Deposit Sweep Program. AAS is incentivized by its business model to use its affiliate’s Bank Deposit Sweep Program, rather than individualized client circumstances. See Item 9 for additional information about this program.
• Clearing and Custody Fees (“C&C Fees”): Client-specific custodial asset-based charges are detailed in the client’s custodial agreement(s) or client’s custodial quarterly statements. The custodial asset-based charge is paid to the custodian, based on a percentage of the market value of the assets held within the account. The investment strategy will determine whether the C&C Fees will be deducted from the Program Fee, paid by the Advisor or deducted from the client’s account. The amount of C&C Fees is usually determined by the level of assets held in the account or particular program. AIS, at its sole discretion, adds a markup to various C&C Fees that are paid by clients. The markup generates additional revenue for AIS. See Item 9 for March 29, 2024 Wrap Fee Program Brochure Page 17 of 34 additional information.
• Trade Execution Costs (“Ticket Charges”): Client-specific custodial transaction-based charges are detailed in the client’s custodial agreement(s) or client’s custodial quarterly statements. The custodial transaction- based charges are billed by and paid on trade date to the custodian when a transaction is executed through the custodian and is based on the specific security or investment involved in the transaction. The investment strategy, investments and related transactions will determine whether the Ticket Charges will be deducted from the Program Fee, paid by the Advisor or deducted from the client’s account. AIS, at its sole discretion, adds a markup to various Ticket Charges that are paid by clients. The markup generates additional revenue for AIS. See Item 9 for additional information.
• Account and Elective Services Costs: All third-party providers, including the custodian, third-party investment managers, and TAMPs available through AAS offer elective (or add-on) services and other charges that are borne solely by the client. For example, wire fees, transfer fees, margin interest, account activity fees, retirement account maintenance fees, platform fees, strategist fees, and annuity/insurance carrier fees. These costs may be waived, in whole or in part, by the third-party based on level of assets maintained with the third party, or other factors and/or conditions. Such fees may be higher or lower than those required by other third-parties.
• Alternative and Complex Products’ Impact on Advisory Fees: Certain alternative and complex products (e.g., Direct Participation Programs involving Non-Traded Private Equity investments and/or Non-Traded REITs; Structured Products) may be deemed illiquid or non-tradeable. Consequently, these products will effectively become static holdings in your portfolio, with other holdings being rebalanced around the static/illiquid product(s). The Program Fee for these types of investments may be calculated based on unaudited net asset values provided as estimates by the sponsor of the product. These unaudited net asset values (deemed a “Fair Value”) are provided by the product sponsor on a reporting period basis (e.g., monthly). AAS does not audit or confirm the accuracy of the Fair Values provided by sponsors. Sponsors do not adjust previously determined Fair Values. These valuations affect the calculation of a Program Fee. For example, the portion of your Program Fee attributed to a Non-Traded Alternative Investment may be calculated based on its Fair Value as of the end of the second month of the previous calendar quarter, rather than as of the end of the previous quarter. Thus, increasing or decreasing your Program Fee. See Item 6 for additional information on risks, including alternative and complex product risks.
• Margin and Margin Interest: The use of margin is permitted in some investment advisory programs and may be recommended by your Advisor, resulting in additional costs, Program Fees and conflicts of interest. Margin, or a margin debit balance, is created by borrowing against your account which gives you access to cash and/or the ability to purchase additional investments. It is a conflict of interest if you borrow on margin in your account because AAS’ affiliate, AIS, and the custodian receives compensation on the interest you pay on your margin debit balance. You are encouraged to evaluate the interest rates you pay by borrowing on margin and compare those interest rates to other available sources of credit (or lenders) from which you can borrow, as the interest you might be charged by borrowing on margin may be greater than loans available to you elsewhere. The use of margin exposes investors to the potential for higher losses. See Item 6 for additional information on risks, including margin and leveraging.
• Variable and Index Annuity and Other Pooled Investment Fund Costs: If a client holds a variable annuity that is managed as part of advisory account, there are mortality, expense and administrative charges, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. Likewise, if a client holds a Unit Investment Trust (“UIT”) in a program account, UIT sponsors charge creation and development fees or similar fees. Clients should understand the costs incurred through these investments, as more fully described in the prospectus that is available upon request from your Advisor.
• Trading Errors: AAS endeavors to identify and correct trade errors as soon as possible. When a trade error has been identified by AAS, the Advisor or client, AAS will promptly correct the error with the goal of restoring the account back to the same condition that would have resulted if the error had not occurred. Losses associated with trade errors that are not caused by the client will be borne by AAS or the Advisor. Under some circumstances, correction of an error could result in a gain; such gains are retained by AAS. For purposes of determining the gain or loss, related transactions are corrected in the aggregate so that profits offset March 29, 2024 Wrap Fee Program Brochure Page 18 of 34 associated losses; a client may not elect to ratify only those portions of a related transaction that are profitable.