Firm Background & Principal Owners Money Concepts Advisory Service (referred to as “MCAS,” “Firm,” “we,” or “us”) is the name we use when providing investment advisory services. MCAS is an unincorporated division of Money Concepts Capital Corp. ("MCCC"), a Florida corporation headquartered in Palm Beach Gardens, Florida. We have been in business since 1991. MCCC is registered with the SEC as an investment adviser and is also registered with the SEC and all 50 states and the District of Columbia as a broker-dealer. We are a member of the Financial Industry Regulatory Authority (“FINRA”). The following entities own, directly or indirectly, 25% or more of MCAS: Direct Owner: Money Concepts International, Inc. Indirect Owner: World Investment Network, Inc. We use the name “Money Concepts Advisory Service” when referring to the activities of our investment advisory business, and we use the name “Money Concepts Capital Corp” when referring to the activities of our broker-dealer business. Most Investment Adviser Representatives (“IARs”) of MCAS are registered as Registered Representatives of MCCC; a portion of the Registered Representatives of MCCC are registered as IARs of MCAS. Some IARs and Registered Representatives are also licensed insurance agents. MCAS offers various investment advisory services to meet a variety of client needs and objectives. We offer the following types of investment advisory services:
• Portfolio Management
• Financial Planning
• Consulting At the onset of our engagement, clients will complete an account profile or questionnaire to help us understand their financial situation, investment objectives, tolerance for risk, and investment time horizon, among other considerations. We will recommend one or more of our services based on their investment profile. Our recommendations may include our brokerage and/or insurance services in addition to, or in place of, our investment advisory services. Services will be provided pursuant to a written agreement. Portfolio Management Based on the client’s investment profile, we will assist the client in selecting a suitable portfolio management program. We offer a variety of portfolio management services on a discretionary and non-discretionary basis, depending on the program selected. Some of the programs utilize model portfolios, while others utilize IAR-designed or IAR-directed portfolios. Additionally, some of our programs may be managed by a sub-adviser. Each program is different, so it is important to carefully read the program descriptions provided to you and to ask your IAR any questions you may have. Differences among the various programs may include, but are not limited to, the following: minimum account size, the use of sub-advisers (if any), the types of securities traded within the portfolio, fees, asset allocations, and rebalancing frequencies. Certain programs may be restricted to investments in certain types of securities, such as exchange-traded funds (“ETFs”) or variable annuities. While clients may not be required to purchase a variable product, certain investments may only be available as subaccounts of a variable product. Once a program is selected, the client’s assets will be managed according to the program’s investment strategy. In some instances, we (or the sub-adviser, as applicable) may allow a client to impose certain restrictions on the types of securities we recommend for the client’s account. In such an instance, clients should be aware that the imposition of account restrictions may result in investment performance that differs from other clients within the same program. Clients are advised that changes in their financial situation, investment objectives, tolerance for risk, or investment time horizon may cause the program or strategy selected by the client to no longer be suitable. In the event of any such change, the client should contact us promptly in order to identify another program or strategy to fit the client’s needs. A client agreement may be canceled at any time, by either party, for any reason upon receipt of thirty (30) days written notice. Upon termination, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. The client has the right to terminate an agreement without penalty within five (5) business days after entering into the agreement. We offer portfolio management services through the following programs: a) Guided Portfolio Solutions (“GPS”) Program b) GPS – Retirement Plan Network c) Managed Allocation Program d) MAP Advisor Assisted Program e) World Class Pension Program Guided Portfolio Solutions (“GPS”) Program There are multiple portfolios and programs within the GPS Program. Generally, custody of participating accounts is provided by Pershing LLC, an affiliate of The Bank of New York Mellon, or Charles Schwab & Co., Inc. (“Schwab”), depending in part on the program selected. The client’s investment advisory contract, which is executed by and between the client and MCAS, will contain important information about the client’s account, including the program selected and other pertinent details, such as whether MCAS has discretionary or non-discretionary authority over an account. Current programs include the following: Program Minimum Account Size Sub-Adviser Investment Authority World Class Total Access $10,000 None Non-discretionary World Class Total Access Premium $10,000 None Discretionary WIN Portfolios $25,000 WIN Advisors, Inc. Discretionary Efficient Allocation Strategy $10,000 None Discretionary World Class Target Allocation $15,000 / $25,000 None Discretionary Investor’s Advantage Portfolios $15,000 / $50,000 / $100,000 / $250,000 / $1,000,000 None Discretionary Castellum Asset Management $500,000 None Discretionary Money Concepts Strategist Determined by sub- adviser BNY Mellon Advisors, Inc. Limited discretionary GPS Guardian $25,000 None Discretionary Liberty One Portfolios $10,000 / $25,000 / $50,000 / $100,000 Liberty One Investment Management Discretionary Dynamic Market Advantage $10,000 / $100,000 / $1,000,000 None Discretionary Howard Capital Management $10,000 / $25,000 / $500,000 Howard Capital Management, Inc. Discretionary Bluegrass Asset Management $10,000 None Discretionary MCAS Separately Managed Accounts Determined by the sub-adviser BNY Mellon Advisors, Inc. or its designee Discretionary BNY Mellon AdvisorFlex Portfolios $50,000 BNY Mellon Advisors, Inc. Discretionary BNY Mellon Target Risk Focus Portfolios $250,000 BNY Mellon Advisors, Inc. Discretionary BNY Mellon Target Risk Portfolios $50,000 BNY Mellon Advisors, Inc. Discretionary Intrinsic Value Portfolios $25,000 None Discretionary Endowment Strategy $25,000 None Discretionary Client assets are invested in accordance with the investment objective and level of risk they, along with their adviser, determine is suitable. With the exception of the World Class Access, World Class Access Premium, World Class Pension, Investor’s Advantage Portfolios, and Castellum Asset Management programs, portfolios are not tailored to meet the specific needs of the individual client. The BNY Mellon AdvisorFlex Portfolios are part of a wrap fee program sponsored by BNY Mellon Advisors, Inc. whereby most advisory fees and brokerage fees are bundled together in a fixed, flat rate, the amount of which may or may not be higher than if such services were provided à la carte. When you participate in the BNY Mellon AdvisorFlex Portfolios, we receive a portion of this wrap fee. For more information about this wrap fee program, please review the wrap fee program brochure for BNY Mellon Advisors, Inc. and related disclosure documents. Clients participating in the World Class Total Access, World Class Total Access Premium,

and Investors’ Advantage programs have the option of participating in a complementary annuity-linking program (the “Annuity-Linking Program”), which incurs a separate add-on fee. The fee charged is based upon a percentage of the linked annuity’s value at the start of the quarter; the percentage charged is 0.5% on a quarterly basis (2% annually). GPS – Retirement Plan Network The GPS – Retirement Plan Network program is available exclusively for the management of retirement assets, such as 401(k) plans. The program utilizes retirement-specific model portfolios that have been created by MCAS. These proprietary model portfolios are comprised of a diverse group of no-load or load-waived mutual funds, collective investment funds, and ETFs. Each model portfolio is actively managed by MCAS. The assets and allocations of a participating client’s portfolio will strongly correlate with those of the model portfolio it follows. There is no account balance required, and accounts are managed on a discretionary basis. This program utilizes investment strategies that are based upon proprietary model portfolios, not the specific needs of an individual client. Under this program, MCAS serves as a “fiduciary” as defined under ERISA. The proprietary model portfolios created by MCAS are intended to assist participating clients in meeting their diversification needs. The composition of assets held in a participating client’s account, as well as the availability of certain investments, are subject to change from time to time. MCAS utilizes an independent, qualified recordkeeper to rebalance participating client accounts at the direction of MCAS and to the extent necessary to comply with the current allocation of the model portfolios they follow. Managed Allocation Program This program manages Variable Annuities on a discretionary basis. The program has a minimum account size of $10,000. In the Variable Annuities program, MCAS invests client assets into subaccounts within variable annuities and makes adjustments therein. Clients participating in this program have the option of participating in the Annuity-Linking Program, which incurs a separate add- on fee. The fee charged is based upon a percentage of the linked annuity’s value at the start of the quarter; the percentage charged is 0.5% quarterly (2% annually). MAP Advisor Assisted Program Two services are offered under the MAP Advisor Assisted Program umbrella: the Variable Annuities program and the American Funds Class F-2 Shares program. Both are offered on a non-discretionary basis. The Variable Annuities program enables participating clients to allocate investments into various sub-accounts within selected annuities. The minimum account size for a variable annuity is $10,000. The American Funds F-2 program offers investments in several share classes of actively managed mutual funds. It does not have a minimum account size. World Class Pension Program In this program, MCAS will advise qualified pension and profit-sharing plans regarding select no-load and load-waived mutual funds available at NAV, and will educate, and provide assistance, where necessary, to plan participants regarding making exchanges between mutual funds available through their plans. MCAS will make ongoing recommendations for adjustments to the funds available through the plan. This program is offered on a non-discretionary basis to sponsors of qualified pension and profit-sharing plans. The sponsor will select the custodian and plan administrator utilized. The minimum plan size is $10,000. Financial Planning Our financial planning service is designed to help individuals, families, and business owners navigate their financial future and reach their financial and personal goals. We work with the client as a team to develop an overall strategy for all aspects of the client’s financial planning, life goals, and legacies. Our financial planning services include the following:
• Onboarding and fact-finding process, including documentation request and review
• Updated (e.g. frequently and regularly refreshed) comprehensive financial plan
• Financial discussions of your personal values, goals, objectives, desires, and dreams
• Implementation meeting to discuss comments, observations, and action items
• Cash flow and budget review, analysis, action items, and/or implementation
• Goal planning, analysis, action items and/or implementation
• Retirement goals, savings, future cash flow analysis, observation, and action items
• College education funding planning, analysis, action items, and/or implementation
• Investment review, analysis, comment and action items
• Risk analysis of personal liability, property, life, disability, and/or long-term care insurance
• Estate, trust, wealth transfer plan review, observations, and action items
• Current and future tax review, observations, and action items
• 2-meeting process per year to review, adjust, update those aspects agreed to
• Financial account aggregation and display online
• Online document storage and access [read only capability]
• Ongoing phone and email consultations, as needed within reason at our discretion The engagement for our financial planning services is in effect for a period of one year with an automatic renewal, unless terminated in writing by either party. Either party may terminate the engagement at any time for any reason, in which case, termination of the agreement shall take effect on the next business day following the other party’s receipt of the written notice. Consulting We offer consulting services on matters such as retirement, estates, insurance, investment research, and administrative matters pursuant to a written agreement. Either party may terminate the agreement at any time and for any reason by providing written notice to the other party. In which case, termination of the agreement shall take effect on the next business day following receipt of the written notice. Types of Investments We provide advice regarding a wide variety of investment products, including:
• Exchange-listed or over-the-counter debt or equity securities
• Warrants, commercial paper
• Money market funds, open-end investment companies (such as mutual funds), ETFs, closed-end funds, and unit investment trusts
• Variable life insurance, variable annuities, and their investment subaccounts
• Certificates of deposit, municipal securities
• Securities issued by the US Treasury, agencies, or government sponsored enterprises
• Options contracts, interests in partnerships investing in real estate, oil and gas interests, and equipment leasing The securities for which we offer advice are more extensive than the investments we generally recommend to our clients. Negotiability For all services, we have the discretion to negotiate the terms of each client’s relationship with us on a case-by-case basis, including, but not limited to, minimum account size. When considering and negotiating these matters, we usually consider, among other factors, the dollar amount of assets to be placed under management by the client and related accounts, anticipated future accounts or other assets, and current or anticipated services or other relationships. We may elect, at our own discretion, to aggregate related client accounts for the purpose of achieving the minimum account size requirements and determining fees. Waivers, discounts, or more favorable terms may be offered to family members and friends of our employees and affiliates. The specific terms of each client’s advisory relationship will be agreed upon in writing by both MCAS and the client. Assets under Management As of December 31, 2023, we manage $1,711,375,691 on a discretionary basis and $1,192,641,330 on a non-discretionary basis.