Item 5: Account Requirements and Types of Clients........................................................................................... 48 Item 6: Portfolio Manager Selection and Evaluation ........................................................................................... 48 Item 7: Client Information Provided to Third-Party Portfolio Managers ............................................................ 50 Item 8: Client Contact with Portfolio Manager .................................................................................................... 50 Item 9: Additional Information ............................................................................................................................ 50 Appendix: Brochure Supplement (Part 2B of Form ADV) .................................................................................. 56 Our Firm Concourse Financial Group Securities, Inc. (“Concourse” or “Firm”) is a registered broker-dealer and registered investment adviser (operating under a DBA of Concourse Financial Group Advisors) that serves as the sponsor of, and in some cases as a portfolio manager for, wrap fee investment programs. Concourse is a wholly-owned subsidiary of Protective Life Corporation, which is wholly owned by Dai-ichi Life International Holdings, LLC(“Dai-ichi”) since February 2015. We provide investment advice through investment adviser representatives (“Advisors”) who are associated with us as independent contractors and business owners. Representatives of Concourse’s investment advisory business are also registered as independent contractor representatives with Concourse’s registered broker-dealer (Member FINRA/SIPC). This dual affiliation allows them to offer brokerage products and services to clients. An Advisor who is appropriately registered may offer a client both investment advisory and brokerage services. Before engaging with an Advisor, clients should take time to consider the differences between an advisory relationship and a brokerage relationship to determine which type of service best serves your investment needs and goals. Clients should speak to the Advisor to understand the different types of services available through Concourse. Concourse, through its Advisors, provides investment advice and management on assets in your account. Each Advisor is responsible for maintaining their client relationships. As of December 31, 2023, Concourse had $4,373,015 in assets under management (“AUM”), of which $3,009,914,318 was managed on a discretionary basis and $1,363,101,224 was managed on a nondiscretionary basis. Our Advisory Services Concourse offers a variety of investment advisory services and programs to its Advisors for use with their clients, including wrap fee programs, advisory programs offered by third-party investment adviser firms, financial planning services, and retirement plan consulting services. Our investment advisory services and programs are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. Concourse offers advisory services on a discretionary and non-discretionary basis. To participate in our discretionary portfolio management services, a client must grant our firm discretionary authority to manage his/her account. Discretionary authorization allows us to determine the specific securities and the amount of securities to buy or sell for an advisory account without client preapproval. Discretionary authority is typically granted by the investment advisory agreement the client signs with our firm, a power of attorney, or trading authorization form. The Advisory Management Plus (AMP) Platform Advisors offer investment management services through the selection of a Concourse-sponsored asset management program managed by the Advisor, Concourse as the Portfolio Manager, or with access to unaffiliated third-party managers. These services include, but are not limited to, providing ongoing investment advice; implementation of a portfolio plan which may include trading and rebalancing of funds necessary to assist the client to meet his or her objectives and risk/return tolerance; as well as ongoing review of a client’s portfolio plan to ensure this plan remains consistent with the client’s financial and personal objectives and risk/return tolerance. The Advisor will review with each client their investment objectives and risk/return tolerance and may recommend investment in the appropriate Concourse-sponsored asset management program. Some Advisors manage each account to models they have created; others customize each account to each client. The advisory services offered are tailored to the individual needs of each client, taking into consideration the client’s risk tolerance, investment objective, time horizon, and other factors. Clients may impose restrictions on investments in certain securities or types of securities; however, such restrictions will impact the performance of the account. Such requests must be submitted to Concourse in writing. Administrative, website, performance reporting, transaction order entry and other services are provided to Concourse by outside service providers and sub-advisors. A client grants us the discretionary authority to select one or more sub-advisors to provide those services to clients and our firm. Envestnet Asset Management, Inc. (“Envestnet”), an unaffiliated third- party investment adviser, provides these sub-advisory services in the Concourse AMP Platform. Clients establishing AMP Platform accounts receive a copy of Envestnet’s Disclosure Brochure in addition to our firm’s Wrap Fee Brochure. AMP Platform Programs Concourse offers a group of investment advisory services and programs to its Advisors to use with their clients, which are designed to accommodate a wide range of investment philosophies, goals, needs and investment objectives. The AMP Platform offers two broad categories of fee-based managed account programs: Advisor Managed and Third-Party Managed accounts, as follows: ADVISOR MANAGED ACCOUNT PROGRAMS
• Capital Asset Management (CAM)
• PreTrade Program
• PreTradePlus Program
• ProTrade Program
• ProTradePlus Program THIRD-PARTY MANAGED ACCOUNT PROGRAMS
• Advisor’s Choice Separately Managed Account Program
• Advisor’s Choice Strategist Program
• Unified Managed Account Program AMP Program Fees The fees differ per program and will either include or exclude transaction execution fees (“ticket charges”). The fee is based generally upon a percentage of the assets under management in the account and not directly upon transactions in the client's account. The client will pay a graduated fee based on the level of assets in the client’s account including or excluding ticket charges depending on the selected program. The fees vary among programs and are subject to negotiation. Concourse offers a group of investment advisory services and programs to its Advisors to use with their clients, which are designed to accommodate a wide range of investment philosophies, goals, needs and investment objectives. For the AMP investment advisory services provided by Concourse and the Advisor, accounts are charged a single management fee, which consists of two components: the “advisory fee” and the “platform fee,” as discussed below:
• The advisor fee is for financial advice offered by Concourse, through the client’s selected Advisor. Fees, fee structure, and experience may vary by Advisor. Therefore, two Advisors may provide similar services with different fee schedules, resulting in their clients paying higher or lower fees than other clients.
• The platform fee covers safekeeping and custodial fees, reporting, and in some cases trade execution fees (ticket charges---see below). The platform fee is calculated on a graduated, blended basis, based on the amount of assets in the client’s account and/or the client’s household total asset level, in accordance with the applicable Program’s fee schedule below. The platform fee commences when the assets are invested by a third-party manager or when the Advisor initiates billing. Clients should consult their Advisor if there are any questions regarding the calculation of the fee. The platform fee is allocated between Pershing, Envestnet, and Concourse as reimbursement for the expenses incurred in providing, among other things, their services, processing, and technology. Ticket Charges In addition to the management fee, clients in CAM, PreTrade Plus, and ProTrade Plus programs pay ticket charges. Ticket charges are fees generated for each trade executed in an account. Ticket charges vary depending upon several factors, such as type of security and the size of the trade. Tables that list the applicable ticket charges by wrap program appear in the Advisory Fees section of the Concourse Wrap Fee Brochure. In instances where Concourse serves as the Introducing Broker- Dealer (IBD), Pershing credits Concourse a portion of the ticket charge. Concourse does not share any ticket charge revenue with the Advisor. In programs that incur ticket charges, more frequent trading results in higher aggregate ticket charges. If you anticipate your account engaging in frequent trading, please check with your Advisor to determine whether it is more appropriate for you to be in an advisory program (e.g., PreTrade or ProTrade) with a platform fee that includes ticket charges. For more detailed information on AMP program costs, please refer to the Wrap Fee Brochure. Third-Party Asset Manager Programs Offered Outside of the AMP Platform Concourse also offers limited access to certain turn‐key third-party asset manager programs (TAMPs), which provide access to professional third-party asset managers that are outside the scope of the AMP platform. TAMP programs offer you access to a variety of model portfolios with varying levels of risk from which to choose. TAMP program accounts are not managed by us; rather, they are managed by one or more third-party portfolio managers on a discretionary basis, and they consist of a variety of different security types, including stocks, bonds, mutual funds, and derivatives. Account minimums for unaffiliated TAMP program accounts generally range between $25,000 and $50,000. Concourse is not the sponsor of these TAMP programs. These programs typically select their own custodian. With respect to TAMPs offered by Concourse, we act in either a “promoter” or “sub‐adviser” capacity as described below: Promoter: When acting as a promoter for the TAMP program, neither Concourse nor your Advisor provide advisory services in relation to the TAMP program account(s). Instead, your Advisor assists you in selecting one or more TAMP programs believed to be suitable for you based on your objectives and risk profile. Concourse and your Advisor are compensated for referring you to the TAMP program. This compensation generally takes the form of the TAMP sharing a percentage of the advisory fee you pay to the TAMP with us, which is then shared with your Advisor. When Concourse acts as a promoter for a TAMP program, you receive a written promoter disclosure statement describing the nature of our relationship, the terms of our compensation, including a description of the compensation that Concourse will receive for referring you to the TAMP program, and the amount, if any, that you will be charged in addition to the advisory fee you would pay without our referral relationship. Adviser or Sub‐Adviser: Under an adviser or sub‐adviser relationship between us and the sponsor of the TAMP program, Concourse and your Advisor fulfill the role of an adviser or sub‐adviser to you. Your Advisor provides you with portfolio management supervisory services with respect to your TAMP account(s) along with the TAMP provider. That means that your Advisor monitors the TAMP program’s performance, investment selection, and continued suitability for your portfolio and will advise you accordingly. Your Advisor helps you determine your investment objectives and risk tolerance in order to help you choose a program that meets your objectives. In some instances, your advisor can manage a portion of the investments at the TAMP. There will be conflicts of interest when recommending one TAMP over another. Concourse and the Advisor receive compensation when they refer you to the TAMP, which is usually a percentage of the advisory fee. The amount of compensation received by our firm and your Advisor from a particular TAMP could be higher than the compensation received from another TAMP. As a result, the Advisor has a financial incentive to recommend one TAMP over another. There are other suitable TAMPs that cost more or less. In certain instances, clients will have lower advisory fees for TAMP accounts as compared to our AMP Platform; however, in addition to an asset-based advisory fee, a client can incur brokerage commissions, mark-ups and mark-downs, transaction charges and other fees, including “ticket charges,” related to the purchase and sale of stocks, bonds and other securities in TAMP accounts. Neither Concourse nor its Advisors receive any of these fees. In other instances, the advisory fees for TAMPs on the AMP Platform may be lower than the TAMP Platform. The maximum Advisor fee for TAMP accounts is 1.50%, which is in addition to the platform and/or manager fees associated with the programs. You will typically enter into an agreement directly with that TAMP, which will outline, among other things, fees, and the trading of the client’s account. Please refer to the relevant Form ADV, Part 2A of each TAMP for a more detailed explanation of each of the different investment advisory programs offered through Concourse. Although Concourse periodically researches, selects, and reviews the TAMPs, we make no guarantees that your financial goals or objectives will be achieved. Nor do we guarantee performance. Concourse currently has adviser or sub-adviser agreements to offer the services of the following TAMPs: Asset Mark, First Mercantile/American Trust Retirement, Orion Portfolio Solutions, Manning & Napier, Morningstar, SEI, and Buckingham Strategic Partners/Loring Ward. Both SEI and FTJ Advisor Direct at Orion Portfolio Solutions (closed to new accounts) allow your Advisor to manage the entire portfolio or a portion (“sleeve”) thereof along with the TAMP. As of the date of this Brochure, our current promoter arrangements are the following: Brinker Capital Inc., Camelot, City National Rochdale, CLS Investments, and Flexible Plan. For more information on these programs, please refer to the Form ADV, Part 2A and related disclosure documents for the investment adviser and program in question. These documents can be found on the SEC’s website at www.adviserinfo.sec.gov and on the applicable program sponsor’s website. Concourse may update TAMP arrangements without notice including adding new TAMPS or discontinuing offering

existing TAMPs. Financial Planning and Financial Advice Services For clients seeking financial advice involving analysis of a particular investment, investment portfolio, or overall financial situation, Concourse, through its Advisors, provides financial planning and investment consulting services designed to meet clients’ financial goals, needs and objectives. The investment consulting services provided to individuals typically take the form of a financial plan. These consulting services include, but are not limited to, a review of an individual’s current financial situation, with an emphasis on portfolio analysis, estate planning, insurance planning, education planning, retirement planning, and/or capital needs planning. To the extent other services are needed, your Advisor will assist you. Advisors will also assist you in coordinating the implementation of any recommendations made, including referral to other practicing professionals whose services may be necessary such as an attorney, accountant, or insurance agent. In preparing a financial plan, the Advisor gathers information deemed relevant to the particular advisory service being provided through fact-finding interviews, documents and/or a profile questionnaire you complete. Based on your responses, the service will include an analysis of your financial information, including items such as your current assets, income, investments, liabilities, short and long-term capital and liquidity needs, risk tolerance, and short and long-term financial goals and objectives. Advisors do not make recommendations concerning the purchase or sale of specific securities when preparing financial plans. However, in response to requests by clients for advice or recommendations to implement a financial plan, the Advisor's recommendations are limited to only those products offered through Concourse, where the Advisor is registered as an investment adviser representative and/or as a registered representative of Concourse. This creates a conflict of interest as Concourse may recommend the use of proprietary insurance or investment products and will recommend a product for which we or our Advisor will earn compensation. You are under no obligation to accept any recommendations from an Advisor pursuant to a financial planning or consulting agreement. You retain discretion and responsibility for implementing recommendations and taking the necessary steps to do so. You may be able to purchase the same or other similar products and services at another broker-dealer or investment adviser, but for a lower cost. Similarly, any insurance recommendations will be limited to the insurance companies with whom the Advisor is appointed as an insurance agent or broker. Most advisors are independent contractors who also offer non-security insurance products as insurance agents. The products offered may include life, health, disability, long-term care and fixed annuity products (other than fixed-indexed annuities). These services are offered independent of, and not supervised by, Concourse Financial Advisors. Retirement Plan Services Concourse, through its Advisors, offers advisory services for employer-sponsored retirement plans that are designed to assist plan sponsors (“Sponsors”). Concourse, through its Advisors, may also assist with enrollment and investment education to plan participants and beneficiaries. Concourse charges a fee for the Retirement Plan Services, as described in this brochure and the ERISA Master Account Application (“Application”). Retirement Plan Services include services considered fiduciary services under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), or comparable state laws. When delivering ERISA fiduciary services, Concourse, through its Advisors, will perform those services to the plan as a fiduciary under ERISA Section 3(21) and will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. When providing any ERISA fiduciary Services, Concourse, through its Advisors, will make recommendations to the Sponsor and the Sponsor retains full discretionary authority (as defined by ERISA Section 3(38)) or control over assets available in the plan. ERISA fiduciary services can be provided to plan participants; the plan participants maintain full discretionary authority and control over their personal retirement accounts. Sponsors may engage Concourse, through its Advisors, to perform the Retirement Plan Services by completing an ERISA application that describes how the Advisor will serve the plan and the fees to be charged for those services. The application describes additional terms of the arrangement between Concourse and the Sponsor, including services in addition to the retirement plan. By signing the application, the Sponsor represents they have 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 based upon the compensation to be paid for the Services. The Plan Sponsor must sign and complete the application before Concourse and/or its Advisors performs any Retirement Plan Services. In providing Retirement Plan Services, Concourse, through its Advisors, may establish a separate client relationship with one or more plan participants, beneficiaries, or Sponsors. Advisors will not solicit services from plan participants or beneficiaries when providing Retirement Plan Services to the plan. If Concourse is providing Retirement Plan Services to a plan, Advisors may, when requested by a plan participant, beneficiary, or Sponsor, arrange to provide services through a separate agreement that excludes any investment advice on plan assets. If a plan participant or beneficiary desires to affect an IRA Rollover, Advisor will obtain a signed disclosure from the plan participant. The plan participant retains final authority to determine whether to affect the rollover. Concourse, its employees, and its Advisors benefit from the compensation paid to Concourse and will directly or indirectly receive a portion of the fees and other compensation paid by Retirement Plan Services clients. Those clients may also use other products or services available from or through Concourse and in such case pay additional compensation. This practice creates a conflict of interest that gives Concourse and its Advisors an incentive to recommend Retirement Plan Services based on the compensation received. Concourse addresses these conflicts through disclosure(s) in this Brochure and additional disclosures concerning compensation we receive, directly or indirectly. Concourse will also offset or refund additional compensation when required by law. As part of our investment advisory services, Advisors can make recommendations to plan participants regarding the rollover of employer-sponsored retirement plan assets. In the case where an Advisor recommends a retirement plan rollover into a Concourse advisory account program, the Advisor will earn a portion of the advisory fee. This presents a conflict of interest because Advisors have an economic incentive to recommend you to rollover your retirement plan into an advisory program account. Plan participants are under no obligation to rollover retirement plan assets to an IRA and should carefully consider all relevant factors, such as penalty-free withdrawals, whether loans are permitted, legal protections, required minimum distributions, fees and expenses, service levels, available investment options, employer stock considerations, and state taxes. Participants of employer-sponsored retirement plans typically have four options upon termination of service from the sponsoring company: (1) leave the assets in the current employer’s plan, if permitted; (2) rollover assets to a new employer’s retirement plan, if available and rollovers are permitted; (3) rollover assets to an Individual Retirement Account (IRA); and (4) withdraw funds from employer plan (subject to taxes and penalties). Plan participants may implement a combination of available options. Annuities Certain fee-based annuities may be linked to an AMP account. All variable annuity sub-account selection and reallocations are processed through the custodian of record for the variable annuity. The Advisor’s advice for these products includes an initial selection of sub-accounts and their allocation, ongoing management, and recommendation of sub-account reallocation, and/or the selection of a third-party manager for the sub-account management. Advisory fees paid by the client may be deducted from a Concourse brokerage or advisory account. Certain annuity carriers pay Concourse a quarterly amount up to 50 basis points on net annuity premiums received including advisory (“fee based”) annuities offered to our clients. Concourse has a conflict of interest to recommend products on which it receives higher compensation. We mitigate this conflict by disclosing it to the client and not sharing this revenue with our Advisors. See the Wrap Fee Brochure for more information on the fee-based fee schedule. Limits on Advice to Certain Types of Investments With some exceptions, Advisors are available to offer advice on most types of investments owned by a client and, at the specific request of a client, will explore investment options not currently owned by a client. However, Advisors are not permitted to provide advice on futures or commodity contracts. It is also required that Third-Party Managers used by Advisors be approved by Concourse. If an Advisor is dually registered as a registered representative with the Concourse broker-dealer, he or she will be restricted to providing advice based on proper FINRA licensing. For example, if an Advisor does not hold a Series 7 license and holds only the Series 6 license, the Advisor will be restricted from managing client assets in an advisor-managed account for any security requiring the Series 7. Concourse imposes limitations on certain types of products offered in advisory accounts, including limits on holding low-priced or “penny” stocks, leveraged or inverse ETFs, and volatility-linked products, to name a few. Securities Backed Lines of Credit: LoanAdvance A LoanAdvance account is an account held through Pershing through which you borrow money from Pershing by pledging the securities in the account. Unlike a margin account, these borrowed funds cannot be utilized to purchase additional securities. Concourse will receive revenue for your participation in this program. Even though this revenue is not shared with your Advisor, the receipt of this additional revenue creates a conflict of interest because of the increased compensation to Concourse. A conflict of interest also exists because Concourse and your Advisor will benefit because you don’t have to liquidate assets in your account to pay for things with cash, which would diminish the assets held in the account and the potential fees that could be earned by Concourse and your Advisor from holding or engaging in future transactions with those assets. For example, with a fee-based account, by recommending that you participate in this program to fund some purchase or financial need rather than liquidate securities, Concourse and your Advisor continue to earn fees on the full account value. Please carefully review the LoanAdvance disclosure documents for additional risks involved in opening a LoanAdvance account. Concourse reserves the right to approve or reject your participation in LoanAdvance for any reason. Advisor Credit Exchange An Advisor Credit Exchange account is an account held through the Envestnet Platform (AMP) through which you borrow money from third-party banks pledging the securities in the account. Unlike a margin account, these borrowed funds cannot be utilized to purchase additional securities. Concourse will receive revenue for your participation in this program. Even though this revenue is not shared with your Advisor, the receipt of this additional revenue creates a conflict of interest because of the increased compensation to Concourse. A conflict of interest also exists because Concourse and your Advisor will benefit because you don’t have to liquidate assets in your account to pay for things with cash, which would diminish the assets held in the account and the potential fees that could be earned by concourse and your Advisor from holding or engaging in future transactions with those assets. For example, with a fee-based account, by recommending that you participate in this program to fund some purchase or financial need rather than liquidate securities, Concourse and your Advisor continue to earn fees on the full account value. Please carefully review the Advisor Credit Exchange disclosure documents for additional risks involved in opening an Advisor Credit Exchange account. Concourse reserves the right to approve or reject your participation in Advisor Credit Exchange for any reason. Concourse also reserves the right to offer programs similar to LoanAdvance and Advisor Credit Exchange that are not sponsored by Pershing or Envestnet. TriState Capital A Tristate Capital securities-based lending account is an account held through Pershing which you may borrow money from TriState Capital bank by pledging the securities in the account. Unlike a margin account, these borrowed funds cannot be utilized to purchase additional securities. A conflict of interest exists because Concourse and your advisor will benefit because you don’t have to liquidate assets in your account to pay for things with cash, which would diminish the assets held in the account and the potential fees that could be earned by Concourse and your advisor from holding or engaging in future transactions with those assets. For example, with a fee-based account, by recommending that you participate in this program to fund some purchase or financial need rather than liquidate securities, Concourse and your advisor continue to earn fees on the full account value. Termination All advisory services continue in effect until terminated by either party (i.e., you, your Advisor, or Concourse) by giving notice to the other party. Any prepaid, unearned fees are promptly refunded to you. Fee refunds will be determined on a pro rata basis using the number of days services are actually provided during the final period. If your Advisor terminates their relationship with Concourse, you will receive notification of termination and all advisory services will be terminated. After termination date, your account will not be monitored, and Concourse will no longer provide investment advice with respect to those assets. If the termination occurs during a billing period, the account will be refunded any pre-paid advisory fees on a pro-rata basis from the date of termination to the end of the billing period. Upon actual receipt of notice of termination, our obligation to manage or advise you with respect to the account immediately terminates. This means that unless we receive instructions from you, we will not buy, sell, reallocate, or rebalance Funds in the converted account. IRA and 403(b)(7) accounts remain subject to the provisions and restrictions of regulations, law, and the custodial Agreement. For clients utilizing TAMPs, termination procedures are determined by the TAMP. Please refer to the specific TAMP’s disclosure brochure for specific termination procedures.