Allworth Financial, LP (also referred to as “Allworth” throughout this document) is owned and controlled, through intermediate subsidiaries, by the Ontario Teachers’ Pension Plan and Lightyear Capital. Allworth Financial has been an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) since June 21, 1996. Allworth is a fee based registered investment advisor providing financial planning and investment management services primarily to retail clients and qualified retirement plans. Allworth’s investment strategies are designed to deliver a customized mix of mutual funds, ETFs and other investment products to match both risk tolerance and performance goals of our clients. On occasion, following the purchase of the business assets of another investment advisory firm, for a brief transition period, the acquired firm and its financial advisors will continue to operate under the firm’s former trade name and logo for marketing purposes. Although a different name is used in addition to Allworth, such financial advisors provide advisory services through Allworth and remain subject to Allworth’s supervision. This brochure also contains information pertaining to Allworth’s RAA division which focuses on serving clients in the airline industry. Description of Types of Advisory Services Offered The following are brief descriptions of the types of advisory services offered by Allworth. Asset Management. Allworth provides discretionary asset management services to our clients through our “wrap fee” program (the “Program”), in which the client pays a specified fee for portfolio management services and trade execution. Allworth provides continuous investment advice to a client and makes investments for the client based on the individual needs of the client. Through this service, Allworth offers a customized and individualized investment program for each client. A specific investment strategy and investment policy is crafted to focus on the specific client’s goals and objectives. Depending on the client’s individual needs, investment recommendations will be made in, but not necessarily limited to, no- load mutual funds and exchange traded funds, and individual equity and fixed income positions. Client assets are allocated to individual investments or through an investment model developed by the Allworth Investment Committee. In addition to providing discretionary investment advice, Allworth also provides asset management services to our clients on a non-discretionary basis. Under these arrangements, Allworth provides advice regarding client account assets based on restrictions directed by the client. For more information relating to Allworth’s wrap fee programs, please refer to Appendix 1 of this document, titled “Allworth Wrap Fee Program Brochure.” Variable Annuity Sub-Account Management. Allworth provides ongoing investment management and advice to clients regarding the management of variable annuity products held in their accounts to ensure that the account is being managed in a manner consistent with the client’s financial goals, risk tolerance and time horizon. Allworth monitors market conditions and the performance of variable annuity sub- accounts and provides advice and recommendations regarding exchanging as necessary between sub- accounts available from the insurance company issuing the variable annuity or variable life contract(s). Financial Planning (Specialized Planning Services). Allworth provides advisory services to clients in the form of comprehensive and issue-specific financial plans in areas including, but not limited to:
• Cash flow and management
• Protection planning (e.g., disability, health, life, long term care, etc.)
• Investment planning (e.g., investment portfolio review, stock options)
• Retirement planning
• Tax planning
• Estate planning After completing a review and analysis of the information provided by the client, Allworth investment adviser representatives develop analyses and recommendations, which are presented to the client in the form of either a comprehensive or issue specific financial plan. These plans can be oral or written, as the client wishes. A comprehensive plan focuses on a client’s overall financial situation and specifically covers the areas of financial position (e.g., cash flow), protection (e.g., insurance), investment, retirement, tax and estate planning. Allworth develops comprehensive plans for its clients by identifying financial concerns and goals and preparing strategies designed to address identified concerns and goals. These services do not involve active management of client investment portfolios. Instead, comprehensive planning services examine a client’s overall financial situation, specifically including (but not limited to) the areas of financial position (e.g., cash flow and net worth), protection plans (e.g., insurance), investment goals (e.g., education, home purchase), retirement, strategic tax planning and estate plan review. Allworth offers different levels of comprehensive plans based upon the services to be provided, including:
• Comprehensive Planning- Advanced involves extensive coordination with other advisors (business, estate, legal, tax) in developing a comprehensive personal financial plan. Advanced planning issues include business succession as well as financial legacy planning to preserve and transfer wealth.
• Comprehensive Planning - Financial Independence focuses on the migration to and preservation of financial independence. The planning process examines and illustrates a myriad of financial independence scenarios. A matrix of variables (i.e., age, income need, investment return on both non- qualified and qualified portfolios, inflation, long-term care, etc.) are examined to determine a most realistic financial independence scenario. This planning service focuses intensely on financial independence. The variables are assessed to determine a plausible financial independence plan. Allworth also offers issue-specific specialized planning services, which focus on specific areas of client concern identified by the client. An issue specific plan focuses only on one or more specific area(s) of client concern, and clients should be aware of this limitation when Allworth’s representatives develop their analyses and recommendations. In addition to comprehensive and issue-specific financial planning services, Allworth offers customized consulting services to clients seeking advice regarding non-securities matters as well as clients seeking advice regarding non-managed accounts (assets under advisement), such as 401(k), 403(b) or profit-sharing plans. Clients have sole discretion regarding whether or not to implement the investment advice and specific recommendations provided as part of a financial plan. Qualified Plan Consulting Services. Allworth provides advisory services for qualified retirement plans. While the primary clients for these services are nonqualified deferred compensation, pension, profit sharing, 401(k) and 403(b) plans, Allworth also offers these services, where appropriate, to individuals and trusts, estates and charitable organizations. Qualified retirement plan consulting services include: the development and maintenance of investment policy statements, plan design consulting, investment due diligence review, model investment portfolios, discretionary and on-discretionary recommendations regarding investment selection, and educational presentations to plan participants. Newsletters and Podcasts. Allworth periodically provides a newsletter and podcasts to its clients. These newsletters and podcasts contain general, educational and informational articles. Non-clients can also subscribe to these newsletters

and podcasts by contacting Allworth or subscribing at Allworth’s website. These newsletters and podcasts are free of charge for clients and non-clients. Seminars. Allworth and its associated persons provide financial seminars to the public on general, informational and educational topics. Specialization. Allworth considers itself to specialize in retirement planning, investment and wealth management. Our advisors work with each client to focus on their individual retirement, planning and investment needs, as applicable. More details regarding our specific services are described in Item 5 of this brochure. In addition, you should refer to Item 8 for a description of some of the common risks associated with our advice and services. Third Party Investment Advisors After a review of a client’s portfolio(s), risk tolerance and investment objectives, Allworth has the option to delegate some or all of its responsibilities for a portion or all of a client’s portfolio to one or more third party investment advisers (each, a “TPA”). Each TPA will actively manage client portfolio(s) and will assume discretionary investment authority over that portion of the portfolio(s) allocated to the TPA. Discretionary investment authority will allow the TPA to place trades and make changes to the account or the portion of the account the TPA is authorized to manage without the client’s prior approval. Allworth will periodically monitor each TPA’s performance to ensure its investment program remains aligned with the client’s goals and objectives. Allworth conducts due diligence of any recommended TPA and monitors the performance of TPAs with respect to the TPA’s management of the designated assets of each account relative to appropriate peers and/or benchmarks. Allworth will retain discretionary authority to hire and terminate each TPA and/or to reallocate client portfolio assets to another TPA where deemed appropriate. The recommendation of TPAs is made either on a discretionary or non-discretionary basis with the specific terms outlined in the Allworth client agreement. When a client authorizes Allworth to have the ability to select TPAs on a discretionary basis, Allworth will have the authority to select and terminate TPAs without the client’s specific approval. When TPA recommendations are made on a non-discretionary basis, the client will need to execute an agreement directly with the TPA. Allworth is available and responsible to answer questions clients have regarding any portion of their account managed by a TPA and will act as the communication conduit between the client and the TPA. A complete description of the TPA’s services, practices and fees will be disclosed in the TPA’s Form ADV Part 2A: Firm Brochure that will be provided to the client. There is a conflict of interest in that Allworth could prefer its internal strategies when selecting portfolio strategies rather than selecting strategies developed by TPAs. To control for and mitigate these conflicts of interest, Allworth seeks select TPAs based on suitability in accordance with the client’s investment goals and objectives and evaluates TPA strategies based upon objective, performance-related and investment-selection criteria. Moreover, the fees Allworth charges participants in the Wrap Free Program does not go up or down based on whether or not a TPA is used or which TPA is selected. Participant Account Management (Discretionary) Allworth provides an additional service for clients with certain 401(k) accounts, health savings accounts and other assets where Allworth has been given discretion to manage the assets, but the assets are not held with one of the qualified custodians with whom Allworth currently has a relationship. Clients with these types of accounts authorize Allworth to provide discretionary investment management of the assets in the account via Pontera, a specialty order management system. Allworth does not have custody of client accounts it manages through Pontera because Allworth is not provided direct access to client log-in credentials to effect transactions. Instead, Allworth obtains access to these client accounts via a secure link provided directly to the client from Pontera. Allworth is not affiliated with Pontera and receives no compensation from Pontera for using its services. Allworth clients do not incur any additional fees in order for Allworth to access their accounts through Pontera. Allworth regularly reviews the available investment options in these client accounts and will implement investment strategies in the same manner as for other client accounts. Types of Investments. Allworth is willing 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, Allworth does not offer advice on warrants, options, commodities or privately offered funds such as hedge funds, private equity funds and other unregistered securities. The following are some of the general categories of securities Allworth will advise.
• Exchange-listed securities
• Securities traded over-the-counter
• Exchange Traded Funds (ETFs)
• Foreign issues
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares (open and closed ended)
• United States government securities
• REITs When providing Asset Management Services, Allworth typically constructs each client’s account holdings using low-fee mutual funds, no-load mutual funds and exchange traded funds to build diversified portfolios. It is not Allworth’s typical investment strategy to attempt to time the market but cash holdings will be increased modestly as deemed appropriate, based on the client’s risk tolerance and Allworth’s expectations of market behavior. Tailored Advisor Services to Individual Needs of Clients Allworth’s services are always designed to be based on the individual needs of each client. Clients are given the ability to impose reasonable restrictions on their accounts including specific investment types and sectors. Retirement Account Rollovers When providing investment advice to individuals concerning their retirement plan accounts or individual retirement accounts (“IRAs”), Allworth is acting as a fiduciary with respect to these retirement accounts. There is a conflict of interest when the firm makes a recommendation that a client roll over assets from the client’s existing retirement account to a different retirement account managed by Allworth, such as a new rollover IRA established through the firm.  The conflict of interest exists because Allworth will receive compensation (e.g., management fees) if the money is rolled over, but it will not if the recommendation is not accepted. The firm addresses this conflict of interest in accordance with the fiduciary requirements under the Employee Retirement Income Security Act of 1974, as amended, and the Internal Revenue Code as applicable. These rules generally require the firm to acknowledge its fiduciary status, describe its services, disclose material conflicts of interest, and adopt policies and procedures designed to ensure compliance with the fiduciary standards that apply when investment advice is provided to retirement account clients. No client is under any obligation to roll over retirement account assets to an account managed by Allworth. Client Assets Managed by Allworth Financial As of December 31, 2023, Allworth had $19,313,695,523 in assets under management (“AUM”), of which $18,601,573,527 was managed on a discretionary basis and $712,121,996 was managed on a non- discretionary basis.