This section will describe the wrap fee programs sponsored by Capital Analysts, LLC (Capital Analysts), how we tailor these programs to your individual needs, and which of our wrap fee programs allows you to impose investment restrictions. This section also provides a description of our wrap fees, how and when these wrap fees are collected, and if refunds are available. Other types of fees and expenses that you may incur are described below in the section titled, "Other Costs That You May Incur." Details regarding other compensation received by Capital Analysts, its affiliates and/or your Advisor and associated conflicts of interest are described below in the section titled, "Other Compensation to Capital Analysts and Our Conflicts of Interest." Our Fiduciary Role…Capital Analysts and your Advisor assume a fiduciary duty to invest or provide to you investment recommendations that are in your best interest. This fiduciary duty extends to all advisory accounts you open with us, but such fiduciary duty does not extend to brokerage or other non-advisory accounts or investments. The level of monitoring in your advisory account will depend on the advisory program you select, your advisory agreement with us and your Advisor. If Capital Analysts or your Advisor have been granted full discretionary trading authority over your advisory account, Capital Analysts or your Advisor will provide ongoing monitoring and will make changes in your account as deemed necessary. If your Advisor has been granted limited discretionary trading authority over your advisory account, your Advisor will provide ongoing monitoring. For all other non- discretionary advisory accounts, you and your Advisor will review your advisory account’s objectives, investments and performance relative to your objectives and financial situation at least annually to allow your Advisor the opportunity to recommend changing or maintaining the objectives or investments in your account. See your investment management agreement for the level of discretion granted to your Advisor or Capital Analysts. Investment Advice Provided to Certain Retirement and Tax-Advantaged Accounts When we and/or your Advisor provides investment advice to you regarding your Covered Retirement Plans, Capital Analysts and your Advisor 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 (“IRC”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us and your Advisor to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we and your Advisor must: meet a professional standard of care when making investment recommendations (give prudent advice); not place our financial interests ahead of yours when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures reasonably designed to ensure that we give advice that is in your best interest; charge no more than is reasonable for our services; and give you basic information about conflicts of interest. Covered Retirement Plans include the following account types: Individual Retirement Account (“IRA”); Individual Retirement Annuity; Roth IRA, Beneficiary IRA, Beneficiary Roth IRA; SEP-IRA, SARSEP, SIMPLE IRA; One-Participant 401(k); Health Savings Account; Archer Medical Savings Account; Coverdell Education Savings Account; Accounts held by ERISA Title I Plan participants/beneficiaries with authority to direct the distribution of assets from their account. When we provide investment advice to your Covered Retirement Plan as described in this paragraph, we will disclose to you the types of services to be provided and material facts relating to conflicts of interest that are associated with the recommendations made to you. These disclosures are provided to you in various documents, including The Lincoln Investment Companies Investor Agreement and Disclosure Handbook, Capital Analysts’ Form CRS, and its affiliated broker-dealer and investment adviser, Lincoln Investment’s Form CRS, your Advisor’s BIO Brochure (Form ADV Part 2B), account applications, prospectuses, and specific platform disclosure documents, and this Capital Analysts Investment Advisory Disclosure Brochure (Form ADV Part 2A and Wrap Fee Program Brochure). General Information Regarding Wrap Fee Programs A Wrap Fee Program is an investment advisory program in which you pay one bundled fee to compensate Capital Analysts and your Advisor for their services and to pay the transaction and clearing costs associated with transactions in your advisory account. Capital Analysts also offers unbundled fee (non-Wrap fee) programs, where you would pay a fee to compensate Capital Analysts and your Advisor for their services, but you would pay separately the transaction and clearing costs associated with the trading in your account. These services are described in Capital Analysts’ Form ADV Part 2A Brochure. Capital Analysts’ Wrap Fee Programs are offered on brokerage platforms where securities such as mutual funds, stocks, bonds, exchange traded funds (“ETFs”), exchange traded notes (“ETNs”) and options, all of which typically have trading costs associated with them, are offered. The Wrap Fee is not based directly upon the actual transaction or execution costs of the transactions in your account. Depending on the underlying investments and amount of transactions you expect to trade in your account, a Wrap Fee account may cost you more than if you chose to pay separately for all of your transaction costs (e.g., pay the advisory fee plus all ticket charges). Pershing and Schwab offer many mutual funds and ETFs with no transaction fees. In lieu of transaction fees, Lincoln Investment, Capital Analysts’ introducing broker-dealer for Pershing accounts, pays an asset-based fee to Pershing to cover the trade execution and clearing costs for equity securities, ETFs, fixed income, and options on the Pershing platform. For mutual funds, Lincoln Investment is assessed a surcharge for transactions in certain mutual funds, but otherwise is not assessed a transaction fee for mutual fund trades on the Pershing platform. Due to this arrangement with Pershing, Capital Analysts has financial incentive to recommend to you no-surcharge mutual fund only portfolios in your Wrap Accounts on Pershing in order to minimize its expenses. Where Lincoln Investment is assessed transaction costs, Capital Analysts has a financial incentive to minimize the costs that will be assumed by the firm on your behalf by not placing transaction orders in those accounts as doing so would increase Lincoln Investment’s transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. Your Advisor will review your investment objectives with you to determine the best offering for you. If the pricing structure of a Wrap Fee Program is suited to your needs, your Advisor will work with you to recommend one or more specific Wrap Fee Program(s) based on your confidential investor profile, in which you provide to Capital Analysts and your Advisor personal and financial information including, but not limited to, your investment goals, income requirements, time horizon, and tolerance for risk in order to tailor his or her recommendations to your needs and objectives. You may have the opportunity to place reasonable restrictions on the types of investments that are purchased in certain Wrap Fee Programs. Please contact your Advisor to discuss any allowable investment restrictions in the Wrap Fee Program(s) you have selected. Further details regarding your specific Wrap Fee Program can be found in your investment management agreement. The services and costs covered by the Wrap Fee are:
• Financial and life planning consultation by your Advisor, as needed or requested by you;
• Investment advice provided by Capital Analysts and your Advisor;
• Investment management provided by your Advisor or Capital Analysts;
• Clearing and trading costs associated with transactions and/or positions in the account, such as ticket charges, surcharge fees for certain no load and load waived funds and confirmation fees (for accounts custodied at Pershing LLC only);
• Short-term trading costs imposed by mutual funds and/or Pershing for trades occurring within Capital Analysts Managed Programs or Advisor Managed Model Portfolios and Client Custom Portfolios;
• Charges imposed if certain investment minimums are not met;
• Monitoring of your advisory account(s). However, your Wrap Fee will not cover standard account administrative fees such as statement fees, electronic fund and wire transfer charges, annual IRA custodial fees, termination fees, and fees for trades executed away from the custodian. You could purchase services similar to those offered in Capital Analysts’ Wrap Fee Programs separately from unaffiliated financial services providers. Wrap Fee Programs may cost you more or less than purchasing the services from another investment adviser. Some cost factors to consider, other than the Wrap Fee itself, when considering an advisory offering include:
• Account custody fees
• Account maintenance and special handling fees, such as wire funds fees
• Volume of trading activity anticipated in your account
• Commissions or ticket charges to be charged in lieu of a Wrap Fee
• Account termination fees
• Account statement and confirmations fees You should review the costs for each of the management services separately, as well as consider the internal costs of mutual funds in your account, when analyzing the total cost to you. Please contact your Advisor for a schedule of fees and costs associated with our Wrap Fee Program(s). The Financial Advisor Fee. Your Advisor receives a portion of the Wrap Fee you pay, which compensates your Advisor for his or her services (“Financial Advisor Fee”). This fee is an annual fee that continues as long as you maintain your account with us. Unless otherwise stated, your Advisor’s fee is negotiable at the Advisor’s sole discretion and to a maximum fee that is established by Capital Analysts. The maximum annual Financial Advisor Fee that your Advisor can charge for his/her services is 1.25% of the assets being advised or managed. The amount of this compensation may be more than what your Advisor would receive from other advisory services offered by Capital Analysts, or more than if you paid separately for investment advice, brokerage, and other services. Advisor managed services and fees typically differ by Advisor, and the Financial Advisor Fee can vary based on advisory services offered. Your Advisor will share in all or a portion of the Financial Advisor Fee based on their payout schedule with Capital Analysts. This fee provides access to your Advisor for financial and life planning consultation, as requested by you, as well as investment advice services which include assisting you in the determination of the appropriate investment advisory investments and advisory programs for you, conversing with you on an as-needed or as requested basis, but, at minimum, annually, to ensure that the investments and programs continue to meet your stated objectives and needs. It is important therefore that you make the time to speak with your Advisor at least annually or whenever there is a material life event that could affect or change your investment objectives or financial needs. In addition to the Financial Advisor Fee described above, Capital Analysts or its affiliates makes certain payments to your Advisor upon meeting certain requirements, including, but not limited to, attaining or maintaining asset or new account enrollment thresholds. For additional details regarding these payments including the criteria for selection and associated conflicts of interest, see Other Compensation to Capital Analysts and Our Conflicts of Interest. Description of Wrap Fee Programs and Fees Capital Analysts sponsors the following Wrap Fee Programs: I. Capital Analysts Managed Programs CAAMS Complete (including Alternative, Yield and Custom Income Strategies) CAAMS AssetBuilder CAAMS ETF (including Environmental, Social and Governance (ESG) Portfolios and Managed Volatility Portfolios) CAAMS Stock CAAMS UMA CAAMS Strategist II. Your Financial Advisor’s Services: Advisor Consulting, Advisor Managed Model Portfolios and Client Custom Portfolios III. Third-Party Managed Model and Third-Party Custom Portfolios CAAMS Select Manager I. Capital Analysts Managed Programs Capital Analysts Managed Programs are managed on a discretionary basis by Capital Analysts through its Investment Management & Research (“IM&R”) team. The IM&R team’s background is described in more detail in the ADV 2B Brochure Supplement to this brochure. When you select a Capital Analysts Managed Program, you must authorize, in writing, full discretionary trading authority to the IM&R team. “Full discretion” means your Capital Analysts has the authority to decide on the securities to purchase, sell or trade in your account without prior consultation with you. For CAAMS Strategist accounts, you are giving Capital Analysts full discretionary authority to manage and/or effect securities transactions in your account based on the model portfolios provided by third-party portfolio managers. Custody and clearing services are performed by Pershing LLC. Charles Schwab & Co. is also an available custodian for certain of the programs, as noted below. The table below provides a comparison of Capital Analysts Managed Programs. Please refer to the specific Capital Analysts Managed Program heading below for further information regarding the management and costs of the program you are considering. The Wrap Fee amounts provided below represent the maximum annual fee that may be charged. Capital Analysts Managed Program Offerings Capital Analysts Managed Program Name Investment Types Max. Annual Capital Analysts Program Sponsor & Management Fee Max. Annual Financial Advisor Fee¹ Max. Annual Total Wrap Fee (Sum of columns to left) ² Minimum Investment (may be waived) Minimum Account Size to Avoid $250 or $150 Annual Management Fee Custodians CAAMS Complete Mutual funds and ETFs 0.39% or $250, whichever is greater 1.25% 1.64% $50,000 $64,102 Pershing LLC; Charles Schwab & Co. CA A MS Com pl e te Sl e ev e s CAAMS Alternative Mutual funds and ETFs 0.39% or $250, whichever is greater 1.25% 1.64% $50,000 $64,102 Pershing LLC; Charles Schwab & Co. CAAMS Yield Mutual funds and ETFs 0.39% or $250, whichever is greater 1.25% 1.64% $50,000 $64,102 Pershing LLC; Charles Schwab & Co. CAAMS Custom Income Strategies Customizable to include corporate, municipal, & government debt, ETFs, options, CDs & stocks 0.25% or $250, whichever is greater 1.25% 1.50% $250,000 $100,000 Pershing LLC; Charles Schwab & Co. CAAMS AssetBuilder Mutual funds 0.60% or $150, whichever is greater 1.25% 1.85% $15,000 $25,000 Pershing LLC CAAMS ETF ETFs 0.30% or $250, whichever is greater 1.25% 1.55% $50,000 $83,333 Pershing LLC; Charles Schwab & Co. CAAMS Stock Stocks and ETFs 0.45% or $250, whichever is greater 1.25% 1.70% $50,000 $55,555 Pershing LLC; Charles Schwab & Co. Capital Analysts Managed Program Offerings Capital Analysts Managed Program Name Investment Types Max. Annual Capital Analysts Program Sponsor & Management Fee Max. Annual Financial Advisor Fee¹ Max. Annual Total Wrap Fee (Sum of columns to left) ² Minimum Investment (may be waived) Minimum Account Size to Avoid $250 or $150 Annual Management Fee Custodians CAAMS Unified Management Account (UMA) Mutual funds, stocks, bonds, ETFs and individual money managers 0.45% or $250, whichever is greater 1.25% 1.70% $50,000 $55,555 Pershing LLC CA A MS S tr at e gi st Clark Capital Management Group (CCMG) Mutual funds and ETFs 0.60% or $250, whichever is greater 1.25% 1.85% $50,000 $41,666 Pershing LLC DoubleLine Tactical Volatility Mutual funds 0.60% or $250, whichever is greater 1.25% 1.85% $50,000 $41,666 Pershing LLC ICON Advisers, Inc. Mutual funds 0.60% or $250, whichever is greater 1.25% 1.85% $50,000 $41,666 Pershing LLC J.P. Morgan Global Multi- Asset Mutual funds 0.60% or $250, whichever is greater 1.25% 1.85% $50,000 $41,666 Pershing LLC Meeder Advisory Services, Inc. Mutual funds 0.60% or $250, whichever is greater 1.25% 1.85% $50,000 $41,666 Pershing LLC Pacific Investment Management Company (PIMCO)3 Mutual funds 0.60% or $250, whichever is greater 1.25% 1.85% $50,000 $41,666 Pershing LLC Russell Investment Company Mutual funds 0.60% or $250, whichever is greater 1.25% 1.85% $50,000 $41,666 Pershing LLC 1 Financial Advisor Fee is negotiable. Capital Analysts may also waive or negotiate Program Sponsor and Management Fees at our sole discretion. 2 Important Note: Clients could pay higher than the percentage fee quoted as the Maximum Annual Total Wrap Fee due to the $250 and $150 annual minimum for Capital Analysts Program Sponsor & Management Fees. See Program Sponsor & Management Fees under each program description below for additional information regarding the impact of the minimum Capital Analysts Annual Program Sponsor & Management Fees on client accounts. 3 PIMCO model portfolios are available only to residents of the United States. You are responsible to notify your Advisor of any changes in your financial situation or investment objectives or to give any investment restrictions that you wish to impose so that your Advisor can suggest the appropriate advisory service for you. If you wish to impose investment restrictions, Capital Analysts’ Managed Programs may not be the appropriate advisory service for you as they may not be able to accommodate your investment restrictions. The Capital Analysts Program Sponsor & Management Fee. The Capital Analysts Program Sponsor & Management Fee is the portion of your Wrap Fee paid to Capital Analysts for the administration and asset management of the Capital Analysts Managed Program selected by you. The Capital Analysts Program Sponsor & Management Fee varies depending on the Capital Analysts Managed Program selected. See the table above, as well as the descriptions below, for the Capital Analysts Managed Programs. All Capital Analysts Managed Programs, except the CAAMS Custom Income Portfolios, are managed as Model Portfolios, which means the portfolio is managed to the stated objectives of the portfolio, not to your personal needs or objectives. Capital Analysts refunds any 12b-1 fees paid to its affiliated broker-dealer, Lincoln Investment, for Capital Analysts advisory accounts. The refunded amounts are identified on your Pershing statement as a line item transaction labeled “12b-1 Fee Credit”. Other custodians do not share 12b-1 fees with Lincoln Investment. Details regarding each Capital Analysts Managed Program are below. CAAMS Complete CAAMS Complete is comprised of model portfolios offering you a choice of portfolios primarily comprised of mutual funds and ETFs with automatic rebalancing. Funds are selected for the CAAMS Complete portfolios using a screening and rating methodology called Capital Analysts Performance Statistics Leaders (“CAPSL”). The objective of CAPSL is to identify mutual funds that consistently outperform their peers and the market for consideration of inclusion in diversified investment portfolios. While the CAPSL list represents funds that have exhibited strong characteristics over full market cycles, it is by no means a buy list. On a quarterly basis, the Investment Management & Research team screens the vast landscape of all U.S. open-ended funds for inclusion on the CAPSL list. Morningstar Direct is used to quantitatively screen thousands of funds. Initial screens typically include funds with a five-year track record and those that have at least $100 million in AUM. Qualifying mutual funds are sorted by Morningstar category and undergo a multi-factor quantitative analysis. Finalists are further subjected to style analysis and a qualitative analysis. The final CAPSL list of approximately 100 funds represents less than 1% of the mutual fund universe. This CAPSL list, together with occasional selected ETFs, forms the basis for CAAMS Complete and CAAMS AssetBuilder portfolios. With the exception of CAAMS Custom Income Strategies, Capital Analysts Wrap Programs are managed as Model Portfolios where the portfolio is managed to the stated objectives of the portfolio, not to you or your account. The CAAMS Custom Income Strategies portfolios are constructed on a client-by-client basis, generally utilizing a corporate, government and/or municipal bond laddering strategy. Seven portfolios are managed by the IM&R team to different risk levels or objectives, each available with standard and tax-aware options:
• Focused Income
• Conservative
• Income & Growth
• Balanced
• Capital Growth
• Aggressive Growth
• High Equity In addition to the seven portfolios above, CAAMS Complete offers specialized “sleeves” to be used in conjunction with other more broadly diversified portfolios:
• CAAMS Alternative CAAMS Alternative model portfolio uses alternative mutual funds and ETFs to gain exposure to alternative investments in order to complement a larger diversified portfolio.
• CAAMS Yield The CAAMS Yield model portfolio is focused on generating income. The portfolio typically allocates to income producing mutual funds and ETFs to gain exposure to both high-dividend equities and yield-bearing bonds.
• CAAMS Custom Income Strategies Capital Analysts offers the CAAMS Custom Income Strategies program. Custom management means your account is constructed and managed to meet your specific objectives, on a discretionary basis. You and your Advisor will work together to determine your specific risk tolerance and potential income needs. Your portfolio will be structured accordingly by the IM&R team using a laddered bond strategy which may use corporate, municipal, and government debt, as well as other investments such as ETFs, preferred and common stocks, and closed-end funds, covered options, and CDs to help increase yield. These portfolios have a higher minimum investment size than other CAAMS Complete programs. Program Sponsor & Management Fee (CAAMS Complete, excluding CAAMS Custom Income Strategies sleeve) Assets Under Management (minimum account $50,000) First $500,000 Next $500,000 Next $1,000,000 Over $2,000,000 Capital Analysts Program Sponsor & Management Fee* 0.39% or $250, whichever is greater 0.34% 0.29% 0.24% * The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month. For account sizes less than $64,102, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.39%, which could make the total annual fee paid by clients exceed 1.64%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. Program Sponsor & Management Fee (Custom Income Strategies sleeve) Assets Under Management (minimum account $250,000) First $500,000 Next $500,000 Next $1,000,000 Over $2,000,000 Capital Analysts Program Sponsor & Management Fee* 0.25% or $250, whichever is greater 0.20% 0.15% 0.10% * The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month. For account sizes less than $100,000, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.25%, which could make the total annual fee paid by clients exceed 1.50%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. CAAMS AssetBuilder CAAMS AssetBuilder is comprised of model portfolios utilizing open end mutual funds only. This Program offers you a choice of three risk levels – Moderate Conservative, Balanced, and Aggressive – with automatic rebalancing. CAAMS AssetBuilder utilizes the same selection discipline as used for CAAMS Complete - the Capital Analysts Performance Statistics Leaders (“CAPSL”) proprietary mutual fund research tool. See the description of the CAAMS Complete program above for more information on mutual fund selection in CAAMS AssetBuilder portfolios. Program Sponsor & Management Fee Assets Under Management (minimum account $15,000) First $500,000 Next $500,000 Next $1,000,000 Over Capital Analysts Program Sponsor & Management Fee* 0.60% or $150, 0.55% 0.50% 0.45% * The minimum annual Capital Analysts Program Sponsor & Management Fee is $150.00 per year, assessed at $12.50 per month. For account sizes less than $25,000, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.60%, which could make the total annual fee paid by clients exceed 1.85%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. CAAMS ETF CAAMS ETF is comprised of model portfolios that invest primarily in exchange-traded funds (“ETFs”) and certain mutual funds across asset classes and styles. Eight portfolios are managed by the IM&R team to different risk levels or objectives, each available with standard and tax-aware options:
• Focused Income
• Conservative
• Income & Growth
• Balanced
• Capital Growth
• Aggressive Growth
• High Equity
• Yield CAAMS ETF implements asset allocation models substantially the same as those used in CAAMS Complete using selected ETFs to create portfolios that correlate closely to industry benchmarks. Use of ETFs can reduce the internal expenses of a portfolio. The IM&R team analyzes hundreds of ETFs representing multiple asset classes to determine those ETFs that are best suited to the asset allocation model and constructs the portfolios typically utilizing 10-15 ETFs. The ETF screening and selection process is accompanied by strategic asset allocation analysis. Portfolios are rebalanced and reallocated as necessary. CAAMS ETF Managed Volatility Model Portfolios. Capital Analysts also offers a Managed Volatility option. Designed to reduce fluctuations of the portfolio over a market cycle, particularly during periods of heightened volatility, these portfolios are based on the same asset allocation models as other CAAMS ETF portfolios but are constructed using ETFs that are overweight low-volatility securities within a given asset class. The Managed Volatility portfolios may sacrifice some potential gains in exchange for the possibility of avoiding large losses. Because of the effect of managed volatility ETFs on the overall risk-return profile of a portfolio, the Managed Volatility option is available for each of the following portfolios only:
• Income & Growth
• Capital Growth
• High Equity CAAMS ESG ETF Model Portfolios. Capital Analysts offers Environmental, Social, and Governance (“ESG”) ETF strategies which are globally diversified portfolios that employ an actively managed investment approach with asset allocation, using exchange traded funds (“ETFs”) representing multiple asset classes and styles. These portfolios focus on ESG ETFs that invest in securities issues by companies and governments performing well in areas of environmental, social and governance issues. The ETFs offer the potential for long-term growth or income while seeking to mitigate risk exposures from ESG-related issues. See Item 6: Portfolio Manager Selection and Evaluation for more information on Environmental, Social and Governance (“ESG”) investing and our CAAMS ESG ETF model portfolios. The ESG ETF portfolios are available for each of the following portfolios:
• Focused Income
• Conservative
• Income & Growth
• Balanced
• Capital Growth
• Aggressive Growth
• High Equity CAAMS ESG ETF portfolios are not available to ERISA plans. CAAMS ETF BlackRock Target Allocation ETF Models. The BlackRock Target Allocation models are a dynamically managed model portfolio series that uses BlackRock ETFs. The models start by setting a strategic asset allocation for each of the ten risk levels and then will make tactical allocations based on the macroeconomic and investment environment. The models will keep equity allocations within 5% of the target, while duration will be managed in the fixed income portion based of the forecasted path of interest rates. While the models are tactical, they tend to make smaller, less frequent moves, trading just four to six times per year on average. Each BlackRock Target Allocation ETF Model is also available as a Target Allocation ESG ETF Model. The Target Allocation ESG ETF Models are not available to ERISA plans. Available model portfolios are indicated below:
• Target Allocation 0% Equity / 100% Fixed Income
• Target Allocation 10% Equity / 90% Fixed Income
• Target Allocation 20% Equity / 80% Fixed Income
• Target Allocation 30% Equity / 70% Fixed Income
• Target Allocation 40% Equity / 60% Fixed Income
• Target Allocation 50% Equity / 50% Fixed Income
• Target Allocation 60% Equity / 40% Fixed Income
• Target Allocation 70% Equity / 30% Fixed Income
• Target Allocation 80% Equity / 20% Fixed Income
• Target Allocation 90% Equity / 10% Fixed Income
• Target Allocation 100% Equity / 0% Fixed Income Program Sponsor & Management Fee CAAMS Stock CAAMS Stock is composed of model portfolios offering core multi-cap, multi-style equity portfolios diversified by individual stocks across industry groups and sectors. Where applicable, the IM&R team will also work with you and your Advisor to identify tax loss harvesting opportunities in your CAAMS Stock account. CAAMS Stock portfolios represent select groups of stocks chosen primarily from the industry groups and economic sectors in the S&P Composite 1500. ETF that track components of the S&P Composite 1500 or other broad-based indexes, as well as ETFs that track international or dividend stock indexes, may be used for some portfolios. Six portfolios are managed by the IM&R team to different objectives:
• Core Equity
• Core Equity Plus
• Global Equity
• Capital Appreciation
• Equity Income
• Dividend Growth Assets Under Management (minimum account $50,000) First $500,000 Next $500,000 Next $1,000,000 Over $2,000,000 Capital Analysts Program Sponsor & Management Fee* 0.30% or $250, 0.25% 0.20% 0.15% * The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month. For account sizes less than $83,333, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.30%, which could make the total annual fee paid by clients exceed 1.55%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. Program Sponsor & Management Fee Assets Under Management (minimum account $50,000) First $500,000 Next $500,000 Next $1,000,000 Over $2,000,000 Capital Analysts Program Sponsor & Management Fee* 0.45% or $250, whichever is greater 0.35% 0.25% 0.20% * The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month. For account sizes less than $55,555, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.45%, which could make the total annual fee paid by clients exceed 1.70%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. CAAMS Unified Management Account (UMA) CAAMS UMA portfolios use both active and passive investment approaches in a single account that combines individual securities from the CAAMS Stock portfolios, ETFs, and mutual funds. These portfolios are appropriate for investors who are interested in a professionally managed account providing the tax efficiency of individual securities and ETFs, and who want their holdings diversified across asset classes and industry groups. Five portfolios are managed by the IM&R team to different risk levels or objectives:
• Income & Growth
• Balanced
• Growth
• Aggressive Growth
• High Equity Custom portfolios managed by the IM&R team may also be available in the CAAMS UMA Wrap Fee Program. Program Sponsor & Management Fee Assets Under Management (Minimum account $50,000) First $500,000 Next $500,000 Next $1,000,000 Over $2,000,000 Capital Analysts Program Sponsor & Management Fee* 0.45% or $250, whichever is greater 0.35% 0.25% 0.20% * The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month. For account sizes less than $55,555, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.45%, which could make the total annual fee paid by clients exceed 1.70%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. CAAMS Strategist CAAMS Strategist provides access to mutual fund and ETF model portfolios developed and managed by certain third-party money managers (“Strategists”) selected by Capital Analysts and the IM&R team. Strategists are registered investment advisers unaffiliated with Capital Analysts, but have entered into agreement(s) to provide the model portfolios, as well as certain research and marketing services. The current Strategists are Clark Capital Management Group, DoubleLine Capital LP, ICON Advisers, Inc., J.P. Morgan Investment Management Inc., Meeder Advisory Services, Inc., Pacific Investment Management Company, and Russell Investment Company each offering the respective portfolios described below. Clark Capital Management Group Clark Capital Management Group (“CCMG”) model portfolios are composed of mutual funds and exchange- traded funds (“ETFs”) from multiple fund families, as well as affiliated funds (Navigator Funds). CCMG utilizes their proprietary quantitative model to tactically position the portfolios in a "risk-on" or "risk-off" allocation. The Navigator® Global Risk Management strategies seek to provide investors the potential for higher returns in the global equity markets with the ability to shift to safer U.S. fixed income sectors. Developed and managed by CCMG’s Investment Team, the strategies are available in three risk allocation profiles: conservative, moderate and growth. CCMG’s tactical approach seeks to identify and adapt to changing market themes in an effort to manage volatility in the portfolios over a full market cycle and deliver successful outcomes to investors.
• Global Risk Managed Conservative
• Global Risk Managed Moderate
• Global Risk Managed Growth
• Tactical Investment Grade Bond DoubleLine Capital LP – Minimum Volatility DoubleLine Capital LP (“DoubleLine”) model portfolios are composed solely of their affiliated funds (“DoubleLine Funds”). Developed and managed by DoubleLine, they offer total return fixed income minimum volatility model portfolios. DoubleLine employs active management of asset class exposure, sector allocations, and security selection to manage volatility in the portfolios over a full market cycle. Tactical allocations may be made as opportunities arise. The portfolios exclusively use mutual funds managed by DoubleLine to implement this strategy.
• Conservative
• Moderate Conservative
• Moderate
• Moderate Aggressive ICON Advisers, Inc. ICON Advisers, Inc. (“ICON”) model portfolios are composed solely of their affiliated funds (“ICON Funds”). ICON brings an analytical logic to the world of investing that aims to reduce subjective decision-making. It enables ICON to challenge conventional wisdom based on disciplined, objective, non-emotional methodology. Led by co-founder and Chief Investment Officer Dr. Craig Callahan, ICON applies the Science of Investing to attempt to identify industries that are underpriced. Dr. Callahan has created a valuation model that advanced the methodology, originally developed by Benjamin Graham, by adapting it to today’s ever-changing market conditions.
• ICON US Income J.P. Morgan Investment Management, Inc. – Global Multi-Asset J.P. Morgan Investment Management, Inc. (“J.P. Morgan”) model portfolios are composed solely of their affiliated funds (J.P. Morgan Funds). Developed and managed by J.P. Morgan, the Global Multi-Asset strategy provides five (5) risk-based model portfolios. J.P. Morgan uses both strategic and tactical asset allocation driven by both quantitative and qualitative analysis across widely diversified asset classes. The portfolios exclusively use mutual funds managed by J.P. Morgan to implement this strategy.
• Conservative
• Moderate Conservative
• Moderate
• Moderate Growth
• Growth Meeder Advisory Services, Inc. Meeder Advisory Services, Inc. (“Meeder”) model portfolios are composed solely of their affiliated funds (Meeder Funds). Developed and managed by Meeder, Meeder offers six (6) risk-based Tactical Allocations Master model portfolios. Meeder uses tactical asset allocation to adjust among asset and sub-asset classes based on short- to intermediate-term market forecasts, with the objective of exploiting inefficiencies or temporary imbalances among them. The portfolios exclusively use mutual funds managed by Meeder to implement this strategy.
• Flexible Income
• Conservative
• Moderate Conservative
• Balanced
• Moderate Growth
• Growth Pacific Investment Management Company Pacific Investment Management Company (“PIMCO”) model portfolios are composed solely of their affiliated funds (“PIMCO Funds”). Developed and managed by PIMCO, they offer model portfolios geared toward producing income. PIMCO employs active management of asset class exposure, sector allocations, and security selection to manage risk and generate current income over a full market cycle. The portfolios exclusively use mutual funds managed by PIMCO to implement this strategy. Each portfolio is available as a taxable model or tax-aware model.
• Capital Preservation
• Enhanced Core
• Income Focus Russell Investment Company Russell Investment Company portfolios are composed solely of their affiliated funds (“Russell Funds”). This is a strategic asset allocation strategy that uses a long-term approach to investing that mixes fundamental asset classes into a target portfolio. Because the Russell portfolios are constructed for long-term investors, short and intermediate term conditions are not a dominant factor in determining the allocations. The Russell portfolios are rebalanced on a semi-annual basis (typically March and September) to maintain the original balance. The Russell investment philosophy is rooted in the belief that financial markets reward knowledgeable, disciplined investors. Based on a philosophy that over a long period of time active managers can add value, Russell selects teams of money managers to help meet clients’ investment goals. Russell aims to reduce risk and attempts to provide benchmark-beating returns both collectively and over time.
• Tax Managed Conservative
• Tax Managed Moderate
• Tax Managed Balanced
• Tax Managed Growth
• Tax Managed Equity Growth Program Sponsor & Management Fee Capital Analysts Managed Programs – ERISA Capital Analysts also makes available to ERISA plans certain CAAMS Complete, AssetBuilder, ETF, Stock, UMA and Strategist Program model portfolios, with the exception of CAAMS ESG ETF model portfolios. The Program Sponsor & Management Fee for Capital Analysts Managed Programs offered to ERISA plans is shown below: Assets Under Management (minimum account $50,000) First $500,000 Next $500,000 Next $1,000,000 Over Capital Analysts Program Sponsor & Management Fee* 0.60% or $250, 0.55% 0.50% 0.45% * The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month. For account sizes less than $41,666, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.60%, which could make the total annual fee paid by clients exceed 1.85%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. Program Sponsor & Management Fee Assets Under Management (minimum account $50,000) ¹ First $500,000 Next $500,000 Next $1,000,000 Over $2,000,000 Capital Analysts Program Sponsor & Management Fee² 0.39% or $250, whichever is greater 0.34% 0.29% 0.24% ¹ Minimum account size for CAAMS AssetBuilder is $15,000. Minimum account size for CAAMS Stock and CAAMS UMA is $50,000. ² With the exception of the CAAMS AssetBuilder program, the minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month. For account sizes less than $64,102, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.39%, which could make the total annual fee paid by clients exceed 1.64%. For CAAMS AssetBuilder, the minimum annual Capital Analysts Program Sponsor & Management Fee is $150.00 per year, assessed at $12.50 per month. For account sizes less than $25,000, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.60%, which could make the total annual fee paid by clients exceed 1.85%. These minimum annual fees would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. II. Your Financial Advisor’s Services: Advisor Consulting, Advisor Managed Model Portfolios and Client Custom Portfolios Unless otherwise stated, your Advisor’s fee is negotiable at the Advisor’s sole discretion and to a maximum fee that is established by Capital Analysts. Advisor managed services and fees typically differ by Advisor, and the Financial Advisor Fee can vary based on advisory services offered. Your Advisor will share in all or a portion of the Financial Advisor Fee based on their payout schedule with Capital Analysts. The maximum annual fee that your Advisor can charge (“Advisor Fee”) for his/her services is 1.25% of the assets being advised or managed. In addition to the Financial Advisor Fee described above, Capital Analysts or its affiliates makes certain payments to your Advisor upon meeting certain requirements, including, but not limited to, attaining or maintaining asset or new account enrollment thresholds. For additional details regarding these payments including the criteria for selection and associated conflicts of interest, see Other Compensation to Capital Analysts and Our Conflicts of Interest. For Accounts Custodied at Pershing LLC Advisor Managed Model Portfolios and Client Custom Portfolios accounts opened on Pershing are offered as Wrap Fee Programs, meaning you pay one bundled fee to compensate Capital Analysts and your Advisor for their services and to pay the transaction and clearing costs associated with transactions in your advisory account. The Wrap Fee will cover: (1) the advice provided to you by your Financial Advisor and Capital Analysts, (2) trading and clearing costs associated with transactions and/or positions in the Account, such as ticket charges and surcharge fees for certain no-load and load-waived funds, (3) short-term trading costs imposed by mutual funds and/or Pershing, (4) charges imposed if certain investment minimums are not met, and (5) trade confirmation fees. The Fee you pay will not cover other standard account administrative fees such as statement fees, electronic fund and wire transfer charges, annual IRA custodial and termination fees. An annual Capital Analysts Administrative Fee will be assessed in addition to your Advisor’s Fee. The Administrative Fee is assessed on a monthly basis. The Capital Analysts Administrative Fee for Advisor Managed Model Portfolios and Client Custom Portfolios is shown below: Administrative Fee Assets Under Management First $500,000 Next $500,000 Next $1,000,000 Over Capital Analysts Administrative Fee¹ ² 0.15% or $200, 0.12% 0.10% 0.08% Your Advisor’s role is to earn and maintain a relationship with you to provide you financial and life planning and consultation, as requested by you, as well as investment advice services which includes assisting you in the determination of the appropriate investment advisory investments and advisory programs for you, conversing with you on an as-needed or as requested basis, to ensure that the investments and programs continue to meet your stated objectives and needs. Some advisors may also provide supplemental reports on a periodic basis to assist you in evaluating the effectiveness of the investments and advisory program(s). Capital Analysts Advisors may provide periodic non-discretionary investment advice to their clients, or certain Advisors provide ongoing discretionary management to their clients. The Advisor has the responsibility to select securities or make recommendations based on your needs and objectives, but if the advisor does not have written discretionary authority over your account, he/she cannot purchase or sell securities without first obtaining your approval. All advice is geared to meet the client’s risk tolerance, income, any investment restrictions, and tax management objectives, if applicable. Advisor Managed Portfolios generally allocate to securities including, but not limited to, mutual funds, ETFs, ETNs, stocks, bonds and options. For those Advisors who have been granted the authority to manage accounts on an ongoing discretionary basis, discretionary authority may be exercised using Model Portfolios, where your account is managed to the stated objectives of the portfolio, or custom managed, where your account is constructed and managed to meet your specific objectives (“Client Custom Portfolios”). Discretionary authority granted to Advisors may be limited or full. “Full discretion” means your Advisor has the authority to decide on the securities to purchase, sell or trade in your account without prior consultation with you. “Limited discretion” means that your Advisor has limited authority to select the time and/or price of the security to be purchased or sold, and/or if applicable to rebalance your account back to a pre-stated asset allocation of pre-selected securities. Limited Discretion, which has been granted to all advisors with respect to Advisor Managed Model Portfolios and Client Custom Portfolios held at Pershing, allows them, when necessary, to liquidate shares in one or more securities for the sole purpose of using proceeds to satisfy a shortfall in funds available for the deduction of the monthly investment advisory fee. An Advisor with limited discretion does not have the authority to select new securities to be purchased in your account. The final decision regarding any new security, whether to buy or sell, remains with the client in a Limited Discretion account. Your written investment advisory agreement will identify whether, and to what degree, you have granted your Advisor discretionary authority on your account. Each Capital Analysts Advisor may follow a different investment discipline and may or may not establish a minimum investment amount. The fees charged by Advisors on Advisor Managed Model and Client Custom Portfolios will vary depending on the platform utilized and the individual Advisor. Most Capital Analysts Advisors manage or advise portfolios containing securities such as, but not limited to, mutual funds, ETFs, ETNs, stocks, bonds and options. Consult with your Advisor to learn more about the advisory services and fees he or she offers. Your Advisor’s education, licenses and professional designations are described in Form ADV Part 2B Brochure Supplement, a copy of which your Advisor will provide to you. Advisor Managed Model Portfolio and Client Custom Portfolio Offerings Advisory Offering Minimum Investment Investment Types Custodian of Assets Advisor Consulting with Advisor Managed Model Portfolios and/or Client Custom Portfolios Depends on platform and individual Advisor Mutual funds Pershing LLC ¹ The minimum annual Capital Analysts Administrative Fee is $200.00 per year, assessed at $16.67 per month. For account sizes less than $133,333, the client is paying an Administrative Fee in excess of the stated 0.15%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. ² The Administrative Fee schedule shown above also applies to Capital Analysts Advisor Managed Model Portfolios and Client Custom Portfolios offered to ERISA plans. Advisor Consulting with Advisor Managed Model Portfolios and/or Client Custom Portfolios Depends on platform and individual Advisor General Securities such as, but not limited to, mutual funds, stocks, bonds, ETFs, ETNs, options Pershing LLC III. Third-Party Managed Model and Third-Party Custom Portfolios CAAMS Select Manager For the CAAMS Select Program, Capital Analysts has entered into agreements with the Select Managers establishing the maximum Select Manager Fees that may be charged. The maximum annual advisory fee shown in the table below compensates the Select Manager, Capital Analysts, and your Advisor. The Select Manager Fee will generally range between 0.40% and 0.65% for equity accounts and between 0.25% and 0.50% for fixed income accounts. The Select Manager Fee will be identified in your investment advisory agreement, which you should carefully review prior to signing. An annual Capital Analysts Administrative Fee will be assessed in addition to your Advisor’s Fee and the Select Manager Fee. The Capital Analysts Administrative Fee for the CAAMS Select Manager Program is shown below: Administrative Fee In the CAAMS Select Program, the IM&R team will work with you and your Advisor to assist in the selection of one or more third-party portfolio managers, called Select Managers, based on your investment objectives and risk tolerance. Capital Analysts relies on the expertise and management disciplines of these Select Managers when they are engaged to manage your assets to their stated discipline and risk level. Capital Analysts, however, retains the authority to terminate a Select Manager at any time. If a Select Manager is removed from Capital Analysts’ offerings, Capital Analysts will notify you in writing, and allow you the opportunity to change Select Managers. You will enter into an agreement with Capital Analysts and, depending upon the Select Manager, a separate agreement with that Select Manager that you choose to provide asset management services. Only the Select Manager exercises discretionary authority to determine the securities to be purchased and sold in your CAAMS Select account. Neither Capital Analysts nor your Advisor has trading authority with respect to your CAAMS Select account. Clearing and custody services are provided by Pershing LLC. Select Managers have account minimum requirements that will vary. A list of Select Managers is shown below. A complete description of each Select Manager’s services, fee schedules, and account minimums will be disclosed in the Select Manager’s respective Forms ADV 2A, Wrap Brochures, or similar disclosure brochures provided to you at or before the time your Capital Analysts agreement is executed and the account is established. Assets Under Management (minimum account size varies by manager) First $500,000 Next $500,000 Next $1,000,000 Over Capital Analysts Administrative Fee1 2 0.15% or $200, 0.12% 0.10% 0.08% ¹ The minimum annual Capital Analysts Administrative Fee is $200.00 per year, assessed at $16.67 per month. For account sizes less than $133,333, the client is paying an administrative fee in excess of the stated 0.15%. This minimum annual fee would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts. ² The Administrative Fee schedule shown above also applies to ERISA plans in the CAAMS Select Manager program. CAAMS Select Managers Select Manager Minimum Investment Max. Annual Fee to Client Investment Discipline(s) Davidson Investment Advisors, Inc. $250,000 1.70% Intermediate Taxable Fixed Income, Municipal Fixed Income First Fiduciary Investment Counsel $100,000 1.80% Large-Cap Value Fiduciary Trust Company International of Pennsylvania $100,000 1.90% Multi-Cap Value Fort Washington Investment Advisors, Inc. $1,000,000 2.00% Active Corporate¹, Core Fixed¹, Intermediate Fixed¹, Municipal Bond, Small Company Fund, International Equity, Focused Equity, Large Cap Focused Equity, Full Discretion Fixed Income (LLC) The Haverford Trust Company $250,000 1.90% Quality Growth, Dividend and Yield, Growth and Income One Capital Management, LLC $500,000 2.05% Global Balanced RNC Genter Capital Management $250,000 1.70% Domestic Fixed Income Thornburg Investment Management, Inc. $100,000 1.90% Core Value Equity, Municipal Fixed Income² Todd Asset Management $1,000,000 1.90% Large-Cap Intrinsic Value Uniplan Investment Counsel, Inc. $100,000 1.90% Real Estate Investment Trusts (“REITs”) Wright Investors’ Service, Inc. $500,000 1.90% Large Cap Core Equity, Dividend Income Each Select Manager sets its own investment management fee, which generally ranges between 0.40% - 0.65% for equity accounts and 0.25% - 0.50% for fixed income accounts, although some Select Managers may assess fees that are higher or lower. Each Select Manager’s current fees are listed in its Form ADV 2A and/or Form ADV 2A & Appendix I, which your Advisor should provide you. ¹ Active Corporate has a minimum investment of $3,000,000. Core Fixed and Intermediate Fixed have minimum investments of $5,000,000. ² Municipal Fixed Income has a minimum investment of $1,000,000. Additional Information Regarding Wrap Program Fees The Wrap Fee Programs described above may cost more or less than if you were to purchase such services separately. Certain factors, such as trading frequency, can impact the cost effectiveness of such Wrap Fee Programs. Generally, in an account where there is infrequent trading, a regular brokerage account incurring transaction fees along with the separate purchase of such investment advice for a fee may be less expensive. Your Advisor shares in the portion of the Wrap Fee that is identified as the Advisor Fee. The Wrap Fee may cover various services rendered and costs incurred under the selected program including client- advisor consultations, transaction costs, investment management, and performance reporting. However, securities transactions executed in your program account(s) may also include mark-ups, markdowns or dealer spreads paid to market makers or other principals from whom securities were obtained. These mark-ups, markdowns or dealer spreads will be retained by the market maker or other principal and will not be credited or reimbursed to your account, Capital Analysts, or its affiliate, Lincoln Investment. Capital Analysts offers fee schedules that vary by platform, program and the size of the assets in your advisory account. Your fee schedule will be reflected in your Capital Analysts Investment Management Agreement. For the majority of CAAMS Wrap Fee Programs offered by Capital Analysts, your Wrap Fee will be assessed on a monthly basis in advance of services rendered and will be based on the account value on the last business day of the prior month. For some clients, fees are assessed monthly in arrears, as indicated in your agreement with Capital Analysts; this is no longer offered to new clients. The specific manner in which advisory fees are calculated and charged is established in your written investment management agreement with Capital Analysts. In your investment management agreement, you must also authorize Capital Analysts to directly debit advisory fees from your account. Fees may be deducted from cash holdings or by liquidating assets held in the account at the discretion of Capital Analysts or your Advisor. Fees for the first month in which services are provided will be assessed based on the assets deposited into the account, and prorated for the number of days for which advisory services are provided in that month for those assets. Capital Analysts will not assess fees for any subsequent deposits or refund fees for withdrawals occurring within the month, other than the initial deposit. For advisory services terminated during the month, any prepaid, unearned fees will be refunded on a pro-rata basis, and any earned, unpaid fees will be due and payable on a pro-rata basis. See your investment advisory agreement for pro-rata fee assessments and refunds thresholds as these vary by platform and program. Capital Analysts can waive or negotiate advisory fees at our sole discretion. In general, a client may terminate Capital Analysts advisory services at any time upon written notice to us. The death of a client also constitutes termination of any agreement with Capital Analysts, though an executor or other authorized representative may choose to continue services under a new or modified agreement. Clients remain responsible to pay fees for services performed but not yet billed. For assets held on platforms other than Pershing, see your investment advisory agreement for billing details, including the frequency of fees assessment, whether your fee is assessed in advance or arrears of services rendered, and any applicable thresholds for inception billing, termination billing, and initial and interim billing on deposits and withdrawals as these can vary by platform and program. You could purchase products or services similar to those offered by Capital Analysts separately from our affiliated investment adviser, Lincoln Investment Planning, LLC or from any financial services provider. Capital Analysts may offer employees, its Advisors, and family members a discount or waiver of Wrap Fee Program fees. Other Fees in Wrap Fee Accounts The Wrap Fee will cover the advice provided to you and all trading and clearing costs associated with transactions in the account, including ticket charges, surcharge fees for certain no-load and load-waived funds, and confirmation fees. You will, however, be responsible for other account service fees that may be imposed by Pershing LLC, such as: IRA Custody and Termination, wire transfer and electronic fund fees, statement delivery charges and any expenses of the underlying investments in your account. For information on the fees applicable to accounts held at Pershing LLC, please refer to www.lincolninvestment.com/Disclosures for the Lincoln Investment Platform Fees and Disclosures -Accounts Held at Pershing or ask your Advisor. Other Costs That You May Incur Total advisory fees paid and other costs associated with your portfolio impact the overall performance of your portfolio. It is important to review these costs when making your advisory and investment decisions. Costs may include the following: 1. Mutual Fund 12b-1 Distribution Fees. An expense within some mutual fund share class offerings is a Mutual Fund Distribution Fee, also called a 12b-1 fee, which is paid to your broker-dealer. For all Capital Analysts advisory accounts on Pershing’s platform, when Lincoln Investment is the introducing broker-dealer on your advisory account and where the 12b-1 fee is paid to Lincoln Investment, we have instructed Pershing to directly refund this fee to your account. You may still incur a 12b-1 fee expense for any portion of the 12b-1 fee expense that the fund does not share with Pershing LLC or that Pershing does not share with Lincoln Investment. This fee-offset or crediting of 12b-1 fees will alleviate the conflict of interest associated with Lincoln Investment receiving this third-party compensation and will also reduce the expense to you associated with purchasing a mutual fund share class which includes a 12b-1 fee expense. Whether you receive and the manner in which you receive this credit depends on the platform where your advisory assets are held. 2. Internal Expenses. Internal management fees, other fund charges or other expenses charged by the mutual fund or sub-account of a variable annuity (also known as the internal expense). All mutual funds and annuity companies charge a fee for the management and operations of their offerings. Higher internal expenses can adversely affect the long-term performance of your portfolio when compared to share classes of the same fund that assess lower internal expenses. For more complete information regarding the internal expenses of an investment and how they impact your costs and performance, you should read “Understanding Share Classes

within your Investment Advisory Accounts” below. 3. Platform Fees. Capital Analysts offers its advisory services on various broker-dealer platforms. Each platform assesses different account fees, such as platform fees, ticket charges, commissions, wire fees, trade-away fees, statement and confirmation fees, retirement plan recordkeeping or custodial fees, and low balance or account termination fees. Depending on the platform/custodian selected, some fees can be avoided or reduced. For instance, applicable fees will be different for an account opened on Pershing versus accounts opened on another third-party platform/custodian. For a description of trading and administrative fees associated with where your account will be held, view the Platform Fees and Disclosures documents found at www.lincolninvestment.com/Disclosures. 4. Mutual Fund Short-term Trading Redemption Fees. Some mutual funds impose short-term trading redemption fees of up to 2% for active trading or exchanging in and out of their funds. Ticket charges may also be imposed if certain fund minimums are not met. This could affect you or your investment adviser’s ability to properly manage your portfolio as these costs will impact the performance of your portfolio or may be an incentive not to trade. Capital Analysts’ decision to reallocate your account assets may result in you incurring a redemption fee imposed by one or more mutual funds held in your account. 5. Variable Annuity Rider and Contract Costs. These costs may include, but are not limited to, annual base annuity contract charges, optional benefit riders, underlying sub-account expenses, and potential surrender fees. 6. Retirement Plan Rollovers. If you decide to roll assets out of a retirement plan, such as a 401(k) plan, into an individual retirement account ("IRA"), we have a financial incentive to recommend that you invest those assets with us because we will be paid an advisory fee on those assets, and other compensation. You should be aware that such fees would likely be higher than those you would pay through the plan, and there can be additional costs and expenses, such as custodial fees and account fees. As securities held in a retirement plan are generally not transferred to an IRA, commissions and sales charges may be charged when liquidating such securities prior to the transfer, in addition to commissions and sales charges previously paid on transactions in the plan. For more information about rollovers, see The Lincoln Investment Companies Investor Agreement and Disclosure Handbook. You may incur additional charges imposed by custodians, broker-dealers, investment and insurance companies and other third parties, such as transfer taxes, wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions. Such charges and fees are exclusive of and in addition to Capital Analysts’ fee. You shall be responsible for payment of any and all taxes that may be due as a result of any transactions in your account. Other Compensation to Capital Analysts and Our Conflicts of Interest Capital Analysts recognizes its fiduciary responsibility to place your interests above ours and that other compensation received by us, or an affiliate, from other sources presents a conflict of interest and could be looked upon by you as an incentive for us to recommend investment products or advisory services based on compensation rather than on your financial needs. Below is a description of conflicts of interest that we have identified in the conduct of our business that we believe could be material. With many of these conflicts, we have taken steps to mitigate or reduce the conflict. Understanding Share Classes in Capital Analysts Advisory Accounts Mutual funds are common investments for individuals. A mutual fund pools money from many investors and invests the money in securities or other assets. A mutual fund has various expenses that are paid from fund assets. These internal expenses are reflected in the fund's "expense ratio." Such expenses include fees paid to the adviser that manages the fund, operational expenses, and fees paid to the brokers that sell shares of, and provide services to, the fund. These are ongoing fees and expenses charged throughout the life of the mutual fund investment. Fees and expenses are an important consideration in selecting a mutual fund because these charges lower an investor's returns. A mutual fund frequently offers investors different "share classes." Each class will invest in the same "pool" or portfolio of securities and other assets, but each class will have different fees and expenses and, therefore, different returns. For example, some share classes have higher expense ratios because they pay brokers more for selling or servicing that particular share class. In contrast, other share classes of the same fund may have lower internal fees and expenses. A single mutual fund will often have share classes with different expense ratios, with the share classes that have higher expense ratios generally having lower returns than share classes with lower expense ratios. In other words, an individual investor may pay more, or less, for precisely the same mutual fund investment, depending on the share class. These internal fees and expenses are in addition to any fees a broker may directly charge customers on particular share classes, such as transaction fees at the time of buying or selling the fund shares and are in addition to the investment advisory fee you will pay. The expense ratio of a fund is disclosed in the fund’s prospectus and annual reports and generally reflects the annual operating costs of the fund, assessed as a percentage of a fund’s average assets. The expense ratio within a mutual fund share class can fluctuate from what is shown in a prospectus for the fund offering and annual report and can vary over time and from year to year. A fund that was deemed to have a lower expense ratio at the time of purchase may not actually maintain that expense ratio during the time that the fund is held and new fund share classes may become available with different expense ratios. Capital Analysts looks at the “Prospectus Net Expense Ratio” as provided by Morningstar, a third-party data provider, for each mutual fund share class to determine the least expensive eligible share class. The Prospectus Net Expense Ratio is a fund’s stated total annual operating expense percentage after any contractual fee waivers or other expense reimbursements to the fund. Capital Analysts’ Share Class Selection Policy for Advisory Accounts This share class selection policy applies to your advisory assets that are custodied at Pershing LLC and for which Capital Analysts and/or your financial professional initiate the trade and is described below. Although you are purchasing at net asset value of the fund, there are internal expenses built into every mutual fund that can impact the performance of your investment over time. Regardless of whether you have selected a discretionary asset management program or a non-discretionary advisory program, share class selection for your mutual fund purchases within your advisory account will be determined by Capital Analysts. Share class expenses can vary across different share classes of the same fund. In furtherance of its fiduciary duty to advisory clients, Capital Analysts will seek to select the least expensive share class available at Pershing LLC for the selected mutual fund for which all of our retail advisory accounts will be eligible (except that money market mutual funds within the Sweep Program are treated differently, as described below). For purposes of this policy, the least expensive share class is defined as the share class of a mutual fund that has the lowest prospectus net expense ratio as published by Morningstar, subject to the share classes’ investment minimums being appropriate for all of our retail advisory investors, obtaining investment minimum waivers where they are available, and selecting a share class that is available to all investors regardless of account tax type. Capital Analysts will also consider various other factors when considering share class conversions in your advisory accounts, including but not limited to, whether the fund will allow tax-free conversions, as well as whether there is a ten basis point (0.10%) or greater difference in the expense ratio between the existing share class and the new, proposed share class. The fund share class used in an IM&R discretionary managed Model Portfolio can be different than for other Capital Analysts non-discretionary advised accounts, as a fund minimum waiver may be available for discretionary IM&R Managed Model Portfolios but not for non-discretionary advisory accounts. Most mutual funds offer varying share classes but all custodians may not make all share classes of a mutual fund available; therefore, the designated share class selected by Capital Analysts will likely vary across custodial platforms. If the fund and share class selected includes a 12b-1 fee, Pershing LLC continues to be instructed on our behalf to credit back to your advisory account any 12b-1 fee revenue received by the firm on behalf of your advisory assets held at Pershing LLC to eliminate the conflict of interest associated with the receipt of such revenue. Capital Analysts will review available mutual fund share classes on a quarterly basis to identify those mutual funds where there has been a prospectus update or a new share class has been made available by the fund in the prior quarter. If it is determined that a lower cost share class is available and meets our policy criteria as described above, Capital Analysts will initiate a share class conversion for all mutual fund investments in a higher expense share class to that lower expense share class (except that money market mutual funds within the Sweep Program are treated differently, as described below). Share class conversions will appear on your account statements. The ability and length of time to effect a share class conversion will vary and is subject to prospectus requirements and custodial platform approval. If you transfer-in shares of a mutual fund into a non-discretionary advisory account that are in a share class that is less expensive than the share class available to our advisory accounts, Capital Analysts will not convert your mutual fund position held in a lower expense share class of the same fund to a more expensive share class of the same fund. However, Capital Analysts may restrict additional purchases of that share class. Capital Analysts can also convert the grandfathered share class during a subsequent periodic review. Until all mutual funds have been converted to the least expensive share class, you should not assume that you are or will be invested in the least expensive share class available, and the share class of a mutual fund offered by Capital Analysts can have higher expenses, and therefore lower returns during the conversion transition period. Additionally, Capital Analysts has selected a higher-cost share class with respect to the Dreyfus Government Cash Management Fund – Service Shares Sweep Product, which is the designated sweep product for non-ERISA 403(b)7 and 457(b) plans and participant accounts and the designated secondary sweep product for excess balances in the Dreyfus Insured Deposits L Sweep Product. There are less expensive share classes of the same money market mutual fund available that would not provide revenue sharing with the firm or would provide lesser amounts of revenue sharing with the firm. Information about the mutual funds and share classes that are available through your account, including their investment policies, restrictions, charges, and expenses, is contained in the mutual funds’ prospectuses. You should read these prospectuses carefully. Third-Party Payments and Revenue Sharing from Pershing LLC Pershing Revenue Sharing and Expense Credit with Lincoln Investment. For advisory accounts held on Pershing LLC’s platform, Pershing provides a credit against expenses to Capital Analysts’ affiliate, Lincoln Investment, as introducing broker-dealer, based on the total asset value of all accounts maintained on the Pershing platform and based on the total number of investor accounts on Pershing, pursuant to a written agreement with Pershing LLC. This revenue does not vary with respect to the investment choices/recommendations made in your Pershing account. Lincoln Investment does not refund or offset this third-party payment against advisory fees paid by clients whose advisory assets are on Pershing. Overall, the expense credits received by Capital Analysts affiliated broker-dealer, Lincoln Investment, from Pershing for 2023 represented less than one percent of Lincoln Investment’s total advisory revenue and approximately 1.5% of Capital Analysts’ revenue. The receipt of these expense credits creates a conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to use Pershing as a custodian over other custodians that do not share these fees, do not provide expense credits to us or that would share lesser amounts with us. We do not believe this revenue is material to Lincoln Investment or its affiliate, Capital Analysts. This revenue is not shared with your Advisor. Contract Extension Credits and Conversion Support Payments. Pershing provides certain credits and payments to Capital Analysts’ affiliate, Lincoln Investment, pursuant to a written agreement in consideration of the extension of Lincoln Investment’s current agreement with Pershing LLC and the attainment of certain milestones, including conversion-related milestones, execution of new contracts and transfer of accounts to Pershing. Capital Analysts does not refund or offset these credits/payments against fees paid by clients. The receipt of these credits and payments creates a conflict of interest to Capital Analysts to recommend and/or use Pershing as a custodian over other custodians that do not share these fees, do not provide expense credits/payments to us or that would share lesser amounts with us. This revenue is not shared with your Advisor. Additionally, under Lincoln Investment’s agreement with Pershing, there is a termination fee schedule with amounts that decrease over time. Therefore, Capital Analysts has an incentive to maintain the relationship with Pershing for a longer period of time. Pershing Margin Participation. For advisory and brokerage accounts held on Pershing’s platform, Capital Analysts’ affiliate, Lincoln Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement with Pershing LLC resulting in a higher margin interest rate to you. This mark-up will not exceed 2.25% above the base interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Capital Analysts to use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit the amount. Capital Analysts mitigates this conflict by disclosing it to you and by not sharing it with your Advisor. Pershing Non-Purpose Loan Markups. For advisory and brokerage accounts held on Pershing’s platform, Capital Analysts’ affiliate, Lincoln Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement with Pershing, LLC resulting in a higher non-purpose loan interest rate to you. This mark-up will not exceed 0.75% above the base interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Capital Analysts to use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit the amount. Capital Analysts mitigates this conflict by disclosing it to you and by not sharing it with your Advisor. Trading and Account Service Fees. Lincoln Investment establishes brokerage commission schedules for its advisory and brokerage accounts. For Capital Analysts’ advisory accounts held on Pershing’s platform for which Lincoln Investment is introducing broker-dealer (i) Pershing charges trading and account service fees for which Lincoln Investment, as introducing broker-dealer, has added a mark-up that ranges from 0% to 400%; (ii) For certain trading and account services for which Pershing does not assess a fee to Lincoln investment, Pershing permits Lincoln Investment, as introducing broker-dealer, to impose its own fee which is charged to you. The receipt of these fees creates a conflict of interest for Lincoln Investment and its affiliate, Capital Analysts, since it creates an incentive for Lincoln Investment and Capital Analysts to continue to use Pershing as custodian over other custodians that do not permit us to mark-up the trading and account service fees or would limit the amount, or that would not permit us to set our own fee. We mitigate this conflict by disclosing it to you and by not sharing the mark-ups with your Advisor. In aggregate, the above described third-party payments and revenue sharing to Capital Analysts’ affiliate, Lincoln Investment, from Pershing attributable to 2023 represented less than 1.5% of Capital Analysts’ total advisory revenue in 2023. The receipt of these third-party payments and expense credits create a conflict of interest to Capital Analysts to use Pershing as a custodian over other custodians that do not share these fees, do not provide expense credits or that would share lesser amounts. We do not believe this revenue is material to Lincoln Investment or its affiliate, Capital Analysts. Capital Analysts mitigates these conflicts by disclosing it to you and not sharing them with your Advisor. The Lincoln Investment Companies Sweep Program: The Lincoln Investment Companies offer a sweep program (“Sweep Program”) under which uninvested cash or “free credit balances” in your eligible accounts that are custodied with Pershing are automatically invested or deposited (“swept”) into money market mutual fund(s) (“Money Fund Sweep Products”), or bank deposit sweep product(s) eligible for FDIC insurance protection up to $2.5 million (“Bank Deposit Sweep Products”) (collectively referred to as “Sweep Product(s)”), which consist of interest-bearing bank deposit accounts (“Deposit Accounts”) at Federal Deposit Insurance Corporation (“FDIC”) member banks. The member banks (“Program Banks”) can include The Bank of New York Mellon (“BNYM”) and BNY Mellon, N.A., banking affiliates of Pershing or other banking affiliates of Pershing. When participating in the Sweep Program, you appoint Pershing as your authorized agent to establish and maintain Deposit Accounts at various Program Banks. Pershing has appointed a third-party service provider IntraFi Network LLC (“IntraFi” or “Administrator”) and Dreyfus Cash Solutions, a division of BNY Mellon Securities Corporation (“BNYMSC”), to provide certain services with respect to the operation of the Deposit Accounts. BNYMSC and its Dreyfus Cash Solutions division, BNYM, and BNY Mellon, N.A. are all affiliates of Pershing. Depending upon your account type, Capital Analysts will designate a Sweep Product for use in your account. Capital Analysts offers two Bank Deposit Sweep Products, the Dreyfus Insured Deposits L (“Tiered Rate Sweep Product”) and the Dreyfus Insured Deposits LV (“Level Fee Sweep Product”), and two Money Fund Sweep Products, the Dreyfus Government Cash Management Fund Service Shares Sweep Product (Ticker symbol DGUXX) and the Dreyfus Government Cash Management Fund Investor Shares Sweep Product (Ticker symbol DGVXX). Each of these Sweep Products except for the Dreyfus Government Cash Management Fund Investor Shares, offered only to ERISA accounts and as the secondary Sweep Product for balances over $2,490,000 in the Level Fee Sweep Product, create financial benefits and conflicts for us as described below. Capital Analysts has designated the Dreyfus Government Cash Management Fund Service Shares for non-ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in excess of $2,490,000 in the Tiered Rate Sweep Product. Capital Analysts has designated the Tiered Rate Sweep Product for use in commission-based individual retirement accounts (IRAs) and most non-retirement brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in advisory IRAs. Lincoln Investment, Capital Analysts’ affiliated broker-dealer, receives a portion of the fee paid to Pershing by the Program Banks in connection with the Bank Deposit Sweep Products and receives distribution assistance payments from Pershing in connection with the Dreyfus Government Cash Management Fund Service Shares Sweep Product. Accordingly, Capital Analysts has a conflict of interest in that we have a financial incentive to designate the Tiered Rate Sweep Product, the Level Fee Sweep Product and/or the Dreyfus Government Cash Management Fund Service Shares Sweep Product as the Sweep Product(s) for your account in order to generate additional revenue to us and our affiliate, Lincoln Investment. This compensation is a significant source of revenue for Lincoln Investment, Pershing, and provides economic benefits to Capital Analysts as Lincoln Investment’s affiliate. Pershing, other financial services firms and third parties could offer the same or similar money market mutual fund sweep products and/or bank deposit sweep products, at a lower overall cost and higher return to the investor than is available through the Sweep Program, whether directly through the provider or through a sweep program offered by a different financial services firm. This receipt of revenue sharing from Pershing creates a conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to use Pershing as a custodian over other custodians that do not share these fees, do not share these payments or that would share lesser amounts or that would not permit us to set our own fee, to offer the Sweep Products, and to recommend that you utilize and maintain a higher balance in the Sweep Products. Capital Analysts and Lincoln Investment receive a greater financial benefit when cash is swept into the above Bank Deposit Sweep Products and Money Fund Sweep Product than it otherwise would if your cash balance is held elsewhere, and any compensation that our affiliate Lincoln Investment receives reduces the interest and/or dividend you receive, and your overall investment return. This compensation is retained by Lincoln Investment and is not shared with you. We and our affiliate Lincoln Investment receive greater compensation as assets and/or accounts utilizing the Sweep Products increase, as more fully described below. The Sweep Product fees that Lincoln Investment receives are in addition to any investment advisory fees that you pay to Capital Analysts and your Advisor. This means that Capital Analysts and its affiliate Lincoln Investment earn two layers of fees on the same Sweep Product balances in your account, which can result in you experiencing a negative overall investment return. We also receive different fees based on the Sweep Product designated for your account. Therefore, we have an incentive for you to use (and invest your assets in) the sweep products that increase our compensation. If you desire to maintain a cash balance in your account for an extended period of time awaiting investment and/or seek the highest yields currently available in the market for your cash balance, please contact your Advisor or Capital Analysts for options outside of the Sweep Products. In order to mitigate these conflicts, Capital Analysts does not share this revenue with your Advisor. Your Advisor has the ability to waive the advisory fee on all Sweep Products, should you request it. Capital Analysts has designated the Tiered Rate Sweep Product for use in commission-based IRAs and most non-retirement brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in advisory IRAs. Bank Deposit Sweep Products are an important source of significant revenue for Lincoln Investment and its affiliate, Capital Analysts, Pershing, and Pershing’s affiliated Program Banks that participate in the Sweep Program. For additional information regarding Pershing’s and their affiliates’ conflicts of interest, please see the link to our Disclosures web page, included below. Lincoln Investment receives a portion of the fee paid to Pershing by the Program Banks, which it can allocate to its affiliate, Capital Analysts. Lincoln Investment sets the amount of the fee it receives from Pershing on your Bank Deposit Sweep Product accounts and/or assets. This is a conflict of interest as it permits Lincoln Investment and its affiliate, Capital Analysts, to assess a higher fee to you in order to increase our revenue. Pershing offers other sweep products for which no remuneration or less remuneration would paid to Lincoln Investment, as introducing broker-dealer. The portion of the fee received by Lincoln Investment on the Bank Deposit Sweep Products is greater than the yield that you will receive. Amounts paid to Lincoln Investment, Pershing and the Administrator reduce the interest rate paid on your Bank Deposit Sweep Product balance. Therefore, the higher the compensation paid to our affiliate, Lincoln Investment, the lower the interest paid to you; the lower the compensation paid to Lincoln Investment, the higher the interest paid to you. You should understand that this can result in you experiencing a negative overall investment return with respect to your balance in the Bank Deposit Sweep Product. Additionally, bank deposit sweep products typically yield lower returns than money market mutual funds. However, because Lincoln Investment earns a higher fee when you invest in Bank Deposit Sweep Products than if you invest in other money market products such as money market mutual funds, within or outside of the Sweep Program, Capital Analysts is incentivized to designate Bank Deposit Sweep Products for your account(s). Lincoln Investment receives greater compensation related to Bank Deposit Sweep Products as the amount of assets and/or accounts utilizing the Sweep Products increase and can take up to 6.00% of the interest rate paid on the balances of your Deposit Accounts. For additional information on Lincoln Investment’s current fees and compensation earned in relation to the Sweep Program, see the link to our Disclosures web page, included below. Accordingly, these arrangements present a conflict of interest to Capital Analysts because they provide an incentive for us to offer the Bank Deposit Sweep Products as our default sweep products, to maintain balances in the Bank Deposit Sweep Products over other investment options, including money market mutual funds, and for us and your Advisor to recommend that you enroll in and utilize the Bank Deposit Sweep Products. For Bank Deposit Sweep Products balances in excess of $2,490,000, Capital Analysts has designated a secondary Money Market Sweep Product. For the Tiered Rate Sweep Product, the secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund Service Shares (Ticker symbol DGUXX). If your excess balance is swept into Dreyfus Government Cash Management Fund Service Shares, Capital Analysts will earn fees on that balance, as further discussed below. For the Level Fee Sweep Product, the secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund Investor Shares (Ticker symbol DGVXX). For additional information regarding these secondary Sweep Products, please see the link to our Disclosures web page, included below. Program Banks do not have a duty to offer the highest rates available or rates that are comparable to money market mutual funds or those offered by other depository institutions or deposits held at Program Banks outside of the Sweep Program. The receipt of revenue sharing from Pershing and the ability for Capital Analysts to set its fee for the Sweep Products creates a conflict of interest for Lincoln Investment and its affiliate, Capital Analysts, to use Pershing as a custodian and to offer the Bank Deposit Sweep Products we make available to you over other custodians or sweep products that do not pay a portion of the their fees to us (share revenue), share lesser amounts, or that do not permit the introducing broker-dealer to set the fee it will assess for the Sweep Products. Capital Analysts has designated the Dreyfus Government Cash Management Fund Service Shares for non- ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in excess of $2,490,000 in the Tiered Rate Sweep Product, and Dreyfus Government Cash Management Fund Investor Shares Sweep Product for ERISA accounts and as the secondary Sweep Product for balances in excess of $2,490,000 in the Level Fee Sweep Product. A Money Fund Sweep Product earns dividends, interest and other income from its investment, and distributes this income (less expenses) to shareholders as dividends. For the Dreyfus Government Cash Management Fund Service Shares Sweep Product, Capital Analysts utilizes a share class that provides remuneration to us (distribution assistance) which reduces the dividend you receive, even though other share classes are available to Capital Analysts that would pay Capital Analysts’ affiliate, Lincoln Investment less and you more. Capital Analysts’ affiliate, Lincoln Investment receives distribution assistance from Pershing in the form of annual compensation of up to 0.55% for assets in the Dreyfus Government Cash Management Fund Service Shares Sweep Product. This is not the least expensive share class of the Dreyfus Government Cash Management Fund available or the least expensive share class available through Pershing. Capital Analysts utilizes a higher expense share class over other less expensive share classes that would otherwise be available and of lower cost to you. There are less expensive share classes of the same money market mutual fund available that would not provide revenue sharing with Lincoln Investment or would provide lesser amounts of revenue sharing. Share classes with higher expenses can lower your returns over time. This receipt of revenue sharing from Pershing creates a conflict of interest to Capital Analysts to use Pershing as a custodian and share classes offered by Pershing that provide remuneration over other custodians and share classes that do not share these fees or payments, or that would share lesser amounts, to offer the Sweep Products and to recommend that you utilize and maintain a greater balance in the Sweep Products. Pershing offers other sweep products for which no remuneration or less remuneration would paid to Lincoln Investment, as introducing broker-dealer. The investment adviser to Dreyfus Government Cash Management Fund Services Shares is BNY Mellon Investment Adviser, Inc. (“BNYM Investment Adviser”). BNYM Investment Adviser has engaged its affiliate, Dreyfus, a division of Mellon Investments Corporation, to serve as the sub-investment adviser for Dreyfus Government Cash Management Fund Services Shares. Capital Analysts has an incentive to offer/recommend Dreyfus Government Cash Management Fund Services Shares due to the agreement between Lincoln Investment and Pershing which incentivizes us to offer Pershing or its affiliates’ products so that we and our affiliate can share in a portion of the revenue. The Dreyfus Government Cash Management Fund Investor Shares Sweep Product, for which no distribution assistance is received by Capital Analysts or its affiliate, Lincoln Investment, is available only to ERISA accounts and as the secondary Sweep Product for balances in excess of $2,490,000 in the Level Fee Sweep Product. As previously indicated, certain Program Banks as well as Sweep Products affiliated with Pershing are made available within the Sweep Program. Due to Lincoln Investment’s custodial and clearing arrangement with Pershing, this creates a conflict of interest for Capital Analysts because it provides an incentive for us to offer a Sweep Product and to recommend utilizing the Sweep Product so that Pershing receives additional compensation and shares it with us and our affiliate. For additional information and clarity regarding all Sweep Products offered including the designated Sweep Product and secondary Sweep Product for your account, eligibility criteria, as well as applicable fees, rates, bank lists, and conflicts of interest, please carefully review our Sweep Program disclosures, available on our public website under our Disclosures section or at https://www.lincolninvestment.com/Disclosures. Please refer to The Lincoln Investment Companies Sweep Program General Terms and Conditions for instructions on how to access the applicable money market mutual fund prospectus. Sales & Marketing Support Revenue Lincoln Investment, as the broker-dealer affiliate of Capital Analysts, receives Sales and Marketing Support as described below and includes Flat Fee Sponsors, Other Sales Support and Asset and Sales Based Sponsors (collectively, “Sales and Marketing Support”). In order to minimize Capital Analysts’ conflicts of interest associated with the receipt of these fees by its affiliate, Lincoln Investment does not receive Flat Fee Sponsor and Other Sales Support payments that are based on the amount of advisory account assets or advisory account transactions with a particular sponsor, or that are based on ERISA advisory account assets. However, Flat Fee and Other Sales Support Sponsors can compensate Lincoln Investment from assets of the mutual fund, the fund’s investment adviser, distributor or other fund affiliates’ assets. While payments out of the fund's investment adviser, distributor or other fund affiliate's revenues or profits are not directly paid from the fund's assets, fund affiliate revenues or profits can, in part, be derived from fees earned for services provided to and paid for by the fund. Payments out of fund assets can lower investor returns and performance over time. Lincoln Investment can also receive Shareholder Services Fees from the same fund families and investment advisers that provide Sales and Marketing Support, and Shareholder Services Fees are in addition to the payment of Sales and Marketing Support fees. These sources of payments are a conflict of interest to Capital Analysts to recommend and promote those funds, fund families, investment advisers, distributors or other fund affiliates over others that do not provide Sales and Marketing Support or that provide lower amounts of Sales and Marketing Support. Flat Fee Sponsors. Lincoln Investment, Capital Analysts’ affiliated broker-dealer, has partnered with a select group of third-party money managers and product sponsors who pay to assist Lincoln Investment in the training and education of and outreach to Advisors at firm sponsored events, on such topics as advisory products and services, practice management, tools and technology, consumer education, and policies, rules and regulations. Additional opportunities can include but are not limited to attendance at and support of recognition club events, exhibit booths, advisor presentations, seminars, mailings and publications. These sponsors provide financial support to Lincoln Investment in the form of a flat-dollar amount that may be amended annually and is not based on the sales of their proprietary products or services. Sponsors can compensate Lincoln Investment from fund assets, the fund’s investment adviser, distributor or other affiliate’s assets. Payments made out of fund assets can lower investor returns and performance over time. Advisors do not share in any portion of these payments so as to mitigate any conflict for an Advisor to recommend one product or money manager over another. This financial support allows Lincoln Investment to defray or offset costs associated with firm sponsored events and other educational and outreach tools and services. The financial support by these Sponsors to Lincoln Investment associated with Capital Analysts presents a conflict of interest to Lincoln Investment and Capital Analysts. All Flat Fee Sponsors do not pay Lincoln Investment the same amount, and depending on the amount of the payment from the Flat Fee Sponsor, the access to Lincoln Investment sponsored events can differ. For example, Lincoln Investment holds a number of sales conferences both nationally and regionally throughout the year to educate Advisors. The higher the annual flat fee payment, the more events the Flat Fee Sponsor will be invited to attend. Flat Fee Sponsors have more opportunities than other product sponsors and money managers that are not Flat Fee Sponsors to market to and educate Advisors, which could pose a conflict to Advisors to offer these sponsors’ products or services over others. Advisors do not share in any portion of these payments so as to mitigate any such conflict. In 2023, the financial support from Flat Fee Sponsors paid to Lincoln Investment, as allocated across all investment advisory assets with Lincoln Investment Planning, LLC and Capital Analysts, LLC did not exceed one percent of total revenue for either of the affiliated registered investment advisers and in aggregate was less than one percent of the combined revenue for both affiliated registered investment advisers. We do not believe that these revenues are material. In 2023, Flat Fee Sponsors who compensated Lincoln Investment with a flat fee payment, and offer a fund or advisory program that could be used in your Capital Analysts advisory account, in order from highest to lowest payment were Russell Investments, Clark Capital Management, PIMCO Funds, AAMA, American Funds, Lord Abbett, Federated Investors, Meeder Funds, Franklin Templeton Group, InterLink, JPMorgan Funds, ICON Advisors, Invesco, and DoubleLine Funds. Some of the Flat Fee Sponsor revenue is used by Lincoln Investment to support the ongoing operational expenses of Lincoln Investment, and its affiliates, and not used solely for sales and marketing support. Other Sales Support. From time to time, product sponsors and third-party money managers assist Advisors in their sales and marketing efforts by subsidizing certain Advisor costs, such as client meetings or workshops, mailings, administrative expenses and technology support. The amount received from any one product sponsor or third-party money manager in 2023 did not exceed $20,000. The sales support presents a conflict of interest in that it could incentivize an Advisor to offer one product or money manager over another that does not provide these subsidies or provides lesser amounts. To mitigate the conflict of interest presented by these payments and subsidies, the amount is approved by The Lincoln Investment Companies and is monitored to ensure that it is not too frequent or excessive. Also, Advisors are invited from time-to-time by product sponsors to due diligence and educational meetings or seminars hosted by the product sponsor or money manager. This presents a conflict of interest that could incentivize an Advisor to offer one product or money manager over another that does not offer these meetings or seminars. We must grant permission to its Advisors to attend any meeting or seminar hosted by a product or advisory service sponsor. The Lincoln Investment Companies approve events that are limited to education or due diligence only and allows the product sponsor to provide meals, hotel accommodations and reimbursement to the Advisor, through us, for travel expenses only. The education of our Advisors in the offerings that are available to them is a key component of providing prudent investment advice to you. Ancillary Sales & Marketing Support Revenue paid to Lincoln Investment that is not tied to your Advisory assets, or the platform where your Advisory assets are held, but is tied to the Non-Advisory assets or transactions in which you may invest Asset and Sales Based Sponsors. In connection with non-investment advisory (non-fee-based) assets of our investors, and in addition to the compensation described above, Lincoln Investment, the broker-dealer affiliate of Capital Analysts, receives Sales and Marketing support from product sponsors, mutual fund companies, insurance companies and other third-party providers to assist in the marketing and sales efforts of employees and Advisors (“Asset and Sales Based Sponsors”). Asset and Sales Based Sponsors have the opportunity to educate and train employees and Advisors with respect to investment products and services, practice management, tools and technology, consumer education, and policies, rules and regulations. Additional opportunities can include but are not limited to attendance at and support of recognition club events, exhibit booths, advisor presentations, seminars, mailings and publications. The support provided by these sponsors is based on brokerage-only (non- investment advisory) assets and brokerage transactions and not based on your advisory account assets or ERISA advisory assets. Lincoln Investment receives compensation from these sponsors in various forms, including as a flat fee, a percentage of the amount of brokerage assets held by investors, a percentage of sales, or any combination of these methods. The amounts of these payments can vary by the type of product and by provider and can include, but are not limited to, distribution fees and shareholder service fees. All Asset and Sales Based Sponsors do not pay Lincoln Investment the same amount, and depending on the amount of the payment, the access to Lincoln Investment sponsored events and other opportunities can differ. The higher the payment, the greater the access for the Asset and Sales Based Sponsor to attend events, participate in marketing and sales opportunities and interact with Advisors. This presents a conflict of interest to Advisors to offer these sponsors’ products or services over others. Advisors do not share in any portion of these payments so as to mitigate any such conflict. Additionally, some Asset and Sales Based Sponsors make a monthly or quarterly payment or additional monthly or quarterly payment based on the assets you hold in a fund or variable insurance product over a period of time. As you may have both a brokerage account and an advisory account with us, we want you to understand that Lincoln Investment will receive Sales and Marketing Support based on assets or sales in connection with your brokerage account assets and transactions. The Asset and Sales Based Sponsors payments present a conflict of interest to Lincoln Investment to recommend Asset and Sales Based Sponsors that provide sales and marketing support over others that do not or that provide lesser amounts. Some of the Asset and Sales Based Sponsor revenue is used by Lincoln Investment to support the ongoing operational expenses of Lincoln Investment, and its affiliates, and not used solely for sales and marketing support. The following is a list of Asset and Sales Based Sponsors in order of high to low total compensation paid to Lincoln Investment as broker-dealer based on non-fee based account assets or sales in 2023: Security Benefit Life, Invesco Investment Services, Franklin Templeton Group, Allianz, Jackson National Life Ins Co, Athene, Nationwide, Lincoln National Life, Brighthouse Financial, AXA Equitable Life Insurance Company, Prudential, Blue Rock Capital, Mewbourne Development Corporation, Voya Mutual Funds, Pershing, CNL Securities, Black Creek Capital Markets, and Meeder Funds. The Asset and Sales based Compensation in 2023 was less than $2.5 million dollars from these product sponsors and represented less than one percent of the total revenues of Lincoln Investment. We are disclosing this information to you as certain providers and products offered by the providers shown above could be available within the investment advisory offerings of Lincoln Investment’s affiliate, Capital Analysts. Outside of the Sweep Program, Pershing LLC, as clearing firm for accounts introduced by Lincoln Investment, shares with Lincoln Investment a nominal amount of asset-based revenue it receives from certain mutual fund companies in non-advisory accounts. As this revenue received from Pershing is non-advisory related and not material, Lincoln Investment is disclosing the conflict that we receive this revenue rather than list each mutual fund product that generated the compensation to the firm. Other Conflicts and Potential Conflicts Ongoing Fiduciary Conflicts. Capital Analysts has a supervisory duty to periodically monitor clients’ portfolios to ensure suitability of investments and to ensure that the advisory services are being performed in recognition of our fiduciary duty to you, which includes acting in your best interest. A conflict of interest exists if an Advisor is assessing an advisory fee but no services are being performed. Supervision is performed over accounts and Advisors to monitor for activities that could be deemed a breach of our fiduciary duty to you, including such periodic reviews as accounts where there is no documentation of services being performed and accounts with uninvested cash balances over a 12-month period of time with no rationale for holding such a large cash position in an advisory account. In an advisory relationship, our fiduciary relationship will be most successful if both the client and the Advisor partner to ensure that there is regular and meaningful contact and that the advisory account continues to meet the needs of the client. Affiliates Other Businesses. Capital Analysts principal business is as an investment adviser. The majority of Capital Analysts revenue comes from the advisory fees we collect from you. Through its affiliated broker-dealer, Lincoln Investment also receives compensation from its brokerage business. This compensation comes from securities and insurance product commissions and mutual fund concessions, 12b-1 distribution fees associated with the sale of mutual funds, shareholder service fees, trailing commissions from annuity sales, and persistency bonuses on insurance and other sources. Lincoln Investment is also an SEC registered investment adviser and Capital Analysts promotes the services of this investment adviser. You always have the option to purchase advisory services, securities products or insurance through non-affiliated investment advisers, brokers or agents. Your Advisor’s Other Businesses. Your Advisor may have more than one relationship with you – one as an Advisor over an advisory account and one as a Registered Representative/Agent of Lincoln Investment over a non-advisory account where he or she may receive a sales commission for the sale of securities or insurance products which would be in addition to any advisory fees earned on your advisory assets. In these situations, our Advisor may have greater financial incentives to offer you both investment and/or insurance sales as well as advisory services. Your Advisor may also be associated with Capital Analysts’ affiliated investment adviser, Lincoln Investment Planning, LLC. This affiliated relationship presents a conflict of interest. Through his or her affiliation with Capital Analysts and possibly with Lincoln Investment, your Advisor may be in a position where he or she can offer the same or similar advisory services to you for different fees and compensation structures. If an identical Sub-Adviser or strategy is available through two affiliated registered investment advisers, you may pay higher fees for an advisory service that is similarly offered through another affiliated investment adviser. You always have the option to purchase advisory services, securities products or insurance through non-affiliated investment advisers, brokers or agents. Capital Analysts pays out to each Advisor a specified percentage of the Advisor’s fee. This percentage varies by Advisor based on such factors as Advisor experience, type of contract the Advisor has with the firm, amount of investor assets with the firm, type of advisory service, categories of products and the amount of investor assets managed by the IM&R Team. These varying payout rates can create a conflict of interest for your Advisor to recommend certain services and categories of products, including advisory services managed by the IM&R Team and your Advisor, over others with a lower payout rate. Most of Capital Analysts’ Advisors are independent contractors who may also offer other non-security financial services and products, such as life, health, disability, long-term care and fixed annuity insurance products, and real estate. These services may be offered independent of The Lincoln Investment Companies. Sales Contests. Lincoln Investment offers sales contests based on such criteria as gross compensation to the Advisor, new accounts, new investors, initiation of periodic contributions, total fee-based assets and net sales of fee-based programs, inclusive of Capital Analysts. These contests can provide your Advisor with a conflict of interest and an incentive to offer you fee-based advisory services over commission-based brokerage services, offer you advisory services managed by the IM&R Team and your Advisor over third-party advisory services and to conduct additional business in order to be eligible. Top achievers in these contests are eligible to receive Lincoln Investment-sponsored trips, awards, cash prizes, bonus commissions, bonus payments, club points, monetary donations in their name to a charity of their choice or other nominal prizes subject to applicable law. To mitigate the conflicts of interest presented by these incentives, no contest is offered which will award the Advisor based upon a specific investment product or on a specific third-party product sponsor. Brokerage commissions and brokerage assets associated with Massachusetts residents are excluded from Lincoln Investment’s sales contests consistent with applicable state law. For Massachusetts’ residents, this creates a financial incentive for your Advisor to recommend advisory services over brokerage services. We mitigate these conflicts by disclosing them to you and supervising the investment advisory activities and brokerage practices of its Advisors. In our capacity as an investment adviser, Capital Analysts and its Advisors recognize they have a fiduciary duty to investment advisory clients. Although Lincoln Investment does not offer specific product sales incentives for securities products, issuers of non-securities insurance products, such as fixed annuity issuers, may offer sales incentives to Advisors in the form of cash bonuses and trips if certain sales thresholds are met. You should ask your Advisor about these incentives at the time of sale. Payments to Employers and Organizations Associated with an Employer who Sponsor Non-ERISA Plans. Lincoln Investment, Capital Analysts’ affiliate, has contracts with employers to enable employees who work for these employers to open and invest in a primary or supplemental retirement account through payroll deduction contributions through an account with us. The majority of employers with whom Lincoln Investment has contracts offer non-ERISA 403(b), 457, SEP IRA and Simple IRA retirement plans to their employees. Also, many of these employers are school districts and the employees are teachers or other eligible employees. Lincoln Investment and our Advisors make contributions from time-to-time to organizations that are associated with an employer, such as administrators and teachers’ associations, consultants, non-profits, and scholarship or grant funds. Lincoln Investment and our Advisors can also sponsor a business or social event, conference, meeting, fundraiser or scholarship by making a monetary contribution or by providing nominal supplies to assist the employer and/or their employees. Third-Party Administrator (“TPA”) Payments and Preferred Providers. Most TPAs that provide administrative services to the employer charge the employer an annual per participant retirement plan administration fee for their services. Certain TPAs and/or employers list Lincoln Investment as a preferred provider when we have agreed to pay the per participant TPA fee for a participant who opens an account with us. This reduces the cost to the employer sponsor of the retirement plan and/or the participant. Exclusive Provider. Less than one percent of our employer contracts are an exclusive arrangement where Lincoln Investment is the only provider who has been authorized to work with the employees to establish a primary/supplemental retirement plan account. A small number of the exclusive arrangements utilize the TPA services of an affiliate, Advisory Services, LLC (“Adserv”). In the Adserv exclusive arrangements, Adserv waives the fees it would otherwise charge for administration and compliance services because the employer has agreed to grant an exclusive provider arrangement to us. You can ask your Advisor whether Lincoln Investment has an exclusive arrangement with your employer. Other Non-Exclusive Provider Payments. In order to be a 403(b) provider/vendor in California, providers/vendors must register with 403bCompare, a program of the California State Teachers’ Retirement System (“CalSTRS”). Lincoln Investment is registered with 403bCompare and pays an annual 403(b) provider/vendor fee as determined and assessed by CalSTRS. The total fee assessed to all providers/vendors covers the cost to administer and maintain the 403bCompare.com website. These payments and fee waivers described in this section create a conflict of interest to the employer and employees since they could serve as an incentive to select the products and services of Lincoln Investment and its affiliates over other providers that do not make these payments or pay lesser amounts. We mitigate these conflicts by disclosing them to you and avoiding payments that we consider too frequent or excessive. Other Asset Level Payments (Available to Certain Advisors). Certain Advisors are eligible to receive, directly or indirectly, additional compensation from Capital Analysts when specified thresholds of total assets are met by that Advisor and other Advisors with whom they are associated (“Other Asset Payment” or “OAP”). OAP creates a conflict of interest for the Advisor to recommend certain offerings, including advisory services managed by the IM&R Team and the Advisor, over others for which they would not receive additional compensation in the form of OAP. These payments to your Advisor directly or indirectly would result in your Advisor receiving greater compensation than what is indicated as the Financial Advisor Fee in your Investment Management Agreement. The payment of OAP to an Advisor, including your Advisor, has no impact on the total client fee paid by you for the selected offering. These payments also create a conflict of interest for Capital Analysts to compensate Advisors in order to maintain or increase assets managed by the IM&R Team and the Advisor, over other advisory services or platforms where Capital Analysts receives less revenue. Capital Analysts mitigates these conflicts by disclosing them to you and supervising the investment advisory activities and brokerage practices of its Advisors. Loans and Advances. On occasion, Capital Analysts’ affiliate, Lincoln Investment extends a loan, provides a bonus, provides a commission/fee advance, and pays for practice management services for an Advisor to assist the Advisor in transitioning to the firm, and/or running his or her business. Sometimes these loans or advances are forgiven (waived) or reduced, in whole or in part, interest rates reduced, and/or a bonus provided if an Advisor remains affiliated with the firms or achieves certain sales or assets under management thresholds, revenue targets, production levels, client transfer goals, client retention goals, recruiting goals and certain practice management goals or conditions set forth by the firms, individually or with other Advisors. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate with and remain affiliated with the firms during the repayment period in order to receive these benefits over other firms that do not offer these incentives or offer a similar level of incentives. These practices also present a conflict in that the Advisor has a financial incentive to generate more business and achieve certain sales, revenue or asset management thresholds in order to satisfy or reduce the amount of the loans or advances. In situations where a sales, production, revenue, assets under management threshold or other financial contingency exists, this conflict of interest will be disclosed in your Advisor’s Form ADV 2B Supplement (BIO Brochure), which is required to be delivered by the Advisor to every client. Capital Analysts mitigates these conflicts by disclosing them to you and supervising the investment advisory activities and brokerage practices of its Advisors. Additionally, Lincoln Investment can extend a loan or advance to an Advisor for which repayment is required which can create a conflict for the Advisor to generate more business in order to repay the loans or advances to the firm during the repayment period. Additionally, some Advisors receive benefits as they transition to the firm and/or for running their business, which can include but is not limited to, technology services, administrative support, licensing, insurance and administrative fees and reimbursement of fees associated with transitioning accounts. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate with and remain affiliated with the firms over other firms that do not offer these incentives or offer a similar level of incentives. Capital Analysts mitigates these conflicts by disclosing them to you and supervising the investment advisory activities and brokerage practices of its Advisors. Advisor Referral Program. Lincoln Investment compensates Advisors and employees who have referred another financial professional to the firm if that referred financial professional then decides to affiliate with Lincoln Investment and/or its affiliate, Capital Analysts. This creates an incentive for Advisors and employees to affiliate with our firm over others that do not offer similar compensation, and to refer financial professionals in order to receive this compensation. We do not believe that this practice presents a material conflict of interest. Gifts and Entertainment. Offering or receiving a gift or entertainment from a product or advisory service sponsor could create a conflict of interest. Lincoln Investment has instituted a policy that prohibits excessive and/or too frequent gifts or entertainment activities to mitigate this conflict. Political Contributions. Providing significant political contributions to a state or local official or candidate could create the perception that Capital Analysts or its Advisors are seeking quid pro quo arrangements with that state or local government or its employees to open an account with our firm. Lincoln prohibits contributions in excess of $350 per election if the Advisor can vote for the candidate and $150 per election if the Advisor cannot vote for the candidate. Charitable Donations. Providing significant charitable donations to a charity organization could create the perception that Capital Analysts or its Advisors are seeking quid pro quo arrangements with that charity or its employees to open an account with our firm. Lincoln allows contributions to charities, but prohibits any donations that are deemed excessive or too frequent. Accounts Maintained on Institutional Platforms The following applies to clients whose accounts are held at Schwab or other institutional platforms (“Institutional Platforms”). Capital Analysts can recommend that clients establish brokerage accounts with one or more Institutional Platforms to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with an Institutional Platform is at the discretion of the Advisor’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Products & Services Available to Us from Institutional Platforms Institutional Platforms serve independent investment advisory firms like ours. They provide Capital Analysts and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to the Institutional Platform’s retail customers. Institutional Platforms also make available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Institutional Platform support services are generally available on an unsolicited basis and at no charge to us. Some institutions such as Charles Schwab and Co., Inc. require we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab to avail ourselves of those services at no charge. These Institutional Platform providers generally do not charge separately for custody services but are compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through them or that settle into their accounts. Services that Benefit Clients Institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Institutional Platforms include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. These services generally benefit clients or their account(s). Services that May Not Directly Benefit Clients Institutional Platforms also make available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They can include both their own investment research and that of third parties. We can use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at the Institutional Platform providing the services. In addition to investment research, Institutional Platforms make available software and other technology that:
• provides access to client account data (such as duplicate trade confirmations and account statements);
• facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
• provides pricing and other market data;
• facilitates payment of our fees from our clients’ accounts; and
• assists with back-office functions, recordkeeping and client reporting. Institutional Platforms also offer other services intended to help us manage and further develop our business enterprise. These services can include:
• educational conferences and events;
• technology, compliance, legal, and business consulting;
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers. Institutional Platforms may provide some of these services. In other cases, they will arrange for third-party vendors to provide the services. They can also discount or waive their fees for some of these services or pay all or a part of a third party’s fees. While, as a fiduciary, Capital Analysts endeavors to act in its clients’ best interests, Capital Analysts’ recommendation that clients maintain their assets in accounts at the Institutional Platform can be based in part on the benefit to Capital Analysts or its Advisors of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by these Institutional Platforms, which creates a conflict of interest.