Introduction LPL Financial LLC (“LPL”) is an investment advisor registered with the Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”). LPL has provided advisory services as a registered investment advisor since 1975. Note that registration as an investment advisor with the SEC does not imply a certain level of skill or training. As of December 31, 2023, LPL managed approximately $462,816,600,000 of client assets on a discretionary basis and approximately $658,900,000 of client assets on a non-discretionary basis. LPL is owned 100% by LPL Holdings, Inc., which is owned 100% by LPL Financial Holdings Inc., a publicly held company. Types of Advisory Services LPL offers various types of advisory services and programs, including wrap fee programs, mutual fund asset allocation programs, advisory programs offered by third party investment advisor firms, financial planning services, an advisor-enhanced digital advice program, and retirement plan consulting services. This Brochure provides a description of the advisory services offered under LPL’s Bank Wealth Program (“BWP”). For more information about LPL’s advisory services and programs other than BWP, please contact LPL for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov/. BWP is a program offered by LPL to clients that are banks, corporate trustees, thrifts, trust companies, broker-dealers, investment advisors, and other financial institutions (“Financial Institution”) and offers various levels of investment advisory, technology, research and back office services to those clients. LPL acts as a service provider to Financial Institutions who then choose how to use the LPL services and how to shape the advice and services they are providing to each end client (“Client”) of the Financial Institution. LPL is also a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”); however, all services provided under BWP are in an advisory capacity. BWP is an open architecture program allowing flexibility to the Financial Institution to use the available LPL services to design the best service for their Client. Financial Institutions choose which components they wish to use within BWP. There are four basic components of BWP: 1. Technology: BWP Technology includes access to a user portal to create and deliver Client proposals, investor questionnaires and reporting. 2. Research: BWP Research is made available through the LPL Research Department. LPL’s Research Department makes available investment research materials, which include recommendations on separate account strategies, and mutual funds. When LPL provides investment research, LPL makes no analysis of and does not consider Clients’ individual circumstances or objectives, and does not tailor any model asset allocation to any specific client’s needs, circumstances or objectives. The BWP Research offering consists of:
• Manager due diligence on a selected list of available managers including managers available within BWP and separately managed account managers accessed through BWP technology. It is important to note that LPL does not perform, and has no obligation to perform, due diligence or other research with respect to investment managers or funds that are not on LPL’s current Recommended Manager Line-Up Sheet (“Non-Covered Managers”), even if Performance Reports prepared by LPL include data provided by such Non-Covered Managers.
• Asset allocation recommendations made available by LPL Research.
• A set list of deliverables created by LPL Research for Financial Institution use.
• Access to economic commentary and capital markets research.
• Access to LPL’s “Portfolio Designer” system for client investment planning.
• Access to the LPL Financial Portal, a web based tool to access research investment information, client performance results, client portfolio accounting and other consulting information. L P L F I N A N CI A L L L C P a g e 3 3. Trade Implementation and Portfolio Management
• SMA Program: LPL will provide access to a platform through which the Financial Institution may engage third-party managers (“Portfolio Managers”)

who will direct and manage the client accounts. Financial Institutions may choose to implement investment decisions by designating the client accounts as SMA accounts and completing the required paperwork to process those accounts with SMA managers. LPL will facilitate the delivery of the required paperwork to the SMA managers for the designated SMA accounts.
• UMA Program: Alternatively, Financial Institution can choose to implement investment decisions through the LPL platform using centralized portfolio management in the UMA program. o The BWP UMA program is a unified management account program that combines managed accounts comprised of individual securities, mutual funds, and ETFs in one diversified portfolio. LPL acts as the Sponsor, otherwise known as the Investment Manager, of the UMA program. LPL may also act in other capacities within the program as detailed below. Additionally, third parties may also participate in the programs as Research Providers or Overlay Managers as detailed below. o A Financial Institution whose Client participates in the UMA establishes a discretionary account that is invested in a manner consistent with one of several multi-manager, multi-asset allocation strategies created by the Financial Institution. o Specifically, responsibilities for management of accounts participating in the UMA are divided as follows:  The Financial Institution is responsible for the creation of a series of multi-manager, multi-asset allocation strategies (“Models”) with varying asset allocations and risk profiles. The Financial Institution is also responsible for recommending which Model(s) a Client may invest in. LPL conducts initial and ongoing due diligence on investment advisers known as Research Providers that provide managed account solutions, typically comprised of individual securities. LPL will also conduct due diligence on and recommend mutual funds which may be selected by the Financial Institutional for use in a model. It is the Financial Institution who makes the final recommendation to the client with regard to which Model(s) they should invest in.  LPL may also act as a Research Provider in the BWP UMA program. In cases where LPL acts as a Research Provider its services as such are provided in addition to the other services provided by LPL, and LPL shall be entitled to collect fees from Financial Institutions for such services.  LPL also acts as the overlay manager in the BWP UMA program to implement investment decisions made by Financial Institutions. As the Overlay Manager, LPL is responsible for making discretionary trading decisions to implement the models in the BWP UMA program. Upon instruction by the Financial Institution, the Overlay Manager may execute transactions according to its tax efficient management strategy, which may cause it to delay or defer causing the account to mirror its applicable model. The Overlay Manager is responsible for providing periodic rebalancing services so the allocation of these accounts remains consistent with the selected model(s). Unless otherwise directed by a Financial Institution and/or Client, Overlay Manager is responsible for seeking best execution on transactions for BWP UMA accounts. The Overlay Manager may take actions for certain accounts that it does not take for other accounts (e.g., for example, in the case of investment restrictions imposed on an account), even when such accounts are intended to be managed according to the same model portfolio. It is important to note that third party Research Providers for the BWP UMA program provide models to LPL, and it is LPL that has discretion for trade implementation and execution in its BWP accounts. Therefore, models submitted to LPL by third party Research Providers may represent activity that has already been implemented on behalf of other clients of such Research Providers. Because of this fact and because LPL (and not the third-party Research Provider) has discretionary authority to implement trades, performance of an BWP account will differ from the performance of such Research Provider’s discretionary accounts. 4. Back Office Services: To the extent agreed upon by LPL and Financial Institution, LPL may perform back office functions on behalf of the Financial Institution including, but not limited to, Client fee calculation and processing. L P L F I N A N CI A L L L C P a g e 4 M e m b e r F I N RA / S IP C