Summit Financial, LLC, a Delaware limited liability company (hereinafter referred to as the "Advisor", "Summit" or "Summit Financial") is a successor to Summit Equities, Inc.'s registration under Section 203(g) of the Investment Advisers Act of 1940 (the "Advisers Act"). Established in 2018, Summit has succeeded from the advisory businesses of Summit Equities, Inc. ("SE") which had been providing investment advisory and financial planning services since 1991. Summit is wholly owned by Summit Financial Holdings, LLC ("SFH") which is owned 72.5% by Summit Financial Services, LLC ("SFS"). SFS is owned 33.2% by Stanley Gregor and 46.8% by SE (which has ceased to operate as an investment adviser but still exists as a corporate entity). Summit offers investment advisory services to individuals, high net worth individuals, corporations and/or business entities, pension and profit-sharing plans, and charitable organizations (each referred to as a "Client" or collectively as "Clients"). Summit serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. The majority of Summit's Clients use Fidelity Brokerage Services, LLC ("FBS"), which provides brokerage services in connection with Client accounts in the programs discussed in Summit's Wrap Fee Program Brochure. National Financial Services LLC ("NFS"), an affiliate of FBS, will continue to provide account custodial services in connection with such accounts. The majority of Summit's Wrap Fee Accounts are custodied at NFS. However, some clients also use Schwab Advisor Services LLC, Pershing LLC, or Goldman Sachs (hereinafter referred to as "Additional Qualified Custodians") as their qualified custodian for Wrap Accounts. All clients will complete documentation provided by the qualified custodian of their choice at account opening and may have also been notified of their selected qualified custodian via the Advisory Program Schedule attached or incorporated by reference to their Investment Management Agreement ("IMA"). For additional information regarding custodians, please contact your Financial Advisor or Summit at [email protected]. Each advisory relationship at Summit is managed by one or more Financial Advisors, acting in the capacity of an investment adviser representative registered with Summit (hereinafter referred to as "Financial Advisor(s)" or "IAR(s)"). The Financial Advisor serves as the primary point of contact between Summit and the Client. The Financial Advisor collects financial information from the Client and based on the Client needs, recommends specific advisory services or programs that would seek to meet their investment objectives. Some Financial Advisors choose to incorporate more of Summit's resources in their provision of advisory services to their Clients than others do, such as consultations with the internal Summit specialists. Some of the Financial Advisors are also associated with unaffiliated broker-dealers Purshe Kaplan Sterling Investments ("PKS")1, Aurora Private Wealth Inc. ("Aurora") and Private Client Services ("PCS") (collectively herein referred to as "Unaffiliated Broker Dealers"). These Unaffiliated Broker Dealers are registered with the SEC as a broker-dealer and are members of FINRA and SIPC. Financial Advisors who are associated with Unaffiliated Broker Dealers can provide brokerage services in the capacity of a Registered Representative ("RR") of that broker-dealer. All brokerage products offered by the Financial Advisor are provided in their capacity as an RR through their broker-dealer, not through Summit or its affiliates. The Financial Advisors who provide (i) investment advisory services, including asset management and financial planning services, through Summit or its affiliated firms, (ii) insurance through Summit Risk Management, LLC ("SRM"), and (iii) brokerage services through PKS or any other unaffiliated broker dealer, are independent contractors or employees of each of these companies. In addition, certain financial advisors that are registered with Summit are employees of affiliated or unaffiliated entities. Some Financial Advisors have other material business interests as well, as described in their Form ADV Part 2B Brochure Supplements ("Financial Advisor Brochure Supplement"). SRM is an affiliate of Summit see Item 10 – Other Financial Industry Activities and Affiliations contains a discussion of this company. Some of our Financial Advisors operate their business under a "doing business as" ("DBA") firm. The investment advisory and financial planning products and services offered through their DBA are provided through Summit. Other business lines such as brokerage and insurance services and products, provided through their DBA, are provided through other unaffiliated and affiliated firms. For more information about a Financial Advisor or their DBA, please refer to the particular Financial Advisor Brochure Supplement. Each Financial Advisor is compensated by Summit for providing investment advisory and related services. The amount of this compensation varies depending on which advisory service or program the Client selects and may be more than what the Financial Advisor would receive if the Client selected a different advisory service or program provided by Summit. Accordingly, Financial Advisors have a financial incentive to recommend one advisory service or program over another to maximize their compensation. This Form ADV Part 2A Disclosure Brochure describes the investment advisory services and programs offered by Summit. Wrap fee programs offered by Summit are described in detail in another brochure, Summit's Wrap Fee Program Brochure, which contains the information required by Part 2A, Appendix 1 of Form ADV. Types of Advisory Services Summit offers several different asset management programs for its advisory Clients as well as financial planning. From time to time, individual Financial Advisors offer custom consulting or other services. In such event, the details will be disclosed in the specific agreements with the Client. 1 SE assisted the Financial Advisors who wished to continue to remain registered representatives of a broker-dealer to register with Purshe Kaplan Sterling Investments a broker dealer and member of FINRA and SIPC ("PKS"). PKS is not affiliated with SE or its successors. If the Financial Advisor continues to offer brokerage products to Clients, it will not be through Summit or any of its affiliates but will be through PKS, or other unaffiliated broker dealers as appropriate. PKS or other unaffiliated broker dealers, through a referral agreement, pay a referral fee to a broker dealer that is owned by Summit Financial Holdings, LLC (LS Securities, LLC) for the brokerage business conducted by the Financial Advisors at PKS or other unaffiliated broker dealers. For the assets in its asset management programs, Summit provides continuous and regular supervisory or management services (as defined by the SEC) based on the Client's individual goals, objectives, time horizon, risk tolerance, liquidity needs, investment assets and income ("financial circumstances") utilizing the investment strategy selected by the Client. Financial Advisors obtain a financial profile for each Client to aid in the construction of a portfolio that matches the Client's specific situation and needs. Many Clients maintain "household" accounts, in which multiple accounts for an individual or members of a family are managed jointly to maximize efficiencies. (The term "Client" includes such households, for purposes of this brochure.) For all of the different types of asset management programs, the Financial Advisor will assist Clients in assessing their goals, risk tolerance, income and tax situation and selecting an investment strategy and asset allocation that is appropriate for the Client's specific circumstances. However, Summit and its Financial Advisors do not provide tax advice to Clients. Summit, through its Financial Advisors, is available to Clients on an ongoing basis to discuss Client financial circumstances, the selected portfolio and the securities therein or to process instructions from Clients concerning advisory assets. Summit or a third-party manager as applicable, will exercise discretion in connection with certain advisory programs as described herein, or pursuant to an investment advisor agreement the Client signs with Summit. By signing Summit's Discretionary Investment Management Agreement, Client appoints Summit and the selected Summit Financial Advisor to provide investment advisory and investment management services on a discretionary basis for assets in the Client's designated accounts which may include all accounts in the Client's household. Account(s) managed under full discretion by Summit and Client's Summit Financial Advisor are part of Summit's Wrap Fee programs. Additional information regarding discretionary services can be found in Summit's Wrap Fee Program Brochure. In connection with non-discretionary services or programs, it is up to the Client to decide whether to accept or reject Summit's recommendations. Summit's securities recommendations seek to be consistent with a Client's financial circumstances and any reasonable guidelines or restrictions provided by a Client. Unless otherwise instructed by the Client, all dividends and other distributions will be reinvested in Client accounts. The investment strategies used by Summit vary by Client and are based on the Clients' individual circumstances. Clients are advised to notify Summit promptly if there are changes in their financial situation, investment objectives or if they wish to impose any reasonable restrictions upon Summit's investment management services. Clients can engage Summit to manage all or a portion of their assets on a discretionary or non-discretionary basis, by selecting one or more advisory programs as set forth in their IMAs with Summit. As applicable, Clients are typically required to enter into additional written agreements with the Custodian for the accounts, third-party investment managers, platform managers, insurance companies or other parties that are not affiliated with Summit. All investments have risk and there is no guarantee that utilizing the asset management or financial planning services of Summit or its Financial Advisors will produce favorable results. 1. Summit Managed Portfolios Summit Managed Portfolios ("Managed Portfolios") are custom designed portfolios constructed by Summit's Investment Management Committee ("IMC"), which includes the Chief Investment Officer ("CIO") and members of the Investment Management Department. The IMC meets regularly to oversee the Managed Portfolios. The IMC also conducts quarterly meetings with the Investment Committee, an advisory group of Financial Advisors, to discuss changes to the Managed Portfolios as well as other investment topics. Summit, acting through the Chief Investment Officer, has discretionary authority over the assets managed under the Managed Portfolios program. The IMC determines the asset allocation, the securities to be bought or sold, the amount of securities to be bought or sold and the timing of the purchases and sales of the securities. Given the long-term nature of many Managed Portfolios strategies, many Managed Portfolios accounts may have little or no activity during a given period. With the exception of the Tax-Deferred Strategies Portfolios ("TDS"), the Managed Portfolios are part of the wrap fee program.2 The TDS program includes managed portfolios that target a specific asset class, market segment or investment strategy or offer various mixes of these components. Each portfolio has a strategic allocation designed to overweight market segments seeking to outperform over the long term and to control exposures to investment risks. Portfolios with a range of investment objectives and potential levels of risk and return are available. These portfolios are only available on the Nationwide Monument Advisor tax-deferred variable annuity platform. The specific strategies offered as TDS are detailed in the Summit Managed Portfolio Brochure which is provided to Clients prior to investing in this advisory program. 2. Strategic Asset Allocation ("SAA") The SAA program enables Financial Advisors to custom design portfolios for Clients, taking into account each Client's circumstances. The Financial Advisor does not have discretion over the assets and must get approval from Clients before entering any trades. SAA accounts primarily include assets for which regular and continuous supervision or management services are provided but from time to time, they hold specific investments for which the Financial Advisor provides only consultative and administrative services, including periodic monitoring, reporting and/or servicing.3 Although most SAA accounts are primarily allocated among mutual funds and ETFs, some Financial Advisors recommend that their Clients also hold individual positions in stocks, bonds, traded and non- traded REITs, hedge funds (including funds of funds), unit investment trusts ("UITs") or other securities. As of December 1, 2022, all alternative investment purchases will occur in SAA accounts. Mutual funds, UITs and ETFs often provide diversification but may be concentrated in a particular asset class or investment style. The risk in these investments is determined by the risk in underlying holdings (e.g., a stock mutual fund's risk is determined by the risk of the stocks in the fund). Further, some of the selected securities may be less liquid than those utilized in the Managed Portfolios. The Financial Advisors are invited to consult with members of the IMC regarding particular securities or 2 For additional information about the Managed Portfolios that are part of Summit's Managed Portfolios wrap fee program, please see Summit's Wrap Fee Program Brochure. 3 For certain assets, such as those invested in hedge funds and non-traded REITS, or those managed by third parties who have a direct relationship with the Client, Summit and the Financial Advisor provide ongoing advice and monitoring rather than what the SEC refers to as "continuous and regular supervisory services." when constructing portfolios, but they are not required to, and some choose to rely solely on their own due diligence regarding the securities recommended. Clients should speak to their Financial Advisors to understand how their Financial Advisor determines which securities to recommend. Given the long- term nature of many SAA strategies, many SAA accounts have little or no activity during a given period. If you have any questions, please speak with your Financial Advisor or contact [email protected]. Assets held in connection with the SAA program may be custodied at NFS, one of the Additional Qualified Custodians or elsewhere as selected by the Client, and when custodied at NFS or one of the Additional Qualified Custodians, they are part of Summit's Wrap Fee Programs. Please take note that certain SAA accounts at NFS, or other qualified custodians, have been grandfathered in from previous programs as non-wrap accounts, and are not part of Summit's Wrap Fee Programs. Additional information regarding SAAs that are part of Summit's Wrap Fee Program can be found in Summit's Wrap Fee Program Brochure. Client can refer to their Advisory Program Schedule document, IMA or contact their Financial Advisor to determine if their SAA account is a Wrap or Non-Wrap account. Within SEI Managed Account Solutions ("SEI MAS") and SEI Mutual Fund Portfolio ("SEI MF") accounts, a Financial Advisor can direct, on a non-discretionary basis, some or all of the Client's assets into non-SEI investments to customize the portfolio based on the Client's needs and circumstances ("Wealth Manager-Directed Non-Discretionary"). Summit treats assets held as part of Wealth Manager-Directed Non-Discretionary (but not other assets held in connection with the SEI MAS and SEI MF accounts) as part of a SAA program. The Wealth Manager-Directed Non-Discretionary assets are primarily allocated among mutual funds and ETFs; however, they may also hold other types of investments, if recommended by the Financial Advisor. When Financial Advisors recommend these other investments in connection with Wealth Manager-Directed Non-Discretionary, Clients incur additional charges. 3. Advisor as Portfolio Manager ("APM") / Flexible Managed Accounts ("FMA") The APM and FMA programs are similar to the SAA program except that the Financial Advisor has discretion to place trades without contacting the Client for approval. The APM and FMA programs are the same. The FMA program name was changed to APM in 2021; however, both FMA and APM accounts can still be opened. Direct investments, such as non-traded REITs and hedge funds, are generally not included in APMs or FMAs. The Financial Advisor reviews the Client's financial circumstances and exercises discretion to determine the securities to be bought or sold in the Client's account, the amount of securities to be bought or sold and the timing of the purchases and sales of the securities. The securities used in these accounts generally include mutual funds, ETFs, UITs, equities, and fixed income. Mutual funds, UITs and ETFs often provide diversification but may be concentrated in a particular asset class or investment style. The risk in these investments is determined by the risk in underlying holdings (e.g., a stock mutual fund's risk is determined by the risk of the stocks in the fund). The Financial Advisors are invited to consult with members of the IMC regarding particular securities or when constructing portfolios, but they are not required to, and some choose to rely solely on their own due diligence regarding the securities recommended. Some Financial Advisors select securities that are less liquid than those utilized by the IMC in connection with the Managed Portfolios. Clients should speak to their Financial Advisor to understand how their Financial Advisor determines which securities to buy and sell. In certain limited instances, a client will be given authorization to trade securities in their own account. Given the long-term nature of many APM/FMA strategies, an APM or FMA account may have little or no activity during a given period. If there are few trades made in a Client's APM/FMA account, then a wrap fee program such as APM or FMA will not be the most cost-effective option for the Client as compared to non-wrap programs. Some Financial Advisors are more tactical and may trade more often to manage risk and or seek opportunities. There are tax implications to more active approaches and there is no guarantee that these strategies will provide greater returns or lower risk. Clients should discuss the approach with their Financial Advisor. For more information on these fees and the APM/FMA Program or if you have any questions, please contact with your Financial Advisor or email [email protected]. Assets held in connection with the APM or FMA program may be custodied at NFS, one of the Additional Qualified Custodians or elsewhere as selected by the Client, and when custodied at NFS or one of the Additional Qualified Custodians, they are part of Summit's Wrap Fee Programs. Additional information regarding APMs or FMAs that are custodied at NFS or one of the Additional Qualified Custodians can be found in Summit's Wrap Fee Program Brochure. Certain APM and FMA accounts at NFS, or one of the qualified custodians, were grandfathered in from previous programs as non-wrap accounts and are not part of Summit's Wrap Fee Programs. Clients can refer to their Advisory Program Schedule document, IMA or contact their Financial Advisor to confirm whether their

account is a Wrap or Non-Wrap account. Within SEI MAS and SEI MF accounts, an IAR can direct, on a discretionary basis, some or all of the Client's assets into non-SEI investments to customize the portfolio based on the Client's needs and circumstances ("Wealth Manager-Directed Discretionary"). Summit treats assets held as part of Wealth Manager-Directed Discretionary (but not other assets held in connection with the SEI MAS and SEI MF accounts) as part of an FMA program. The Wealth Manager-Directed Discretionary assets are primarily allocated among mutual funds and ETFs; however, they may also hold other types of investments, if recommended by the Financial Advisor. When Financial Advisors recommend these other investments in connection with Wealth Manager-Directed Discretionary, Clients incur additional charges. 4. Third Party Managers ("TPM") In the TPM program, the Financial Advisor reviews the Client's financial circumstances and recommends an unaffiliated third-party investment manager to manage the Client's assets. Some of the TPMs are sub-advisers under agreements with Summit and others will have separate advisory agreements directly with the Client. Some of the third-party managers operate on the NFS platform (such as Envestnet and AllianceBernstein); some operate on separate platforms (such as SEI MAS). For additional information about Summit's sub-advisory stock portfolios with Seeds, Parametric and AllianceBernstein or the Municipal Bond Program, a TPM program under which AllianceBernstein serves as sub-adviser and pursues a municipal bond strategy, please see Summit's Wrap Fee Program Brochure. In some cases, Summit acts as a solicitor on behalf of the TPM. TPMs actively manage the assets on a continuous basis and have discretion to buy, sell and trade stocks, bonds, mutual funds and/or other securities in accordance with the program selected by the Client. Depending on the TPM, the Financial Advisor will provide either consultative or continuous and regular supervisory services to assets in TPM programs and may recommend periodic rebalancing among the TPM's offerings. Clients are advised to review the investment advisory brochure for any recommended TPM. In some cases, the Financial Advisor can create custom allocations on a TPM's platform. If you have questions about a particular TPM or program, please ask your Financial Advisor or contact [email protected]. Some of the TPM programs constitute "wrap programs." For example, the SEI MAS program is a wrap program sponsored by SEI that utilizes third party managers and/or mutual fund models. The investment advisory brochure for the specific TPM will indicate if its program is a wrap program and contain important disclosures about the program. Clients are encouraged to read those brochures and follow up with their Financial Advisor if they have any questions. Summit and SEI have entered into an arrangement where SEI will compensate Summit for providing administrative and marketing services on behalf of SEI. The compensation for these services are paid based on the fees SEI collects from Summit clients as of October 2023. This arrangement poses a conflict of interest since the more assets Summit places with SEI, the more compensation Summit receives, thus providing Summit with incentive to recommend SEI to its clients. If you have any questions related to this arrangement or would like to understand how this affects you, please contact your Financial Advisor. Certain TPM accounts are part of Summit's Wrap Fee Program. Please see Summit's Wrap Fee Program Brochure for information about TPM accounts that are wrap, including the nature of the advisory services provided, fees and expenses, and discussion of relevant conflicts of interest. Client can reference their Advisory Program Schedule document, IMA or contact their Financial Advisor to determine if their TPM account is a Wrap or Non-Wrap account. 5. SEI Mutual Fund Portfolios The SEI Mutual Fund Portfolios program (which is separate and distinct from the SEI MAS program) enables Financial Advisors to design portfolios for Clients, taking into account the Client's financial circumstances, and uses actively managed SEI mutual fund asset allocation portfolios to help meet Client investment objectives. The Financial Advisor and Client decide whether to subject the accounts to automatic quarterly rebalancing so the allocation selected by the Client remains consistent over time. The Financial Advisor provides ongoing advice and monitoring and does not have discretion over the assets and must get approval from the Client before entering any trades (except for automatic rebalancing or Wealth Manager-Directed Discretionary, if selected). Given the long-term nature of most of the strategies, a SEI MF account may have little or no activity during a given period. Assets in the program are custodied at SEI, which is unaffiliated with Summit. As permitted by SEI, other assets may be held in the accounts, as well. As stated previously, SEI and Summit Financial have entered into an arrangement that poses a conflict of interest. Please see above for additional information. 6. Outside Investment Monitoring In some cases, Clients ask their Financial Advisors to oversee assets managed by other advisers, assets at brokers, or alternative investments such as hedge funds. Often, these are assets held in retirement plans. In these cases, the Financial Advisor provides ongoing consultative services which take into account the Client's financial circumstances. Services include periodic investment monitoring, reporting and/or servicing to the Client. In connection with this service, the Financial Advisors typically do not have the ability to direct the trades, which must occur through the broker of record. 7. Alternative Investments Held Directly ("AID") The AID Program enables your Financial Advisor to recommend Alternative Investments based on your needs and circumstances. These are held directly at the issuer, not at one of Summit's qualified custodians, but may be shown on your custodian statement. You must approve each recommended transaction. All assets are subject to regular and continuous supervision or management. Liquidity, custody and other features of Alternative Investment are detailed in the offering documents that you sign with the issuer, platform manager or other third party. Certain AID accounts are part of Summit's Wrap Fee Programs. Please see Summit's Wrap Brochure for information about AID accounts that are wrap, including the nature of the advisory services provided, fees and expenses, and discussion of relevant conflicts of interest. Client can reference their Advisory Program Schedule document, IMA or contact their Financial Advisor to determine if their AID account is a Wrap or Non-Wrap account. 8. Retirement Plan Advisory Services Summit provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a "Plan") and the company (the "Plan Sponsor"). The Advisor's retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. In addition, Plan Sponsors may engage Summit to serve as a 3(38) Fiduciary to their plan and assume investment discretion over the Plan. In such instances, the Plan Sponsor shall authorize this discretion to select and implement the Plan investment options. Summit may provide the following retirement plan advisory services:  Vendor Analysis  Employee Enrollment and Education Tracking  Investment Policy Statement ("IPS") Support  Investment Management  Performance Reports  Ongoing Investment Recommendation and Assistance  ERISA 404(c) Assistance  Benchmarking Services Summit may provide investment advisory services on behalf of the Plan and Plan Sponsor, which may be in either a 3(21) or 3(38) context depending on whether or not it is also providing discretionary investment management over the Plan assets. For 3(38) services, Summit shall have the discretion to select the investments for the Plan and/or make investment decisions on behalf of Plan Participants. In addition, We use Pontera Solutions, LLC, a third-party platform, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to have direct access to Client accounts without Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, your Wealth Manager will review the current account allocations. When deemed necessary, Your Wealth Manager will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to coordinate investment allocation with the client's overall portfolio objectives utilizing investment choices available within the Client's benefit plan. Client account(s) will be reviewed at least annually and allocation changes will be made as deemed necessary. 9. Financial Planning Financial planning is designed seeking to meet the Client's financial goals, needs and objectives. The scope of the financial plan varies depending on the Client and typically involves some combination of a review of the Client's current financial situation, including estate planning, insurance planning, education planning, retirement planning, business succession planning and portfolio analysis. Summit does not typically advise on business value analysis, and/or business liquidations, or property and casualty insurance, but these components can be referred out to third parties. The financial planning team includes income tax and estate specialists, insurance specialists and/or members of the IMC. Although some members of the Summit financial planning team are admitted attorneys and/or CPAs, they act in a non-representative capacity. Neither they, nor any Summit entity, provides tax, accounting or legal advice to Clients. Clients should make all decisions regarding the tax and legal implications of their investments and plans with their independent tax or legal advisors. Following delivery of the financial planning services, which may or may not include a written financial plan, the investment advisory relationship terminates for Clients who have engaged Summit as investment adviser for the limited purpose of providing financial planning services. Clients are free to implement none, some or all of the recommendations and may do so through Summit and its affiliates or through other providers of such services. Charges may be lower or higher if the plans are implemented away from Summit and its affiliates. If additional services are selected by the Client, they will be covered under separate agreement(s). Financial planning services will include various recommendations and planning strategies, depending on the nature of the financial planning services selected. These may include recommendations to allocate your assets among generic product or account types or they may include more specific recommendations. Implementation of financial planning recommendations is your responsibility. The actions necessary to implement a financial planning recommendation and the costs of doing so are not included in the financial planning fee. As noted above, most Financial Advisors are also RRs of PKS, a broker-dealer that is not affiliated with Summit and are also insurance agents of SRM. In the Financial Advisor's capacity as an RR and/or an insurance agent, he or she is authorized to provide securities brokerage services and/or sell insurance. In those capacities, and separate from the financial planning services, the Financial Advisor may help you implement one or more financial planning recommendations included with the financial planning services. If you accept the Financial Advisor's offer to assist with implementation of the financial plan, the Financial Advisor may make additional recommendations to invest in specific products or accounts or to purchase additional investment advisory services, but any such recommendations will be limited to those products, accounts and services that the Financial Advisor is authorized to offer. You are under no obligation to engage the Financial Advisor to implement the financial plan, or to purchase any investment or insurance product or obtain an advisory service from the Financial Advisor to implement the recommendations made in your financial plan. In circumstances where the Financial Advisor recommends specific investments and/or otherwise is involved in implementing the plan, the opportunity for the Financial Advisor and Summit, SRM or LS Securities to receive additional compensation as a result of such recommendations creates a conflict between your interests and those of the Financial Advisor and Summit. In addition, if you separately purchase a product or service recommended by the Financial Advisor to implement a financial planning recommendation, you generally will be charged commissions or fees in connection with those transactions and services that are separate from and in addition to the fees charged by Summit for financial planning services. The obligations of SRM when it is acting as an insurance agency, as well as the obligations of PKS when it is acting as a broker-dealer, differ from Summit's obligations to you when Summit is acting as an investment adviser. Similarly, your Financial Advisor's obligations when acting as an insurance agent for you or providing securities brokerage services to you differ from his/her obligations to you when acting as a Financial Advisor. Client or Summit may terminate an advisory program at any time by providing notice of such election to the other party. Refunds for financial plans are addressed in Item 5, below. In addition to these core investment advisory services and platforms (i.e., Managed Portfolios, SAA, APM, FMA, TPMs, SEI MF, Outside Investment Monitoring accounts and Financial Planning), Clients and Financial Advisors may negotiate other types of services for a retainer, flat fee or otherwise. These arrangements will be documented separately with the Client, the Financial Advisor and Summit. All investments have risk and there is no guarantee that utilizing the financial planning, asset management and/or advisory consulting services of Summit or its Financial Advisors will produce favorable results. 10. Variable Annuity Contracts Summit offers Client's access to variable annuity products. Variable annuity contracts facilitate long-term investment on a tax-deferred basis. A variety of investments options with different objectives, strategies and expenses are generally available. Add on features with a death benefit or living benefit may also be available, sometimes for an additional cost. Any obligations of the contract are subject to the claims-paying ability of the issuing insurance company. Contract values may be invested in the fixed account of the issuing insurance company or in sub-account investment funds. Investment funds may be affiliated funds or managed by third-party sub-advisors. The issuing insurance company is responsible for selecting the available investment funds which may include asset allocation fund of funds that are diversified across multiple asset classes and underlying funds. Clients should discuss fees related to Variable Annuity products with their Financial Advisor to see if there are alternative channels that would have lower fees. Other Aspects of Asset Management In its provision of investment advice and asset management, Summit utilizes various types of investments including but not limited to mutual funds, ETFs, equities, UITs, fixed income, hedge funds, traded and non-traded REITs, and insurance products such as variable life insurance and variable annuities. Summit offers the same suite of services to all of its Clients. However, each Financial Advisor determines, based on his or her own analysis, management style and preferences, in conjunction with each Client's specific profile and financial circumstances, which services and products to recommend and whether to recommend Summit's wrap fee programs or Summit's non-wrap advisory programs. Clients may impose reasonable restrictions on Summit regarding investing in certain securities or types of securities in accordance with their values or beliefs (or based on their employer or regulatory restrictions). However, if the restrictions prevent Summit or the TPM, as applicable, from properly servicing the Client account, or if the restrictions would require Summit to deviate from its standard platform of services, Summit reserves the right to end the relationship. Summit's IMC and its Financial Advisors participate in wrap fee programs by providing portfolio management services. The asset management services of the IMC do not differ depending on whether it is managing a wrap fee account as opposed to another account (e.g., an account participating in the TDS Managed Portfolio). Financial Advisors provide portfolio management services in connection with SEI MAS program accounts and some non-wrap accounts (i.e., SAAs, APMs and FMAs that are not custodied at NFS or one of the Additional Qualified Custodians and SEI MF programs). For their services in connection with any wrap fee programs, Summit and the Financial Advisors receive a portion of the wrap fees paid by accounts participating in such programs. As noted above, Financial Advisors act as portfolio managers in connection with the SAA, FMA and APM programs that may or may not be custodied at NFS or one of the Additional Qualified Custodians. Certain conflicts arise in connection with these related persons acting as portfolio managers in these programs. In particular, the advisory fee paid by Clients differs depending on the specific service they select and often varies from Client to Client. Clients should be aware that Financial Advisors, therefore, have an incentive to recommend the programs or services in which they receive more of the advisory fee. Summit is aware of the conflicts of interest created by the variability in advisory fee compensation and has adopted practices to supervise recommendations of programs and services. Financial Advisors acting as portfolio managers in connection with the SAA, FMA and APM programs have to conduct their own due diligence of securities and allocations they recommend and select under these programs, while they do not have to conduct the same degree securities-level due diligence in connection with the other programs. Because the SAA, FMA and APM programs involve this additional effort by Financial Advisors, Financial Advisors may be disincentivized from recommending these programs to Clients. Summit is aware of the conflicts of interest created by variability of the role the Financial Advisor plays in connection with the different programs and has adopted practices to supervise program recommendations. In certain limited instances, the client will be given authorization to trade securities in their own account. If there is little or no trading activity in the account, a Client may pay more in advisory fees than commission charges if the assets were in a non-managed program. Assets Under Management As of December 31, 2023, Summit provided advisory services to Clients with respect to $8,015,765,521 of their assets, approximately $3,269,287,418 of which is on a discretionary basis. (Note that Summit does have limited discretion with respect to the remaining assets to sell securities if there is insufficient cash in an account to pay the fees.) This includes assets for which regular and continuous supervision and management are provided as well as assets for which other consultative services, including periodic monitoring, managing, supervising, reporting and/or servicing.