A. First Nebraska Advisory LLC (“Adviser”) is an investment adviser founded in September 2018, registered with the Securities and Exchange Commission (“SEC”), and is principally owned by JW “John” Smith and Darrel Smith.
B. Adviser offers the following types of advisory services: i.Investment Management: Adviser provides ongoing non-discretionary investment management services to its clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s). Adviser generally recommends that clients fulfill their investment objectives by allocating their assets across a diversified risk-based portfolio of mutual funds. This portfolio is rebalanced periodically to remain in-line with the client’s agreed-upon asset allocation, though the asset allocation may be changed from time to time based on changes to a client’s specific situation. Adviser typically provides investment advice with respect to limited types of investments, which generally include mutual funds.
For most clients, Adviser recommends the retention of an independent and unaffiliated third-party investment adviser to provide advisory and administrative services: Buckingham Wealth Partners LLC (“Buckingham”). Buckingham is a turnkey asset management provider, and is compensated directly by clients for the services it provides, including model portfolio construction, transaction processing, custodial engagement, back-office support, quarterly reporting, fee-debiting, and educational conference hosting.
Both Adviser and Buckingham share responsibility for managing and administering client accounts; however, Adviser remains responsible for overseeing, managing, and directing the ultimate investment recommendations with respect to client portfolios. Furthermore, Adviser evaluates alternative turnkey asset management providers on an ongoing basis for the purpose of comparing such providers to Buckingham and assessing whether they would be better suited for the management and administration of client accounts. It is Adviser’s goal to only make turnkey asset management provider recommendations that are in the best interests of clients, and that meet or exceed Adviser’s requirements in terms of management style, cost, responsiveness, and general professionalism and experience in the industry.
ii.Financial Planning: As part of its Investment Management services, Adviser also provides financial planning advice to clients related to topics such as retirement plan investment selection, lifetime income analysis, education funding, retirement income diversification, market volatility defense mechanisms, and estate planning. Such services are representative of common financial planning matters discussed and analyzed, but the specific financial planning topics are customized for and dependent on the needs of the particular client. Clients do not pay separate fees for Financial Planning services, as they are simply included as part of Adviser’s ongoing Investment Management services.
iii.ERISA Plan Advisory Services: Specifically with respect to clients that are defined benefit or defined contribution plans under the Employee Retirement Income Security Act of 1974 (“ERISA”), Adviser provides certain fiduciary services to such plans pursuant to Section 3(21)(A)(ii) of ERISA. These fiduciary services can include, for example, non-discretionary investment advice with respect to the selection of available

plan investment options pursuant to the plan’s investment policies and objectives; non-discretionary investment advice with respect to asset classes, diversification, and investment alternatives available to the plan; development of an investment policy statement consistent with the plan’s investment policies and objectives; assistance with the selection of designated investment alternatives offered to the participants of the plan; assistance with the selection of the plan’s qualified default investment alternative; and periodic monitoring with respect to the services described above. To the extent requested by a particular plan, Adviser will also provide certain non-fiduciary services such as assistance with the selection of applicable independent third-party services providers (such as third-party administrators or recordkeepers, e.g.) and participant education with respect to general investment concepts and the investment options available within the plan (but not any specifically-tailored participant investment recommendations or advice).
The specific fiduciary and non-fiduciary services will be described in the plan advisory agreement signed between Adviser and the responsible plan fiduciary on behalf of the plan.
C. Adviser tailors its advisory services to the individual needs of its clients by taking the time to understand clients’ current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s). This information will then be used to make investment recommendations that reflect clients’ individual needs and objectives on an initial and ongoing basis. Adviser’s recommendations will allocate portions of clients’ account(s) to various asset classes classified according to historical and projected risks and rates of return. Adviser will review all such recommendations with clients, and clients will have the opportunity to accept or reject any recommendations. Clients are under no obligation to accept or implement any recommendation made by Adviser. Clients may impose restrictions on investing in certain securities or types of securities so long as such restrictions may reasonably be implemented by Adviser.
D. Adviser does not participate in any wrap fee programs.
E. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), 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 to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: i.Meet a professional standard of care when making investment recommendations (give prudent advice); ii.Never put our financial interests ahead of yours when making recommendations (give loyal advice); iii.Avoid misleading statements about conflicts of interest, fees, and investments; iv.Follow policies and procedures designed to ensure that we give advice that is in your best interest; v.Charge no more than is reasonable for our services; and vi.Give you basic information about conflicts of interest.
F. As of December 31, 2023, Adviser manages $357,535,542 of non-discretionary client assets and $0 discretionary client assets.