Firm Description Lombard Advisers Incorporated (“Lombard Advisers”) was established in 1991 as a wholly owned subsidiary of Lombard Securities Incorporated, a Maryland corporation founded in June 1990. Lombard Advisers is a Securities and Exchange Commission (“SEC”) Registered Investment Advisor and provides personalized investment management to individuals, pension and profit- sharing plans, trusts, estates, charitable organizations, and small businesses. Advice is provided through consultation with the client and includes general portfolio management, growth and/or income investing, education funding, and retirement planning. Principal Owners Lombard Securities Incorporated is a 100% stockholder of Lombard Advisers Incorporated. Types of Advisory Services Lombard Advisers provides for the following types of investment management services: a) Investment Adviser Representative (IAR) Directed Discretionary Investment Management – A Lombard Advisers sponsored program in which the firm and IAR fully manage and direct the assets in the client’s platform account with discretion, that is without prior consent of the client. Discretionary authority is limited to prudently buying and selling securities with the amount of capital in the platform account. Margin trading is not permitted in discretionary accounts. The firm’s discretionary authority rests with the advisory agreement which, for a discretionary account contains a limited power of attorney. b) Client Directed Portfolio Management (non-discretionary) – A Lombard Advisers sponsored program in which the firm and IAR assist the client in managing and directing the assets in the client’s platform account in which the ultimate decision on how to direct the account including all purchases and sales of securities rests with the client. c) Held Away Asset Management – A program by which the firm and IAR utilize an unaffiliated third-party order management system to facilitate management of certain held away assets, such as defined contribution plan accounts, with discretion. Discretionary authority is limited to the review of available investment options, allocation of investments, and rebalancing when deemed appropriate. The firm’s discretionary authority rests with the advisory agreement which, for a discretionary account contains a limited power of attorney. d) Wrap Programs offered through Wells Fargo Clearing Services, LLC (WFCS, LLC) - Lombard Advisers has entered into an agreement through our clearing firm, First Clearing, pursuant to which WFCS, LLC provides advisory platform services with respect to certain unaffiliated wrap fee programs and for execution, clearance, settlement, and custody of client assets. Lombard Advisers will provide the client with the applicable WFCS, LLC Wrap Fee Brochure and Client Relationship Summary (Form CRS). The client may also receive a Firm Brochure, Form CRS, or other disclosure documents directly from WFCS, LLC or third- party managers utilized on the WFCS, LLC Platform. The agreement between our firm and WFCS, LLC offers, among other things, the following programs:
• Client Directed Programs: o The Asset Advisor Program - Asset Advisor is a non-discretionary, Client directed investment Program in which the IAR provides investment recommendations based on client investment objectives, financial circumstances, and risk tolerance. Clients have the option of accepting these recommendations or selecting different investments for the account. o The Custom Choice Program – a non-discretionary mutual fund wrap program which allows for the allocation of assets among open-end mutual funds. Based on client investment objectives and risk tolerance, the IAR will recommend an appropriate mix of open-end mutual funds and money market funds and target allocation percentages. The client has the option of accepting the recommendations or selecting an alternative combination of funds. The IAR will implement the client investment decisions, but will not have investment discretion over the account, except for the limited discretion to rebalance the target asset allocation, with client authorization. In a taxable Account, the client is advised that decisions relating to investments in mutual funds will have tax consequences that should be discussed with a tax advisor.
• Separately Managed Programs: o Personalized Unified Managed Account – The IAR assists the client selecting among various investment options available within the Program, which includes investments in affiliated and unaffiliated Managers of WFCS, LLC, mutual funds, ETFs, and advisory annuities, each known as a “strategy”. The Program offers three investment strategy types:  Single Strategy, in which one strategy of a certain affiliated or unaffiliated Manager per account is selected.  Multi Strategy Optimal Blends, in which target allocations comprised of strategies of certain Managers, mutual funds and/or ETFs designed for Clients with various investment objectives are selected. These Optimal Blends are based upon Manager, mutual fund and ETF due diligence provided by WFCS, LLC affiliate, Wells Fargo Investment Institute (WFII).  Multi Strategy Custom Blends, custom target allocations consisting of multiple strategies of Managers, mutual funds, ETFs and/or advisory annuities in one account are created. o FundSource® - A discretionary investment advisory Program that offers a broad array of mutual funds that invest in and across different investment asset classes and employ varied approaches to investment management. The program offers a number of "Optimal Blends" that offer managed portfolios of recommended funds, based on due diligence and asset allocation guidance provided by WFCS, LLC affiliate, WFII, and market exposures and fund combinations that they believe are appropriate for a number of different investment objectives. Based on client investment objectives, financial circumstances, and risk tolerance, the IAR will recommend either an Optimal Blend or a Customized Blend, where the client selects a target allocation in consultation with the IAR. Once the client chooses an Optimal or Customized Blend, the assets in the account will be invested by the IAR on a discretionary basis. o Private Advisor Network – IAR assists the client in identifying a Manager to advise and counsel client with respect to the investment of assets.

The intent of the Program is to offer a roster of Managers representing a broad array of investment classes and styles from which the client selects a Private Advisor Network Manager to handle the day-to-day management of the Account(s). Private Advisor Network services typically include matching the personal and financial data provided by the client with a database of Managers and providing reports to allow for periodic evaluation and comparison of account performance with objectives. Private Advisor Network Managers classified as "Cleared" in the WFCS, LLC Program have provided sufficient information to their affiliate, WFII, for review and have passed their screening qualifications on an ongoing basis. Some of the factors that are considered for clearing a manager include track record, number of investment professionals, assets under management, and legal and disciplinary history. Those Private Advisor Network Managers not classified as "Cleared" have not met all or some of the screening qualifications, but certain Clients have specifically requested their inclusion. Generally, in these cases, Clients have a pre- existing relationship with the Manager that they'd like to continue. If such a request is accommodated, these Managers are not included in the Manager identification or in the ongoing review processes described above. Under the Private Advisor Network Program, the client grants the Manager complete discretionary trading authority and authorizes the Manager to handle the day-to-day investment management of the account in accordance with the separate management agreement between the client and the Manager. o Customized Portfolios - Under the Customized Portfolios Program, the IAR assists the client in selecting from portfolios based on the investment strategies of WFCS, LLC affiliate, WFII. These include Fixed Income Portfolios, Custom Option strategy, and Option Premium Income strategy Portfolios. Tailored Relationships The goals and objectives for each client are documented on Lombard Securities’ client profile. Portfolio management should reflect the stated goals and objectives for each client. Clients may impose restrictions on investing in certain securities or types of securities. Types of Agreements For Lombard Advisers sponsored programs with respect to platform accounts, one standard Investment Advisory Agreement is utilized which covers both discretionary and non- discretionary investment management services. Lombard Advisers utilizes a separate agreement that is specific to the management of held away assets on a discretionary basis. Wrap Programs offered through WFCS, LLC utilize Client Agreements specific to the applicable program. With respect to the Private Advisor Network program, the client enters into a separate management agreement with the selected Program Manager. Lombard Advisers will provide the client with the applicable WFCS, LLC Wrap Fee Brochure and Form CRS. The client may also receive a Firm Brochure, Form CRS, or other disclosure documents directly from WFCS, LLC or third-party managers utilized on the WFCS, LLC Platform. These documents should be carefully reviewed in order to understand WFCS, LLC program features, fees, and other important information. Advisory Service Agreement Although Advisory Agreements are ongoing agreements and adjustments are sometimes required, the length of service to the client is at the client’s discretion. The client or Lombard Advisers may terminate an Agreement by written notice to the other party. At termination of an agreement related to a platform account, fees will be billed on a pro-rata basis for the portion of the quarter completed. The net portfolio value at the completion of the prior full billing quarter is used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination. For held away asset management accounts, the pro-rata fee billed at termination is determined pursuant to the fee negotiated between the IAR and the client at the inception of the arrangement. Asset Management Platform Accounts (held through the clearing firm) Assets may be invested in no-load mutual funds, exchange-traded funds, equities, corporate bonds, municipal securities, U. S. government securities, covered call option contracts, FDIC insured CDs and bank deposits and certain other investments approved by Lombard Advisers. At present, Lombard Advisers’ clients must have a designated advisory account set up at the firm’s parent, Lombard Securities, and all brokerage transactions and reporting are handled by Lombard Securities’ correspondent clearing firm, First Clearing. No commissions are charged to the client with regards to purchases or sales of securities in an advisory account. There may be other brokerage-related fees charged to your account. (Please see the “Other Fees” section below). Held Away Asset Management Investment options, in most cases open end mutual funds, are determined by the Client’s plan sponsor. At the inception of the arrangement, a link is provided to the Client allowing them to connect an account(s) to the third-party order management system. Once the Client account(s) is connected to the system, the IAR will review the current investment options, account allocation, and when deemed necessary, the IAR will rebalance the account considering client investment goals and risk tolerance. Termination of Agreement A Client may terminate the aforementioned advisory agreement within 5 days of signing, without penalty. Thereafter, the Client may terminate at any time by notifying Lombard Advisers in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client has made any advance payment, Lombard Advisers will refund any unearned portion of the advance payment. Lombard Advisers may also terminate the aforementioned advisory agreement at any time by notifying the client in writing. Please review the applicable WFCS, LLC Wrap Fee Brochure(s) for information related to the termination of the advisory agreement specific to programs offered through the WFCS, LLC platform. Assets under Management Total Assets under management $366,417,835 (calculated as of 12/31/2023) Discretionary $167,509,847 Non-Discretionary: $198,907,988 Form ADV, Part 2A, Item 5