FSAM LLC (“FSAM”) was established as a Registered Investment Adviser since 2017. FSAM is owned by Heath Hawk, Vasileios Sfyris and Benjamin Eiler. FSAM provides investment advisory services and utilizes the different advisory programs offered through Pershing LLC (“Pershing” or the “Custodian”) and AssetMark, Inc. (“AssetMark”). FSAM is responsible for all advice and suitability of such advice regarding these accounts. A full description of all services is provided in the account services agreement. FSAM provides discretionary and non-discretionary account management in which the client is provided with on-going investment advice and monitoring with respect to their security holdings and will manage the account according to the client’s objectives. FSAM does not offer a wrap fee program. FSAM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients could incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to FSAM’s fee, and FSAM shall not receive any portion of these commissions, fees, and costs. FSAM provides advisory services, giving continuous advice based on the client’s individual needs. Through personal discussions in which goals and objectives based upon the client’s personal objectives are established, the FSAM will develop a personal investment policy based upon an investment objective questionnaire and manage the portfolio according to the criteria. Each client has the ability to impose reasonable restrictions on the management of his/her account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should be sold if held in the account. If a client’s instructions are unreasonable or an Investment Advisor Representative believes that the instructions are inappropriate for the client, FSAM will notify the client that, unless the instructions are modified, it will cancel the instructions in the client’s account. A client will not be able to provide instructions that prohibit or restrict the Investment Adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund. ERISA and Individual Retirement Accounts Disclosure 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 and/or the Internal Revenue 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 interests ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice).
• Never put 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 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. AssetMark GuidePath Accounts FSAM offers this advisory program to customers who wish to have their assets managed by an institutional money manager. This program is offered through AssetMark by using their GuidePath Funds.

This program offers different funds for each of the asset allocation models that cover capital appreciate and income strategies. The Investment Advisor makes the asset allocation decisions using a variety of factors to determine which allocation is the best fit for the customer. Advisory Managed Account Solutions - Pershing Account FSAM provides advisory services, giving continuous advice based on the client’s individual needs. Through personal discussions in which goals and objectives based upon the client’s personal objectives are established, the Advisor will develop a personal investment policy, which will include recommended model allocations, based upon an investment objective questionnaire and manage the portfolio according to the criteria. Most accounts are managed on a non-discretionary basis, meaning that the advisor does not have discretion over what securities to buy and sell. However, clients may elect to have their account managed on a discretionary basis, meaning that the client does not have to consent to each trade in the account. This trading discretion and any limitations on it will be set forth in the client agreement. The services provided are the same regardless of the account structure selected. Depending on the client’s investment objectives, the advisor may manage and provide advice on mutual funds, stocks, bonds, exchange traded funds (ETFs), LPs, and options. Alternative investments may be recommended to qualified investors based on the client’s objectives and risk tolerance. Alternative investments could include real estate, Private Equity, Hedge Funds, Commodities, etc. Alternative Investments can provide diversification benefits to traditional portfolios of stocks and bonds. Termination of Advisory Account Upon notification of the death of a client, FSAM will cease advisory services. No additional trading or liquidations will occur, and the account will be frozen until the necessary documents are provided to transfer the account to the individual’s estate, joint owner, or beneficiary, as applicable based on the account type and instructions set up by the client. In addition, all POAs will be cancelled. Any prepaid, asset-based fees will be prorated to the date FSAM was notified and rebated to the client. Upon written receipt of notice to terminate its client agreement for any reason, and unless specific transfer instructions are received, FSAM and its agent will cease advisory services. Should the client provide specific instructions to liquidate, FSAM will proceed with liquidation of the client’s account in an orderly and efficient manner. There will not be a charge by us for such redemption; however, the client should be aware that certain mutual funds impose redemption fees as stated in each company’s fund prospectus in certain circumstances. Clients must keep in mind that the decision to liquidate security issues or mutual funds may result in tax consequences that should be discussed with the client’s tax advisor. Factors that could affect the orderly and efficient manner would be size and types of issues, liquidity of the markets, and market makers’ abilities. Should the necessary securities’ markets be unavailable, and trading suspended, efforts to trade will be done as soon as possible following their reopening. Due to the administrative processing time needed to terminate client’s investment advisory service and communicate the instructions to client’s Investment Advisor, termination orders received from clients are not market orders; it may take several business days under normal market conditions to process the client’s request. During this time, the client’s account is subject to market risk. FSAM and its agent are not responsible for market fluctuations of the client’s account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. As of March 21,2023, FSAM, had $19,688,410 in discretionary assets under management and $52,862,724 in non-discretionary assets under management.