Description of Services Sigma Planning Corporation (“SPC”) is registered with the United States Securities and Exchange Commission (the “SEC”) as an investment adviser. SPC is a corporation formed under Michigan law in 1983. SPC is also under common ownership and control with Sigma Financial Corporation (“SFC”) and Parkland Securities, LLC (“Parkland”). SFC and Parkland are independent broker-dealer firms that are each members of the Financial Industry Regulatory Authority, Inc. (“FINRA”) as well as the Securities Investor Protection Corporation (“SIPC”). Moreover, SFC and Parkland are both registered as insurance agencies with various state insurance regulators. The Jerome S. Rydell Revocable Living Trust dated 12/21/1998, as amended and restated on 10/23/2020 (the “Trust”), owns all controlling (i.e., voting) equity interests in SPC, SFC, and Parkland. Jerome S. Rydell is the trustee of the Trust as well as the Chief Executive Officer of SPC, SFC, and Parkland. As used in this brochure, SPC’s “associated persons” are SPC’s officers, employees, and all individuals providing investment advice on behalf of SPC (“Associated Persons”). Additionally, Associated Persons who provide investment advice or services to SPC’s clients are referred to as “investment adviser representatives” (“IARs”) throughout this brochure. Finally, as used in this brochure, the words “we,” “our,” “our firm,” and “us” refer to SPC and/or its IAR who is assisting you, as the context requires, and the words “you,” “your,” and “client” refer to you, as the context requires, as either a client or prospective client of SPC. In the case of retirement plans, “you,” “your,” and “client” (and related terms) refer to the retirement plan, the sponsor of such plan and/or the named fiduciary of such plan, as the context or situation requires. With a commitment to personal service, SPC partners with IARs looking to grow their practices in a professional and ethical manner. We provide investment management, financial planning and consulting services, and other services which allow our IARs to manage the assets of Middle American investors. Most but not all of our IARs are registered representatives of SFC or Parkland, which are affiliated broker-dealers. Those IARs who are also registered representatives can offer securities and brokerage services in their capacities as registered representatives of SFC or Parkland. All of our IARs provide investment advisory services in their capacities as IARs of SPC. In the event your IAR deals with you in his or her brokerage capacity, he/she will notify you orally or in writing at or before the time he/she does so. As a result, when creating financial plans or providing portfolio management services, these IARs will be limited to the securities and insurance products approved by SFC and Parkland. The following pages describe our services. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. In certain cases, we may provide clients with a complimentary general consultation to discuss available services, to give a potential client time to review desired services, and to determine the possibility of a client-adviser relationship. Portfolio Management Services We provide portfolio management services through the SIGMA Managed Account. The SIGMA Managed Account is ordinarily a discretionary account by default, however clients can elect a non-discretionary arrangement upon written request. The SIGMA Managed Account is tailored to meet your needs and investment objectives. The custodian and clearing firm for assets held in SIGMA Managed Accounts is National Financial Services LLC (“NFS”), and the introducing broker is Fidelity Brokerage Services LLC (“FBS,” and together with NFS and their affiliates, “Fidelity”). Through this arrangement, Fidelity provides SPC and its IARs with custodial services as well as other services and benefits in order to help us conduct our business and serve many types of clients. SPC does not have custody of client funds or securities, except to the limited extent that SPC can automatically deduct its advisory fees from client accounts. SPC also possesses the ability to effect certain bank wire transfers to a client’s same-registration account outside Fidelity upon receipt of direct written instructions from the client. SPC is independently owned and operated and is not affiliated with Fidelity. NFS is also the custodian and clearing firm utilized by SFC and Parkland, our broker-dealer affiliates, and by SPC for its wrap fee program. If you retain SPC for portfolio management services, one of our IARs will meet with you to determine your financial situation, investment profile, investment objectives, risk tolerance, and other relevant information (collectively, your “suitability information”). This suitability information will serve as the basis for your IAR’s recommendations and assist us with ensuring that your assets are managed appropriately. We will use the suitability information we gather to develop a strategy that enables us to give you continuous and focused investment advice and to recommend or make investments on your behalf. Your IAR’s recommendations are based on your suitability information. You must promptly notify your IAR if your financial situation, goals, objectives, or needs change. Your IAR may tailor his or her services to focus only on certain portfolio components, depending upon your wishes and/or the nature of the engagement with your IAR. However, comprehensive investment needs and objectives may not be fully considered if you elect to receive limited services and/or provide us with limited information. In the case of a SIGMA Managed Account, your IAR will customize an investment portfolio for you in accordance with your suitability information. Once your IAR constructs an investment portfolio, your IAR will monitor your portfolio’s performance on an ongoing basis and will either rebalance or trade the portfolio (in discretionary accounts) or recommend new allocations (for nondiscretionary accounts) as required by changes in market conditions or your investment needs and objectives. It is important to understand that your portfolio allocation may cease to be suitable for you based on certain changes in your financial situation, investment objectives, risk tolerance, or investment time horizon. In the event of any such changes, you should promptly contact your IAR in order to discuss the continued suitability of your portfolio allocation. If you participate in our discretionary portfolio management program, we require you to grant SPC and your IAR discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities and the amount of securities to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted either by the client services agreement you sign with our firm or by trading authorization forms. You may limit our discretionary authority (e.g., by limiting the types of securities that can be purchased in your account) by providing our firm with your restrictions and guidelines in writing. However, such restrictions and guidelines may affect the composition and performance of your portfolio and/or our ability to meet your investment objectives. For nondiscretionary accounts, we will contact you to obtain consent prior to executing any transactions. Clients who wish to open a SIGMA Managed Account or a direct-at-fund program account (discussed below) will complete and sign a client services agreement with SPC. (While the same agreement is used for both types of accounts, the applicable terms differ with respect to each account type.) In the case of a SIGMA Managed Account, in the event your IAR dies, becomes permanently disabled, terminates his or her relationship with SPC, or provides you with written notice terminating your relationship, your client services agreement will continue in full force and effect as between you and us. In determining the disposition of your account, we will, in our sole discretion, elect to take one of the courses of action outlined in the client services agreement. Such courses of action include: (i) providing more limited on-demand nondiscretionary services for a significantly reduced annual asset-based fee of twenty (20) basis points (0.2%); (ii) reallocating your account among one or more model portfolios that we offer; (iii) reallocating your account based on the algorithmic recommendations of a robo- advisor to which we subscribe for advice; (iv) appointing a new IAR to manage your account, regardless of whether or not your IAR had a succession plan in place (SPC may also elect this option in the event your IAR sells his or her book of business to another IAR of SPC, regardless of whether or not your IAR terminates his or her relationship with SPC, in order to help facilitate the sale transaction); or (v) converting your account to a retail brokerage account with Fidelity. Alternatively, you can request termination of your agreement and/or that we assist you with transferring your account to another investment adviser or provide your name and contact information to one or more IARs within your geographic proximity in order to locate a new IAR to service your account. We are not presently in the process of developing the options described in clauses (i) through (iii) above and have not yet begun to utilize these options with clients. However, we have included these options in our client services agreement to reserve these options for future use. In the case of the option described above in clause (i), we anticipate that on-demand nondiscretionary services would consist of servicing the client’s SIGMA Managed Account and providing the client with recommended investment allocations at the client’s reasonable request and based upon the client’s documented investment objectives, risk tolerance, time horizon, goals, and investment guidelines and restrictions. Under this arrangement, the client would be responsible for proactively monitoring the performance of the investments in the client’s SIGMA Managed Account, contacting SPC to request recommended investment allocations, reviewing such recommendations prior to implementation, and conveying approval of such recommendations to SPC in order that SPC may place the necessary trades in the account, with the client being responsible for the cost of any ticket charges incurred in connection with any transactions. If and when we begin utilizing the options described in clauses (i) through (iii) with clients, we will update this brochure accordingly to describe the options in greater detail, including, but not limited to, the applicable policies, procedures, fees, and conflicts of interest associated with each option. Succession plans are discussed below in this brochure. The client services agreement may be canceled at any time, by any party thereto and for any reason, upon written notice to the other parties, as provided in such agreement. However, in the event that the total value of the holdings in a SIGMA Managed Account fails to exceed $100 for any reason, SPC reserves the right to cancel the client services agreement without notice by removing itself (and the IAR) from the account and converting the account to a retail brokerage account with Fidelity. For the calendar month in which the client services agreement is terminated, our fee will be prorated and refunded based on the number of days that the client services agreement was in effect during such month. Charitable Investment Advisor Program Account holders with more than $250,000 in a donor-advised fund at Fidelity Charitable are eligible to nominate their IAR to manage some of the account assets for Fidelity Charitable. SPC permits IARs to provide such account management services, however the investment options are generally conservative or moderate in nature. IARs who manage these accounts are required to adhere to the terms and conditions set forth in Fidelity’s Charitable Investment Advisor Program: Investment Policies and Guidelines as well as the Fidelity Charitable Policy Guidelines: Program Circular. For more information, please contact the SPC Department or visit www.FidelityCharitable.org. Direct-at-Fund Programs SPC offers limited direct-at-fund programs for clients who are primarily or solely interested in the funds of a particular mutual fund company. A direct-at-fund program is a fee-based discretionary account held with a single mutual fund company that provides clients with access to mutual fund shares that do not impose charges or fees (e.g., sales loads, surrender charges, or 12b-1 fees) beyond the expenses associated with managing and administering the fund. If you retain SPC for portfolio management services through a direct-at-fund program, one of our IARs will meet with you to determine your suitability information. Based upon your suitability information, the IAR who services your direct-at-fund account will utilize an investment management methodology to construct and actively manage a portfolio consisting entirely of mutual fund shares made available by the mutual fund company sponsoring the direct-at-fund program. Once your IAR constructs an investment portfolio for you, your IAR will monitor your portfolio’s performance on an ongoing basis and will rebalance or trade the portfolio as required by changes in market conditions or your investment needs and objectives. Direct-at-fund programs are designed for managing client portfolios and accounts on a discretionary basis using the funds of a single mutual fund company. If you participate in a direct-at-fund program, we require you to grant SPC and your IAR discretionary authority to manage your direct-at-fund account. Discretionary authorization will allow us to determine the specific mutual funds to be purchased or sold in your account without your approval prior to each transaction. Discretionary authority is typically granted in both the client services agreement that you sign with SPC as well as the mutual fund company’s account application and/or account conversion form. You may limit our discretionary authority (e.g., by limiting the types of mutual funds that can be purchased in your account) by providing SPC with your restrictions and guidelines in writing. Such restrictions and guidelines may affect the composition and performance of your portfolio and/or our ability to meet your investment objectives. In the event your IAR dies, becomes permanently disabled, terminates his or her relationship with SPC, or provides you with written notice terminating your relationship, your client services agreement will continue in full force and effect as between you and us. In determining the disposition of your discretionary managed account, we will, in our sole discretion, elect to take one of the courses of action outlined in the client services agreement. Such courses of action include: (i) reallocating your account among one or more model portfolios that we offer, or (ii) appointing a new IAR to manage your account (SPC may also elect this option in the event your IAR sells his or her book of business to another IAR of SPC, regardless of whether or not your IAR terminates his or her relationship with SPC, in order to help facilitate the sale transaction). Alternatively, you can request termination of your agreement and/or that we assist you with transferring your account to another investment adviser or provide your name and contact information to one or more IARs within your geographic proximity in order to locate a new IAR to service your account. We are not presently in the process of developing the option described in (i) above and have not yet begun to utilize this option with clients. However, we have included this option in our client services agreement to reserve this option for future use. If and when we begin utilizing this option with clients, we will update this brochure accordingly to describe the option in greater detail, including, but not limited to, the applicable policies, procedures, fees, and conflicts of interest associated therewith. The client services agreement may be canceled at any time, by any party thereto, for any reason, upon written notice to the other parties, as provided in such agreement. Mutual fund companies sponsoring direct-at-fund programs are free to choose the timing of when advisory fees for portfolio management services will be charged (e.g., quarterly or monthly) and whether such fees will be charged in arrears or in advance. If the client services agreement is terminated, no fee refund will be necessary for fees charged in arrears, whereas fees charged in advance will be refunded according to the fund platform’s stated policies. In either case, our fee will be prorated based on the number of days that the client services agreement was in effect during such billing period. Retirement Plans This section describes our services and fees for employer-sponsored retirement plans, particularly those covered by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). However, depending on the circumstances, we can also offer our services to retirement plans that are not covered by ERISA due to one or more federal exemptions. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to the individual needs of such retirement plans. In certain cases, we will provide clients with a complimentary general consultation to discuss available services, to give a potential client time to review desired services, and to determine the possibility of a client-adviser relationship. Types of Retirement Plan Services Offered We offer a variety of services to employer-sponsored retirement plans and their participants, including discretionary fiduciary services, nondiscretionary fiduciary services, and non-fiduciary retirement plan consulting services. Depending on the type of retirement plan and the specific arrangement with the plan’s sponsor, we will provide one or more of these services. The plan sponsor can engage our IARs to perform retirement plan services by completing the Qualified Plan Service Agreement (the “QPSA”). The QPSA outlines the terms and the nature of our relationship with the plan and the plan sponsor, including a description of the services to be provided and the fees to be charged. Moreover, the QPSA enables us to obtain important information about the plan, including the plan’s design, the plan’s objectives, investment risk tolerance information, plan participant demographics, and the plan’s third- party service providers. The responsible plan fiduciary must sign and submit the QPSA to SPC before any services are provided. Our retirement plan services are described below in greater detail. ERISA § 3(38) Discretionary Fiduciary Services These services are designed to allow the plan sponsor (or plan fiduciary) to delegate responsibility for managing, acquiring, and disposing of plan assets that meet the requirements of ERISA. We will perform these investment management services through our IARs and will charge a fee for the investment management services, as described in this brochure and the QPSA. We will perform these services for the plan as an investment manager under ERISA § 3(38) and will act with the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under similar circumstances. The plan sponsor (or plan fiduciary) can engage us to perform any of the following services by selecting the appropriate boxes in Appendix A of the QPSA: 1. Selection, Monitoring, and Replacement of the Plan’s Designated Investment Alternatives (“DIAs”) We will review the investment objectives, risk tolerance, and goals of the plan with the plan sponsor (or plan fiduciary). We will also provide the plan sponsor (or plan fiduciary) with an investment policy statement (“IPS”)—if it does not already have one—that contains criteria from which we will select, monitor, and replace the plan’s DIAs. We will review the investment options available to the plan and will select the plan’s DIAs in accordance with the criteria set forth in the IPS. On a periodic basis, we will monitor and evaluate the DIAs and replace any DIAs that no longer satisfy the IPS criteria. 2. Creation and Maintenance of Model Asset Allocation Portfolios (“Model Portfolios”) We will review the investment objectives, risk tolerance, and goals of the plan with the plan sponsor (or plan fiduciary). We will also provide the plan sponsor (or plan fiduciary) with an IPS (or other documentation)—if it does not already have one—that contains criteria from which we will select, monitor, and replace the plan’s Model Portfolios. We will create a series of risk-based Model Portfolios comprised solely of the plan’s DIAs and, on a periodic basis or upon reasonable request, we will reallocate and rebalance the Model Portfolios in accordance with the IPS or other guidelines approved by the plan sponsor (or plan fiduciary). 3. Selection, Monitoring, and Replacement of Qualified Default Investment Alternatives (“QDIAs”) We will review the investment objectives, risk tolerance, and goals of the plan with the plan sponsor (or plan fiduciary). We will also provide the plan sponsor (or plan fiduciary) with an IPS (or other guidelines)—if it does not already have one—which contains criteria from which we will select, monitor, and replace the plan’s QDIAs. Once the plan sponsor (or plan fiduciary) confirms the plan’s desired type of QDIAs, we will select, monitor, and replace the plan’s QDIAs in accordance with the IPS or other guidelines approved by the plan sponsor (or plan fiduciary). 4. Participant Investment Management We will meet with plan participants, periodically and upon reasonable request, to collect information necessary to complete an investor profile to identify the participant’s investment objectives, risk tolerance, time horizon, and other suitability information. Based upon each participant’s profile, we will invest the participant’s plan account among one or more of the plan’s DIAs or Model Portfolios, if applicable. We will have sole discretion over the investment of the participant’s account. ERISA § 3(21)(A) Nondiscretionary Fiduciary Services These services are designed to allow the plan sponsor (or plan fiduciary) to retain full discretionary authority and control over the plan’s assets. We will solely make recommendations to the plan sponsor (or plan fiduciary). We will perform these nondiscretionary investment advisory services through our IARs and will charge a fee for these fiduciary services, as described in this brochure and the QPSA. We will perform these investment advisory services for the plan as a fiduciary under ERISA § 3(21)(A) and will act with the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under similar circumstances. The plan sponsor (or plan fiduciary) can engage us to perform one or more of the following nondiscretionary investment advisory services by selecting the appropriate boxes in Appendix A of the QPSA: 1. Recommendations to Establish or Revise the Plan’s IPS We will review the investment objectives, risk tolerance, and goals of the plan with the plan sponsor (or plan fiduciary). If the plan does not have an IPS, we will recommend investment polices to assist the plan sponsor (or plan fiduciary) in establishing an appropriate IPS. If the plan has an existing IPS, we will review it for consistency with the plan’s objectives. If the IPS does not represent the objectives of the plan, we will recommend revisions to the plan sponsor (or plan fiduciary) that will establish investment policies which are congruent with the plan’s objectives. 2. Recommendations to Select and Monitor the DIAs Based on the plan’s IPS or other guidelines established by the plan, we will review the investment options available to the plan and will make recommendations to assist the plan sponsor (or plan fiduciary) in selecting the DIAs to be offered to plan participants. Once the plan sponsor (or plan fiduciary) selects the DIAs, we will provide reports, information, and recommendations, on a periodic basis or upon reasonable request, to assist the plan sponsor (or plan fiduciary) with monitoring the investments. If the IPS criteria require an investment to be removed, we will provide information, analysis, and recommendations, on a periodic basis or upon reasonable request, to assist the plan sponsor (or plan fiduciary) with evaluating replacement investment alternatives. 3. Recommendations to Select and Monitor QDIAs Based on the plan’s IPS or other guidelines established by the plan, we will review the investment options available to the plan and will make recommendations to assist the plan sponsor (or plan fiduciary) in selecting the plan’s QDIAs for plan participants who fail to direct the investment of their accounts. Once the plan sponsor (or plan fiduciary) selects the QDIAs, we will provide reports, information, and recommendations, on a periodic basis or upon reasonable request, to assist the plan sponsor (or plan fiduciary) with monitoring the investments. If the IPS criteria require an investment to be removed, we will provide information and analysis to assist the plan sponsor (or plan fiduciary) with evaluating replacement investment alternatives. 4. Recommendations to Allocate and Rebalance Model Portfolios Based on the plan’s IPS or other investment guidelines established by the plan, we will review the investment options available to the plan and will make recommendations to assist the plan sponsor (or plan fiduciary) in creating and maintaining Model Portfolios. Once the plan sponsor (or plan fiduciary) approves the Model Portfolios, we will provide reports, information, and recommendations, on a periodic basis, designed to assist the plan sponsor (or plan fiduciary) with monitoring the plan’s investments. If the IPS criteria require an investment to be removed, we will provide information and analysis to assist the plan sponsor (or plan fiduciary) with evaluating replacement investment alternatives to be included in the Model Portfolios. Upon reasonable request, we will make recommendations to the plan sponsor (or plan fiduciary) to rebalance the Model Portfolios to maintain their desired allocations. ERISA Non-fiduciary Retirement Plan Consulting Services We offer retirement plan consulting services designed to assist the plan sponsor (or plan fiduciary) in satisfying its fiduciary duties to administer the plan in the best interests of plan participants and their beneficiaries. Retirement plan consulting services are limited to non-fiduciary services under ERISA. The plan’s custodian, not SPC, will be responsible for arranging for the execution of securities transactions through a broker-dealer that it believes can provide best execution. We will not have any discretionary authority or discretionary responsibility over the administration of the plan, or any authority to interpret plan documents, approve the distributions to be made by the plan, or determine participant eligibility, benefits, or vesting. We will not perform record-keeping or brokerage services on behalf of the plan, nor will we assume the duties of a trustee or plan administrator (as defined in ERISA § 3(16)). The plan sponsor (or plan fiduciary) can elect for us to provide any of the following services: 1. Administrative Support Assisting the plan sponsor (or plan fiduciary) with:  Reviewing plan objectives and options available through the plan  Reviewing retirement plan committee structure and administrative policies and procedures  Recommending participant education and communication policies under ERISA § 404(c)  Coordinating and reconciling participant disclosures under 29 C.F.R. § 2550.404a-5  Developing requirements for responding to participant requests  Assisting with the development and maintenance of a fiduciary audit file and document retention policy  Delivering fiduciary training and/or education periodically or upon reasonable request 2. Service Provider Support Assisting the plan sponsor (or plan fiduciary) with:  Developing a process to select, monitor, and replace service providers  Reviewing covered service provider (“CSP”) disclosures under ERISA § 408(b)(2) and fee benchmarking  Providing reports and/or information designed to assist with monitoring CSPs  Reviewing ERISA spending accounts or plan expense recapture accounts (“PERAs”)  Preparing and reviewing requests for proposals (“RFPs”) and/or requests for information (“RFIs”)  Coordinating CSP replacements and conversions 3. Investment Monitoring Support Assisting the plan sponsor (or plan fiduciary) with:  Periodically reviewing the IPS in the context of plan objectives  Monitoring investment performance  Educating committee members, as needed, regarding replacement of DIAs and/or QDIAs  Assisting with monitoring designated investment managers (“DIMs”) and/or third-party advice providers, as necessary 4. Participant Services Assisting the plan sponsor (or plan fiduciary) with:  Facilitating group enrollment meetings  Coordinating employee education regarding plan investments and fees  Helping participants with financial wellness education, retirement planning, and/or gap analysis Direct-at-Fund Programs SPC also offers direct-at-fund programs to retirement plans that are primarily or solely interested in the funds of a particular mutual fund company. As explained above, a direct-at-fund program is a fee-based discretionary account held with a single mutual fund company that provides clients with access to mutual fund shares that do not impose additional charges or fees (e.g., sales loads, surrender charges, or 12b-1 fees). If SPC is retained for portfolio management services through a direct-at-fund program, SPC will perform these services for the retirement plan as an investment manager under ERISA § 3(38) and will act with the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under similar circumstances. Mutual fund companies sponsoring direct-at-fund programs are free to choose the timing of when advisory fees for portfolio management services will be charged (e.g., quarterly or monthly) and whether such fees will be charged in arrears or in advance. If the QPSA is terminated, no fee refund will be necessary for fees charged in arrears, whereas fees charged in advance will be refunded according to the fund platform’s stated policies. In either case, our fee will be prorated based on the number of days that the QPSA was in effect during such billing period. Non-ERISA Retirement Plans Depending on the circumstances, we can also provide any of the services described above to retirement plans that are not covered by ERISA. In providing services to such plans, we would act as a fiduciary under the Act, but not as a fiduciary under ERISA § 3(21)(A). Potential Additional Retirement Services Provided Outside of the QPSA In providing services to retirement plans, SPC and its IARs are also able to establish client relationships with one or more plan participants

or beneficiaries. Such client relationships develop in various ways, including, without limitation: (1) as a result of a decision by the participant or beneficiary to obtain advisory services from SPC not involving the use of plan assets; (2) as part of an individual or family financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relate exclusively to assets held outside of the plan; or (3) through an Individual Retirement Account rollover (“IRA Rollover”) from a retirement plan. IARs will not, however, solicit plan participants or beneficiaries when providing services to the retirement plan. If SPC is providing services to a retirement plan, the IAR working with the plan will, when requested by a plan participant or beneficiary, arrange to provide services to that participant or beneficiary through a separate agreement that excludes any investment advice on plan assets (but will consider the participant’s or beneficiary’s interest in the plan in providing that service). If a plan participant or beneficiary desires to complete an IRA Rollover, any decision regarding whether to complete the IRA Rollover or what to do with the IRA Rollover assets remains solely that of the participant or beneficiary. No Responsibility for Preparing ERISA Documents Neither SPC nor any of its IARs shall be responsible for drafting or preparing, on behalf of the plan or plan sponsor (or plan fiduciary), any mandatory reporting documents required under ERISA or other federal or state legislation, including, but not limited to, Form 5500, the lifetime income disclosure required by Section 203 of the SECURE Act, and the participant disclosure document required under 29 C.F.R. § 2550.404a-5. No Responsibility to Provide Fiduciary Education or Verification Neither SPC nor any of its IARs shall be responsible to the plan or plan sponsor (or plan fiduciary) for any of the following:  Providing recommendations to ensure, or help ensure, that the plan’s interested parties and/or fiduciaries are fulfilling their respective fiduciary responsibilities.  Verifying fees paid by the plan to a third party other than SPC.  Verifying that there is no difference in quarterly yield between a provider’s proprietary and non- proprietary funds due to the receipt of revenue reimbursement.  Verifying that a provider’s current annual administration fee does not contain a surcharge to make up for a revenue reimbursement amount. Potential Conflicts and Related Policies Associated persons and affiliates of SPC are permitted to provide other non-fiduciary retirement services to plans, such as record-keeping and third-party administrator (“TPA”) services, and receive variable compensation therefrom. This presents a conflict of interest, as any IAR who recommends such non-fiduciary retirement services will receive compensation in connection therewith. However, the plan sponsor (or plan fiduciary) is free to obtain such non-fiduciary retirement services from the service provider of its choosing and need not work with the IAR who made the recommendation. Recommendation of Third-Party Investment Advisers Your IAR may refer you to a third-party investment adviser (“TPIA”) for the professional management of your entire investment portfolio or a portion thereof. Factors that your IAR will take into consideration when making such a recommendation include, but are not limited to, the TPIA’s historical performance, manager tenure, strategy, methods of analysis, and fees, as well as your suitability information. Your IAR will periodically monitor the TPIA’s performance to ensure its management and investment style remain aligned with your investment goals and objectives. When recommending the services of a TPIA, your IAR will provide you with the TPIA’s disclosure brochure and compensation disclosure document. Certain TPIAs require minimum portfolio conditions as outlined in each TPIA’s disclosure brochure. You are never under any obligation to engage the services of a TPIA that your IAR recommends. SPC has direct relationships with various TPIAs. A “direct” relationship is one in which SPC has entered into a contractual agreement directly with the TPIA after performing appropriate due diligence on the TPIA. In some instances, SPC functions as a co-advisor under the terms of a written tri-party agreement between the client, SPC, and the TPIA, thereby providing contractual services to the client separate from the TPIA’s investment advisory services. As a result, clients will pay a management fee to the TPIA for its account management and investment advisory services, and pay a separate fee to SPC for the other client relationship services agreed upon between the client and IAR, including, but not limited to, meeting with the client at least annually (or more often upon request) to discuss and review the TPIA’s performance, being available during regular business hours to answer the client’s inquiries regarding the TPIA, and periodically monitoring the TPIA’s performance on an ongoing basis. At the TPIA’s instruction, SPC’s separate fee is collected from the client’s account by the account custodian, and thereafter SPC’s fee is remitted directly to SPC by the TPIA. However, in most cases, our agreements with TPIAs call for SPC to function as a promoter, within the meaning of Rule 206(4)-1 under the Act. As the TPIA’s promoter, SPC’s primary role is to introduce you to the TPIA, and thereafter SPC is contractually obligated to provide you with basic assistance with establishing an account with the TPIA; answering questions about the TPIA, on an ongoing basis; and performing other non-advisory services as outlined in SPC’s agreement with the TPIA. Under such an agreement, we receive referral fee compensation for introducing you to the TPIA. The amount and nature of this compensation is described in a disclosure document delivered to you before you engage the TPIA for advisory services. SPC mitigates TPIA conflicts of interest by reviewing each recommendation to open a TPIA account, along with the recommendation to fund the account with the proceeds from liquidated investments, to ensure that the proposed course of action is suitable. You will customarily be required to sign an agreement with a recommended TPIA to open an account. You will be permitted to terminate your advisory relationship with the TPIA according to the terms of your agreement with the TPIA. You should review each TPIA’s disclosure brochure for specific information on how you may terminate your advisory relationship with the TPIA and how you will receive a refund, if applicable. You should contact the TPIA directly for questions regarding your advisory agreement with the TPIA. As providers of investment advisory services, TPIAs are responsible for the specialized portfolio management, portfolio reporting services, best execution review, quarterly reporting, trade error resolution, custodial reconciliations, and trade implementation within their respective programs. When Your IAR Terminates When you open an account with a TPIA, the TPIA will assign your IAR to service your account. If your IAR terminates his or her relationship with SPC, for any reason whatsoever, our process is to notify you and the TPIA of your IAR’s termination. If your IAR had a succession plan in place, meaning a written agreement for another IAR (or group of IARs) (the “successor IAR(s)”) to take over your IAR’s book of business, we or the successor IAR(s) will notify you of that as well, including the name and contact information of the successor IAR(s). Thereafter, the successor IAR(s) will likely contact you to obtain updated suitability information and to request that you complete any necessary paperwork related to updating your account. Depending on whether your IAR had a succession plan in place, your account with the TPIA will be updated as follows upon your IAR’s termination:  Multiple IARs. If your account is jointly assigned to multiple IARs, then the terminated IAR’s name will be removed from your account, leaving the remaining IAR(s) assigned to your account. In this scenario, SPC will continue receiving fees from the TPIA related to your account, as SPC will continue servicing your account.  Succession Plan. If your account is solely assigned to your IAR, and your IAR had a succession plan in place, then after your IAR's departure, SPC will assist the successor IAR(s) with updating your account so that the successor IAR(s) are assigned to your account. The process for reassignment varies, as some TPIAs require new client paperwork, whereas other TPIAs will accept a letter of instruction from SPC. If your account is not reassigned to the successor IAR(s) within approximately three (3) months of your IAR’s departure, SPC will instruct the TPIA to stop paying fees to SPC until a new IAR (e.g., a successor IAR) is assigned to your account. However, a cessation in the payment of fees to SPC has no impact on the amount of fees you will pay to have your account managed by the TPIA, or your obligation to pay these agreed-upon fees for so long as your client agreement with the TPIA remains in effect. Moreover, while your account has no IAR assigned to it, you will not receive the benefit of the client relationship services that are included in the overall cost of your participation in the TPIA’s program, as SPC does not have the capability to service your account unless an IAR of SPC is assigned to your account. While you have the option to work with the financial advisor of your choosing, or terminate your participation in the TPIA program at any time, we strongly encourage you to work with any new IAR of SPC who contacts you to request updated account profile information and the completion of any paperwork necessary to have such new IAR assigned to your account, as SPC is unable to service your account while no IAR is assigned to it. After your IAR’s departure, and prior to a new IAR (e.g., a successor IAR) being assigned to your account, the TPIA will continue managing your account according to the client profile information the TPIA currently has on file. If you would like to update your client profile information on file with the TPIA, you should contact the TPIA directly. Please note, however, that the TPIA may not be able to facilitate any such update to your client profile information until you obtain the assistance of a new financial advisor to service your account with the TPIA. SPC cannot handle the communication of any such client profile information to the TPIA while your account remains unassigned to an IAR of SPC.  No Succession Plan. If your account is solely assigned to your IAR, and your IAR had no succession plan in place, then after your IAR’s departure, your account will be reassigned to and serviced by an in-house IAR who works in SPC’s home office, and SPC will continue to receive fees from the TPIA based on the in- house IAR’s services. The process for reassignment varies, as some TPIAs require new client paperwork, whereas other TPIAs will accept a letter of instruction from SPC. The in-house IAR will contact you in order to introduce himself or herself, request updated suitability information from you, request new client paperwork if required by the TPIA for account reassignment, and answer any questions you may have. The in-house IAR will also service your account on an ongoing basis in accordance with the terms of the written agreement between SPC and the TPIA. Financial Planning and Ongoing Consulting Services We provide financial planning and consulting services on an hourly, fixed fee, project and/or ongoing basis. Services can be tailored to your needs and may be comprehensive in nature or may only focus on certain aspects of your financial situation. The scope of services to be provided will be memorialized in our Letter of Engagement. The Letter of Engagement is the agreement we use with clients for financial planning and consulting services. The four services that SPC offers—hourly financial planning, ongoing consulting services, comprehensive financial plans, and segmented financial plans—are described in greater detail below and in the Terms and Conditions of the Letter of Engagement. IARs may provide non-legal advice and assistance with respect to financial management, risk management, asset allocation, investment research, understanding the financial impact of divorce or marital status, investment- related tax issues, retirement planning, education funding, financial goal setting, and other financial or investment-related needs that you identify. The financial planning process will involve the review of your current financial condition, needs, and goals. At his or her discretion, your IAR may also elect to utilize a client questionnaire to assist with making recommendations, and the advice offered may include recommendations for updates and reviews. Segmented and Comprehensive Financial Planning We offer segmented financial plans, including, but not limited to, the following:  Asset allocation / risk tolerance analysis  Retirement planning analysis  Social Security analysis  College cost analysis  Income planning analysis Such plans will be developed based on recommendations consistent with your stated objectives and goals. Additionally, we offer more detailed, broad-based financial plans that comprehensively address most (or all of) a client’s identified financial needs, interests, and goals. Depending on the circumstances, we can also provide, on a limited basis, non-legal consultations, advice, research, or project assistance relating to subject matters which do not involve financial planning per se but still relate to your securities and investment accounts. However, SPC is not a general consulting firm, and we do not provide accounting services, estate planning services, estate planning coordination services, real estate advice or consultations, detailed tax advice, or other non-investment services that we deem as falling outside the definition of “investment adviser” under the Act. Financial planning engagements terminate upon the delivery of services and will not include any reviews, follow- ups, or other services. Each engagement (other than single engagements involving two hours or less of hourly financial planning) is documented with a specific client invoice or other appropriate work documentation as described more fully in the Letter of Engagement. If other services are desired, you are welcome to secure additional or follow-up services under the same or a new Letter of Engagement. Financial plans are based on your financial situation at the time your IAR constructs the plan for you and based on the financial information you provide to your IAR. You must promptly notify your IAR if your financial situation, goals, objectives, or needs change. Ongoing Consulting Services In addition to financial plans, we also offer ongoing consulting services for clients who are interested in receiving continuous assistance with achieving their financial goals and objectives. If you elect this option, on either a monthly or quarterly basis, as agreed upon with your IAR, your IAR will provide you with one or more of the following ongoing consulting services:  Performance reviews and asset allocation recommendations for your selected accounts that are held away from SPC (e.g., 401(k) plans) and for which your IAR is not listed as the representative of record.  Performance reviews and subaccount allocation recommendations for fee-only annuities that you purchased at net asset value.  Telephone, e-mail and/or in-person consultations and education related to general financial matters for which you request your IAR’s assistance, and also on an as-needed basis during regular business hours. Advice Implementation Financial planning services will include various recommendations and planning strategies, depending on the nature of the financial planning services selected. These recommendations are typically generic in nature and may include recommendations to allocate your assets among generic product or account types, although it is possible they could also include recommendations to purchase specific services or investments. Implementation of financial planning recommendations is the client’s responsibility. You are welcome to implement any recommendations in whole or in part at the financial services firm of your choice. You are also free to use the service provider of your choosing for implementation of any advice or recommendations pertaining to non- securities matters (such as insurance). Your IAR is also available to assist with implementation services as well, either in his or her advisory capacity as an IAR of SPC, or, as applicable, in his or her brokerage and/or insurance capacity as a registered representative and/or agent of SFC or Parkland. If you accept your IAR’s offer to assist with implementation of the financial plan, your IAR 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 SPC or its broker-dealer affiliates have authorized your IAR to offer. For information about which products and services your IAR is authorized to offer on behalf of SPC or its affiliates, please reach out to your IAR. When implementing the recommendations made in your financial plan, you are under no obligation to employ your IAR, SPC, or either of SPC’s affiliated broker-dealers to implement the financial plan, or to purchase any investment or insurance product or obtain an advisory service from your IAR, SPC, or either of SPC’s affiliated broker-dealers. Our affiliates’ obligations to you when they act as a broker-dealer or insurance agency differ from SPC’s obligations to you when SPC is acting as an investment adviser. Similarly, your IAR’s obligations to you when acting as an insurance agent or providing securities brokerage services to you differ from your IAR’s obligations to you when acting as an investment adviser representative. Your IAR may suggest that you work closely with your attorney, accountant, insurance agent, and the custodian of your account for implementation of a financial plan. When financial planning or consulting services only focus on certain areas, needs, or are otherwise limited, you should understand that your overall financial and investment needs and objectives may not be comprehensively considered as a result of time and/or service restraints that you place on our services. If you require assistance on issues relating to matters outside of investment advisory services, such as accounting, estate planning, estate planning coordination, or other legal issues, you should consult your accountant, legal counsel, or other qualified professionals for advice, as SPC does not provide such services. When providing plan-related services, the advice and recommendations are limited to plan offerings. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations set forth in a financial plan, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm of your choosing. In connection with financial planning and/or consulting services, we may render advice relative to variable life/annuity products and/or individual employer-sponsored retirement plan accounts. In such cases, your IAR will either direct or recommend the allocation of assets among the various subaccounts or mutual funds that comprise the investment options available through the variable life/annuity product or the retirement plan. Moreover, your assets will be maintained at the specific insurance company that issued the variable life/annuity product or at the custodian designated by the sponsor of the retirement plan. The financial planning Letter of Engagement includes language that permits us to modify or assign the Letter of Engagement by means of certain negative consent procedures. Specifically, we may propose to increase or otherwise modify the fees charged, to modify the services provided, to assign the Letter of Engagement, or to otherwise modify or amend the Letter of Engagement by giving you at least sixty (60) days advance notice of the proposed modification. The notice will: (i) explain the proposed assignment or modification of the fees, services or other provisions of the Letter of Engagement; (ii) fully disclose any resulting changes in the fees to be charged as a result of proposed modifications to the services or other provisions of the Letter of Engagement; (iii) identify the effective date of the modifications; (iv) explain your right to reject, in writing, the modifications or terminate the Letter of Engagement; and (v) state that pursuant to the provisions of the Letter of Engagement, if you fail to object to the proposed modifications before the date on which the modifications become effective, you will be deemed to have consented to the proposed modifications. If you reject any modification to the Letter of Engagement proposed by us in this manner, we will not be authorized to make the proposed modification without your affirmative consent. The financial planning Letter of Engagement may be canceled at any time, by any party thereto and for any reason, upon notice to the other parties, as provided in the Letter of Engagement. In the event of termination, you will be charged for the portion of work performed, and you will receive a prorated refund of any pre-paid fees which we have not earned. Otherwise, except for ongoing service agreements, the agreement automatically terminates upon completion of the services to be rendered. Seminars From time to time, IARs may hold seminars. These seminars may include presentations on general investment, securities, or financial planning strategies. We may charge a fee to those in attendance, not to exceed $100 per attendee. In such cases, our refund or cancellation policy will be clearly outlined in the invitation or announcement. Attendees are welcome, but are never under any obligation, to utilize our other services. Health Savings Accounts (HSAs) Clients who participate in a qualified high-deductible health insurance plan have the option of opening a health savings account (“HSA”) with Fidelity. These HSAs are structured as SIGMA Managed Accounts, although account minimums do not apply. Clients can use HSA funds to pay current medical bills as well as future healthcare costs; there is no deadline to use the money. HSAs offer clients the opportunity for tax-deductible contributions, tax-deferred growth, tax-free withdrawals for eligible medical expenses, and the ability to carry over unused balances year after year (i.e., no “use it or lose it” constraint). However, clients who open HSAs should understand that these tax-advantaged savings accounts are intended for use in paying eligible medical expenses such as co-payments, deductibles, and coinsurance. HSA funds are subject to income taxes and a tax penalty if used for any non-medical expenses before age 65. While there is no penalty after age 65, income taxes still apply if HSA funds are used to pay for something other than eligible medical expenses. Total annual contributions are limited to specified amounts set by the Internal Revenue Service (“IRS”). You and your IAR should carefully discuss beforehand how you plan to use the money in your HSA. For example, if you plan to use your HSA primarily as an investment vehicle for future healthcare costs, your IAR will need to consider your anticipated time horizon and the impact of fees on performance in connection with actively managing your HSA. On the other hand, if you plan to use your HSA primarily as a spending vehicle for current medical bills, the actively managed HSA that we offer may not be appropriate for you. For more information regarding HSAs, please consult the related Investor Bulletin published by the SEC.1 Fee-Only Annuities The IRS has recently begun issuing private letter rulings (“PLRs”) that permit owners of annuity contracts to pay for investment advice (provided by an investment adviser) related specifically to the contract, using funds from the annuity itself (rather than a separate account) without running afoul of Section 72 of the Internal Revenue Code of 1986, as amended (the “IRC”). As a result, insurance companies have begun offering fee-only annuities which are sold by an agent at net asset value or “NAV” (i.e., without a sales commission) and then serviced, for an ongoing advisory fee, by an investment adviser. According to the terms of the PLRs:  The annuity contract owner will receive ongoing investment advice from the investment adviser with respect to the contract so that the owner may properly utilize the contract. The investment adviser is expected to help the owner select options related to the contract.  The fees paid from the contract’s cash value will not serve as consideration for anything other than investment advice provided by the investment adviser in relation to the contract. Furthermore, the fees 1 https://www.sec.gov/oiea/investor-alerts-and-bulletins/investor-bulletin-health-savings-accounts-hsas cannot exceed an annual rate of 1.5% of the contract’s cash value based on the period in which the fees related.  The fees will only be used to pay for investment advisory services relating to the contract. Because the contracts are designed to work with an investment adviser, the contract is solely liable for the fees. The fees do not constitute compensation to the investment adviser for services related to any assets of the owner other than the contract, or any services other than investment advice services with respect to the contract. In late 2024 or beyond, we anticipate that IARs will be able to offer investment advice to owners of fee-only annuity contracts issued by insurance companies that obtained such PLRs. In addition to any required insurance paperwork, clients will sign an advisory agreement unique to fee-only annuities to obtain the investment advisory services. The agreement may be canceled at any time, by any party thereto, for any reason, upon written notice to the other parties. If the agreement is terminated, no fee refund will be necessary for fees charged in arrears, whereas fees charged in advance will be refunded according to the annuity carrier’s stated refund policies. If and when we begin offering investment advice to owners of fee-only annuity contracts, we will update this brochure accordingly to describe the service in greater detail, including, but not limited to, the applicable policies, procedures, fees, and conflicts of interest associated with each option. Types of Investments We do not primarily recommend or utilize one specific type of investment over another because each client has his or her own investment objectives, risk tolerance, needs, and goals. By way of example, we may recommend investments in mutual funds, including index funds; individual securities; exchange-traded funds; money market funds; certificates of deposit; commercial paper; variable life insurance and variable annuities; U.S. Government debt securities, municipal bonds, and other fixed-income securities; securities options; and alternative investments. Securities-Backed Lines of Credit As the SEC explains,2 securities-backed lines of credit (“SBLOCs”), also referred to as non-purpose loans (“NPLs”), are revolving lines of credit that allow clients to borrow money using securities held in their investment accounts as collateral. SBLOCs are NPLs, which means the proceeds may not be used to purchase or trade securities. Clients can continue to trade and buy and sell securities in their pledged accounts. An SBLOC requires the borrower to make monthly interest-only payments, and the loan remains outstanding until repaid. Clients typically have the option to repay some (or all) of the outstanding principal at any time, then borrow again later. The contract specifies the maximum amount clients are permitted to borrow, and they must agree to use their investment account assets as collateral. If the value of the borrower’s securities declines to an amount where it is no longer sufficient to support the line of credit, the borrower will receive a “maintenance call” notification that they must post additional collateral or repay the loan within a specified period (typically two or three days). If the borrower is unable to add additional collateral to the account or repay the loan with readily available cash, the firm can liquidate securities and keep the cash to satisfy the maintenance call. SBLOCs are just one type of securities-based lending offered to clients. Other types include margin and stock- based loan programs. The fact that you might be eligible for an SBLOC does not mean taking a loan is necessarily a wise or prudent idea. SPC makes SBLOCs available solely as a convenience to clients. Neither SPC nor any of its IARs receive any compensation whenever a client decides to borrow money through an SBLOC. Although neither SPC nor your IAR receives compensation in connection with SBLOCs, they do have an incentive to recommend that you use an SBLOC for liquidity purposes rather than liquidating your holdings or using other sources of liquidity. SPC and your IAR will benefit from your SBLOC because you don’t have to liquidate assets in your account to pay for things with cash, which would diminish the assets held in the account and the potential fees that could be earned by SPC and your IAR from holding or engaging in future transactions with those assets. For example, by encouraging investors to take out an SBLOC to fund a purchase or financial need rather than liquidate securities or withdraw cash from their accounts, SPC and your IAR will continue to earn fees on the full account value. 2 https://www.sec.gov/oiea/investor-alerts-bulletins/sbloc.html Assets Under Management As of December 31, 2023, we manage $5,549,645,955 in client assets on a discretionary basis and $13,293,239 in client assets on a non-discretionary basis. Advertising SPC advertises its advisory services in compliance with Rule 206(4)-1 under the Act. Specifically, IARs are permitted to disclose their affiliation with SPC in communications with the public and to list the advisory services they provide through SPC. However, IARs are not permitted to advertise investment performance or share hypothetical performance with clients or prospective clients. In addition, if an IAR operates their financial services practice using a trade name or “doing business as” (“DBA”) name, the IAR must disclose that such entity or enterprise is independent of SPC, as neither SPC nor your IAR conducts advisory business under any such trade name or DBA name. All investment advisory services are offered and provided by your IAR solely through SPC. Policies and Procedures In accordance with Rule 206(4)-7 under the Act, SPC has adopted and implemented written compliance policies and procedures reasonably designed to prevent violation, by SPC and its Associated Persons, of the Act and the rules promulgated under the Act.