Equity Services, Inc. (“ESI”) is a registered broker/dealer, as well as a federally registered investment adviser, doing business as ESI Financial Advisors (“EFA” or “the Firm”). ESI was founded in 1968 as an affiliate of National Life Insurance Company (“National Life”), which began doing business in 1848. NLV Financial Corporation is the sole shareholder of ESI, and the National Life Group companies, which includes National Life and Life Insurance Company of the Southwest (“LSW”). EFA provides financial planning/consulting services and asset management services to individuals, corporations, trusts, estates, charitable organizations, and retirement plans including pension and profit-sharing plans. EFA has been registered with the SEC since 1992. As of 12/31/2023, the Firm managed approximately $1.5 billion in non-discretionary assets and approximately $637 million in discretionary assets across its advisory programs. Before investing in an advisory program, clients should decide if they are comfortable delegating the day-to-day management of their account(s). Investors in advisory programs typically:  Desire advice and guidance when making investment decisions;  When working with a discretionary manager, are at ease with a financial professional making their day-to-day investment decisions;  Are willing to follow a disciplined investment strategy;  Are comfortable paying quarterly, asset-based (percentage) fees for investments and advice rather than individual commissions or sales charges. EFA offers a variety of advisory programs, many of which engage the services of third-party asset managers (“TPAM”) with discretionary trading authority, and some in which the client is required to authorize some or all trading activity in their account. Clients should ensure they understand the nature of their advisory agreement with EFA and any other TPAM they engage to provide asset management and/or financial planning services. Financial planning and consulting services are available through EFA and its network of Investment Adviser Representatives (“advisory representatives” or “IAR”). Advisory representatives can offer financial planning services whereby the client receives a financial or investment plan, or similar service, for a fee. Services will generally include a written financial plan addressing the topics agreed upon in the planning agreement. Depending on their needs, clients have the option to select either a full financial analysis or an analysis of a specific financial area. In any event, the analysis will contain generic recommendations for the client and will not include specific product recommendations. Advisory representatives also offer financial consulting services under a separate consulting agreement. In addition, EFA makes asset management services available to its clients. These programs can be managed by multiple third-party investment advisers, or by the advisory representatives and the client. EFA also acts as the adviser or co-adviser on certain of its advisory program offerings, specifically:  ESI Illuminations  American Funds Retirement Plan Solutions  AssetMark (advisor model)  Morningstar Investment Services  Saratoga Advantage Trust  Schwab Retirement Advisor Services ES0408(0424) 2  SEI Investments Third-party asset managers (called “Strategists” on the Envestnet platform, and those that manage other programs described below) can, and often do, use proprietary funds in their model portfolios. Clients should refer to the appropriate third-party manager’s Form ADV Part 2A disclosure brochure for additional information on fund and share class selection specific to their selected model portfolio. Within its ESI Illuminations Flagship Select and ESI Directions programs, clients instruct EFA to exercise discretion (as described under Item 16 of this Brochure) to rebalance accounts when the performance of various account holdings causes or has the potential to cause the account to vary outside the acceptable risk range tolerance for the client’s chosen investment objective. ESI Compass permits EFA and its representatives to exercise discretionary trading authority in determining which securities to buy and/or sell in conjunction with model portfolio management. EFA’s asset management programs are intended to meet an individual’s needs and goals based on an analysis of the client’s liquidity, time frame, and income and tax bracket, as well as an evaluation of the client’s risk tolerance and investment objective. The client’s advisory representative will seek to review and update this information at least annually, or at the client’s request. EFA asset management programs use different investment vehicles to meet a client’s needs and goals. Depending on the program selected, the following types of investments are used: Exchange-listed securities U.S. government securities Over-the-counter securities Corporate debt securities Certificates of deposit Interests in partnerships Municipal securities Options (real estate, oil and gas Mutual fund shares Cash equivalents interests, equipment leasing) Recommended investment strategies are primarily long-term strategies. However, based on the client’s needs and goals, short-term strategies and trading may be suitable, as well as margin transactions or option writing (including covered options, uncovered options, or spreading strategies). Clients have the ability to impose restrictions on investing in certain securities or types of securities, subject to the discretionary manager’s ability to comply with the request. EFA offers investment advisory services through the following asset management programs: ESI Illuminations Working with Envestnet|PMC, Inc. (“Envestnet”), EFA has developed a customized investment management platform called ESI Illuminations. The following Envestnet asset management programs are available on the ESI Illuminations Platform: Third-Party Strategist, Advisor as Portfolio Manager, Multi-Manager Accounts, Unified Managed Accounts, and Separately Managed Accounts. Clients complete a profile questionnaire which assists in determining which of up to fourteen possible investment models is appropriate based on indicated objectives, risk tolerance, and overall financial goals. Based on this information, an investment strategy is developed and documented. Investment recommendations in the ESI Illuminations program include mutual funds from which ESI (acting in its capacity as broker/dealer) receives compensation through revenue sharing arrangements. Not all mutual funds on the platform provide the Firm with such additional revenue. Funds that do not pay the Firm additional revenue, and which provide similar market exposure as ES0408(0424) 3 those that do, are available. Third-party asset managers are responsible for selecting the various funds and share classes in which clients’ assets are invested, based on the funds available for each model portfolio. Clients have the ability to inquire whether or not cheaper funds and/or share classes are available for any given portfolio. EFA and its advisory representatives do not have authority to implement investment transactions on a discretionary basis, except as noted in Item 16 of this brochure. Unless Envestnet, a third- party Strategist, other separate account managers, or the advisory representative have been given discretionary authority by the client, all transactions must be expressly approved by the client. Custody of client assets is maintained by National Financial Services, LLC ("NFS") with accounts registered in the client's name. A copy of this Brochure1 and of Envestnet’s Form ADV Part 2A is given to ESI Illuminations clients. In addition, clients choosing a third-party manager on the ESI Illuminations platform will receive a Form ADV Part 2A for the chosen manager. Clients have the ability to place reasonable restrictions on the investments within the ESI Illuminations programs. This also includes the ability to place restrictions on the investments purchased through separate account manager(s). Contact your advisory representative for assistance with facilitating these restrictions. ESI Illuminations - Third-Party Strategist Programs In the Third-Party Strategist program offered by Envestnet, EFA selects various asset management firms (“Strategists”) to offer actively managed portfolios, comprised of mutual funds or exchange-traded funds. These Strategists manage the accounts on a discretionary basis. Envestnet manages the programs pursuant to trade and rebalancing instructions provided by the Strategist. Each Strategist establishes their own minimum investment requirement(s), but reserves the right to, at their discretion, permit initial investments below the stated minimum. ESI Illuminations - Advisor as Portfolio Manager The Advisor as Portfolio Manager programs are branded Flagship Select, ESI Directions, and ESI Compass. These programs offer access to portfolios comprised of securities recommended to clients by the advisor, acting as the portfolio manager, using the tools and technology available from Envestnet. For discretionary accounts (described in Item 16 of this Brochure), model portfolios are constructed and managed by EFA and its advisory representatives in accordance with the client’s Advisory Agreement. For non-discretionary accounts, the client must provide consent, prior to execution, for any transactions in their account. EFA reserves the right to waive minimum investment requirements for accounts in the Envestnet/PMC-managed programs. Flagship Select is an asset allocation program where the advisory representative can recommend appropriate mutual funds, exchange-traded funds (“ETFs”), and/or money market funds to build the portfolios, and the client may choose to purchase the recommended securities. The program generally includes no-load, load-waived, and no transaction fee (“NTF”) funds (for additional information regarding NTF funds, see “Fees and Expenses: NTF vs Non-NTF Funds” below). The program also includes load

mutual funds (for example, transfers of existing positions into the program). Minimum investment: $50,000. 1 Clients in ESI’s wrap fee programs receive the version of ESI’s ADV Part 2A-Appendix 1 that corresponds to their selected program. ES0408(0424) 4 ESI Directions is an asset management program where the advisory representative works with the client to select securities that are appropriate for the client’s investment model. Envestnet provides system tools which are used to analyze the information obtained through a client profile questionnaire and recommends an appropriate asset allocation model based on indicated objectives, risk tolerance and overall financial goals. Based on this information, the advisory representative and client select the appropriate securities for the account including, but not limited to: stocks, bonds, mutual funds, options, ETFs, unit investment trusts (“UITs”), certificates of deposit, structured products, and/or cash equivalents. Minimum investment: $50,000. ESI Compass is an asset management program where the client grants the advisory representative discretionary trading authority to select securities that are appropriate for the client's investment model. Envestnet provides system tools which are used to analyze the information obtained through a client profile questionnaire and recommends an appropriate asset allocation model based on indicated objectives, risk tolerance and overall financial goals. Based on this information, the advisory representative selects the appropriate securities for the account including, but not limited to: stocks, bonds, mutual funds, options, ETFs, unit investment trusts (“UITs”), certificates of deposit, structured products, and/or cash equivalents. Minimum investment: $50,000. ESI Illuminations – Unified Managed Accounts (“UMA”) The ESI Illuminations UMA program gives clients the ability to utilize the services and strategies of multiple managers within one brokerage account. ESI, through its IARs, builds and recommends UMA portfolios, which provide diversification among strategies and/or third-party managers, as well as Separate Account Managers. As the administrator, Envestnet executes trading activity, as instructed by the various third-party managers, and maintains the allocation in accordance with the client’s Statement of Investment Selection (“SIS”). The platform technology provides the ability to unify multiple strategies and apply ongoing re-balancing within one account. Strategist Managed UMA programs give clients the ability to select a Strategist, available on the Envestnet platform, to build and manage diversified UMA portfolios, which can incorporate general securities, as well as investment models managed by other third-party Strategists. As the overlay manager, Envestnet executes trading activity, as instructed by the Strategist, who builds and manages the account on a discretionary basis, in accordance with the client’s SIS. These programs are designed for high-net worth clients and have minimum investments starting at $500,000. Separately Managed Accounts (“SMA”) are available under the UMA program. SMAs give clients the ability to invest in specific sectors and/or asset classes. The SMA manager is the discretionary manager and often uses general securities, but also has the option of utilizing mutual funds or ETFs. Clients utilizing a SMA in their UMA portfolio have the ability to use additional overlay services, at an additional cost, such as tax management and Impact Overlay (which allows the investor to incorporate certain policies, such as Environmental and Social Governance (ESG), into their portfolio). Navigator Select is a SMA program that gives the client indirect access to one or more separately managed account managers who fund model portfolios with general securities. The IAR and the client choose separate account managers which are pre-screened by Envestnet Portfolio Solutions. The separate account managers choose the general securities to fund the portfolios and have trading discretion. This program is closed to new investors. ES0408(0424) 5 American Funds Retirement Plan Solutions (“American Funds”) American Funds is generally designed to serve small and mid-sized employer-sponsored retirement plans, but also offers solutions for large plans. American Funds provides retirement plans with investment options consisting of mutual funds and stable value funds. In designing the plan, the client, the plan sponsor, selects an investment menu from the American Funds platform. These solutions are available in a variety of share classes to accommodate varying plan objectives. The Plan Sponsor will determine the appropriate investments and share class(es) for the plan offerings. Plan design is based on a variety of factors, including administration objectives, plan size, financial advisor service levels, investment choice, and over-all expense objectives, and the investment options – including the fund families and risk level – will vary based on the platform selected. AssetMark AssetMark offers asset allocation services. Working with AssetMark, EFA, through its advisory representatives, assists clients in establishing an investment strategy consistent with their investment objectives and risk tolerance. The creation of the investment strategy is based on a client profile questionnaire that helps determine such factors as risk tolerance, investment objectives, and financial goals. AssetMark provides advisory services to EFA clients on a discretionary basis. Account administration, fee billing and performance reporting are provided via internet-based software. EFA acts as co-adviser on AssetMark’s advisor model portfolios, and shares in the fees collected by AssetMark. AssetMark utilizes the custodial services of AssetMark Trust Company, Pershing, and TD Ameritrade. The specific custodial arrangement is established under an agreement between the customer and the custodian, separate from the customer’s agreement with AssetMark. Minimum investment varies by program: Mutual fund models: As low as $10,000 (varies by Strategist) ETFs and privately managed accounts: $100,000 Multi-manager models: $50,0002 Morningstar Investment Services (“Morningstar”) In addition to being a Strategist through the Illuminations Third-Party Strategist Program, Morningstar also offers asset allocation services in its Select Equity portfolios on a direct basis. Working with Morningstar, EFA, through its advisory representatives, assists clients in establishing an investment strategy consistent with their investment objectives and risk tolerance. The creation of the investment strategy is based on a client profile questionnaire that helps determine such factors as risk tolerance, investment objectives, and financial goals. Morningstar, as the discretionary manager, selects the various stocks, initiates portfolio re-balancing, and provides detailed quarterly performance reports to the IARs and clients. EFA acts as co-adviser, and shares in the fees collected by Morningstar. Custodial services are provided by Fidelity, Charles Schwab, and BNY Mellon. Minimum investment: $100,000. Saratoga Advantage Trust ("Saratoga") Saratoga offers objective setting and asset allocation services. EFA, through its advisory representatives, prepares asset allocation recommendations for each client based on an investor profile questionnaire. Saratoga Capital Management, LLC, selects the sub-advisors for the various funds, recommends portfolio models based on the investor profile questionnaire, and 2 AssetMark’s standard minimum investment is $50,000. However, minimum investment requirements for other Strategists offered through the multi-manager models may vary. Investments in the multi-manager models must meet the specific Strategists’ minimums, which may be higher than that of AssetMark ES0408(0424) 6 provides detailed quarterly performance reports to the IARs and clients. Saratoga changes model allocations based on their capital market assumptions. Clients determine whether or not to follow the model recommendations made by Saratoga Capital Management, LLC. EFA acts as advisor, and shares in the fees collected by Saratoga. Custodial services are provided by First National Bank for IRA assets, and by BNY Mellon for all other accounts. This program is closed to new investors. Schwab Retirement Advisor Services (“SRAS”) (FKA TD Ameritrade Retirement Plan Platform) SRAS is a retirement plan platform. Custodial services are provided by Charles Schwab Trust Bank and brokerage services are provided through Charles Schwab & Co., Inc. (“Schwab”) SRAS provides clients with access to mutual fund and ETF investments for use in their retirement portfolio. Working through SRAS, clients will establish an investment strategy consistent with their investment objectives and risk tolerance based on a questionnaire and client profile. Once an investment strategy is established, assets are invested through Schwab. Clients have the option of selecting their own investments, without the assistance of a professional asset manager, or they have the option of selecting a professional discretionary asset manager from a list provided through SRAS. Minimum investments will vary, depending on the plan sponsor. SEI Investments ("SEI") SEI offers objective setting and asset allocation services. Working with SEI, EFA, through its advisory representatives, assists clients in establishing an investment strategy consistent with their investment objectives and risk tolerance based on a questionnaire and client profile. SEI acts as sponsor, and SEI Investments Management Corporation is the discretionary investment manager for both the Managed Account Program and the Integrated Managed Account. SEI selects the sub-advisors for the various mutual funds, initiates quarterly portfolio re-balancing, and provides detailed quarterly performance reports to the clients and IARs. EFA acts as co- adviser, and shares in the fees collected by SEI. SEI Private Trust Company acts as custodian for the assets. There is no minimum investment.