9AT: SECURITIES AMERICA ADVISORS, INC.

SECURITIES AMERICA ADVISORS, INC.

SECURITIES AMERICA ADVISORS, INC.

1865 WEALTH ADVISORS AT BANK ON BUFFALO

BROUILLETTE GROUP

BROLEN DAVIS INTEGRATIVE WEALTH MANAGEME

BRIDGEHEAD FINANCIAL GROUP, LLC

BRENNAN FINANCIAL GROUP

BRENDA CATUGNO

BREITENFELDT GROUP

BREIDENBAUGH FINANCIAL

BRECEK AND YOUNG FINANCIAL SERVICES

BRASS CITY FINANCIAL

BRANCH DEVELOPMENT PARTNERS

BRADY INVESTMENTS & WEALTH PLANNING

BRADY FINANCIAL

BRADFORD INVESTMENT SERVICES

BRADEN FINANCIAL SERVICES

BRAD WERNER & COMPANY

BPA FINANCIAL ADVISORS

BOZEMAN FINANCIAL ADVISORS

BOOTH FINANCIAL GROUP

BONGIOVANNI INSURANCE & FINANCIAL

BOND FINANCIAL NETWORK

BOLIVAR INVESTMENT SERVICES

BLUEMARK ADVISORS

BLUE CHIP FINANCIAL GROUP

BLUE CHIP FINANCIAL

BLOSSER FINANCIAL SERVICES

BLANCHARD WEALTH SOLUTIONS

BLAKENEY FINANCIAL GROUP

BLAKEMAN BRISTER PUTMAN FINANCIAL GROUP

BLADE FINANCIAL SERVICES

BLACKHAWK FINANCIAL ADVISORS, INC.

BLACK RIVER ASSOCIATES

BLACK OAK INVESTMENT COUNSEL, INC.

BLACK EARTH WEALTH MANAGEMENT

BJURSTROM WEALTH MANAGEMENT

BIXBY FINANCIAL SERVICES

BISON WEALTH STRATEGIES

BIRDS EYE WEALTH PLANNING

BIGSKY FINANCIAL PLANNING GROUP

BIGMAN CONSULTING SERVICES

BIG SKY FINANCIAL PLANNING GROUP

BIG SKY FINANCIAL

BIERMAIER FINANCIAL MANAGEMENT

BHL FINANCIAL SERVICES

BG&CFS, P

BETHEA, ANGST AND HICKS WEALTH MANAGEMNT

BETHEA, ANGST & HICKS

BETCHER FINANCIAL GROUP

BERRIN MANAGEMENT GROUP

BERNARDY FINANCIAL GROUP

BENSON FINANCIAL SERVICES

BENSON FINANCIAL GROUP

BENEFITS WEST

BEN CAIN & ASSOCIATES

BEAU MCNICHOLAS

BEARD FINANCIAL GROUP

BEACONPATH WEALTH MANAGEMENT

BEACH HOUSE WEALTH MANAGEMENT

BDM FINANCIAL ADVISORS

BCA FINANCIAL SERVICES

BC&I WEALTH MANAGEMENT

BAYSIDE FINANCIAL STRATEGIES

BAYPORT FINANCIAL

BAY VIEW CAPITAL

BAY POINTE WEALTH MANAGEMENT

BAY INVESTMENT GROUP

BARTLER WEALTH MANAGEMENT GROUP

BARONE FINANCIAL GROUP

BARNEY FINANCIAL SERVICES

BARKER FINANCIAL SERVICES

BARE WEALTH ADVISORS

BARBER FINANCIAL CO

BANKS WEALTH MANAGEMENT

BANK ON BUFFALO INVESTMENT ADVISORS

BALL WEALTH MANAGMENT

BAILLIE & ASSOC WEALTH MANAGEMENT

BAILEY FINANCIAL SERVICES

BACKCOUNTRY INSURANCE SERVICES

AZEVEDO INVESTMENT CORPORATION

AXION FINANCIAL GROUP

AVH INVEST

AUGUSTINE FINANCIAL GROUP

ASTUTE WEALTH MANAGEMENT

ASTRA INVESTMENT SERVICES

ASSOCIATED INVESTOR SERVICES, INC.

ASSOCIATED FINANCIAL CONSULTANTS INC

ASSOCIATED FINANCIAL CONSULTANTS & INVES

ARMSTRONG ADVISORY GROUP

ARMSTRONG ADVISORY

ARKTOS WEALTH MANAGEMENT

ARCH WEALTH ADVISORS

ARCADE WEALTH ADVISORS

ARATA INVESTMENT MANAGEMENT

ARANEO TAX AND FINANCIAL

ANTHONY GIULIANO

ANN M. MOROCCO

ANDERSON-VANHORNE INSURANCE & FINANCIAL

ANDERSON-VANHORNE ASSOCIATES

ANDERSON WEALTH PLANNING

AMS FINANCIAL GROUP

AMERIWEALTH RETIREMENT SERVICES

AMERICAN WEALTH PARTNERS

AMERICAN WEALTH MANAGEMENT

AMERICAN NATIONAL BANK WEALTH MANAGEMENT

AMANDA M. BONOMI, E.A., CFP

ALTSTATT FINANCIAL STRATEGIES

ALTER RETIREMENT PLANNING

ALTA FINANCIAL

ALPHA ONE

ALPHA FINANCIAL SERVICES

ALPHA & OMEGA FINANCIAL SOLUTIONS

ALLLISON WEALTH MANAGMENT

ALLIED FINANCIAL SERVICES

ALLIED FINANCIAL PARTNERS

ALLIED ASSET MANAGEMENT

ALLIANCE WEALTH MANAGEMENT

ALLAIRE FINANCIAL STRATEGIES

ALL IN FINANCIAL

AGRIFAMILY FINANCIAL SOLUTIONS

AGP FINANCIAL

AGGREGATE WEALTH MANAGEMENT

AFR FINANCIAL GROUP

AFR FINANCIAL

ADVANTAGE FINANCIAL SERVICES

ADVANTAGE FINANCIAL GROUP

ADVANCE FINANCIAL GROUP

ADMIRAL FINANCIAL

ADG FINANCIAL SERVICES

ACERRA & ASSOCIATES

ACCENTRA INVESTMENT SERVICES

ABELS FINANCIAL SERVICES LTD

ABD INSURANCE AND FINANCIAL SERVICES

A3 FINANCIAL PLANNING

A.M. GINSBERG ADVISORY GROUP

A.B. CAMPBELL & ASSOCIATES

A. KRANITZ ASSOCIATES

88 PROSPERITY WEALTH MANAGEMENT

457 PLAN SERVICE GROUP

3G FINANCIAL

2ND OPINION PARTNERS

21ST CENTURY SECURITIES

20/20 WEALTH ADVISORS

20/20 FINANCIAL GROUP

2 SISTERS FINANCIAL

1ST STRATEGIC WEALTH ADVISORS

1ST STEP FINANCIAL

1ST FINANCIAL SERVICES

1865 WEALTH ADVISORS AT FC BANK

1865 WEALTH ADVISORS AT ERIEBANK

1865 WEALTH ADVISORS AT CNB BANK...

BALANCED WEALTH MANAGEMENT

BRADFORD CAPITAL GROUP

ACACIA WEALTH MANAGEMENT

ALLIANT FINANCIAL SOLUTIONS

435 FINANCIAL

BLOOMFIELD HILLS ADVISORY

1865 WEALTH ADVISORS AT CNB BAN...

Adviser Profile

As of Date	06/22/2024
Registration status	Terminated
ADV Location	LA VISTA, NE, United States
Contact Info	402 xxxxxxx
Websites

AUM^*	40,420,443,233 6%
of that, discretionary	35,169,262,364 27%
Number of Employees	4,468 19%
of those in investment advisory functions	2,025 -4%
Private Fund GAV^*	0
Avg Account Size	191,430 0%
% High Net Worth	5.71% 11%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Pension and profit sharing plans
- Charitable organizations
- Corporations or other businesses not listed above

Advisory Activities

- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses
- Pension consulting services
- Selection of other advisers
- Educational seminars/workshops

Compensation Arrangments

- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)

Reported AUM

38B 33B 27B 22B 16B 11B 5B

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Brochure Summary

Overview

The Architect/Structure Program (“Program”) is sponsored by Securities America Advisors, Inc. (“SAA”, the “Firm,” “us” or “we” or “our”), an SEC-Registered Investment Adviser. Securities America Advisors, Inc. (“SAA”) is registered as an investment advisor with the Securities and Exchange Commission (“SEC”), SEC File No. 801-45628, in order to offer investment advisory products and services to its advisory clients. Securities America, Inc. (“SAI”), SAA’s broker-dealer affiliate, is registered with the SEC as a broker-dealer engaged in the offer and sale of securities products and is a member of the Financial Industry Regulatory Authority (“FINRA”). Advisory products and services are offered through certain Financial Advisors (“FAs”) who have registered as Investment Advisor Representatives (“Advisory Representative”). Registration does not imply a certain level of skill or training. SAA and SAI are wholly owned subsidiaries of Securities America Financial Corporation (“SAFC”). SAFC is a wholly-owned subsidiary of Osaic Holdings, Inc.(“Osaic”), which is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P. and The Berlinski Family 2006 Trust. SAA will henceforth be referred to as “we,” “us,” “our” or “the Firm. The Program is presented to the client (“you”) by Advisory Representatives of SAA. You will enter into an investment advisory client agreement (“Client Agreement”) with us and establish a brokerage account (“Program Account”) on a fully disclosed basis with SAI. SAI is a Related Person to us and there are conflicts of interest that are further described herein and/or within the Form ADV 2A. Related Persons are defined as entities that we control or control us or are under common control with us. Advisory Services The Architect/Structure Program is not being offered to new customers and is only available to the existing owners of the Transferred Investacorp Accounts. The Architect/Structure Program (“Program”) is sponsored by SAA. In July 2020, SAA entered into an agreement with Investacorp Advisory Services, Inc. (“IAS”), a registered investment adviser, and Investacorp, Inc. (“Investacorp”), IAS’s affiliated broker/dealer, to acquire certain advisory business and Advisory Representatives (the “Transferred Investacorp Accounts”). As a result of this agreement, SAA and SAI replaced IAS and Investacorp, as the associated registered investment adviser and broker/dealer, respectively, on the Transferred Investacorp Accounts in the Program. Accounts in the Architect/Structure Program are managed on a discretionary basis. As a result, you grant SAA complete and unlimited trading discretion to manage your account. Pursuant to this grant of discretion, you authorize SAA to invest and reinvest the assets in each account at such time and in such manner as SAA, in its discretion, determines and to act on your behalf in all other matters necessary or incidental to the trading in each account, without discussing individual transactions or actions with you in advance. If you have assets in one of the Transferred Investacorp Accounts, the Architect and Structure Platform programs provide you with investment advisory and brokerage execution services for a fee through an arrangement with Envestnet Asset Management, Inc. (“Envestnet”), an unaffiliated SEC-registered investment advisor that provides investment management and investment advisory services. Envestnet’s technology assesses and assists your Advisory Representative in determining your risk tolerance. Based upon your risk tolerance, the Architect/Structure Program utilizes a system that assists your Advisory Representative in selecting investment products, program account types and/or asset allocation that align(s) with your risk tolerance. Our Advisory Representatives’ services are tailored to the individual needs of their clients. Our Advisory Representatives assist with establishing and monitoring your investment objectives, risk tolerance, asset allocation goals and time horizon. You have the opportunity to place reasonable restrictions or constraints Architect/Structure Program Part 2A – 2024.1 5 Current as of March 28, 2024 on the way your accounts are managed; however, such restrictions may cause your Advisory Representative to deviate from a strategy or recommendations that your Advisory Representative would have made if such restrictions or constraints were not in place. Thus, your account’s performance may be lower than it otherwise would have been. The services that SAA provides under some or all of these wrap fee programs may be available from other providers for lesser fees. In addition, clients may buy securities (e.g., mutual funds, exchange-traded funds, etc.) outside of these programs without incurring the Wrap Fee. The types of securities and other investments that our Advisory Representatives recommend to you under each program are as follows: Architect Program Our Advisory Representatives may recommend to you investments from a diverse group of securities, including exchange listed and NASDAQ traded stocks, bonds and warrants, as well as exchange traded real estate investment trusts, secondary market closed-end investment company securities, secondary market unit investment trusts, mutual funds, select variable annuity products, cash equivalents and other securities that SAA allows to be transacted and held in your account. This program is custodied at National Financial Services, Inc. (“NFS”) and administered through the Envestnet, Inc. platform. Structure Program Our Advisory Representatives may recommend to you investments from a diverse group of securities, including exchange listed and NASDAQ traded stocks, bonds and warrants, as well as exchange traded real estate investment trusts, select fee-based non-traded alternative investment products, secondary market closed-end investment company securities, secondary market unit investment trusts, NTF mutual funds, load-waived mutual funds purchased at Net Asset Value (“NAV”), no-load mutual funds, select variable annuity products, cash equivalents and other securities. This program is custodied at National Financial Services, Inc. (“NFS”) and administered through the Envestnet, Inc. platform. SAI as broker/dealer executes trades for accounts in the above programs and NFS acts as custodian. Program Costs Each account will be charged an asset-based fee (“program fee”). The program fee will be calculated based on the value of the assets in the account and charged in advance on a quarterly basis, as set forth in your Program agreement. The maximum annual program fee rates are: Program Name Maximum Annual Program Fee Architect 2.34% Structure 2.20% Architect Program SAA charges an asset-based advisory fee at the beginning of each quarter up to a maximum of 2.0% per annum based on the value of the assets for each account. The rates are subject to negotiation between you and SAA. SAA pays all or substantially all of the advisory fee to your Advisory Representative. SAA also receives a platform fee equal to a maximum annual fee up to 0.34% based on the value of the assets in each account, which is non-negotiable and charged to the client. This platform fee includes administrative services provided by Envestnet, Inc. The platform fee rate is blended, i.e., as the value of the assets reaches various thresholds, the assets above each threshold are charged a successively lower advisory fee rate. The account is not Architect/Structure Program Part 2A – 2024.1 6 Current as of March 28, 2024 charged transaction charges. The actual fee rates paid by the client are set forth in the client’s agreement with SAA. Architect Account Breakpoints Account Size Platform Fee First $250,000 0.34% Next $250,000 0.24% Next $500,000 0.15% Next $4,000,000 0.10% Over $5,000,000 0.06% Architect accounts are subject to a minimum annual maintenance fee of $170, which is charged quarterly at $42.50. Additionally, accounts are subject to an annual account service fee of $50. The minimum maintenance fee and annual account service fee cover certain administrative services provided by IAS and its affiliates. These fees are in addition to the advisory and platform fees. Advisory Representatives can negotiate a discounted platform fee which is often based on assets under management within the Program. This creates a conflict of interest for your Advisory Representative to put more assets into the Program. Structure Program SAA charges an asset-based advisory fee at the beginning of each quarter up to a maximum of 2.00% per annum based on the value of the assets for each account. The rates are subject to negotiation between you and SAA. SAA pays all or substantially all of the advisory fee to your Advisory Representative. SAA also receives a platform fee up to a maximum annual fee of up to 0.20% based on the value of the assets in each account. The platform fee is charged to you. The platform fee rate is blended, i.e., as the value of the assets reaches various thresholds, the assets above each threshold are charged a successively the lower advisory fee rate. The account is also be charged transaction charges. This charge will not apply to transactions in mutual funds that have been designated by the Custodian as “NTF” or no-transaction charge funds. The actual fee rates paid by clients are set forth in each client’s agreement with SAA. Please also refer to the Client Fee Disclosure - NFS Clearing located at www.securitiesamerica.com/disclosures to find additional details regarding custodial fees. Structure Account Breakpoints Account Size Platform Fee First $250,000 0.20% Next $250,000 0.18% Next $500,000 0.15% Next $4,000,000 0.10% Over $5,000,000 Negotiable Structure accounts are subject to a minimum annual maintenance fee of $100, charged quarterly at $25. The maintenance fee covers certain administrative services provided by SAA and its affiliates. These fees are in addition to the advisory and platform fees. If fees are suspended for any reason, SAA reserves the right to charge your Advisory Representative for uncollected platform fees. Advisory Representatives can negotiate a discounted platform fee, which is often based on assets under management within the Program. This creates a conflict of interest for your Advisory Representative to put more assets into the Program. Architect/Structure Program Part 2A – 2024.1 7 Current as of March 28, 2024 Imposing the minimum fee can cause the effective program fee rate (expressed as a percentage) to be greater than the fee rates specified in your Program agreement. You can terminate the Program agreement and a pro rata portion of any program fee paid in advance will be remitted to you based on the number of days left in the quarter following receiving notice of termination by SAA. The program fee covers the portfolio management services provided by your Advisory Representative, program administrative services provided by SAA and Envestnet, execution of transactions through SAI and custodial services (unless otherwise agreed between the custodian and the client). Each program can cost a client more or less than purchasing such service separately, depending on the frequency of trading in the accounts, commissions charged at other broker/dealers for similar products, fees charged for like services by other advisers and broker/ dealers and other factors. The program fee does not cover charges imposed by third parties for investments held in the account, such as contingent deferred sales charges or 12(b)-1 trails on mutual funds. All 12(b)-1 fees incurred by the client are fully rebated to applicable account. Other costs assessed by broker/dealers or the custodian that are not included in the program fee include fees for transactions executed away from SAI, dealer mark-ups and spreads paid to market-makers. Also, the program fee does not cover fees and charges in connection with debit balances, margin interest, annuities, odd-lot differentials, IRA fees, transfer taxes, exchange fees, wire transfers, extensions, non-sufficient funds, mailgrams, legal transfers, bank wires, postage, surcharges, SEC fees or other fees or taxes required by law and costs associated with exchanging foreign currencies. Subject to approval, Advisory Representatives may trade on margin for clients’ accounts, which could result in a high portfolio turnover ratio and higher transaction charges in accounts with such charges. Additionally, the use of margin may also result in interest charges, as well as all other fees and expenses associated with the security or account involved. General Information Concerning Fees and Other Client Charges Confirmation & Prospectus Paper Fees In addition to the fees discussed above, Confirmation and Prospectus Paper Fees also apply to your Program account. The Confirmation Fee can be avoided by signing up for electronic delivery. Your Advisory Representative can also choose to pay this fee on your behalf. Refer to the trade confirmation to determine if this fee applies to you. The Prospectus Fee can be avoided by signing up for electronic delivery. The Prospectus Fee is paid by your Advisory Representative. In cases where your Advisory Representative pays the above fees, there is an incentive for your Advisory Representative to trade less often or to recommend different products to avoid the fee. Our policy and procedures are designed to ensure our Related Persons make recommendations to you that are in your best interest. Furthermore, to mitigate this conflict, you can sign up for electronic delivery. Please also refer to the Client Fee Disclosure - NFS Clearing located at www.securitiesamerica.com/disclosures to find additional details regarding custodial fees. Architect/Structure Program Part 2A – 2024.1 8 Current as of March 28, 2024 Mutual Funds Please be aware that Account Fees are charged on all mutual fund shares that are designated as Program Investments, including shares on which you have previously paid a sales charge. Also, to the extent that cash used for investments in an account comes from redemptions of your other non-managed mutual

fund investments, you should consider the cost, if any, of the sales charge(s) previously paid and redemption fees that would be incurred. Such redemption fees would be in addition to the Account Fee on those assets. Please be aware that such redemptions and exchanges between mutual funds that participate in the Program might have tax consequences, which should be discussed with your independent tax adviser. You will bear a proportionate share of the fees and expenses of any mutual funds selected and for money market funds used as “sweep vehicles” for uninvested cash balances. These fees and expenses typically include investment advisory, administrative, distribution, transfer agent, custodial, legal, audit and other customary fees and expenses related to investment in Funds and are in addition to the Account Fee. Please read the prospectuses of the funds selected for a more complete explanation of these fees and expenses. You have the option to purchase shares of mutual funds outside of the Program directly from the mutual fund issuer, its principal underwriter or a distributor without purchasing the services of the Program or paying the Account Fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge is determined by the mutual fund (as described in the mutual fund prospectus) and may be more or less than the applicable account fee. Mutual funds generally offer multiple share classes available for investment based upon certain eligibility and/or purchase requirements. For instance, in addition to the more commonly offered retail share classes (typically, Class A, B, and C shares), certain mutual funds also offer institutional share classes and other share classes that are specifically designed for purchase in an account enrolled in fee-based investment advisory programs. Institutional share classes or classes of shares designed for purchase in an investment advisory program usually have a lower expense ratio than other share classes. Clients should not assume that they will be invested in the share class with the lowest possible expense ratio. With regard to any assets invested in mutual funds that are advised by SAA or an affiliate of SAA, the assets will be excluded from the calculation of the administrative fee. Retirement Accounts There are additional fees relating to IRA and Qualified Retirement Plan accounts such as maintenance and termination fees. You will find these fees disclosed in the account application paperwork provided to you associated with these accounts. Accordingly, you should review the Account Fee and the other fees outlined above to fully understand the total amount of fees you pay. Depending upon the level of the Account Fee, your Advisor may receive more compensation: 1) as a result of your participation in the Program than if you participate in other programs that your Advisor offers. 2) if your Advisor charges you the Wrap Account Fee which wraps management, administrative and transaction costs into one fee rather than having you pay for these services separately. As such, your Advisor could have a financial incentive to recommend the Program to you over other programs or services. Advisory Representatives have the ability to purchase certain securities products outside of an advisory account, but which are held in the client’s advisory account. Though these assets are not subject to the Architect/Structure Program Part 2A – 2024.1 9 Current as of March 28, 2024 advisory account fee, you should be aware that the purchases are subject to commissions or loads which are earned by the Advisory Representative. Illiquid and Alternative Investments There is a $35.00 annual fee charged for registered daily NAV REITs and alternative investments. Surcharge Fees Imposed on Your Account A surcharge of up to $10 is assessed to you for transactions in certain mutual funds. The surcharge applies to each purchase and sale transaction for such mutual funds but excludes exchanges and periodic investments. Upon request, your Advisory Representative will provide you with a list of mutual funds subject to the surcharge fee. This list is subject to change from time to time. For additional information regarding these fees please refer to the Client Fee Disclosure - NFS Clearing located at www.securitiesamerica.com/disclosures . Sweep Program When your Program Account is maintained at one of our clearing firms, NFS, your free credit balance will be automatically deposited or “swept” to a deposit account at one or more banks whose deposits are insured up to applicable limits by the Federal Deposit Insurance Corporation (“FDIC”) (the “Sweep Program”). Under the Sweep Program, SAI maintains two FDIC-insured deposit programs, the Bank Deposit Sweep Program (“BDSP”) and the Insured Cash Account Program (“ICAP”), that create financial benefits for SAI as described below. For certain Program Account types, free credit balances are swept to a money market mutual fund product (the “Money Market Mutual Fund Program”), which does not create financial benefits for SAI. Please see the Sweep Program Terms and Conditions document, available from your Advisory Representative or from the website listed below, for full details about the Sweep Program. As set forth in the terms of your Customer Agreement with SAI, you may remove your Program Account from participating in the Sweep Program by notifying your Advisory Representative. If you remove your Program Account from the Sweep Program, cash balances will be held by the clearing firm as a free credit balance. In addition, there are always alternatives for the short-term investment of cash balances, including non-sweep money market mutual funds, treasury bills, and brokered certificates of deposit, that offer higher returns than the sweep options made available to you. FDIC Insured Deposit Program (BDSP & ICAP) Eligible account types: all accounts except ERISA Title 1 accounts, 403(b)(7), & Keogh plans Free credit balances swept to a deposit account will earn interest that is compounded daily and credited to your Program Account monthly. Interest begins to accrue on the date of deposit with the banks participating in the program (“Program Banks”), through the business day preceding the date of withdrawal from the deposit account. The daily rate is 1/365 (or 1/366 in a leap year) of the posted interest rate. Bank Deposit Sweep Program - BDSP SAI has established deposit levels or tiers which ordinarily pay different rates of interest depending on deposit balances. Generally, Program Accounts with higher deposit balances receive higher rates of interest than accounts with lower balances. The interest rate payable to you is determined by us and is based on the amounts paid by the Program Banks to obtain the deposits. The amount we retain, less a fee paid to our clearing agent and the third-party administrator, will not exceed 600 basis points (6.00%) per year (the “Maximum Program Fee”) on the average daily balances held in the BDSP. Interest paid on the deposit accounts will generally be lower than the rate of return on (i) other investment products that are not FDIC insured, such as money market mutual funds and (ii) on bank deposits offered outside of the BDSP. Your Advisory Representative does not receive any portion of the fees paid by the Program Banks. The income we earn from Program Banks based on your balances in BDSP will in almost all circumstances be substantially greater than the amount of interest you earn from the same balances. As such, we receive a substantially higher percentage of the interest generated by deposit Architect/Structure Program Part 2A – 2024.1 10 Current as of March 28, 2024 balances in the BDSP than the interest credited to your accounts. When evaluating whether to utilize the Sweep Program and the extent to which our fee exceeds the interest rate you receive, you should assume that we are receiving the Maximum Program Fee described above. Insured Cash Account Program - ICAP SAI will receive a monthly per-account fee for services it provides in connection with maintaining and administering the Sweep Program for IRAs held in an advisory/ fee-based account (the “Sweep Account Fee”). The Sweep Account Fee that each Osaic’s affiliated broker-dealer can earn from Program Accounts participating in ICAP is subject to a maximum monthly per account fee that is between $34.25 and $36.75. Please refer to the applicable Sweep Program Terms and Conditions document, which you can obtain from your Advisory Representative or from the website listed below; refer to “Disclosures,” then to the FDIC Insured Deposit Program used in your account (ICAP), for further details about the maximum monthly per account fee. The Sweep Account Fee does not depend on or vary with (and is not affected by) the actual amounts held in any particular account or your Program Account. Thus, our compensation for Program Accounts that participate in ICAP is composed solely of the Sweep Account Fee. The fee received may differ among each Program Bank. You will have no rights to the amounts paid by the Program Banks, except for interest actually credited to your account. The Sweep Account Fee will reduce the interest you are paid on the amount of assets in your Program Account. The Sweep Account Fee will generally be paid by the Program Banks on your Program Account’s behalf; however, the Fee or any portion thereof can be deducted directly from your Program Account if, for example, the amounts paid by the Program Banks are insufficient to cover the Sweep Account Fee. In the event that we debit all or a portion of the monthly account fee from your account, each such amount will be reflected on your account statement. The amount of fees received by SAI, our clearing agent, and any other service provider reduces the interest you receive on your deposit account(s). Your Advisory Representative does not receive any portion of the fees paid by the Program Banks. Money Market Mutual Funds - NFS Free credit balances in the following Program Account types custodied at NFS will be automatically swept into either the Fidelity Government Cash Reserves Fund (FDRXX), or the Fidelity Government Money Market Fund – Capital Reserves Class (FZAXX) (“Fidelity Funds”), which are both managed by Fidelity Investments:
• All ERISA Title 1 account types, including Profit Sharing Plans, 401(k), Roth 401(k), Simple 401(k), Individual 401(k), qualified deferred compensation plans, defined benefit plans, target benefit plans, and money purchase pension plans
• 403(b)(7) accounts
• Keogh plans The Fidelity Government Cash Reserves Fund and the Fidelity Government Money Market Fund are money market mutual funds and seek to maintain a stable share price of $1.00 per share. Both Fidelity Funds invest at least 99.5% of their total assets in cash, U.S. Government securities and/or repurchase agreements that are collateralized fully (i.e., collateralized by cash or government securities). Both Fidelity Funds invests in U.S. Government securities issued by entities that are chartered or sponsored by Congress but whose securities are neither issued nor guaranteed by the U.S. Treasury. Although the Fidelity Funds seek to preserve the value of your investment at $1.00 per share, neither can guarantee they will do so. An investment in the fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. SAI does not receive any compensation from Fidelity Funds. For additional information about the Sweep Program for accounts custodied at NFS please visit our website located at www.securitiesamerica.com/disclosures-sweep-program-resources . Architect/Structure Program Part 2A – 2024.1 11 Current as of March 28, 2024 Material Conflicts of Interest Because the Sweep Program generates significant payments from third parties (i.e., the Program Banks that participate in BDSP and/or ICAP) to SAI, a conflict of interest exists. A conflict of interest also arises because we earn more compensation from cash balances being swept to or maintained in the Sweep Program than if you purchase other investment funds or securities. The more client deposits held in BDSP, and the longer such deposits are held, the greater the compensation we, our clearing firms, and the third-party administrator receive. By investing through an advisory account, the compensation we receive from the BDSP or ICAP, as applicable, is in addition to the advisory fees that you pay. This means that we earn two layers of fees on the same cash balances in client advisory accounts with us. If we did not receive such compensation, which is in addition to advisory, transaction, servicing and other fees and compensation related to Program Accounts, such client fees (including advisory fees) would generally be higher. In addition, a conflict of interest arises as a result of the financial incentive for the Firm to recommend and offer a Sweep Program over which they have control of certain functions. SAI has the ability to establish and change interest rates paid on Sweep Program balances, to select or change Program Banks that participate in the BDSP and ICAP, and to determine the tier levels (if applicable) at which interest rates are paid, all of which generates additional compensation for SAI. The Advisory Representative who makes investment recommendations for your Program Account does not receive any compensation from these payments or based on the selection of the sweep vehicle. The Firm maintains policies and procedures to ensure recommendations made to you by its Advisory Representatives are in your best interest. For more information about this service and benefits that we receive in connection with such deposits, please refer to the Sweep Program terms and conditions document, which you can request from your Advisory Representative. Given the conflicts discussed above, each client should consider the importance of BDSP and ICAP to us when evaluating our total fees and compensation and deciding whether to utilize the BDSP and/or ICAP.