D.A. Davidson & Co. ("D.A. Davidson", the “Firm”, or “we”), a wholly-owned subsidiary of D.A. Davidson Companies, a financial services holding company, is a dually registered investment adviser and broker-dealer with its principal place of business located in Great Falls, Montana. This ADV 2A Firm Brochure (the “Brochure”) describes the advisory services offered by D.A. Davidson through its Financial Advisors and other investment professionals in the areas of Retirement Plan Services, and Financial Planning Services. This includes important information concerning the fees, conflicts of interest, and other information clients should consider at or prior to entering into an agreement with D.A. Davidson for such services. In addition, this Brochure provides certain information about advisory services provided to The Concordant Fund, a private fund, offered only to sophisticated, qualifying investors. All discussions of The Concordant Fund in this Brochure, including, but not limited to, its investments, the investment strategies implemented on behalf of The Concordant Fund, the fees and other costs associated with an investment in The Concordant Fund, and conflicts of interest inherent in D.A. Davidson’s management of The Concordant Fund, are qualified in their entirety by reference to The Concordant Fund’s confidential private placement memorandum and governing documents (referred to collectively as the “Concordant Fund Offering Documents”). The information contained in this Brochure is current as of the cover date and is subject to change at D.A. Davidson’s discretion. Please retain this Brochure for your records. D.A. Davidson also acts as a portfolio manager and/or sponsors several wrap fee programs for which it receives a fee for its services described in a separate brochure, called a “Wrap Fee Program Brochure”. The Wrap Fee Program Brochure provides details on, among other things, the wrap fee programs and services, program fees, and conflicts of interest for each program. You may obtain a copy of that brochure by contacting your Financial Advisor, by mailing your request to 8 Third Street North, Great Falls, MT 59401, Attn: Compliance Department, or by calling 406-727-4200 or 800-332-5915. You may also obtain a copy of that brochure and other important disclosures online at dadavidson.com/Disclosures. Clients are also encouraged to carefully consider the differences between brokerage and investment advisory services including D.A. Davidson’s obligations, costs, and the need for the services provided. For additional information, please review the Firm’s Form Client Relationship Summary (“Form CRS”), which provides information about the differences between brokerage accounts and advisory accounts. Generally, the Firm and its Financial Advisors have an incentive to recommend investment advisory services over brokerage services because the Firm and Financial Advisor receive higher fees for advisory services than brokerage services, and higher fees for some advisory programs than others. The Firm requires its financial professionals to consider a number of factors, such as the type and level of services required and the expected trading frequency, before recommending an account type to a retail client. This is intended to help ensure that the Firm’s account type recommendations to clients are reasonably expected to be cost-effective choices in light of their investment services and needs. Additionally, the Firm does not impose requirements on how many accounts a financial professional must have that are brokerage accounts or advisory accounts, nor incentivize the decision through differential compensation. SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE Advisers Act Fiduciary Duty. As a registered investment adviser, D.A. Davidson is subject to a fiduciary duty under the Investment Advisers Act of 1940 (the “Advisers Act”), which includes both a duty of care and a duty of loyalty (referred to in this Brochure as the “Advisers Act Fiduciary Duty”). This means D.A. Davidson and D.A. Davidson’s registered investment advisors (each, a “Financial Advisor,” and collectively, “Financial Advisors”) are required to act in the client’s best interest when providing advisory services, including those described in this Brochure. The duty of care requires, among other things, for D.A. Davidson and its Financial Advisors to seek best execution and to provide advice that is in the client’s best interest based on the client’s investment objectives, risk level, investment time horizon, financial information and other circumstances (collectively, client’s “Investment Profile”) or mandate. The duty of loyalty requires D.A. Davidson to provide full and fair disclosure of, and obtain client’s consent to conflicts of interest. The duties also require D.A. Davidson to monitor accounts when providing certain advisory services based on the terms of the agreement between D.A. Davidson and a client. Special Rules for Retirement Accounts. When it comes to retirement and other qualified accounts, including employer-sponsored plans (“plans”), individual retirement accounts (“IRAs”), SEP IRAs, SIMPLE IRAs, Keogh plans, Coverdell educational savings accounts, and other similar accounts (collectively, “retirement accounts”) we are “fiduciaries” under Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (the “Code”), when we provide investment advice or manage a client’s account. ERISA and the Code limit the types of products and services D.A. Davidson can offer and provide with respect to retirement accounts. When making recommendations that clients open, rollover or transfer retirement account assets to an advisory account and change account types, the Firm relies on Prohibited Transaction Exemption (“PTE”) 2020-02, which allows D.A. Davidson, its financial professionals and affiliates to earn variable compensation for such recommendations subject to certain conditions. PTE 2020-02 requires D.A. Davidson to act in client’s best interest and not put their interest ahead of clients’ interests when providing these recommendations (“fiduciary acknowledgement”). Under the PTE 2020-02, D.A. Davidson and its financial professionals must also:
• Meet a professional standard of care (give prudent advice);
• Not put the Firm’s financial interests ahead of client’s (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that the Firm and its financial professionals give advice that is in client’s best interest;
• Charge no more than is reasonable for the Firm’s services; and
• Give the client basic information about conflicts of interest. This fiduciary acknowledgment does not create or modify a contractual obligation, or fiduciary status or obligations under state law. This fiduciary acknowledgement does not apply to federal, state, local, non-US or other types of workplace employee benefit plans that are subject to laws other than ERISA or Section 4975 of the Code. The above acknowledgement applies solely with respect to the following recommendations for advisory accounts (“Covered Recommendations”), as may be applicable:
• Roll Out Recommendations. From time to time, the Firm in coordination with client’s financial professional (and a centralized review team) will provide a written recommendation that client roll out assets from a plan to an IRA, from an IRA to a plan, or from a plan to a plan.
• Account Type Recommendations at the Firm. From time to time, the Firm or client’s financial professional will recommend that client open a brokerage or advisory IRA, transfer money between brokerage and advisory IRAs, or transfer money from one wrap fee program or portfolio to another within an advisory IRA. Under the Firm’s wrap fee programs the financial professional may recommend that client engage the services of an investment manager for their advisory IRA, which may include one of D.A. Davidson’s affiliates. The above acknowledgement does not apply to other suggestions, recommendations and services the Firm and its financial professionals provide, and are governed exclusively by the terms of clients’ other agreements with, and disclosures from, the Firm, as may be applicable. D.A. Davidson refers to these as “Excluded Recommendations and Transactions.” Excluded Recommendations and Transactions refer to communications that are not reasonably intended to be viewed or construed as an individualized/personalized suggestion for client to take a particular course of action with respect to their retirement accounts (“General Information and Education”) or that are otherwise not to be treated as Covered Recommendations under this disclosure, including, but not limited to:
• General Information and Education about the financial markets, asset allocations, financial planning illustrations and the advantages and risks of particular investments;
• General Information and Education materials about issues and alternatives that should be considered when deciding whether to roll out or transfer retirement account assets to the Firm;
• Transfers of IRA assets held at a financial service company other than the Firm (including directly with an investment product sponsor);
• Recommendations about investments in accounts that are not retirement accounts (i.e., taxable accounts) client maintains with D.A. Davidson or accounts held at other financial institutions;
• Transactions clients enter into without a recommendation from D.A. Davidson or its financial professionals, or that are contrary to, or inconsistent with, their recommendation;
• Ongoing recommendations of securities or other transactions or discretionary investment advice through a wrap fee program (other than Account Type Recommendations), except as otherwise agreed to in writing in such wrap fee program’s applicable agreements or disclosures;
• Recommendations or investment advice that the Firm provides to clients with respect to an account that they have at the Firm, which clients choose to implement in another account or at another financial services company without the Firm’s written consent; and
• Recommendations that are not fiduciary “investment advice” as defined in Department of Labor regulation section 2510.3-21 (i.e., investment advice for a fee or other compensation rendered on a regular basis pursuant to a mutual understanding that such advice will serve as a primary basis for client’s investment decision, and that will be individualized to the particular needs of client’s retirement account) The Best Interest Standard and Reasonable Compensation. The best interest standard under both the Advisers Act Fiduciary Duty and PTE 2020-02 does not require that D.A. Davidson guarantee the performance of any investment or that client’s investment objectives will be achieved. In addition, D.A. Davidson and its financial professionals may provide recommendations and take actions in connection with the accounts of other clients that may differ from the recommendations and services provided to client. There may be times when D.A. Davidson is legally prohibited from making a recommendation that may be otherwise considered to be in client’s best interest, such as due to insider trading. Client understands any recommendations

D.A. Davidson or its financial professionals make will reflect the information client provides to the Firm about their investment objectives, risk level, investment time horizon, financial information and other circumstances and D.A. Davidson will not be responsible for any information client omits or fails to provide, including changes thereto. D.A. Davidson and its financial professional’s recommendations and advice will also reflect any limitations client imposes, including through applicable investment restrictions and guidelines. Clients are responsible for notifying D.A. Davidson and their financial professionals if their investment objectives, risk tolerance and financial circumstances change. D.A. Davidson and its Financial Advisors will not be responsible for clients’ decision to invest or transfer their IRA or employer sponsored retirement plan assets in a manner that is different from, or inconsistent with, D.A. Davidson’s recommendations or other advice and guidance, and clients assume the risk of such decision, nor will D.A. Davidson or its financial professionals be responsible for clients’ delay in implementing a recommendation. Reasonable compensation under retirement laws has generally been determined based on the compensation paid or received in an arm’s-length transaction considering the nature and extent of all services (including products, features and benefits) provided. This standard does not require D.A. Davidson to offer its services at the lowest cost, or for the least compensation, in the marketplace, or that it offer its services to clients at the same or lower cost or compensation levels than it offers them to other clients, including similarly situated clients. Certain clients may have negotiated lower fees and compensation for their advisory services than others. By entering into an agreement with D.A. Davidson, client agree that they believe the fees and other compensation payable for the Firm’s services are reasonable in light of the totality of the services provided. If client decide not to use all or some of the services made available, client agrees the Firm has no obligation or responsibility to reduce or lower its fees and compensation during the period those services are available. If client wants to change the services the Firm makes available to them, or have any concerns regarding the level of fees their retirement account pays or D.A. Davidson’s compensation, clients should contact their financial professional immediately. DESCRIPTION OF SERVICES Retirement Plan Services D.A. Davidson’s Retirement Plan Services group and Financial Advisors provide services to employer sponsored retirement plans subject to the Employee Retirement Income Security Act ("ERISA"), (“ERISA covered plans” or “Plans”). Examples of Plan services offered include:
• Assistance in preparing and monitoring investment policy statements (IPS) for compliance with ERISA requirements and the plan’s cash flow needs;
• Recommending plan investments, including Qualified Default Investment Alternative (QDIA), in accordance with the Plan’s IPS, or investment mandate;
• Reviewing quarterly/annual fund management and performance versus benchmarks;
• Plan expense and comparative analysis to industry averages; and
• Vendor reviews and selection assistance. Services are provided pursuant to ERISA Rules 3(21) or 3(38) and a written agreement with the Plan sponsor or trustee (the “Plan Fiduciary”). Investment recommendations made to the Plan Fiduciary are limited to open end mutual funds. The Plan Fiduciary may also impose restrictions on certain funds or limit the number of funds available to Plan participants. As an ERISA 3(21) Investment Advisor, D.A. Davidson is a co-fiduciary to the Plan and provides non-discretionary investment recommendations to the Plan Fiduciary. The Plan Fiduciary, however, retains final decision-making authority for the investments and may accept or reject D.A. Davidson’s investment recommendations. As an ERISA 3(38) investment adviser, D.A. Davidson has discretionary authority and is responsible for the selection, monitoring and replacement of investment options. In this case, D.A. Davidson is authorized to implement and effect investment advice without the Plan Fiduciary’s prior authorization. When an ERISA 3(38) investment adviser is appointed, the Plan Fiduciary is relieved of its fiduciary responsibility for the investment decisions, but retains the duty to monitor the ERISA 3(38) activities to assure they are properly performing the agreed upon tasks using the agreed upon criteria. In addition, ERISA 3(21) and 3(38) services are offered to Plan participants pursuant to separate service agreement between D.A. Davidson and Plan fiduciaries that wish to add a brokerage or investment advisory option for Plan participant directed accounts. Such services are provided to the Plan and Plan participants under a separate written agreement and are described further in D.A. Davidson’s Regulation Best Interest Disclosures or the Wrap Fee Program Brochure, respectively. Financial Planning Services D.A. Davidson provides financial planning services to clients and prospective clients through its Wealth Planning Group and Financial Advisors who are Series 65 or 66 licensed, and have received and have ongoing access to financial planning training and support from the Wealth Planning Group. Financial Advisors who are CERTIFIED FINANCIAL PLANNERTM certificants, and/or meet specified tenure, licensing, and training requirements may be permitted (at the discretion of D.A. Davidson management and the Wealth Planning Group) to charge a one-time fee for financial planning services. Depending on a client’s specific needs and goals,, financial planning services may include a wide spectrum of services to meet a client’s wealth or financial planning needs through the creation of a Financial Plan. The Financial Plan will generally evaluate a client’s retirement savings, and cash flow needs, as well as address certain aspects of their insurance needs. In addition, a Financial Plan may address a client’s estate and wealth planning needs, such as wealth accumulation and preservation strategies, the transfer of wealth, charitable pursuits, risk management, insurance planning, and tax awareness. Estate plan analysis should not be considered tax or legal advice and clients are urged to consult their tax and legal professionals about the tax and legal consequences of any specific estate planning strategy. Clients or prospective clients may engage D.A. Davidson, either through their Financial Advisor or the Wealth Planning Group, for a finite period of time in connection with the preparation and delivery of a Financial Plan or financial planning services. Financial planning services may be provided at no charge or for a one-time fee, at the discretion of the Financial Advisor. All Financial Planning Engagements with D.A. Davidson’s Wealth Planning Group professionals or licensed Financial Advisors are episodic.
• No-cost financial planning services begin with the verbal agreement to engage in the financial planning process and terminate with the delivery of the financial plan or 90 days after the start of the financial planning relationship, whichever is earlier. A client may also request and engage in a subsequent plan review or update, which is a new planning engagement subject to the same process and timeline.
• Paid financial planning services commence with the client entering into a Financial Planning Engagement Agreement (the “Agreement”). The Agreement explains that the client is hiring D.A. Davidson, either through their Financial Advisor or the Wealth Planning Group, for a finite period of time in connection with the preparation and delivery of a Financial Plan or financial planning services. The financial planning relationship will commence with the client’s signature on the Agreement and end upon the delivery of the Financial Plan to the client, or 90 days after the start of the financial planning relationship, whichever is earlier. If the financial planning relationship ends because 90 days elapse and the Financial Plan has not been delivered to the client, a new engagement letter will need to be signed by the client in order for the process to continue. A client may also enter into a new agreement for a subsequent review and delivery of a new Financial Plan. Clients who engage D.A. Davidson for financial planning services provide certain information for D.A. Davidson to evaluate the client’s financial needs, goals and other information and to provide any recommendations set forth in the Financial Plan. This generally involves a discovery interview with the client, a financial planning questionnaire, and collection of other documentation. The content of a Financial Plan will depend on the specific needs and circumstances of the client, as well as the information that is provided. The Financial Plan will then set forth recommendations intended to assist the client in reaching their financial goals, needs, and objectives as understood by D.A. Davidson during the particular point in time when it is prepared. Any recommendations made under the Agreement are general in nature and do not include any specific investments or insurance products. Clients are not required to transact business through D.A. Davidson to implement the Financial Plan and D.A. Davidson does not assume any responsibility under the Agreement to implement or monitor the recommended. However, at the client’s request, and pursuant to a separate written agreement, D.A. Davidson will assist the client in implementing the Financial Plan through other investment advisory or brokerage account services. Please see the Wrap Fee Programs section below for further information on the wrap fee programs offered by D.A. Davidson, further described in D.A. Davidson’s Wrap Fee Program Brochure and Regulation Best Interest Disclosures, respectively. The Concordant Fund D.A Davidson is the manager of and adviser to Concordant Partners, LLC (“The Concordant Fund” or “The Fund”) a limited liability company organized in the state of Nebraska. The Concordant Fund is managed for D.A. Davidson by Bradley L. Knuth, Curtis K. Lane, and Clinton T. Rushing. The Concordant Fund’s investment objective is to achieve a high total return through investments in and trading of publicly traded securities, primarily, but not exclusively, shares of common stock. The Fund description and related information disclosed in this brochure are included for informational purposes only and is not an offer to sell or a solicitation to purchase interest in or “units” of The Fund. Only sophisticated qualifying investors may invest in The Concordant Fund. ASSETS UNDER MANAGEMENT As of September 30, 2022, D.A. Davidson has approximately $49,300,000 in regulatory assets under management on a discretionary basis for The Concordant Fund. In addition, as of September 30, 2022, D.A. Davidson has approximately $23,892,500,000 in regulatory assets under management for its wrap fee programs. Approximately $21,318,600,000 of which was managed on a discretionary basis and $2,573,900,000 of which is managed on a non-discretionary basis. Further, information concerning D.A. Davidson’s wrap fee programs is included in the Firm’s Wrap Fee Program Brochure and is available upon request.