A. The SOA Premier Assets Program The sponsor. SOA Premier Assets is an SEC-registered investment adviser with its principal place of business located in Syosset, New York. David Lerner is the principal owner, founder, and President of SOA Premier Assets. Since 1997, SOA Premier Assets has provided portfolio management services to mutual funds. As of the date of this wrap-fee brochure, SOA Premier Assets offers portfolio management services to individuals (which includes trusts, estates, 401(k) plans and Individual Retirement Accounts (“IRAs”) of individuals and their family members) and high net worth individuals, through a wrap-fee program that it sponsors called the SOA Premier Assets Program (“Program”). While the terms and conditions of wrap-fee programs across the industry vary, their defining, common feature is that program participants pay a single, bundled (or “wrap”) fee for investment management and brokerage services. Program overview. SOA Premier Assets manages discretionary investment advisory accounts through the SOA Premier Assets Program (“Premier Assets Accounts” or “PAAs”) using model investment portfolios (“SOA Premier Assets Strategies” or “Strategies”) and any agreed upon, client-requested modifications to or allocations of the Strategies (together, the “Investment Instructions”). SOA Premier Assets reserves the right to decline or terminate the Premier Assets Account if it determines for any reason that requested modifications or allocations are not reasonable or practicable. SOA Premier Assets only accepts accounts on a discretionary basis (i.e., where the client authorizes SOA Premier Assets to manage his or her account). SOA Premier Assets also does not participate in separately managed account programs and services, and does not utilize third-party portfolio managers. Key program personnel. SOA Premier Assets employs in-house model providers to design and maintain the Strategies (“SOA Premier Assets Strategists” or “Strategists”), and investment adviser representatives (“IARs”) to solicit the Program to prospective clients, maintain client relations, and monitor client accounts. SOA Premier Assets utilizes computer software to maintain the Strategies and IARs input Investment Instructions and any updates thereto into the electronic program to service the PAAs. Some employees have multiple responsibilities for SOA Premier Assets. Key program features. Although the SOA Premier Assets Program provides convenience and other advantages to investors, it is not the right investment program or approach for all investors. SOA Premier Assets encourages all persons interested in the Program to review this brochure carefully and ask their IAR at SOA Premier Assets any follow-up questions. To participate in the Program, clients must adhere or agree to the following: 1. Clients open and maintain a brokerage account at David Lerner Associates, Inc. (CRD#: 5397) (“DLA”). DLA is an SEC-registered brokerage firm and member of FINRA (Financial Industry Regulatory Authority, Inc.) and SIPC (Securities Investor Protection Corporation), and an affiliate of SOA Premier Assets. SOA Premier Assets and DLA share the same principal place of business. Mr. Lerner, who is the owner of SOA Premier Assets, is also the principal owner (voting rights are separately held in an independent trust), founder, former President, and a current employee of DLA. SOA Premier Assets does not allow Program clients to use other brokers to conduct this service. 2. RBC Correspondent Services, Inc. (“RBC”), a division of RBC Capital Markets, LLC (CRD#: 31194), performs clearing, custody, and execution services with respect to the Premier Assets Accounts. 3. The minimum account size to open a PAA is $25,000. In addition, each Strategy has a minimum investment requirement of $25,000, $50,000 or $75,000 (see Strategy descriptions below). Each Strategy maintains a minimum .5% cash balance, which is .5% of the cash and securities under management. 4. SOA Premier Assets has full discretionary authority over the PAA. When clients authorize advisers to have full discretionary authority over their accounts, it means, among other things, that SOA Premier Assets (working through a broker) can buy and sell securities for the PAA without seeking the client’s permission first. 5. Clients pay a single, bundled fee (which is asset-based) for investment management and brokerage services as opposed to separate fees (which may be asset-based or commission-based) for those services. Clients provide written authorization for the bundled fee to be debited from the PAA to cover the fee. The Strategies. Even if a prospective client is willing and able to adhere to the above requirements, he or she may not be a fit for the SOA Premier Assets Programs. To determine fit, SOA Premier Assets requests that prospective clients complete a customer profile which, among other things, gathers client information regarding risk tolerance, investment time horizon, and financial circumstances. Clients should understand that they are fully responsible for providing SOA Premier Assets with complete and accurate information. SOA Premier Assets uses the information provided as-is to determine which SOA Premier Assets Strategy or Strategies (if any) are in the client’s best interest given to the client’s objectives and circumstances. Below are brief descriptions of each SOA Premier Assets Strategy, which the Strategists group by investment minimum. Each Strategy focuses on investments in mutual funds and exchange-traded funds (“ETFs”). Of note, SOA Premier Assets excludes from the universe of possible investments any mutual fund that carries a load or any ETFs that carries a transaction fee or commission at the time of purchase. In short, a no-load fund is a mutual fund in which shares are sold without a commission or sales charge. A no-fee ETF is an ETF for which the broker does not charge a commission or fee to be traded. Such exclusions restrict the universe of securities that the Strategists consider for inclusion in one or more of the SOA Premier Assets Strategies. In addition, SOA Premier Assets excludes from its SOA Premier Assets Strategies any securities issued by its client, Spirt of America Investment Fund, Inc. For information regarding the internal fees and expenses of mutual funds and ETFs, see the subsection below called “Other Fees and Expenses.” $75,000 Minimum Investment Name and Investment Objective Types of Securities in Strategy Equity-Weighted Strategy. Seeks to achieve long-term growth and capital appreciation through diversified investments focused in equity securities.
• Mutual funds and ETFs with portfolios containing small cap, mid cap and large cap issuers (that are defined as having market capitalizations of $1 billion and less, $1 to $5 billion, and $5 billion or more, respectively), as well as growth and value stocks.
• Select mutual funds and ETFs in this strategy may also have portfolio holdings of income-oriented products, including master limited partnerships, dividend paying equities, and preferred securities. Income-Weighted Strategy. Seeks to achieve a consistent stream of income that generates interest and dividends.
• Mutual funds and ETFs with portfolios containing taxable municipal bonds, corporate bonds, treasury securities, preferred securities and dividend paying equities.
• The underlying bond holdings of these funds are evaluated to ensure they have an emphasis on quality, which SOA Premier Assets defines as the underlying bonds having an investment grade rating of “BBB” or higher.
• Select mutual funds and ETFs in this strategy may also have portfolio holdings in equity securities. Balanced Strategy. Seeks to achieve a combination of long- term growth and current income through interest and dividends from diversified investments in fixed
• Mutual funds and ETFs with portfolios containing taxable municipal bonds and corporate bonds, as well as preferred securities and common equities.
• The underlying bond holdings of these funds are evaluated to ensure they have an emphasis on quality, which SOA Premier Assets defines as the underlying bonds having an investment grade rating of “BBB” or higher. income and equity securities.
• The majority of the equity portion of this strategy concentrates on securities that focus on large cap companies ($5 billion or more), as well as growth and value stocks. $50,000 Minimum Investment Name and Investment Objective Types of Securities in Strategy Municipal Tax Advantaged Strategy. Seeks to provide income that is exempt from federal income tax.
• Mutual funds and ETFs with portfolios holding tax-free municipal bonds. These portfolios are evaluated to ensure they have an emphasis on quality, which SOA Premier Assets defines as the underlying bonds having an investment grade rating of “BBB” or higher.
• Select mutual funds and ETFs in this strategy may also have portfolio holdings that focus on state specific, tax free municipal bonds that may provide investors that reside in those states with additional state and local tax exemptions. $25,000 Minimum Investment Name and Investment Objective Types of Securities in Strategy Conservative Strategy. Seeks to provide a conservative investing approach through a selection of mutual funds and ETFs that are focused on the equity and fixed income markets.
• Mutual funds and ETFs with portfolios containing large cap equities ($5 billion or more), as well as growth and value stocks.
• Mutual funds and ETFs with portfolios containing taxable municipal bonds, corporate bonds, treasury securities, preferred securities, and dividend paying equities.
• Select mutual funds and ETFs in this strategy may contain shorter duration, fixed income securities. Moderate Strategy. Seeks to provide a balanced and investing approach by selecting mutual funds and ETFs with a focus on equity and fixed income securities.
• Mutual funds and ETFs with portfolios containing small cap, mid cap and large cap issuers (market capitalizations of $1 billion and less, $1 to $5 billion, and $5 billion or more, respectively).
• Select mutual funds and ETFs in this strategy may also have portfolio holdings of taxable municipal bonds, corporate bonds, treasury securities, preferred securities, and dividend paying equities. Dynamic Strategy. Seeks to provide a more aggressive approach through a selection of mutual funds and ETFs.
• Mutual funds and ETFs with portfolios holding a full range of equity securities as well as sector-specific securities including sectors such as energy, real estate, health care, information technology, and financials.
• Select mutual funds and ETFs in this strategy may also have portfolio holdings of fixed income securities, including taxable municipal bonds, corporate bonds, and treasury securities. Below are brief descriptions for terms that SOA Premier Assets uses when explaining the Strategies. They are not legal interpretations or necessarily comprehensive. SOA Premier Assets encourages all persons interested in the SOA Premier Assets Program to ask their IAR at SOA Premier Assets any follow-up questions.
• Common Equities are instruments that signify an ownership position in a corporation.
• Corporate Bonds are debt securities issued by a corporation in order to raise financing for a variety of reasons such as funding, ongoing operations, mergers and acquisitions, or to expand business.
• Dividend Paying Equities are stocks that regularly pay a sum of money to shareholders out of its profits or reserves.
• Exchange-Traded Funds (ETFs) are a type of an investment company (either an open- end company or unit investment trust) that differs from traditional mutual funds, because shares issued by ETFs trade on a secondary market and are only redeemable by authorized participants such as large broker-dealers from the fund itself in very large blocks (blocks of 50,000 shares, for example) called creation units.
• Growth Stocks are companies whose earnings are expected to grow at above-average rates relative to the market and may choose to reinvest retained earnings instead of paying a dividend.
• Master Limited Partnerships (MLPs) are limited partnerships traded on public exchanges just like corporate stock. MLPs engage in business activities that primarily exist in the energy industry.
• Mutual Funds are professionally managed investment programs funded by shareholders for the purpose of purchasing a collection of stocks, bonds, or other securities.
• Preferred Securities are stocks that entitle the holder to a fixed dividend, whose payments take priority over the dividends of common stock.
• Sector-Specific Securities refer to mutual funds and ETFs that invest a high concentration of their holdings in one of the sectors of the S&P 500.
• Taxable Municipal Bonds are debt securities issued by a local government such as a city or county or related agencies that pay federally taxable interest.
• Tax-Free Municipal Bonds are debt securities issued by a state, municipality or county to finance its capital expenditures and projects for the public good that pay federally tax exempt interest.
• Treasury Securities are bonds issued by the U.S. federal government.
• Value Stocks tend to trade at a lower price relative to their fundamentals and are commonly characterized as having a high dividend yield, low price-to-book ratio and/or a low price-to-earnings ratio. In selecting and updating the investments for each Strategy, SOA Premier Assets follows certain standard methods of analysis. Specifically, the Strategists research possible investments and, before including them

in a Strategy, analyze the holdings and/or financial data applicable to the investment. With respect to potential mutual fund investments for the SOA Premier Assets Strategies, the Strategists seek to invest in funds with assets under management of at least $1 billion; lower than average expense ratios; a history of performance; holdings that are primarily U.S.-issued securities; and that do not utilize leverage or derivative products to achieve investment returns. With respect to index-based ETFs, the Strategists seek to invest in ones that consistently track U.S.-focused indices (e.g., S&P 500) do not utilize leverage as a core investment strategy of the ETF; and have lower expense ratios. Another factor taken into consideration is the history of the firm sponsoring the mutual fund or ETF. SOA Premier Assets generally assumes for purposes of selecting investments for SOA Premier Assets Strategies that the investment, if selected, will remain in the Strategy for the long- term, which SOA Premier Assets generally defines as one year or more. Investing in securities involves risk of loss that all investors, including participants in the SOA Premier Assets Program, should be prepared to bear. For information regarding the types of risks presented by the Program and the types of investments that SOA Premier Assets makes for investors therein, see Item 6 herein. B. The Wrap Fee The fee schedule. Investors in the SOA Premier Assets Program pay an annual bundled fee (the “Wrap Fee”) that covers investment advice (from SOA Premier Assets), introducing brokerage services (from DLA), and clearing, custody, and execution services (from RBC). As of the date of this wrap-fee brochure, DLA does not charge for these introducing brokerage services or receive any portion of the Wrap Fee for providing introducing brokerage services. The amount of the Wrap Fee varies depending on the amount of cash and securities that the investors place under management through the SOA Premier Assets Program (see tiered-schedule below). SOA Premier Assets Program Wrap Fee Schedule Assets under Management In the SOA Premier Assets Program Percentage $25,000 – $99,999 1.67 $100,000 – $499,999 1.62 $500,000 – $999,999 1.52 $1,000,000 – $2,499,999 1.40 $2,500,000 and Over 1.25 Here is an example for how to read the above schedule. A client with $600,000 in his or her PAA will be charged 1.67% on the first $99,999 of the $600,000, 1.62% on the next $400,000, and 1.52% on the remaining $100,001. The Wrap Fee is negotiable. Specifically, IARs are permitted to negotiate the Wrap Fee with clients. If the IAR is willing to reduce the Wrap Fee for a client, the IAR must obtain approval from SOA Premier Assets. SOA Premier Assets encourages all persons interested in the SOA Premier Assets Program to ask their IAR at SOA Premier Assets any follow-up questions, including questions with respect to the Wrap Fee. Clients should be aware that SOA Premier Assets pays a portion of the Wrap Fee directly to the IARs. The portion of the Wrap Fee paid to the IARs is no more than 60 basis points of the Wrap Fee (i.e., no more than approximately 36% of the Wrap Fee) with respect to the Premier Assets Accounts that the IAR serves. No portion of the Wrap Fee is paid directly to the Strategists; rather, for their work, the SOA Premier Assets Strategists receive a salary. SOA Premier Assets employees are eligible for discretionary bonuses. Where an employee is eligible, and as applicable, SOA Premier Assets considers, among other criteria, the overall financial performance of SOA Premier Assets, the employee’s adherence to SOA Premier Assets’ policies and procedures, and (as permitted by law) the amount of assets in the PAAs that the employee serves. Neither SOA Premier Assets nor its personnel receive compensation from a third party, directly or indirectly, including (without limitation) asset-based sales charges or service fees, from the purchase or sale of mutual funds, ETFs, or any other investments in the SOA Premier Assets Strategies. SOA Premier Assets and DLA personnel (and related family members) with Premier Assets Accounts pay a reduced Wrap Fee. Quarterly, advance, debited payments. As part of the documentation they sign to open an account, SOA Premier Assets Program participants provide written authorization for their Wrap Fee to be debited from their brokerage accounts in advance of services rendered. The Wrap Fee is not debited all at once. Rather, several debits occur throughout the year, as described below. No debit occurs more than three months in advance of the services rendered. Calculating the first payment. The first payment covers the initial quarter (pro rata) and the second quarter, in advance. To determine what the client owes for the second quarter, an independent pricing service determines the market value (or if none, the fair market value) of the cash and securities that the client has under management through the SOA Premier Assets Program at the close of business on the last business day in the initial quarter. The pricing service takes that amount and multiplies it by the percentage(s) that is or are applicable under the tiered-fee schedule (see above chart), and then multiplies the resultant amount by one-quarter of the annual percentage. To determine what it owes for the initial quarter, the pricing service pro-rates this amount for the days in the initial quarter. Calculating the subsequent, quarterly payments. To determine what the client owes for each subsequent quarter, an independent pricing service determines the market value (or if none, the fair market value) of the cash and securities that the client has under management through the SOA Premier Assets Program at the close of business on the last business day in the quarter. The pricing service takes that amount and multiplies it by the percentage(s) that is or are applicable under the tiered-fee schedule (see above chart), and then multiplies the resultant amount by one- quarter of the annual percentage. This figure is how much the client owes for its quarterly Wrap Fee payment. Termination of investment advisory services. At any time, a client may terminate its participation in the SOA Premier Assets Program by providing written notice to SOA Premier Assets. Upon such notice, SOA Premier Assets ceases providing discretionary management services. SOA Premier Assets automatically returns to the client the difference between the amount the client was charged in advance for the calendar quarter and the remaining days of the quarter post-termination. Combining Accounts. If a client has cash and securities in more than one PAA, SOA Premier Assets uses the combined value of those assets across the accounts to determine where the client falls on the tiered Wrap Fee schedule. Account Statements and Fees. RBC, as the custodian for the PAA, delivers the account statements to the client or its designated contact. These deliveries occur no less frequently than quarterly. The account statements show the deduction of the Wrap Fee from the account. These deliveries occur no less frequently than quarterly. The statements detail the account value on which the Wrap Fee was based and the amount charged. Clients are advised to review their statements, and to promptly report any inaccuracy or discrepancy to SOA Premier Assets. C. Other Fees and Expenses Fund fees. As with any business, running a mutual fund or ETF involves costs. Funds pass these costs along to investors by charging fees and expenses. Typically, mutual funds and ETFs pay themselves for these costs with fund assets; in other words, the funds do not request payment from shareholders directly. For information regarding the actual internal fund costs that investors in the Program incur, investors should review the prospectus or other applicable offering documents for each investment product in which they invest. Such costs include (for example) investment management fees, distribution (12b-1) fees, shareholder servicing fees, transfer agency fees, networking fees, legal accounting fees, marketing support payments, administration fees, custody fees, expense reimbursements, expenses associated with executing securities transactions for the investment product’s portfolio, and redemption fees. A fund with higher costs must perform better than a lower-cost fund to generate the same returns for investors. Fund costs can significantly reduce investor returns, particularly over time. Tax liabilities. The Program is not responsible for any tax liabilities that result from the purchase and sale of securities in the PAA or the purchase and sale of securities within the mutual funds and ETFs in which the Strategies invest. SOA Premier Assets does not provide tax advice. Investors should consider consulting tax and legal advisors. Miscellaneous costs. The Program reserves the right to charge or pass on to clients any other fees and expenses that are unique to a client’s account and activity. Such costs include (without limitation) servicing fees such as termination fees, fees that apply to the transfer of assets between financial institution accounts, fees that apply to the transfer of cash between financial institution accounts, IRA account maintenance fees, and mark-ups, mark-downs, or spreads paid to market-makers. D. Alternative Fee and Expense Arrangements It is important that all participants in the SOA Premier Assets Program understand that the total cost of the Program (see above) may be higher or lower than the total cost the investor would incur if he or she purchased the same or similar services (i) through a wrap-fee program sponsored by a different investment adviser or (ii) separately from each service provider (e.g., paying a separate adviser fee, broker fee, and custodian fee). To assess the overall cost of any program or approach (e.g., bundled or unbundled services, asset-based or commission-based fees), investors should understand at minimum the investment strategies offered, the types of investments that will be made, and the amount of anticipated trading activity. Relative transaction infrequency, for example, may bear on whether a wrap, asset-based fee account is more appropriate for an investor than a commission-based account. SOA Premier Assets places no restrictions on investors contacting SOA Premier Assets IARs to discuss questions regarding the SOA Premier Assets Program, including questions regarding the fees and expenses of the SOA Premier Assets Program relative to other investment options. E. Financial Incentives and Material Contracts SOA Premier Assets and DLA are affiliates. As of the date of this wrap-fee brochure, they have two contracts that are material to a prospective client’s evaluation of the Program. The referral agreement. SOA Premier Assets has established financial incentives for DLA to recommend the SOA Premier Assets Program to its existing clients. Specifically, SOA Premier Assets compensates DLA with a referral fee for DLA referring an existing client of DLA to the SOA Premier Assets Program. The referred client must enter into an investment advisory agreement with SOA Premier Assets for SOA Premier Assets to owe DLA a referral fee. Of note, the DLA personnel making the referral, under most circumstances, is also the SOA Premier Assets IAR who receives the referral. While DLA does not share the referral fee it receives from SOA Premier Assets with the DLA person who makes the referral, DLA personnel are aware that their employer has the opportunity to earn these fees and thus could cause referrals to be made for reasons other than the best interest of the referred investor. Additionally, DLA personnel are aware that the number of referrals they make will be a factor taken into consideration by DLA when determining non-cash bonuses and incentives and/or awards to, DLA personnel during the year, which could also cause referrals to be made for a reason other than the best interest of the referred investor. SOA Premier Assets agreed to pay this fee to DLA to assist SOA Premier Assets in establishing its customer base. The fee does not exceed 10% of the Wrap Fee for as long as the cash and securities remain under management in the SOA Premier Assets Program or three (3) years, whichever period is shorter. SOA Premier Assets pays for these referrals out of its total revenues. The opportunity for DLA to earn money, and DLA personnel to earn awards, may cause DLA and/or persons working for DLA to recommend the SOA Premier Assets Program to investors over other investment advisory programs or services, even where the SOA Premier Assets Program is not in the best interest of the investor. To mitigate this potential conflict, SOA Premier Assets (1) follows its new client intake procedures, which include (among other things) a determination of whether a wrap, asset-based account is or may be better or worse for the client than a commission-based fee brokerage account, and (2) provides a copy of this brochure to investors before it enters into an investment advisory agreement with an investor. SOA Premier Assets also has adopted policies and procedures that direct the Chief Compliance Officer of SOA Premier Assets (the “CCO”) or his or her designee to review the documentation in the account files for SOA Premier Assets Program participants for legal and regulatory compliance, including compliance with SOA Premier Assets’ fiduciary duties owed to clients. Expense and reimbursement arrangement. SOA Premier Assets and DLA have entered into an expense and reimbursement arrangement pursuant to which SOA Premier Assets utilizes certain services and assets such as office space of DLA for which it reimburses DLA at cost or a reasonable approximation of such cost. SOA Premier Assets shares offices with DLA.