A. United Planners
1. Introduction:
United Planners Financial Services, (United Planners, UP, Firm, we, us, or our) is a national
wealth management firm that is registered with t
he Securities and Exchange Commission (SEC) as an
Investment Advisor (IA) and a Broker-Dealer (BD). United Planners is also a member of the
Financial Industry
Regulatory Authority (FINRA) and th
e Securities Investors Protection Corporation (SIPC). United Planners
offers advisory and brokerage services and the related fees and costs to each service varies depending on
the capacity in which you engage our services, so it is important to know the differences. Given the importance
of these details, United Planners encourages you to review
Investor.gov/CRS to access free and simple tools
to research firms and financial professionals in our industry as well as get access to educational materials
about IAs, BDs, and investing. United Planners has been a BD since 1987 and an IA since 2000.
2. UP Disclosure Brochure and Relationship Summary: This UP Disclosure Brochure is a detailed document
that describes eighteen (18) different material aspects of our business (per the Table of Contents on previous
page). This UP Disclosure Brochure can be a lot of information to digest. Therefore, United Planners also
has a Relationship Summary to provide a higher-level overview on just five (5) core aspects of our business,
which is intended to be a lighter read. Collectively, these informational reference documents (UP Disclosure
Brochure and Relationship Summary) are designed to help you understand the nature of our business and
the products and/or services that United Planners can offer you to meet your financial needs. To obtain a
copy of this Relationship Summary, please go to the following websites:
a. United Planners
: https://unitedplanners.com/investors/#section=investor-information
b. SEC
: https://adviserinfo.sec.gov/firm/summary/20804
3. Corporate Structure and Ownership: United Planners is a privately owned Limited Partnership structured
as follows:
a. General Partner: The General Partner is United Planners Group, Inc. (UPG), who owns 45% of United
Planners and is charged with overall management of United Planners*. UPG is owned and managed by
the following shareholders:
i. Michael A. Baker, President and CEO
ii. Billy Oliverio, Executive Vice President and Chief Marketing Officer
iii. Chad Shindel, Executive Vice-President and Chief Financial Officer
iv. Sheila Agasi, Executive Vice President-Chief Revenue Officer
b. Limited Partners: Certain Financial Professionals (as defined below in 4.B.1.) of United Planners are
Limited Partners of United Planners. This group of Financial Professionals own 55% of United Planners.
*United Planners also manages a profit interest entity to enable qualified employees to share in 5% of the
profits to attract and retain talent.
4. Assets Under Management: As of December 31, 2023, United Planners had a total of $9,326,336,708 in
Assets Under Management (AUM). The following is breakdown of this AUM:
a. $482,632,391 in discretionary AUM
b. $8,843,704,317 in non-discretionary AUM
B. Financial Professionals
1. United Planners provides IA services through its Financial Professionals, who are Investment Advisor
Representatives (IARs) under our IA. Since United Planners is a dual-registrant (as described above in
4.A.1.), our IARs are also Registered Representatives (RRs) of United Planners in its BD capacity. Our IARs
are appropriately licensed, qualified, and authorized to provide advisory services nationwide.
2. IARs are independent contractors and may be involved in other business activities including, but not limited
to: insurance services, estate planning, tax preparation, business consulting, and employee benefit services.
Complete information regarding a particular IAR’s other business activities and interests are disclosed in the
respective IAR’s Form ADV Part 2B. In some cases, an IAR may have a DBA (Doing Business As) Name
that he/she operates under and in certain cases, United Planners may add that DBA Name to our Form ADV
for marketing purposes.
3. The specific types of advisory services to be provided to you will be determined between you and the IAR.
IARs may not provide all advisory services available from United Planners. However, the advisory services
provided to you will be based upon your individual financial needs and objectives, which may be different than
the advisory services provided to other clients.
4. Transition Support via Loans and Non-Loans to IARs: On occasion, UP may provide transition support to
IARs as part of the process to recruit an IAR to join United Planners. This transitional support may create a
conflict of interest for IARs in determining which BD and/or IA to join. Transition support is in the form of
money to help the IAR with the fees and costs that the IAR incurs when changing from one BD or IA to another.
This transition support helps the IAR offset some of these transition costs, which may include, but are not
limited to: registration fees, licensing fees, account transfer and/or termination fees, insurance costs, and other
internal affiliation fees. The type and amount of this transitional support is unique to each individual IAR based
on various facts and circumstances. There are two ways that transitional support is provided:
a. Loans: United Planners may provide an IAR a forgivable or non-forgivable loan to pay for transitional
costs. These loans are either repaid by the IAR or forgiven by United Planners based on the IAR satisfying
the terms and conditions of the loan.
b. Non-Loans: United Planners may pay certain fees and/or costs or waive certain fees and/or costs that
the IAR would incur to transition to United Planners and the IAR is not required to repay United Planners
for covering such transitional fees and/or costs.
The receipt of such transitional support (as described above) requires the IAR to agree to specific terms and conditions
such as the requirement to maintain their affiliation with United Planners, comply with United Planners’ policies and
procedures, and generate revenue for United Planners. Regardless of whether an IAR received transitional support or
not, the IAR has a fiduciary obligation to act in the best interests of the clients and the IAR’s activity is supervised and
monitored by United Planners supervisory and compliance staff. IARs who receive transitional support from United
Planners are required to disclose the receipt of such transitional support on their respective Form ADV Part 2B.
C. IARs Can Offer and Provide the Following Investment Advisor Services
1. Financial Planning and Consulting Services
a. Financial Services Firms: In providing financial planning and consulting services to you, your IAR may
utilize one or more of the several programs that United Planners has authorized through relationships
with other financial services firms that are financial technology companies. United Planners has
agreements with these financial services firms to provide various services, including but not limited to:
financial planning services, risk assessment services, and investment research services, which are further
described as follows:
i. Financial planning services that involve the development of financial plans (whether it be goals-
based, or cash-flow based).
ii. Risk assessment services that involve the measurement of client risk (i.e., risk tolerance at
household or account level) and investment risk at the security level or strategy level.
iii. Investment research that involves the analysis of securities and/or strategies.
b. Financial Planning and Consulting Services: Pursuant to a
Financial Planning and Consultation
Services Agreement, your IAR will meet with you, whether you are an individual or business entity, to
gather important financial information including but not limited to: outline financial goals, identify potential
financial problems, assess investment risk tolerance, and define investment objectives based on the
specific needs. Areas for financial planning and consulting for individuals and businesses may include
but are not limited to: cash flow management, budgeting, insurance/risk management, financial strategies,
investment modeling, portfolio construction, portfolio rebalancing, taxes, education savings, social
security, charitable strategies, retirement income planning, retirement and/or estate planning. Areas for
discussion and planning for businesses may focus on cash flow management, taxes, employee benefits
and/or succession planning. IARs will gather specific financial information from you to provide you with
a written financial plan and/or provide ongoing consulting services. Generally, such financial planning
and consulting services involve the preparation and delivery of a financial plan. However, in other cases
this service can also be to merely provide you various financial analyses through various reports on topics
such as asset allocation, insurance/risk assessments, financial review/assessment, social security
optimization, retirement income planning, securities analysis, cash flow analysis, budgeting, etc. Or, in
other cases, the service can also be to merely provide you advice, insights and guidance to consult you
on your financial needs, circumstances and objectives in conjunction with actionable items that you may
have to execute on your own, such as managing your participant account at an employer retirement plan
(i.e., 401k, 403b, 457, pensions, etc.). Analyses may encompass a variety of factors, including but not
limited to: contribution amounts, asset allocation, investment time horizon, current and anticipated assets
and liabilities, insurance, savings, investments and anticipated retirement or other employee benefits,
such as 401k, 403b, 457, pensions, etc. The IAR has the discretion and flexibility to provide all the
aforementioned services, in whole or in part, based on your specific needs and objectives. The specific
financial planning arrangement will be agreed upon by you and your IAR in accordance with a
Financial
Planning and Consultation Services Agreement.
2. Portfolio Management Programs
a. Financial Services Firms: In providing portfolio management services to your account, your IAR may
utilize one or more of the several programs that United Planners has authorized through relationships
with other financial services firms that are custodians and/or IAs. United Planners has agreements
with these financial services firms to provide various services, including but not limited to: custodial
services, brokerage services, investment management services and reporting/billing services, which are
further described as follows:
i. Custodial services that involve the safekeeping of your assets in an account for your benefit.
ii. Brokerage services that involve the buying and selling of investments in your account.
iii. Investment management services that involve the management of assets for your benefit.
iv. Reporting/Billing services that involve account related reporting and fee billing for various fees.
b. Portfolio Management Programs: These programs can be provided in different capacities. Below is a
brief description of the main types of programs. A more detailed description is provided further down in
this section. The brief descriptions are as follows:
i. Pershing Accounts: Accounts that are held at Pershing LLC (Pershing). United Planners
relationship to Pershing is further described below in “4 – Pershing Accounts” in this section.
ii. Third Party Custodian (TPC) Accounts: Accounts that are held at TPCs. TPCs consist of the
institutional divisions of the following TPCs: Axos Advisor Services (a division of Axos Clearing,
LLC), Fidelity Institutional Wealth Services (a division of Fidelity Investments), Schwab Advisor
Services (a division of Charles Schwab & Company, Inc.), American Funds-F2 Program, and
Teachers Insurance and Annuity Association (TIAA) Advisor Network.
iii. Directly Held Accounts: In certain situations, an IAR may also provide portfolio management
services to clients who have an account held directly at product sponsor such as mutual fund
and/or variable annuity company.
iv. Third Party Money Manager (TPMM) Accounts: Accounts that are serviced through an
arrangement that involves the utilization of a TPMM to assist the IAR with investment management
services (i.e., risk assessments, proposals, portfolio strategies, construction, rebalancing,
performance reporting, cash management, etc.) and portfolio management services (i.e.,
proposals, billing, reporting, technology, etc.).
c. In any of the aforementioned Portfolio Management Programs, the client will enter into an Investment
Advisory Agreement (This term may vary depending on its context and can also be referred to as the
Investment Management Services Agreement;
Client Services Agreement,
IA Agreement, etc.) with
United Planners and the IAR. Please refer to Item 12 for additional information about Brokerage
Practices.
d. Wrap Fee Programs: United Planners is not a sponsor of any sort of proprietary wrap fee program.
However, wrap fee programs may be available through an approved Portfolio Management Program (as
stated immediately above in “b – Portfolio Management Programs”).
3. General Discussion About Portfolio Management Services
a. Background Relating to Portfolio Management Services: IARs may provide personalized portfolio
management services in which your assets are held in an individual account maintained by a custodian.
b. Suitability and Risk Assessment: After obtaining information from you about your financial situation,
investment objectives, investment experience, risk tolerance, other investments, liquidity needs, tax
status, and investment time horizon and any special instructions that you want to incorporate into the
management of the account, your IAR will provide recommendations to invest in various securities, such
as: equities (stocks), fixed income (bonds), options, mutual funds, exchange traded funds, convertible
securities, direct participation programs, and American Depository Receipts. You will enter into an
agreement with United Planners and your IAR which authorizes, among other things, your IAR to place
trades in your account to manage those assets on your behalf.
c. Changes to Your Financial Situation: You should keep your IAR informed of changes in your financial
situation, income, investment objectives, risk tolerance levels or other information that may affect how
your account should be managed.
d. Client Meetings: It is important that your IAR meet with you at least annually to review your situation and
discuss various items such as: suitability, services being provided, performance, fees, costs, etc.
e. Special Instructions: You may work with your IAR to incorporate any special instructions on the
management of your assets, including the ability to keep from purchasing/selling particular securities. For
example, you may not want your IAR to invest in a specific security that is associated with a particular
industry, country, environmental concern or government. You should specifically identify any such special
instructions that you wish to incorporate into your agreement with your IAR. You should keep in mind
that any special instructions that you incorporate may cause your IAR to deviate from investment
decisions your IAR would otherwise make. If you do not incorporate special instructions on your account,
it is likely that your assets will be managed and/or allocated in a manner very similar to that of the IAR’s
other clients with similar investment objectives and risk tolerances.
f. Investment Discretion: Your IAR may provide portfolio management services to you on either a
discretionary or non-discretionary basis, as further
explained in Item 16.
g. Investment Performance: You should keep in mind that United Planners and your IAR cannot guarantee
that your investment objectives will be met, and past performance is not a guarantee of future results.
Additionally, active management services like those provided by your IAR will likely cost more than a self-
managed passive buy and hold strategy.
4. Pershing Accounts
a. Pershing is a SEC registered BD and a member of FINRA, New York Stock Exchange (NYSE) and SIPC.
Pershing is United Planners’ clearing firm and acts as custodian and executing broker. For accounts that
United Planners introduces to Pershing (i.e., opening an account), Pershing and its affiliates provide
various services to United Planners that include but are not limited to the following: technology support,
brokerage services, advisory services, and custodial services. Pershing is not affiliated with United
Planners.
b. United Planners has different types of advisory accounts available through Pershing, which include
programs called UPlan, UPlan II and Do-It-Yourself (DIY). These different types of accounts have varying
features, benefits and costs associated with them which are discussed in more detail in Item 5 and
elsewhere in this brochure.
c. Private Lending Services: Pershing offers various private lending services to their account holders via
their parent company BNY Mellon. If the IAR determines that a client can benefit from any of Pershing’s
various private lending services, the IAR may facilitate the introduction to their private lending services
team. United Planners and the IAR are not compensated for such introductions, nor are United Planners
or the IAR compensated for any such private lending services that the client actually engages. Making
such private lending services available to a client is purely a value-added benefit that a client can take
advantage of as being an account holder at Pershing. Private lending services may include services such
as Securities-Backed Line of Credit (SBLOC or SBL for Securities-Backed Lending), custom tailored
mortgages, life insurance premium finance or commercial real estate financing. The benefit to the clients
could be that such private bank lending services are more competitive than the traditional retail
marketplace given their existing business relationship on the investment side. When an IAR refers a
client to such private bank lending services the Private Bank Lending Services Disclosure and
Acknowledgement form must be completed.
5. TPC Accounts
a. IARs may also open and manage accounts at authorized TPCs, who are also registered BDs that act in
the capacity of a custodian and are not affiliated with United Planners.
b. TPC accounts are customarily “advisor-managed” (aka “advisor-as-portfolio-manager”) which means that
the IAR is directly responsible for the trading and managing of the account.
c. The TPC provides safekeeping of your assets along with varying levels of custodial service and support
to both you and your IAR.
d. Private Lending Services: Some TPCs offer various private lending services to their account holders via
their respective banking relationships. If the IAR determines that a client can benefit from any of the
various private lending services, the IAR may facilitate the introduction to their private lending services.
United Planners and the IAR are not compensated for such introductions, nor are United Planners or the
IAR compensated for any such private lending services that the client actually engages. Making such
private lending services available to a client is purely a value-added benefit that a client can take
advantage of as being an account holder of the particular TPC. Private lending services may include
services such as Securities-Backed Line of Credit (SBLOC or SBL for Securities-Backed Lending),
custom tailored mortgages, life insurance premium finance or commercial real estate financing. The
benefit to the clients could be that such private bank lending services are more competitive than the
traditional retail marketplace given their existing business relationship on the investment side. When an
IAR refers a client to such private bank lending services the Private Bank Lending Services Disclosure
and Acknowledgement form must be completed.
e. Digital Investment Solutions: Some TPCs offer digital investment solutions that are designed to be
operationally cost efficient. So long as the particular digital investment solution has been approved by
United Planners, IARs can offer these digital investment solutions to their clients.
6. TPMM Accounts
a. IARs may utilize the services of a TPMM to further assist with the investment management needs and
portfolio management services that are delivered to a client.
b. TPMMs are IAs and, in some cases, may also be affiliated with a BD. TPMMs are not affiliated with
United Planners. Some TPMMs may have an affiliated entity to provide custodial services (such as
AssetMark and SEI, who both have proprietary custodial platforms).
c. TPMM services may be offered in different ways, but they are primarily offered in the following manner:
i. Sub-Advisor Arrangements (aka Co-Advisor)
o Description: A sub-advisor arrangement is when the IAR is the “primary IAR” on the client
account, and then brings in a TPMM (in the capacity of a sub-advisor) to engage the TPMM’s
investment management services, who would be considered a “secondary IA” on the client
account.
o Institutional Structure: These arrangements are institutional in nature (i.e., meaning the sub-
advisor does not deal directly with the client) because it requires a financial intermediary between
the client and the sub-advisor. UP and your IAR are collectively the financial intermediary
between the client and the sub-advisor to deliver such investment management services to their
clients.
o Compensation Structure: The IAR will be compensated for his/her services as stipulated in the
IA Agreement between you and your IAR. The sub-advisor will also be compensated for their
services as stipulated in a separate IA Agreement between you and the sub-advisor. Depending
on various portfolio management billing capabilities and program structures, the respective
compensation to your IAR and the sub-advisor can vary. For example: a.) the respective
compensation to your IAR and sub-advisor may be debited from your account separately,
which would be the most transparent process (i.e., $X goes to the IAR and $Y goes to the sub-
advisor); or b.) the respective compensation to your IAR and the sub-advisor is debited together
as one consolidated debit. In these cases, an itemized breakdown of what amount is attributed
to your IAR and what amount is attributed to the sub-advisor is disclosed in an advisor fee notice
that either your IAR or the sub-advisor can provide (depending on which party is processing the
compensation).
ii. Promoter Arrangements (aka Promoter or Referral Model and fka Solicitor):
o Description: A promoter arrangement is when the IAR engages a TPMM to manage a client’s
account (via their respective investment management capabilities and available investment
strategies). Your IAR is considered a “promoter” for the TPMM and your IAR is your primary
point of contact for servicing your account. Your IAR may work with one or more TPMMs to get
access to and be able to deliver various investment management services to their clients. IARs
engage a TPMMs to increase their operational efficiency, investment capabilities, servicing
capabilities, technology capabilities, and overall value-proposition.
o Institutional Structure: These arrangements are institutional in nature (i.e., meaning the TPMM
does not deal directly with the client) because it requires a financial intermediary between the
client and the TPMM. UP and your IAR are collectively the financial intermediary between the
client and the TPMM to deliver such investment management services to their clients.
o Compensation Structure: The IAR receives compensation in the form of a promoter fee from
the TPMM, which is typically a portion of the TPMM’s compensation (i.e., investment advisory
fee or platform fee) that is debited from the client’s account. The TPMM facilitates the
compensation process. An itemized breakdown of what amount is attributed to your IAR (for the
promoter compensation) and what amount is attributed to the TPMM is disclosed in an advisor
fee notice.
iii. Turnkey Asset Management Programs (aka TAMPs):
o Description: A TAMP arrangement is when the IAR engages a TAMP to provide the most robust
investment management services to a client. Your IAR is still your primary point of contact for
servicing and overall management of your account(s). The TAMP enable the IAR to provide a
wider array of portfolio management services because they offer the ability to engage numerous
TPMMs and their respective strategies on a single platform. In some cases, the IAR can use a
combination of “advisor-managed strategies” in combination with “TPMM strategies” to create
more sophisticated portfolios to better suit the needs of a client. TAMPs also offer portfolio
management services through the use of Separately Managed Accounts (SMAs) and/or Unified
Managed Accounts (UMAs). SMAs are accounts that are managed by a single TPMM for a
specific investment strategy. UMAs are accounts that enable multiple TPMMs to manage
designated portions/percentages of a single account, which is basically an operational efficiency.
At times, TPMMs are referred to as sub-advisors, co-advisors or strategists depending on
various factors and context.
o Institutional Structure: These arrangements are institutional in nature (i.e., meaning the TAMP
does not deal directly with the client) because it requires a financial intermediary between the
client and the TPMM. UP and your IAR are collectively the financial intermediary between the
client and the TPMM to deliver such investment management services to their clients.
o Compensation Structure: The IAR will be compensated via the TAMP for their respective
services in the form of an “advisory fee” or “investment management fee” or “advisor fee” (these
terms can vary depending on the TAMP). The TAMP will also be compensated for their
respective platform services in the form of a “platform fee” or “program fee” (this compensation
varies depending on the TAMP services being engaged which may also include costs for
investment strategy expenses, tax management, direct indexing, etc.).
d. Institutional Structure: TPMMs enable the IAR to provide institutional level investment management
services that include a wide range of investment strategies. Your IAR is responsible for selecting the
most appropriate TPMM (i.e., sub-advisor, promoter, TAMP) along with the applicable investment
strategy(ies), and other value-add services (i.e., tax management, direct indexing) based on your financial
situation, investment objective and risk tolerance. Additionally, TPMMs can also offer you and your IAR
technology services to enhance the overall servicing experience (such as account opening technologies,
client portal technologies, portfolio proposal technologies, portfolio reporting technologies, planning
technologies). You will receive additional disclosure materials about the TPMM and their services. You
may also be required to enter into separate IA agreements with the TPMM as well as with United Planners
(i.e., Tri-Party Agreement). Your IAR is your liaison to the TPMM. Your IAR will collect and convey
information about you to the TPMM. Likewise, the TPMM will collect and convey information about you
to your IAR.
e. Discretionary Authority: The TPMM typically assumes discretionary authority over the account to
efficiently manage your account.
f. Private Lending Services: Some TPMMs offer various private lending services to their account holders
via their respective banking relationships. If the IAR determines that a client can benefit from any of the
various private lending services, the IAR may facilitate the introduction to their private lending services.
United Planners and the IAR are not compensated for such introductions, nor are United Planners or the
IAR compensated for any such private lending services that the client actually engages. Making such
private lending services available to a client is purely a value-added benefit that a client can take
advantage of as being an account holder of the particular TPMM. Private lending services may include
services such as Securities-Backed Line of Credit (SBLOC or SBL for Securities-Backed Lending),
custom tailored mortgages, life insurance premium finance or commercial real estate financing. The
benefit to the clients could be that such private bank lending services are more competitive than the
traditional retail marketplace given their existing business relationship on the investment side. When an
IAR refers a client to such private bank lending services the Private Bank Lending Services Disclosure
and Acknowledgement form must be completed.
g. Digital Investment Solutions: Some TPMMs offer digital investment solutions that are designed to be
operationally cost efficient. So long as the particular digital investment solution has been approved by
United Planners, IARs can offer these digital investment solutions to their clients.
h. Self-Custody: Some TPMMs (such as AssetMark and SEI) have their own custodial platforms (via an
affiliated entity) which may enable them to provide more favorable custodial services, support, pricing,
and technical operational efficiencies opposed to using a TPC (i.e., Axos, Fidelity, Schwab, etc.).
7. Cash Management Accounts
a. As part of UP’s investment management services, IARs have access to a cash management program
that enables them to utilize a Cash Management Service Provider (CMSP) to better manage cash
positions within an investment portfolio.
b. Cash positions in an investment portfolio may not offer competitive interest rates on cash positions.
Therefore, through a cash management program, a CMSP may offer better interest rates on cash
positions based on their network of banks, savings institutions, and credit unions (compared to an account
held at Pershing, a TPC, a TPMM, directly held sponsor account).
c. Cash positions managed within the cash management program are covered by the FDIC (Federal Deposit
Insurance Corporation) or the NCUA (National Credit Union Administration).
d. Institutional Structure: This arrangement is institutional in nature because it requires an agreement
between UP and the CMSP. Therefore, your IAR will provide you support as a financial intermediary
between you and the CMSP. UP and your IAR are collectively the financial intermediary between you
and the CMSP to make such cash management services available to you. Your IAR will provide you
support to get established with the CMSP.
D. Retirement Plan Services
1. IARs can and may provide fiduciary and/or non-fiduciary services to retirement plans (i.e., 401k, 403b, etc.).
Retirement plans may or may not be subject to the U.S. Department of Labor’s Employee Retirement Income
Security Act (ERISA). Regardless of whether the retirement plan is subject to ERISA, IARs can provide
fiduciary and/or non-fiduciary services to a retirement plan in a discretionary [3(38)] or non-discretionary [3(21)]
capacity. Discretionary 3(38) can only be done at the retirement plan level.
2. Retirement plan documents typically designate one or more persons, such as the plan trustee(s), to undertake
fiduciary responsibility for the operation of the retirement plan. Such persons are known as Responsible Plan
Fiduciaries (RPFs). Pursuant to a Retirement Plan Services Agreement (RPSA), an IAR can offer the
following types of services to a retirement plan. Please refer to the agreement for a more detailed description
of these different types of services.
a. ERISA Fiduciary Services
Selection of Investments
Assessment of Investments
Participant Investment Advice
Investment Policy Statement (Individually Designed)
b. Non-ERISA Fiduciary Services
Investment Policy Statement (Review)
Performance Monitoring
Third Party Service Provider Liaison
Employee Enrollment
Employee Education
Vendor Review/Conversion
3. IAR is not permitted to act in the capacity of an RPF on behalf of a client’s retirement plan.
E. Seminars
1. IARs are permitted to conduct seminars that are educational in nature and/or promote the services of the
particular IAR. The topics of the seminar may vary but should be general in nature and will not include any
individualized investment advice or recommendations based on the specific needs of any person.
***the remainder of this page was intentionally left blank***