Level Four Advisory Services, LLC, also doing business as Level Four Financial, (referred to as “LFAS”, the “Firm”, “us” and “we” in this document) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and has developed and sponsors the ICA Platform Program (referred to as the “Program”). The Program is a wrap-fee program. Only investment advisor representatives of LFAS may serve as portfolio managers in the Program. Therefore, participants in the Program must be advisory clients of LFAS. The following bullets provide basic background regarding our Firm.
• The Firm has been registered as an investment adviser since July 2005.
• The Firm is owned and controlled by Level Four Group. Level Four Group is a holding company and the 100% owner of LFAS. Level Four Group is owned and operated by Carr, Riggs & Ingram Capital, L.L.C., a Delaware limited liability company. Carr, Riggs & Ingram Capital, L.L.C. is 100% owned by Carr, Riggs & Ingram, L.L.C., an Alabama limited liability company. No individuals own more than 25% of Carr, Riggs & Ingram, L.L.C.
• We provide fee-only investment advisory services through LFAS. The nature and extent of the specific services provided to clients, including you, will always depend on each client’s financial status, objectives and needs, time horizons, concerns, expectations and risk tolerance.
• LFAS Advisory Representatives and LFAS branch offices may use marketing names or other names that are held out to the public. Such names are known as “doing business as” names. The purpose of using a name other than LFAS or Level Four Financial is for the Advisory Representative to create a brand that is specific to the Advisory Representative and/or branch but separate from LFAS or Level Four Financial. While LFAS allows its Advisory Representatives to use a name other than LFAS or Level Four Financial, the Advisory Representative must disclose on advertising and client correspondence that advisory services are offered through LFAS. LFAS provides investment advisory services other than the Program described in this brochure including services through other wrap-fee programs. A description of all fee-based investment advisory services provided by LFAS is available in the LFAS’ Disclosure Brochure and the applicable Wrap Fee Program Brochure. Any of these Wrap Fee Program Brochures are available upon request by contacting LFAS at 866-834-1040. Some LFAS Advisory Representatives may also provide securities advice as registered representatives of Level Four Financial Services, LLC (“LFF”), a broker/dealer, member of the Financial Industry Regulatory Authority (“FINRA”) and Securities Investors Protection Corporation (“SIPC”). In that separate capacity as registered representatives of LFF, LFAS’s Advisory Representatives may charge commissions on a per-transaction basis when implementing their advice on behalf of clients (see Item 9 of this brochure for more details). LFAS and LFF are affiliated companies, as the parent company of LFAS acquired ownership in LFF in October 2020. When making the determination of whether one of the advisory programs available through LFAS is appropriate for their needs, clients should bear in mind that fee-based accounts, when compared with commission based accounts, often result in lower costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, such arrangements may result in a higher annual cost for transactions. Thus, depending on a number of factors, the total cost for transactions under a fee account versus a commission account can vary significantly. Some such factors are account size, amount of turnover, type and quantities of securities purchased or sold, commission rates and the client’s tax situation. Client Obligations. In performing its services, LFAS shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify LFAS if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising LFAS’ previous recommendations and/or services. Clients should have a conversation with their Advisory Representative and read this brochure carefully as it explains, in detail, the Program. Description of The Program sponsored by Level Four Advisory Services, LLC – ICA Platform Program This Program has been developed through an arrangement Raymond James & Associates (“RJA”) whereby LFAS utilizes RJA’s Independent Clearing Account (“ICA”) platform. Through the Program, LFAS provides investment management (also known as asset management) services which are defined as providing continuous investment advice to a client and making investments for the client based on the individual needs of the client. Through this service, LFAS offers a customized and individualized investment program for clients. LFAS will manage each client’s individual account(s) based on the individual needs of the client. Pursuant to each client’s specific investment objectives, securities held in Program accounts will generally include no-load and load-waived mutual funds, unit investment trusts (UITs), closed-end and Exchange Traded Funds (ETFs), stocks, bonds, certificates of deposit, hedge funds, managed futures, structured products, and options. LFAS may limit its discretion with respect to the client account and the securities eligible to be purchased for the client account. LFAS will work with each Program client to obtain information needed to determine the client’s financial situation and investment objectives. Accounts are managed on the basis of each client’s financial situation and investment objectives. At least annually, LFAS contacts each individual client to determine whether their financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of accounts managed. LFAS shall be reasonably available to consult with individual clients relative to the status of their accounts. Clients shall have the ability to impose reasonable restrictions on the management of their accounts, including the ability to instruct LFAS not to purchase certain securities. Client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the account. This means the client will be the sole owner of all securities held in their accounts. A separate account is maintained for each client with the custodian and clients retain right of ownership of the account (e. g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). Program accounts are established at LFF in its capacity as a registered broker/dealer. Clearing, custody and other brokerage services are provided by RJA for accounts established through the Program. Therefore, clients will be required to establish a brokerage account(s) through LFF on RJA’s ICA platform. Program accounts allow clients to authorize LFAS to purchase and sell securities on a discretionary basis. LFAS may limit its discretion with respect to the client account and the securities eligible to be purchased for the client account. Upon establishment of a Program account, an Advisory Representative of LFAS will be granted trading authorization on the client’s account. However, upon a client’s request, LFAS will manage Program accounts on a non-discretionary basis. Clients must authorize in writing LFAS’ to manage accounts on a discretionary basis. Such authorization will be memorialized in the LFAS Investment Advisory Agreement. Discretionary authority allows LFAS to determine the type of securities and the number of securities that can be bought or sold for the client portfolio without obtaining the client’s consent prior to each transaction. Accounts participating in the Program may either be managed on a discretionary or non-discretionary basis by the representative or may be managed on a discretionary basis with a sub-advisor appointed as portfolio manager who provides management of model portfolios of equity and/or fixed income securities. When your account(s) are managed using models, investment selections are based upon the underlying model and the firm does not develop customized (or individualized) portfolio holdings. However, the determination to select a particular model or models is always based on a client’s individual investment goals, objectives, and mandates In the event a sub-advisor is selected by LFAS to manage the account on a sub-advisory basis, the sub-advisor utilized will be Level Four Capital Management, LLC (“LFCM”), an investment adviser registered with the SEC. LFCM is also owned by the same parent company as LFAS, Level Four Group, and accordingly is an affiliate of both LFF and LFAS. Administrative Services Provided by SS&C Black Diamond Wealth Platform LFAS has contracted with SS&C Black Diamond Wealth Platform(referred to as “Black Diamond”) to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, research, client database maintenance, quarterly performance evaluations, payable reports, web site administration, models, trading platforms, and other functions related to the administrative tasks of managing Program accounts. Due to this arrangement, Black Diamond will have access to client accounts, but Black Diamond will not serve as an investment adviser to Program clients. LFAS and Black Diamond are non-affiliated companies. LFAS compensates Black Diamond on a basis point fee basis with account minimum and maximum charges per account. The fee paid to Black Diamond does not result in an increase to the overall fee charged by LFAS relative to other advisory programs available through LFAS. Suitability and Investment Strategy LFAS will assist clients in determining their objective(s), investment strategy, and investment suitability, prior and subsequent to opening a Program account. Clients must advise LFAS of any changes in their investment objective(s) and/or financial situation. LFAS’ services are provided based on the individual needs of the individual client. Clients are given the ability to impose restrictions on their accounts including specific investment selections and sectors.

When managing client accounts through our Program, we will generally manage a client’s account in accordance with one or more models developed by our Investment Committee. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. More information about our models and strategies is provided at Item 6. Brokerage, Clearing and Custody The RJA ICA platform is used for all Program accounts and therefore LFF will be used as the introducing broker dealer, with RJA as the clearing broker/dealer. If the client chooses not to direct the firm to execute transactions through RJA, the firm reserves the right not to accept such account. Not all advisers require their clients to direct brokerage. Advisory Representatives of LFAS offering this Program may also be registered representatives of LFF and are required to use the services of LFF when acting in their capacity as registered representatives. LFAS representatives that are registered with LFF may be limited in the broker/dealer or custodians that they are allowed to use due to LFAS’s Advisory Representatives’ relationship with LFF. LFF may limit or restrict the broker/dealer or custodial platforms for its registered representatives that are also independently licensed due to its duty to supervise the transactions implemented by these individuals. Clients should understand that not all investment advisers require the use or a particular broker/dealer or custodian. Some investment advisers allow their clients to select whichever broker/dealer the client decides. By directing clients to use a particular broker/dealer (LFF) and custodian (RJA), LFAS may not achieve the most favorable execution of client transactions and the practice requiring the use of LFF and RJA may cost clients more money than if the client used a different broker/dealer or custodian. The firm believes that RJA provides quality execution services based on several factions, including but not limited to the ability to provide professional services, reputation, experience and financial stability. Program Fees The annual investment advisory fee charged to Program accounts will not exceed 2.5% of the assets held in the account on an annual basis. The annual fee is negotiable with the client depending on the market value of the account, asset types, the client’s financial situation and trading activity. In the event a sub-advisor (LFCM) is utilized, minimum asset values for participation in the program will vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The advisory representative receives a portion of the fee for services provided and LFCM’s sub- advisory fee is paid out of the total advisory fee. In general, there is no minimum account size required for participation in the ICA Program. For accounts managed in investment strategies developed by the LFCM Investment Committee, a minimum of $10,000 is required for asset allocation models, $100,000 for equity portfolios, $100,000 for taxable fixed income (corporate bonds), $175,000 for tax exempt/municipals, and $500,000 for tax exempt high yield municipals. Exceptions to these minimums may be granted at the discretion of LFAS/LFCM. The annual fee shall be divided and payable monthly in advance through a direct debit in the client account. Fees are based on the account's asset value as of the last business day of the prior month. New accounts are billed twice at the beginning of the month following funding date – once in arrears from funding date through the end of the month and once in advance for the next month billing. In the event of termination, the Firm will refund the prorated portion of the Advisory Fee for the remainder of the month in which the account is terminated. RJA is responsible for debiting all fees from client accounts. In this Program, the client must provide RJA written authorization to debit advisory fees from their account(s) and pay such fees to LFAS. The custodian sends a quarterly statement to the client which reflects all amounts disbursed from the account, including fees paid to LFAS as adviser. Clients may incur certain charges imposed by third parties, including without limitation, the custodian, other than LFAS in connection with investments made through the account, including but not limited to, annual maintenance fees, 12b-1 fees and surrender charges, and IRA and qualified retirement plan fees. Management fees charged by LFAS are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to clients. Certain open-end mutual funds may, in addition to assessing management fees, internally assess a distribution fee pursuant to Section 12(b)-1 of the Investment Company Act of 1940 or an administrative of service fee (“trail”). Trails are included in the calculation of the annual operating expenses of a mutual fund. A description of these fees and expenses are available in each investment company security’s prospectus. However, LFAS does not get paid mutual fund sales loads, 12b-1 fees and surrender charges in fee-based advisory accounts. Although clients may be charged 12b-1fees in certain load mutual funds, RJA will retain all fees and LFAS or its Advisory Representatives (even in their separate capacities as registered representatives of LFF) do not share or receive such fees. Clients are not charged front end sales loads because the front-end sales loads for mutual funds are waived in fee-based advisory programs. The ICA Platform Program may cost the client more or less than if the assets were held in a traditional brokerage account. In a brokerage account, the client is charged commissions for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold investment strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than an ICA Platform managed account. As disclosed in this section, LFAS as well as affiliate LFCM for sub-advised accounts, receive compensation as a result of a client’s participation in the Program. LFAS therefore has a financial incentive to recommend Program over other programs or services. The amount of LFAS’ compensation may be more or less than what a client would pay if the client participated in programs sponsored by other financial firms or paid separately for investment advice, brokerage, and other services. Additional Compensation, Economic and Non-Economic Benefits While there will not be a direct linkage between the investment advice provided by LFAS and the qualified custodian, economic benefits may be received that would not be received if LFAS did not use these services to implement the investment advice provided. These benefits may include, but not necessarily be limited to: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk; the ability to have investment advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; receipt of compliance publications; and access to mutual funds that generally require significantly higher minimum initial investments or are generally only available to institutional investors. The Advisory Representatives of LFAS who are registered representatives or insurance representatives may be eligible to receive various incentives that may be based upon production levels. These incentives may include marketing reimbursements, educational conference trips or discounts on various software or investment-related research materials. LFAS may also be provided with various newsletters or publications from financial services firms as a customary consideration. Aggregate Trades In some instances, trades for more than one client’s account may be aggregated (“block trades”) and executed as a single trade in order to provide fair and equitable prices among managed client accounts. All clients will receive equal treatment when LFAS and its Advisory Representatives perform block trades for managed accounts. Securities purchased or sold using block trades will then be allocated in a fair and equitable manner to all client accounts involved in the block trade. If for any reason the entire block trade cannot be completed on the day the trade is placed, client accounts will receive an equal pro-rata portion of the securities traded. LFAS will keep records of all block trades executed and the allocations for each client account that participates in the block trade. LFAS and its Advisory Representatives will not receive additional compensation as a result of block trading. Trade Error Policy Based on industry practice and SEC guidance to broker-dealers, a trade error under this policy is defined as including:
• Inaccurate transmission or execution of any term of an order including, but not limited to: price; number of shares or other unit of trading; identification of the security; identification of the account for which securities are purchased or sold; short sales that were instead sold long or vice versa; or the execution of an order on the wrong side of a market;
• Unauthorized (because of misunderstanding or mistake) or unintended purchase, sale or allocation of securities, or the failure to follow specific client instructions; and
• Incorrect entry of data into relevant systems, including reliance on incorrect cash positions, withdrawals or securities positions reflected in an account. LFAS has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of LFAS to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole and any loss resulting from the trade error will be absorbed by LFAS if the error was caused by the Firm. If the error is caused by the broker-dealer, the broker-dealer will be responsible for covering all trade error costs. LFAS will never benefit or profit from trade errors.