Description of Services and Fees Flagstar Advisors (the "Firm")is registered with the SEC as an investment adviser. The Firm is a corporation formed under the laws of the State of New York. We are also a registered insurance agency and broker-dealer, and a member of the Financial Industry Regulatory Authority, Inc. ("FINRA") and the Securities Investors Protection Corporation ("SIPC"). We are a wholly owned non-bank subsidiary of Flagstar Bank, N.A., a member of the FDIC. As used in this brochure, our Associated Persons are the Firm's management, employees, and all individuals providing investment advice on behalf of the Firm. We refer to Associated Persons who provide investment advice as Investment Adviser Representatives ("IARs") throughout this brochure. As used in this brochure, the words "we", "our" and "us" refer to the Firm and our IARs. The words "you", "your" and "client" refer to you as either a client or prospective client of the Firm. Some of our Associated Persons are also Registered Representatives of the Firm, acting in its capacity as a broker-dealer, and/or licensed insurance agents. Our Investment Adviser Representatives provide investment advisory services in their capacities as IARs and they provide securities brokerage services in their capacities as Registered Representatives. Portfolio Management Services Flagstar Advisors offers a suite of investment advisory services and programs to IARs for use with their clients. Our investment advisory services and programs are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. Through our various advisory programs and services, clients have access to a wide range of securities products, including, but not limited to, common and preferred stocks; municipal, corporate, and government fixed income securities; mutual funds; exchange-traded products ("ETPs"); options and derivatives; unit investment trusts ("UITs"); and variable and fixed-indexed insurance products, as well as other products and services, including a variety of asset allocation services, financial planning, and consulting services. Cash and cash equivalents held in your account(s) are included as "assets under management" when assessing fees for portfolio management services. Our investment management services are tailored to meet your individual needs and investment objectives.
Flagstar Advisors' investment advisory services and programs consist of wealth management, retirement plan consulting services, and the Managed Account Program. The investment recommendations and advice Flagstar Advisors and its IARs offer do not constitute legal, tax, or accounting advice. Clients are encouraged to coordinate and discuss the impact of the financial advice they receive from an IAR with their attorney and accountant. Clients should promptly inform their IAR of any changes in their financial situation, investment goals, needs, or objectives. Failure to notify the IAR of any material changes could result in investment advice not meeting the changing needs of the client.
Managed Account Program We will recommend an allocation of your assets amongst various third-party advisers ("TPAs"), mutual funds, Exchange Traded Funds (ETFs), and alternative investments. One of our IARs will first meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. In consultation with you and based on the information provided, the Firm will prepare an investment strategy which will be memorialized in an Investment Policy Statement. As part of, and in accordance with, that strategy, the Firm will advise you regarding asset class allocation and, on a discretionary basis, will select, monitor and replace (if appropriate) investment managers and investment funds for your account. Moreover, the Firm will provide you periodic reviews and reporting on the investment performance of the assets in 4 your account, as well as reallocate those assets and/or investment managers if the Firm considers reallocation appropriate. Accordingly, you appoint the Firm as your investment manager to act on your behalf with authority to buy, sell and otherwise effect investment transactions for the assets in your account, and the Firm accepts that appointment. We require you to grant the Firm discretionary authority to manage your account. Discretionary authority will allow the Firm to re-allocate your assets without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with the Firm or trading authorization forms. You may limit our discretionary authority (for example, by limiting the types of securities that can be purchased or sold for your account, or by providing our firm with restrictions and guidelines in writing). You must promptly notify us if there are ever any changes in your financial situation or investment objectives, or if you wish to impose any reasonable restrictions upon our management services. Failure to promptly notify your IAR of any material changes may result in investment advice or activity within your account that is inconsistent with your current needs, objectives, and circumstances.
Selection of Other Advisers As mentioned above, we will recommend or select certain TPAs to actively manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we will recommend that you engage a specific TPA or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the TPA's performance, methods of analysis, and fees, as well as your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPA's performance to ensure its management and investment style remains aligned with your investment goals and objectives. The TPA(s) will actively manage your portfolio and will assume discretionary investment authority over your account. We will assume discretionary authority to hire and fire the TPA(s) and/or reallocate your assets to

other TPA(s) where we deem such action appropriate. Retirement Plan Consulting Services We offer retirement plan consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
• Diversification;
• Asset allocation;
• Risk tolerance; and
• Time horizon Our educational seminars may also include other investment-related topics specific to the particular plan. 5 We may also provide additional types of other consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. This agreement is intended to remain in force indefinitely until terminated. Otherwise, the parties agree the agreement may be terminated by either party with sixty (60) days written notice to the other parties. Individualized Services and Client-Imposed Restrictions The investment advisory services provided by our IARs depends largely on the personal and financial information the client provides to the Firm. In order for IARs to provide appropriate investment advice to, or, in the case of discretionary accounts, make tailored investment decisions for, the client, it is very important that clients provide accurate and complete responses to their IAR's questions about their financial condition, needs, goals, and objectives, and notify their IAR of any reasonable restrictions they wish to apply to the securities or types of securities to be bought, sold, or held in their managed account. It is also important that clients promptly inform their IARs of any changes in their financial condition, investment objectives, personal circumstances, or reasonable investment restrictions pertaining to the management of their account, if any, that may affect their overall investment goals and strategies or the investment advice provided or investment decisions made by their IARs.
In a discretionary managed account, your IAR will manage the account and will make changes to the allocation as deemed appropriate. The IAR will determine the securities to be purchased and sold in the account and will alter the securities holdings from time to time without prior consultation with you. The IAR may actively trade securities and hold such positions for periods of 30 day or less or maintain positions for longer- or shorter-term periods. Cash and cash equivalents held in your account(s) are included as "assets under management" when assessing fees for portfolio management services. Discretionary authority will be granted by you via the execution of the Firm' Discretionary Management Agreement. Based on risk tolerance, margin may be deployed as part of the overall investment strategy in a client's account(s). When an investor buys a stock on margin, the investor pays for part of the purchase and borrows the rest from a brokerage firm. Clients cannot borrow from Flagstar Advisors. Please see the additional information related to the risks of trading on margin under the Methods of Analysis, Investment Strategies & Risk of Loss section.
In general, the IAR is responsible for delivering investment advisory services to clients, and clients generally deal with matters relating to their accounts by contacting their IAR directly. Of course, clients may contact Flagstar Advisors directly for administrative and operational questions about the advisory services offered through Flagstar Advisors.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement 6 accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice for, because those assets increase our aggregate assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2023, we provide continuous management services for $966,652,484 in client assets on a discretionary basis.