Description of Krilogy Financial This Brochure provides clients (“client,” “you” or “your”) with information about Krilogy, the fees charged for our services, and our business practices. Please review this Brochure carefully and consult with your tax professional before you decide to invest. Krilogy Financial® LLC (“Krilogy”) is a fee-based federally registered investment adviser with the Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940 and has been in business since 2008. Krilogy is primarily headquartered in St. Louis, Missouri. Krilogy is the primary operating subsidiary of Krilogy, LLC and affiliated with Krilogy Advisors, LLC (“Krilogy Advisors”), Krilogy Tax Services, LLC. In Texas, Krilogy also does business as Krilogy Texas, LLC. Krilogy is also affiliated through certain common ownership to Krilogy Capital Management Partners, LLC, Krilogy Capital Management, LLC, Krilogy Capital Management Partners II, LLC, and Krilogy Capital Management II, LLC. For more information, please see Item 10: Other Financial Industry Activities and Affiliations for further discussion. Krilogy provides the following types of services: Portfolio Management, Financial Planning and Consulting, Corporate Retirement Plan Consulting and Management, Investment Management and Research Subscription Licensing Services for other Investment Advisers and their clients known as a Separately Managed Account Program(“SMA”) through Krilogy Portfolio Services (“KPS”) a division of Krilogy. While this Brochure generally describes the business of Krilogy, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors, (or other persons occupying a similar status or performing similar functions), and Employees or any other person who provides investment advice on Krilogy’s behalf and is subject to the Firm’s supervision or control. Supervised Persons who provided advisory services on behalf of Krilogy are also known as Investment Adviser Representatives. (Herein referred to as “Financial Advisor,” “Wealth Advisor,” or simply “Advisor”). While all Krilogy Financial Advisors share a common association with Krilogy, many are still independent and their individual investment philosophies and strategies they use may differ significantly from each other. Consequently, Krilogy does not necessarily provide Clients who have similar investment objectives or risk tolerances the same investment strategies or advice. Clients should, therefore, select the Krilogy Financial Advisor whose investment philosophy and strategy is consistent with, among other things, the Client’s investment objectives, risk tolerances, and investment experience. As of market close on December 31, 2023, Krilogy managed $2,434,121,900, in discretionary assets and $71,267,300 in non-discretionary assets with total assets under management of $2,505,389,200. Advisory Services We Offer Asset Management & Investment Management Services for Direct Krilogy Clients1 Krilogy manages investment portfolios for a wide variety of clients including individuals, high net worth individuals, qualified retirement plans, charitable organizations and foundations as well as corporations both directly to clients of Krilogy Advisors and indirectly to clients of other Financial Institutions as outlined below in the Sub-advisory Services section. This section discusses the relationship with direct Krilogy Clients. Krilogy provides direct portfolio investment management advisory services (“Services”) to Krilogy Clients pursuant to your Investment Advisory Agreement (“Agreement”) with the firm. We provide our Services through accounts maintained at a qualified custodian (please refer to Item 15 – Custody for more information). In the provision of the direct Services, your experience with Krilogy is rooted in the working relationship between you and your Krilogy Financial Advisor. Krilogy provides your financial advisor tools that include the ability to utilize centralized design of investment portfolio model management by the firm’s Krilogy Portfolio Solutions Department to meet or assist in meeting your particular Investment Profiles, Objectives, and Risk Profile. However, your advisor is not required to utilize these investment portfolio models in providing you Service. Your advisor is required to continuously monitor your accounts and have a reasonable basis for making an investment recommendation or decision. The firm also utilizes software to track a client’s portfolio drift from its Portfolio Objective. To facilitate the Services, your Krilogy advisor works with you to help understand and determine your appetite for risk, corresponding investment profile and objectives at a household level to manage your accounts to your stated needs. For prospective clients, the process generally also involves a review of your existing financial position articulated personal goals and risk appetite against existing investments. During these reviews, consideration is also given to subjective factors such as a client’s prior investment experience, ability and desire to manage their assets, risk tolerance, and familiarity with various investment vehicles. Each client’s situation is unique and due to client individual circumstances, one client’s plan may be more complex than another client. Each client is expected to provide complete information in all relevant areas. You are always responsible for notifying us of any changes to your financial situation or investment objectives. Upon becoming a client, your Krilogy advisor will then periodically review your goals, investment objectives, time horizon, and risk tolerance with you. For certain clients, the advisor periodically provides other wealth management services, which are more holistic services than just investment management and may include financial planning or financial consulting, such as: retirement planning, charitable gift planning, college planning, financial estate planning, risk management counseling, social security planning, assistance in the establishment of and counsel on retirement plans, and assistance with assets outside Krilogy’s direct management, among other things. 1 These Services exclusive of the SMA Services set forth below As part of our Services for certain clients, we are also able to manage clients held-away accounts, that are maintained at independent third-party custodians. These are primarily 401(k) accounts, 529 plans, variable annuities and other assets Krilogy maintained by the client. These Services are offered through Krilogy’s Total Portfolio Program (“TP Program”). By participating in the TP Program, the client is directing us to manage the accounts at the current custodian as part of the Services provided. In this TP Program, the firm pulls outside account information into its portfolio software to provide reporting and management along-side those client accounts that are directly managed. These held-away accounts are managed on a static schedule. Upon review, generally, the current holdings and available investment options are reviewed and rebalanced based upon your investment strategy across the entire household. Krilogy portfolio allocations may include mutual funds, equities, bonds, fixed income, debt securities, equity and fixed income ETFs, hedge funds, third-party money managers, Business Development Companies (BDCs), REITs, exchange-traded and non-exchange traded alternative investments, affiliated proprietary private placements, government securities, and cash or cash equivalents. Krilogy may use other securities as well to help diversify a portfolio when applicable. Your portfolio may utilize one or more of Krilogy’s proprietary model portfolios as a result of the recommended Investment Profile and Objective, if your advisor recommends or you request utilization. For certain clients with sufficient assets, Krilogy may recommend customized laddered bond portfolios. In the case of laddered bond portfolio recommendations, it is the firm’s intent to hold the bonds until maturity or call absent a change in the investment or other investment decisions such as tax-loss harvesting opportunities. If Krilogy does not maintain discretionary authority on the account, it will typically request additional discretionary authority from clients to manage their fixed-income assets. Discretionary authority is necessary to enable Krilogy to purchase such assets in a timely manner when they are available at quoted prices. Complete customized, laddered fixed-income portfolios generally require a minimum level of assets allocated to fixed income. Otherwise, Low-cost managed fixed-income, mutual funds, or ETFs are typically used for smaller allocation amounts. These ETF and Mutual Funds are generally to provide income as part of the client’s portfolio objective and not as a total return (e.g., capital appreciation) vehicle within the client portfolio. For certain clients, Krilogy may recommend the use of semi-liquid or illiquid alternative investments that are reviewed and approved by the firm’s Krilogy Portfolio Services Department. A client must meet certain industry standards for investor qualifications and have a certain amount of assets under management with Krilogy to be eligible. Upon eligibility, the firm still maintains limitations on the amount of each individual alternative investment that can be held and total amount of alternative investments that may be held based upon the client’s stated risk tolerance and corresponding investment objectives. Due to the illiquid nature of many of the alternative investments, these securities are seen as more risky investments because they cannot be easily liquidated should the client have a capital need. The firm will not follow nor recommend the continued holding of alternative investments that are either not on the firm’s approved list or were previously purchased by a client. However, the client may still have to maintain these securities in his/her account(s) due to the lack of liquidity. Due to the semi-liquid or illiquid nature of these securities, it may not be possible to liquidate these securities. Should the client wish to consolidate the non-recommended alternative investment holding within accounts under the firm’s management, the client understands that (1) the firm does not recommend the holding of these securities, (2) the firm will not provide active management of the securities, and (3) the firm will manage the other securities in these accounts in-spite of these securities holdings. In certain unique circumstances or if requested by a client, Krilogy will allocate a portion of a portfolio to an independent third-party investment advisor (“separate account manager”) for separate account management based upon individual client circumstances and objectives including, but not limited to, client account size, investment strategy, and tax circumstances. Upon the recognition of such situations, Krilogy will work with the custodian, separate account manager, and you under a formal agreement for the management of those securities. There is no guarantee that any investment, strategy or model recommended and/or purchased will perform in any particular manner. Past performance is not a guarantee of future results. It is important that the client read the prospectus –provided by the Custodian -- of any security bought and held and contact the financial advisor if the client determines that he/she does not wish to be invested in that security. Krilogy and financial advisor may make changes to the client portfolio from time-to-time that may include changing out securities entirely or changing the allocation percentage invested in a security or asset class without prior notice. Liquidation may cause a taxable event as well as additional fees and expenses. While the potential tax consequences and additional expenses may be factored in, ultimately, the firm’s final decisions on your portfolio will be focused on whether the investment and allocation meet the client’s stated investment objective. If the client decides to engage Krilogy’s Services, the relationship begins when Krilogy accepts the executed written Agreement between the client and Krilogy and the client provides the firm complete information regarding appetite for risk, corresponding investment profile, and objectives for which to provide Services that meets the client’s stated needs. Acceptance does not occur upon signature of the Agreement by the client and the financial advisor alone. Any preliminary discussions or recommendations made before the written Agreement is accepted do not constitute investment advice and should not be relied upon as such. Any recommendations made for accounts for which the client does hold under Krilogy’s relationship with custodian’s Charles Schwab or Fidelity, but Krilogy does not receive a Fee as described in Item 5 are made as a courtesy and are complimentary meaning that these accounts are not governed by the Agreement between you and Krilogy and Krilogy does not provide ongoing Services, including but not limited to fiduciary investment advice. See Item 5 for further information on Fees. Krilogy will not offer ongoing portfolio management under the Agreement for any accounts that Krilogy does not receive an information feed from the custodian/platform provider to the firm’s portfolio software. Before engaging the Services of Krilogy, the client should decide if the client is comfortable forgoing the day-to-day management of his/her account(s). Clients of Krilogy typically:
• Need advice and guidance when making investment decisions
• Are at ease with a financial professional making their day-to-day investment decisions
• Are willing to follow a disciplined investment strategy
• Are comfortable paying asset-based (percentage) fees for investments and advice rather than individual commissions or sales charges Clients should consider a number of factors when evaluating whether to hire Krilogy and the Advisor as well as other fee-based advisory programs providing Services similar to those referenced here. Clients may be able to obtain some or all the same or similar services through other fee-based advisory programs of another investment adviser, commission-based broker- dealers, or by performing the services themselves. Clients should consider that, depending on the circumstances, other broker-dealer or investment advisors provide the same or similar Services for a lower overall aggregated fee. Clients may also experience different performance results or tax consequences from what by purchasing the investments separately or through another broker-dealer or investment adviser. Generally, Krilogy will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. However, clients who choose non-discretionary authority will be responsible for all trading and investment decisions in their account and should not rely solely on the recommendations of Krilogy or their financial advisor in choosing investments. Securities Limitations and Corresponding Services: Clients may impose restrictions in investing in certain securities in accordance with values or beliefs by providing those specific restrictions to the financial advisor in writing. Should those restrictions include the restriction against selling certain securities, Clients agree that Krilogy and the advisor would not be responsible for the performance of those securities. Krilogy may allow the transfer in of securities that it would not otherwise recommend or would liquidate at account opening under its management at the specific request of the client with the understanding that those securities would not be part of the Services provided by Krilogy and your Advisor. In such instances, the client would be responsible for advising the advisor when it would be acceptable to liquidate the security and bear the responsibility for the performance or lack thereof those securities that have been restricted from sale. As one example, a client may request that Krilogy continue to maintain securities with a low-cost basis that a client has held for a long period. In this instance, Krilogy and the Advisor will manage the client’s overall portfolio to account for the specific request or restriction of holding a particular security within the account. In another instance, a client may request that an illiquid alternative investment that Krilogy does not follow be held within accounts managed by Krilogy for consolidated reporting purposes. However, if the restrictions prevent Krilogy from properly servicing the client account or if the restrictions would require Krilogy to deviate from its standard suite of Services, Krilogy reserves the right to end the relationship. Depending upon the limitations imposed, client will not be able to participate in Krilogy’s investment models and dynamic rebalancing process. Retirement Account Clients Krilogy is a fiduciary under ERISA with respect to discretionary Fee-based investment management services and investment advice provided to clients, including ERISA plan participants. Krilogy is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided within Individual Retirement Accounts (IRAs) and other tax-qualified accounts under the IRC. As such, Krilogy is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest unless there is an exemption. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid, eliminate the conflict, or rely upon a prohibited transaction exemption. A compensation conflict of interest arises when Krilogy makes recommendations to Clients regarding the distribution and rollover of Client Employer Plan Assets (“Plan”) to an IRA managed under the Agreement with Krilogy (“Rollover”) because Krilogy and the client’s Advisor receive compensation for subsequently providing Services on those assets that it would not have received absent the recommendation, e.g., Fees for advising a rollover IRA. Separately, the DOL considers a Rollover to include a client rolling over tax-qualified IRA accounts that the client previously managed on his/her own or were managed on a commission or fee basis by a broker dealer or registered investment adviser. However, ERISA and IRC allow these rollover recommendations under PTE 2020-02, so long as, after analysis of all relevant factors are completed, the recommendation is in the best interest of the client and provided in writing to the client. No client is under any obligation to Rollover Plan or IRA assets to an IRA or other account advised or managed by Krilogy. Krilogy seeks to mitigate any potential conflict through disclosure, providing education, and assisting in analysis of the client’s options. Typically, Krilogy seeks to not make a recommendation, but to provide education to Clients to help make an informed decision on whether to Rollover their Plans, which will include exploring the clients’ options – Keeping the assets at the former employer, rolling over the assets to an IRA with Krilogy, rolling over the assets to an IRA that the client manages, moving the assets to a new employer plan, if applicable, or cashing out -- including the services and costs of the options of the rollover to Krilogy’s management or leaving the assets in the employer-sponsored plan. Krilogy interprets the DOL rules to exclude providing education on a client’s options along with a discussion about how the Plan assets are currently managed as against Services provided by Krilogy and the advisor on a client’s existing and/or performing a rollover at client’s instruction from ERISA’s definition of advice and/or rollover recommendations. More often than not, a Rollover of a client’s Plan assets take place when an existing Krilogy client leaves his or her employment to either retire or move to a new employer and wishes to consolidate the employer plan assets with Krilogy to gain better control and reporting over the assets and professional management. In those cases, Krilogy and the advisor is already providing Services to the client. As a result, the client is weighing the value ongoing Services typically is heavily weighed by the client when deciding between options. Their advisor is managing their other assets and here is a discussion around how the employer plan account is managed versus its current accounts. Clients should review the costs associated with leaving the assets with your employer versus moving the assets to an IRA as part of your independent review and determination of how to handle the assets in Plan. With regard to IRA Rollovers, the Krilogy Advisor typically works with the client to understand the client’s risk appetite, goals, time horizon and portfolio objectives and then helps the Client assess whether the client’s current accounts are in line. More often than not, the Client is weighing subjective factors, including but not limited to education on his/her current portfolio, discussion and provision of certain financial and tax planning strategies, services provided by Krilogy affiliates, and general intangibles provided by the Advisor in determining whether to hire Krilogy to provide Services. In some cases, where the client has another professional providing investment management services, the professional’s fee is the same or greater than Krilogy’s Fee for Services. Should Krilogy make a Rollover recommendation, Krilogy will manage the compensation conflict through an analysis process designed to develop an informed recommendation in the best interest of the client. To do so, the Advisor will request the client's assistance in obtaining the Plan Benefit Documents from the employer to obtain information about services and expenses within the Plan. The Plan is required to have a Plan Benefits Document. If the client is unable to obtain the Plan Benefit Documents, the Advisor will request recent statements and/or attempt to obtain 5500 information, and potentially utilize industry benchmarks based upon Plan size. Clients should be aware that the use of benchmarks is based upon averages that are not specific costs and expenses of Client’s employer sponsored plan. Please note that certain low-expense investment options may be available through an employer’s (or former employer’s) retirement plan that would not be available to an IRA. Additionally, the Plan may provide low or no cost professional investment guidance services that are

the same or similar to the Services provided by Krilogy. Please note there may also be other advantages to factor in when determining whether should remain at an employer’s (or former employer’s) Plan. A Client should weigh these other factors which included but are not limited to services and investment options received from both the Plan, a new employer retirement plan (if applicable), and Krilogy when making a determination on what to do. The advisor will analyze the Plans investment options, services, and expenses versus Krilogy Fees and Services as well as consider factors specific to the Client, which include, but are not limited to the Services currently being provided by Krilogy; investment advice/education options and level of personalization currently provided on the client’s Employer Sponsored Plan Assets both before and after employment termination and corresponding cost; client’s current employment status and desire to remain connected to the employer; client options for the assets within the Employer Sponsored Plan, and personal preferences for how the client wishes the Plan assets to be managed. The client should understand that leaving the client’s assets in the former employer plan, moving it to the new employer plan, or client managed rollover to an IRA in almost all cases is less expensive than Krilogy’s Fees to provide professional Services. Clients that choose to Rollover these assets are doing so despite the additional cost. As a result, typically whether the Rollover is in the best interest of the client is not measured simply by the quantitative cost, but the amount, quality and ease of Krilogy Services as well as the personalized relationship that Krilogy and the client’s Advisor provide and the corresponding qualitative value attach to those factors for the additional Fee paid to Rollover the Plan assets. Custody Services Krilogy does not provide qualified custodian services for Client accounts. Client accounts will be maintained at a financial institution of a qualified custodian. Clients generally provide Krilogy and/or certain independent managers with the authority to directly debit their accounts for payment of Services. The qualified custodians have agreed to send statements to clients not less than quarterly detailing all account transactions, including the amount paid to Krilogy. Clients will also receive written trade confirmations of securities transactions from the Qualified Custodian. Krilogy provides a summary on a quarterly basis upon request; however, this information is based upon information fed by the custodian to the firm’s internal software systems. Clients should review their account statements from their qualified custodian carefully and notify us immediately if an error or a discrepancy is detected from any Krilogy reports. Financial Planning Provided Under Portfolio Management Services (exclusive of SMA Program): As a complement to Krilogy’s Services described above, at the Advisor’s discretion the Advisor will provide financial planning services under several formats at the client’s specific direction. Typically, the financial planning is geared toward integrating a client’s professional and personal life, but on limited occasions can be standalone financial planning or financial consulting services. There is not a specific asset under management minimum for which this would be offered. The client must request and the financial advisor must agree to provide such services. The financial planning services provided, may be specific or modular in their preparation (unique to each client in their depth of preparation). Topics included as part of the financial planning services can include, but are not necessarily limited to, the following:
• Personal: Organization of family records and assessment of family records, budgeting, personal liability, estate information, and financial goals
• Retirement Planning: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals
• Education Planning: 529 Plans and general assistance in preparing to meet dependents continuing educational needs
• Long-term Care
• Risk Management & Insurance Planning: Cash needs at death, income needs of surviving dependents, and disability income analysis
• Debt Management
• Investments: Analysis of investment alternatives and their effect on a client’s portfolio
• Tax & Cash Flow Planning: Income tax, spending analysis, and planning for past, current, and future years
• Estate Planning (this does not include legal advice, guidance or document preparation)
• Life Events Information gathered includes a client's current financial status, future goals, and attitudes toward risk. Should a client choose to implement the recommendations contained in the plan, Krilogy suggests the client work closely with his/her attorney, accountant, and/or insurance agent. Implementation of financial plan recommendations is entirely at the client's discretion. Financial planning recommendations are of a generic nature and are not limited to any specific product or service offered by a broker-dealer or insurance company. Sub-advisor Services Krilogy through KPS provides investment management and portfolio construction services through model portfolio delivery. These models include an array of equity strategies, risk-based asset allocation models and target objective models (“Sub-advisory Services”). Sub-advisory Service clients (“Sub-advisory Clients”) may include entities such broker-dealer, investment advisory firms or other financial institutions (on behalf of their clients) (“Financial Institutions”), charitable institutions, foundation endowments, and registered investment companies. These Sub-Advisory Services are offered primarily through non-Krilogy financial advisors (“Outside Advisor”) of these Financial Institutions who work with clients to examine the client’s current financial situation and financial goals, to understand the risk tolerance and investment time horizon to develop an overall investment strategy. As part of the overall strategy the Outside Advisor assists the client in utilizing the appropriate equity strategy or risk-based asset allocation model. The accounts managed by the Outside Advisor are maintained with the client’s Financial Institutions. As a result, KPS and Krilogy do not direct the Outside Advisor or Outside Advisor’s client which Financial Institution to utilized or for which to execute the security transaction. These Sub-advisory Services are offered either on a “discretionary” or a “non-discretionary” basis. However, there are distinct differences set forth below based upon whether Krilogy and KPS have discretionary or non-discretionary authority. Regardless of discretion, Sub-advisory Services are limited to portfolio management and do not include financial planning, wealth management, accounting, retirement planning, legal, tax advices or any other related or unrelated services. Krilogy and KPS negotiate and enter into agreements to provide discretionary SMA Services to clients with Financial Institutions and other third-party platforms. When KPS is providing discretionary Sub-advisory Services, which is typically referred to as separately managed account services (“SMA Services”), the Outside Advisor assists the SMA Client in opening an account at the Financial Institution to select third-party investment advisory firms (such as Krilogy and KPS) to manage all or a portion of the assets in the account. These SMA Services arrangements can be “single contract,” in which Krilogy enters into contract with the Financial Institution to provide discretionary SMA Services to the SMA Clients of such Financial Institution, or can be “dual contract,” in which Krilogy enters into a contract directly with the client to provide SMA Services to the SMA Client, which is in addition to the SMA Client’s contractual agreement with such Financial Institutions. Regardless, the Outside Advisor is responsible for assisting the SMA Client with selecting the appropriate strategy or risk-based asset allocation model. Krilogy and KPS rely upon the client’s Financial Institution’s representation of which KPS strategy is appropriate. When Krilogy maintains discretion of an SMA Client’s account, Krilogy is granted the authority by the SMA Client to determine the securities or other assets to purchase or sell in the account. This discretion will remain in effect unless revoked by the SMA Client or the Outside Advisor. Krilogy will monitor the SMA Client’s account and purchase and sell securities and other assets in the account consistent with the strategy/strategies and/or risk-based asset allocation models selected by the SMA Advisor on behalf of the SMA Client. As part of the SMA Client’s overall investment plan. The SMA Client through the Outside Advisor may provide reasonable restrictions in writing to Krilogy. However, despite providing reasonable restrictions, Krilogy reserves the right to decline the management of the SMA Client even if the restrictions are reasonable. In a non-discretionary account, KPS makes recommendations to Financial Institutions and its Outside Advisor concerning securities and other assets, but KPS does not have the authority to implement such recommendations. The Outside Advisor, on behalf of their client, has the sole authority to determine whether securities or other assets in the account are purchased or sold on the client’s behalf in accordance with KPS recommendations and to determine the Financial Institution through which such transactions are implemented. As a result, the non-discretionary Sub-advisor Services typically take the form of model portfolios, which represent Krilogy’s recommendations as to the composition of a portfolio of securities that would be reasonably appropriate to meet a stated investment objective based upon criteria provided by the client to their Financial Institution. Krilogy and KPS’s role is solely to provide to these Financial Institutions recommendations as to the securities composing the portfolio and advice on changes to the portfolio. Any non-discretionary model services provided are provided to the end client’s Financial Institution, whom makes an individual determination on whether the services are in the best interest of the client. The Financial Institution will utilize these recommendations in managing the accounts of the clients of the Financial Institution. The Financial Institutions retain full discretion to accept, modify or reject Krilogy and KPS’s recommendations and retain trading authority over their client’s accounts. The model portfolios for non-discretionary Sub-advisory Services clients are similar to the portfolios of SMA Clients with the same investment strategy. Due to the difference in discretion and corresponding management between SMA Clients and non-discretionary Sub-advisor Services clients, performance difference are expected to occur because Krilogy and KPS do not have trading discretion over the model portfolios as well as the Sub-advisory Service’s Client’s Financial Institution’s full discretion in incorporating none, some or all of Krilogy and KPS’s model recommendations. Differences are also likely to occur based upon the Financial Institution setting drift thresholds from Krilogy and KPS directed model target allocations in order to minimize trades and trade costs. Regardless of whether the Sub-advisory Servies are offered discretionarily or non-discretionarily, some direct Krilogy Clients utilize the same KPS risk-based asset allocation models as part of Krilogy Services to them. Krilogy and KPS indirectly manage assets for Sub-advisory Services Clients that are employee benefits plans or retirement accounts covered under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and the Internal Revenue Code (the “IRC”) as further outlined in the Retirement Account section above. Financial Planning & Consultation Services Only2 While Krilogy and its advisors do not typically provide one-time Financial Planning & Consulting Services Only, in rare cases, Krilogy and the advisor may agree to do so for an hourly or flat fee. These financial planning services may include, but are not limited to: investment/financial consulting, life insurance; tax concerns; retirement planning; college planning; debt/credit planning and investment/portfolio recommendations. The written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. These services are provided under a Financial Planning Agreement. Financial Planning and Consulting Services provided under a Financial Planning Agreement do not include continuous investment and financial advice and are deemed completed upon provision of the agreed upon financial planning output. The client is responsible for implementing and monitoring any investment/financial consulting provided. 2 Exclusive of SMA Services Corporate Employee Benefit Retirement Consulting and Management Services (K) Plans, a division of Krilogy also provides advisory services to retirement plans using the third- party administration services of certain retirement plan service providers. For such clients, Krilogy is engaged by plan fiduciaries to provide both fiduciary and non-fiduciary investment management and advisory services that include but are not limited to plan consulting, participant education and enrollment, investment policy statement development assistance and investment menu selection, and performance monitoring. Krilogy may act under the Employee Retirement Income Section Act (“ERISA”) as either a 3(38)-investment manager or a 3(21)-investment advisor to a variety of retirement plans. As a Section 3(21) investment advisor, Krilogy is responsible for making investment recommendations to the plan regarding the fund options made available to plan participants. The plan fiduciaries are ultimately required to exercise their discretion to act upon the investment recommendations made to Krilogy. As a Section 3(38) ERISA investment manager, Krilogy is responsible for determining the appropriate investment options available to plan participants and provides those options to the third-party administrator and qualified custodian so that they may be available to plan participants. Krilogy performs ongoing monitoring of investment options and implements changes as necessary. Consent of the Plan for investment option changes is not required. Plan fiduciaries will be given notice of changes to existing allocations and/or menu choices; however, Krilogy will implement those changes as promptly as possible in coordination with the third- party administrator and plan custodian. Krilogy may also provide certain plan participant enrollment and educational services. These services are non-fiduciary consulting services. The educational presentations provide assistance to plan participants in how to evaluate their specific goals, objectives, and risk tolerance to identify an asset allocation that best suits their goals as well as understanding how asset allocation affects investment results. Krilogy may also provide non-fiduciary consulting services that include facilitating benefit committee meetings and consulting on industry trends. Krilogy provides investment management and investment consulting services to large institutional clients, endowments, foundations, and charitable organizations as well. Wrap Fee Program In 2019, Krilogy implemented a Wrap Fee Program exclusively for a specific advisor and his clients who joined the firm. These clients were previously enrolled in a similar program. In this program, Krilogy, through the advisor acts as a portfolio manager for and sponsor of a wrap fee program which utilizes a specific investment philosophy to predominantly invest in individual company securities. The program is designed for the client to pay one stated fee that includes management fees, most trading/transactions costs, and other administrative fees. Clients that are not in the Wrap Fee Program can incur transaction and other trade costs associated with the purchase and sale of securities in the management of the client’s investment portfolios. However, this Brochure describes non-wrap fee advisory services. Clients utilizing Krilogy’s Wrap Fee Portfolio management should review the separate Wrap Fee Program Brochure. Krilogy manages the investments in the Wrap Fee Program but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. Fees paid under the Wrap Fee Program will be given to Krilogy as a management fee. Krilogy does not actively solicit the Wrap Fee Program to any other clients beyond the specific advisor’s clients referenced above. Given the cost from Krilogy’s fee perspective of two percent (2%) this is generally a more costly program than the Services offered in this Brochure for the Fees discussed in Item 5. While Krilogy does not actively solicit this program, the firm would allow a client to request whether it should be considered as part of the Services provided. An important factor to consider is the amount of individual trading activity in the client accounts and the corresponding brokerage commissions and transaction costs that would be charged depending upon the security. These costs would also be impacted by the advisor and Krilogy’s ability to aggregate trades. Other factors to consider include the costs and availability of services, if provided separately, which in turn depends on the prices and specific services offered by different providers. Clients also may experience different performance results or tax consequences from what when purchasing the investment separately or through another broker- dealer or investment advisor. Separately, Krilogy recommends the use of AQR Capital Management’s Flex SMA strategy to limited ultra-high net worth clients as a tax savings strategy. AQR requires Krilogy’s clients invest in this strategy in a Wrap Fee structure. AQR is the manager and sponsor of this Wrap Program through Fidelity. However, Krilogy treats the recommendation of AQR’s strategy as no different from recommending an SMA or ETF under this Brochure and does not utilize a Wrap Program for participating clients’ accounts. However, to comply with AQR’s requirements, the assets invested in this strategy are separated and the client is provided AQR’s management brochure. Insurance and Other Services Krilogy and its financial advisors may recommend changes or additions to a client’s health, life, disability, or long-term care insurance coverage as part of financial planning. This service is complimentary and the client is free to follow or decline such recommendations. In those instances where a client elects to purchase the recommended insurance policy, they can do so through Krilogy and the advisor, acting as a licensed insurance agent, or an outside insurance broker. The purchase of insurance is separate and apart from the Services provided under the Agreement between with Krilogy and the Services set forth in the Wrap Fee Program. Krilogy and the advisor has a compensation conflict of interest as any purchase of insurance coverage results in additional compensation beyond Fees charged. The compensation is paid to Krilogy and the advisor by a separate insurance provider in the form of commissions related to the premiums of the insurance product sold. Advisors also receive cash (e.g., money) and non- cash awards (e.g., trips) from third-party vendors for aggregate insurance sales. Please see Item 5 – Fees and Compensation, Other Forms of Compensation for additional information regarding commissions received in connection with the sale of insurance products. No Legal or Public Accounting Advice While certain financial advisors are licensed attorneys or certified public accountants, Krilogy is not a law firm or a public accounting firm and our advisor would not provide legal or tax advice. However, the client may engage an affiliate Krilogy Tax Services under separate engagement to provide tax preparation and planning. The client may also engage KEP Law, LLC d/b/a Krilogy Law, a separate and independent law firm that maintains affiliation through a common owner, to provide estate and business planning legal services under separate agreement. Organizational Oversight Krilogy has instituted various levels of oversight to ensure its professionals adhere to the firm’s policies and procedures and standards of business conduct. The Strategic Planning Committee manages and supervises the overall strategic direction of the firm with input from the Board. It also manages and supervises the overall day-to-day business operations of the firm. Services are based on the recommendations of Krilogy and your Advisor. As part of the organizational oversight, your Advisor agrees to be legally responsible for following the firm’s policies and procedures as well as any decisions made in your accounts. Krilogy is comprised of an Investment Committee made up of senior leadership and advisors lead by its Chief Investment Officer. The Investment Committee believes in building portfolios to match the investor’s ability and willingness to take risk and do so in a cost-efficient way. The Investment Committee provides a centralized decision-making process in the formulation of investment models that can be, but does not have to be, utilized by your advisor in providing Services. The Investment Committee establishes investment guidelines for formulating investment strategies. These policies help to formulate the oversight of client portfolios whether your advisor chooses to utilize the Investment Committee’s investment models as part of your overall portfolio or not. Even so, because your investment advisor may operate independent of the Investment Committee and the firm’s investment strategy offerings and is in best position to understand your specific needs, your Advisor has the final decision on any investment strategy in your accounts. Your financial advisor monitors and evaluates those investments against your Investment Profile and Objective. Generally, a client’s accounts are managed at the Household level with a Household portfolio objective. While each account could be managed in a different fashion, the focus is on the overall management of the household. The firm regularly supervises client accounts/portfolios utilizing predefined parameters for each Investment Profile and Objective to identify accounts/portfolios for further review, update and/or documentation to support the rationale for current management by your advisor. A client’s account(s)