Benjamin F. Edwards & Company (“BFE” or the “Firm”) is a registered investment adviser and a broker-dealer. BFE became registered as a broker-dealer in March of 2009 and, until May 2010, conducted its investment advisory business through an affiliate, BFE Asset Management, LLC. In May 2010, all investment advisory operations and programs of BFE Asset Management transitioned to BFE, which at that time had become registered as an investment adviser subject to the jurisdiction of the Securities and Exchange Commission (“SEC”). In addition to being a registered investment adviser, BFE is engaged in a variety of investment-related business activities. BFE is registered as a broker-dealer and its management persons are registered representatives of the broker-dealer. In addition, BFE is also a member of the National Futures Association as an Independent Introducing Broker (IIB) and some of its management personnel are associated persons of the IIB. BFE is also licensed as an insurance agency and sells a wide variety of insurance products. BFE also operates an equity and fixed income trading desk. Transactions facilitated by the trading desk that involve investment advisory clients will generally only be done on an agency basis. In limited circumstances, BFE is permitted to engage in transactions involving an investment advisory account on a principal basis; however, any such transaction would require the client’s prior express consent. Transactions facilitated by the trading desk that involve brokerage clients may be done on an agency, principal or “riskless principal” basis. BFE also provides “mergers and acquisition” (M&A) advice to businesses. Such advice is not typically provided as part of the Firm’s investment advisory services and would typically involve separately negotiated compensation. BFE’s principal owner is its holding company, Benjamin Edwards, Inc. (“BEI”), which owns 100% of BFE. In August 2018, BEI started a separate related registered investment advisor firm, Benjamin F. Edwards Wealth Management, which is also an investment adviser registered with the SEC. BFE’s primary advisory service involves investment programs that bundle or “wrap” services (investment advice, reporting trade execution, custody, etc.) together and charge a fee based on the value of assets under management. Additionally, BFE offers Financial Planning, Retirement Plan Consulting, Investment Management Consulting, and Plan Participant Advisory Services. These programs are outlined in further detail below. BFE retains a portion of advisory fees paid, including wrap fees, as compensation for its services; the remainder is used to compensate third parties, such as Pershing LLC (“Pershing”), BNY Mellon Advisors, Inc. (“BNY Mellon Advisors”), and third-party asset managers or model providers for services they provide. As of December 31, 2023, BFE has $8,277,983,829 managed on a discretionary basis and $4,880,430,675 managed on a non-discretionary basis. Investment Advisory Accounts and Transaction-Based Brokerage Accounts When a client chooses to purchase products and services through BFE and work with a BFE financial advisor, the client has the option of investing through a transaction-based account, such as a brokerage account, a fee-based investment advisory program, or both. It is important for clients to understand the services they will receive, the fees, costs, and expenses they will pay, and BFE and the BFE financial advisors’ conflicts of interest in connection with different account and relationship types. Broker-Dealer Relationship – In a brokerage account, the relationship between the client and the financial advisor is centered on transactions. Therefore, a client pays a separate commission for each transaction that covers the cost of executing the transaction, and certain related services and incidental advice. For example, if a client desires that a financial advisor make recommendations in connection with a brokerage account, the financial advisor will document, usually at account opening, certain suitability characteristics based on questions contained in the Firm’s General Account Agreement. Based on that information, the financial advisor, from time to time, provides incidental recommendations or advice. Transaction commissions also compensate the Firm for some non-transaction-related Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 6 of 45 services such as delivery of account statements, prospectuses, and proxy mailings (where applicable); and, if desired, custody services for securities owned by the client. Additional detail about BFE’s brokerage services, fees and conflicts can be found in the Firm’s “Regulation Best Interest Disclosure”, located at benjaminfedwards.com under “Important Disclosures”. Investment Adviser Relationship – In an investment advisory account on the other hand, the relationship between the client and the financial advisor is centered on advice. Therefore, in a wrap-fee based advisory account, a client pays a fee based on the value of assets in the account, which compensates the Firm for more comprehensive initial client assessment, ongoing investment advice, ongoing monitoring of the account, the cost of any transactions that may occur, and for certain responsibilities and risks that BFE assumes in connection with being a statutory fiduciary that is subject to a different regulatory scheme. In addition, BFE will serve as a fiduciary as defined by the Department of Labor for certain qualified retirement accounts. Wrap Programs On April 1, 2023, Benjamin F. Edwards & Company (“BFE” or the “Firm”) consolidated its legacy investment advisory programs. As a result of the consolidation, BFE now offers investment advisory services through the following wrap fee based advisory programs:
• Benjamin F. Edwards Discretionary Investment Advisory Program
• Benjamin F. Edwards Non-Discretionary Investment Advisory Program BFE will continue to support clients who enrolled in BFE’s legacy advisory programs prior to April 1, 2023 (“legacy clients”) in accordance with the respective program features and fees described in this section. Prior to April 1, 2023, BFE offered investment advisory services through the wrap fee based advisory programs listed below (“legacy programs”). BFE’s legacy programs also represent current strategies offered by asset managers that include BFE, BFE financial advisors and third-party asset managers under BFE’s new consolidated Discretionary and Non-Discretionary Investment Advisory Programs.
• Benjamin F. Edwards Mutual Fund Portfolios
• Benjamin F. Edwards Mutual Fund Model Strategies
• Benjamin F. Edwards Active Passive Portfolios
• Benjamin F. Edwards Exchange Traded Fund Portfolios
• Benjamin F. Edwards Equity Portfolios
• Benjamin F. Edwards Private Portfolios
• Benjamin F. Edwards Separately Managed Portfolios
• Benjamin F. Edwards Unified Managed Account
• Benjamin F. Edwards Tax Transition Strategies
• Investment Management Consulting (with Execution)*
• Benjamin F. Edwards Client Portfolios
• Benjamin F. Edwards Custom Mutual Fund Portfolios
• BNY Mellon Target Risk Portfolios (formerly Lockwood Asset Allocation Portfolios) Services and Fees As described more in this disclosure brochure, BFE offers strategies in its discretionary investment advisory program and legacy programs that involve the use of third-party asset managers. Under the same regulations that require BFE to deliver this disclosure brochure to our clients, third-party asset managers also must produce and distribute disclosure brochures to BFE clients when applicable. Delivery of the third-party asset manager’s disclosure brochures is handled initially and ongoing by BFE or a designated third-party. Clients may inquire through BFE or their financial Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 7 of 45 advisor if they would like a copy of the third-party manager’s disclosure brochure. BFE will work on a best-efforts basis to obtain the disclosure brochure to provide to our clients. Services provided as part of the wrap fee include:
• Access to a BFE advisor for personal service and financial advice
• Review of suitability based on information provided in advisory agreement, General Account Agreement, and client interview*
• Portfolio management services*
• Delivery of account statements
• Performance reporting*
• Fee billing*
• Execution of transactions
• Custody and clearance of securities*
• Administration of requests for reasonable restrictions on the management of accounts * These services may or may not be provided in the Investment Management Consulting (with Execution) program depending on the services negotiated and agreed upon. Please see the “Investment Management Consulting (with Execution)” section for further detail. Additional services may be provided based on the advisory program selected. In addition, some of the services above will vary in situations where any assets are held with the issuer or a custodian other than Pershing, as described further below. Benjamin F. Edwards Current Investment Advisory Wrap Programs Benjamin F. Edwards offers a Discretionary Investment Advisory Program and a Non-discretionary Investment Advisory Program. The degree and nature of investment discretion clients grant with respect to their accounts will vary according to the investment advisory program chosen. Additional detail on both programs, including fees and additional services, are as follows. Discretionary Investment Advisory Program The Benjamin F. Edwards Discretionary Investment Advisory Program is an advisory program where portfolio management services are provided to the client on a discretionary basis for a wrap fee based on the value of the account. As a discretionary account, the financial advisor is not required to contact the client prior to each transaction or investment decision. Clients grant full discretionary trading authority for their selected strategy within the Discretionary Investment Advisory Program. Clients also grant full discretion to BFE and the financial advisor to change the manager and strategy on the account without further client approval. BFE offers several strategies within the Discretionary Investment Advisory Program. Strategies are offered by BFE, BFE financial advisors, and third-party asset managers. Clients work with their financial advisor to identify a strategy that is appropriate based on the client’s investment profile and objectives. The financial advisor will monitor the account to ensure the strategy remains appropriate. Within the Discretionary Investment Advisory Program, BFE is authorized to implement the selected strategy on a discretionary basis, either through BFE or BFE’s third-party service providers, or through another registered investment adviser or broker-dealer, including for purposes of funding the client’s participation in the advisory program, for the ongoing management of the account, and placement and execution of transactions. Benjamin F. Edwards Non-Discretionary Investment Advisory Program The Benjamin F. Edwards Non-Discretionary Investment Advisory Program is an advisory program where portfolio management services are provided to the client on a non-discretionary basis for a wrap fee based on the value of the account. As a non-discretionary account, the client retains final decision-making authority with Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 8 of 45 respect to opening and closing transactions. BFE can convert mutual funds into equivalent ETFs when the option exists with the issuer, is a tax-free event, and is deemed to be an appropriate option for the client. The financial advisor and client will work together to identify an appropriate investment strategy. The financial advisor will monitor the account to ensure it remains consistent with the strategy and make recommendations as needed. Benjamin F. Edwards Discretionary Investment Advisory Strategies BFE’s current investment advisory strategies also include some of our legacy investment advisory programs. BFE will continue to support clients who opened accounts prior to April 1, 2023 in accordance with the terms outlined in their original Investment Advisory Agreement, which remains in full effect. The following represents BFE’s current discretionary strategies offered by asset managers that include BFE, BFE financial advisors and third-party asset managers. Characteristics and additional services for BFE’s investment advisory strategies are as follows: Benjamin F. Edwards Mutual Fund Portfolios Benjamin F. Edwards Mutual Fund Portfolios is a discretionary advisory strategy in which the portfolios are comprised of mutual funds and/or exchange traded funds (“ETFs”). Traditionally, this strategy has invested solely in mutual funds; however, with the evolution of ETFs, it is possible that an ETF will be utilized in this strategy if deemed to be an appropriate vehicle to be used for economic or investment reasons. The asset allocation models include a variety of asset types that, together, offer appropriate style diversification (i.e., diversification among large, mid and small-cap funds, as well as value vs. growth strategies, as well as models with exposure to alternative investments) to accommodate each investment objective. Additionally, models containing only alternative investments are available. Clients will work with their financial advisor to determine the asset allocation model most appropriate for their needs. The models developed and used by BFE are strategic (but not static) in nature, consistent with a 7-to-10-year investment horizon. They are reviewed on an ongoing basis and a full asset allocation study is conducted at least annually. Adjustments to the asset class weightings (equity vs. fixed income) are expected to be relatively minimal while the allocations by sub-category (international vs. domestic or large cap vs. small cap) could happen more frequently as part of the annual review. The models are designed to provide the investor with broad style diversification. Where appropriate, multiple funds are selected for a style to provide additional diversification. Additional Services:
• BFE shall invest, reinvest, sell or retain assets in its sole discretion for this account
• Ongoing monitoring, due diligence, and research on the mutual funds and ETFs offered in the Benjamin F. Edwards Mutual Fund Portfolios
• Maintenance and trade implementation of the fund models
• Rebalancing of the funds to conform to the investment allocations per the frequency selected and as needed for deposits/withdrawals
• Proxy voting by BFE o If client authorizes BFE, clients may contact their financial advisor to request information regarding how the proxies were voted Benjamin F. Edwards Mutual Fund Model Strategies Strategies are provided by Russell Investments and American Funds. Mutual Fund Model Strategies is a discretionary advisory strategy. Russell offers three sets of strategies: mutual fund only, tax managed mutual fund only, and hybrid models that utilize exchange traded products and mutual funds. In these models, the mutual funds are Russell Investment’s funds, but the exchange trade products are not Russell products. Russell provides the models and the funds to use within each model. These models allow for balanced and diversified portfolios. Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 9 of 45 American Funds offers a suite of strategies comprised of American Funds’ funds. Currently, these strategies are comprised of mutual funds; however, with the evolution of actively managed ETFs, American Funds may deem it appropriate to use ETFs in these strategies in the future. American Funds provides the models and the funds to use within each strategy. These strategies are diversified objective-based portfolios. Clients will work with their financial advisor to determine the asset allocation most appropriate for their needs. Additional Services:
• BFE shall invest, reinvest, sell, or retain assets in its sole discretion for this account
• Ongoing monitoring, due diligence, and research by BFE on the Model Strategies
• Ongoing monitoring, due diligence, and research by the model providers on the funds and allocations
• Maintenance and trade implementation of the mutual fund models on BFE’s platform
• Rebalancing of the funds to conform to the investment allocations per the frequency selected and as needed for deposits/withdrawals
• Proxy voting by BFE o If client authorizes BFE, clients may contact their financial advisor to request information regarding how the proxies were voted Benjamin F. Edwards Active Passive Portfolios Benjamin F. Edwards Active Passive Portfolios is a discretionary strategy that combines mutual funds and exchange traded funds (“ETFs”) in a suite of models. The mutual funds and ETFs used in this strategy are a combination of actively managed and passively managed products to provide exposure to both methodologies of investing in one account. The asset allocation models include a variety of asset types that, together, offer appropriate style diversification (i.e., diversification among large, mid and small-cap funds, as well as value vs. growth strategies as well as models with exposure to alternative investments) to accommodate each investment objective. Clients will work with their financial advisor to determine the asset allocation model most appropriate for their needs. The models developed and used by BFE are strategic (but not static) in nature, consistent with a 7-to-10-year investment horizon. They are reviewed on an ongoing basis and a full asset allocation study is conducted at least annually. Adjustments to the asset class weightings (equity vs. fixed income) are expected to be relatively minimal while the allocations by sub-category (international vs. domestic or large cap vs. small cap) could happen more frequently as part of the annual review. The models are designed to provide the investor with broad style diversification. Where appropriate, multiple funds are selected for a style to provide additional diversification. Additional Services:
• BFE shall invest, reinvest, sell or retain assets in its sole discretion for this account
• Ongoing monitoring, due diligence, and research on the mutual funds and ETFs offered in the Benjamin F. Edwards Active Passive Portfolios
• Maintenance and trade implementation of the models
• Rebalancing of the securities to conform to the investment allocations per the frequency selected and as needed for deposits/withdrawals
• Proxy voting by BFE o If client authorizes BFE, clients may contact their financial advisor to request information regarding how the proxies were voted Benjamin F. Edwards Exchange Traded Fund Portfolios Benjamin F. Edwards Exchange Traded Fund Portfolios is a discretionary advisory strategy that utilizes exchange traded funds (“ETFs”) and/or exchange traded notes (“ETNs”) as the portfolio’s investment vehicles. BFE, Confluence Investment Management LLC (Confluence), First Trust Portfolios L.P. (First Trust), Laffer Tengler Investments (Laffer), and Morningstar Investment Services, LLC (Morningstar) serve as the model providers for this strategy and supply the models and recommendations for specific investments within each model. BFE may Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 10 of 45 modify those recommendations when implementing the strategy. The Confluence models are style-diversified and cyclical in nature. The First Trust models are designed to meet core equity and core fixed income objectives or to meet broadly defined risk profiles. Laffer provides a global equity strategy model and a U.S. inflation model. Morningstar Strategic Ibbotson models are style-diversified and strategic in nature. The models developed and used by BFE are strategic (but not static) in nature, consistent with a 7-to-10-year investment horizon. They are reviewed on an ongoing basis and a full asset allocation study is conducted at least annually. Adjustments to the asset class weightings (equity vs. fixed income) are expected to be relatively minimal while the allocations by sub- category (international vs. domestic or large cap vs. small cap) could happen more frequently as part of the annual review. The models are designed to provide the investor with broad style diversification. Where appropriate, multiple funds are selected for a style to provide additional diversification. Clients will work with their financial advisor to determine the asset allocation model most appropriate for their needs. Additional Services:
• BFE shall invest, reinvest, sell or retain assets in its sole discretion for this account
• Ongoing monitoring, due diligence, and research by BFE on Confluence Investment Management LLC, First Trust Portfolios L.P., Laffer Tengler Investments and Morningstar Investment Services
• Ongoing monitoring, due diligence, and research by Confluence Investment Management LLC, First Trust Portfolios L.P., Laffer Tengler Investments and Morningstar Investment Services in connection with securities and allocations that they recommend
• Maintenance and trade implementation of the models
• Rebalancing of the securities to conform to the investment allocations and as needed for deposits/withdrawals
• Proxy voting by BFE o If client authorizes BFE, clients may contact their financial advisor to request information regarding how the proxies were voted Benjamin F. Edwards Equity Portfolios Benjamin F. Edwards Equity Portfolios is a discretionary model-based advisory strategy that uses a portfolio of individual equity securities. BFE has developed and utilizes a quantitative, factor-based approach with a qualitative overlay to manage the equity model(s). Balanced portfolios that utilize taxable or municipal bond ETFs are also available for fixed income exposure. Additional Services:
• BFE shall invest, reinvest, sell, or retain assets in its sole discretion for this account
• Ongoing monitoring, due diligence, and research on the equity securities offered in the Benjamin F. Edwards Equity Portfolios
• Monitoring and trade implementation of the stocks in the model(s) as needed to stay aligned with the stated investment strategy
• Proxy voting by BFE o If client authorizes BFE, clients may contact their financial advisor to request information regarding how the proxies were voted Benjamin F. Edwards Private Portfolios Benjamin F. Edwards Private Portfolios is an advisory strategy where portfolio management services are provided by the BFE financial advisor to the client on a discretionary basis for a wrap fee based on the value of the account. As a discretionary account, the financial advisor is not required to contact the client prior to each transaction or investment decision. The client and financial advisor will work together to develop an investment strategy. When implementing

the client’s investment strategy, the financial advisor has the option to administer any portion of the allocation directly, or to employ solutions offered by BFE or a third party. The financial advisor will monitor the account to ensure it remains consistent with the investment strategy and that the strategy remains appropriate. Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 11 of 45 Additional Services:
• Investing, reinvesting, selling or retaining assets at the financial advisor’s sole discretion, based on the client’s suitability profile
• Utilizing solutions offered by other investment advisors (BFE and/or third-party asset managers) at the financial advisor’s sole discretion, based on the client’s suitability profile
• Ongoing monitoring and security selection by the financial advisor
• Development of an asset allocation
• Rebalancing of the securities as needed to conform to the investment allocations and/or for deposits/withdrawals Benjamin F. Edwards Separately Managed Portfolios Benjamin F. Edwards Separately Managed Portfolios advisory strategies provide the client with an opportunity to access investment strategies of third-party asset managers that BFE makes available on its advisory platform. BFE and/or its delegates conducts initial and ongoing research and due diligence on these asset managers. BFE outsources the due diligence reviews of third-party asset managers to external parties that specialize in such reviews. BFE may rely on these outside parties when making recommendations to clients to use, terminate or replace an asset manager. BFE will utilize this due diligence along with evaluating the economic efficiencies, level of interest in the asset manager and strategy, and how the strategy fits into BFE’s strategic offering when approving asset manager strategies for inclusion. Additionally, BFE performs ongoing monitoring of any external parties utilized for ongoing due diligence of third-party asset managers. BFE is the sponsor of the strategy with the asset manager serving as the sub-advisor. Strategies may be implemented by the third-party asset manager directly, or by the asset manager providing models to BFE and/or third-party investment advisers that partner with BFE, who will manage the account per the model provided. Periodic information regarding the asset manager and its strategy will be available to BFE’s financial advisors to provide to clients upon request. Additional Services:
• The asset manager, BFE, or a third-party investment adviser, as applicable, shall invest, reinvest, sell or retain assets in its sole discretion for this account
• Ongoing monitoring and due diligence on the asset manager strategies by BFE or its delegate
• Ongoing monitoring, due diligence, and research by the Manager on the securities utilized in the strategies
• Proxy voting by BFE or the asset manager, as applicable o If client authorizes BFE or the manager to vote, clients may contact their financial advisor to request information regarding how the proxies were voted Benjamin F. Edwards Unified Managed Account (“UMA”) UMA is a discretionary, multi-discipline managed account product housed in a single account. There are six diversified core models that span the Firm’s nine strategic allocation models. BFE is the sponsor, and BNY Mellon Advisors, Inc. (“BNY Mellon Advisors”) serves as the overlay manager. BFE and BNY Mellon Advisors work together to determine the default asset allocation percentages and allowable bands for each model. BNY Mellon Advisors and BFE select the investments to be used for each style allocation, also known as each sleeve, of the core models. Additionally, BNY Mellon Advisors’ investment committee and BFE approve each investment vehicle available in the UMA. A sleeve can contain a third-party asset manager’s strategy, an exchange traded fund, a mutual fund, or a combination of all three. Additionally, a mutual fund model or ETF model provided by BFE or a third-party strategist may be used within the UMA. The BFE UMA is a flexible UMA in that, once the client has selected a model, the Advisor has discretion to follow the core model as determined by BFE and BNY Mellon Advisors or to adjust asset allocation/style percentages Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 12 of 45 within the allowable bands in addition to substituting in other approved investment vehicles. This customization and flexibility allows the Advisor to work with the client and tailor the UMA to their needs, objectives, preferences and circumstances. Additional Services:
• BNY Mellon Advisors shall invest, reinvest, sell or retain assets in its sole discretion for this account per the model selected
• Ongoing monitoring, due diligence, and research by BFE and/or BNY Mellon Advisors on the securities, managers and strategists available in the UMA
• Maintenance and implementation of the models
• Rebalancing of the securities to conform to the model allocations
• Proxy voting by BNY Mellon Advisors depending on election made on the client advisory agreement o If client elects for BNY Mellon Advisors to vote the proxies, clients may contact their financial advisor to request information regarding how the proxies were voted Benjamin F. Edwards Tax Transition Strategies Benjamin F Edwards Tax Transition Strategies (“TTS”) is a discretionary investment management strategy that is customized to address the investment objective and unique tax considerations of each client account. The objective of a TTS portfolio is to provide a tax aware conversion from a basket of securities to a managed target strategy. Working with a BFE financial advisor, a client enrolled in a TTS portfolio sets an annual threshold for capital gains and/or a time horizon to transition to the target strategy. The amount of taxes paid can vary depending on the chosen path of transition and the tax budget. If limiting capital gains in any given year is a priority, it will take longer to complete the transition plan. The portfolio managers use a third-party tax quantitative transition tool to periodically surveil the portfolio for opportunities to buy and sell securities in a tax efficient manner with the goal of being fully invested in the target model. BFE or its third-party designate shall invest, reinvest, sell, or retain assets in its sole discretion for this account as needed to stay aligned with the stated investment strategy. Additional Services:
• BFE or it’s designated third-party shall invest, reinvest, sell, or retain assets in its sole discretion for this account
• Ongoing monitoring, due diligence, and research on the securities in the target strategy
• Ongoing monitoring and due diligence on the tax transition tool and strategies by BFE or delegate
• Monitoring and trade implementation of the securities in the account as needed to stay aligned with the stated investment strategy
• Proxy voting by BFE o If client authorizes BFE, clients may contact their financial advisor to request information regarding how the proxies were voted Investment Management Consulting (with Execution) The Investment Management Consulting (with Execution) strategy is a service whereby BFE may, based on a negotiated scope of services, consult with clients with respect to any or all the services below, either on an ad- hoc or ongoing basis. BFE will not actually manage client assets as part of the Investment Management Consulting strategy. As a wrap program strategy, the cost of execution of transactions will be included in the advisory fee. Additional Services may include:
• Investment Policy Statement Preparation
• Investment Policy Statement Review
• Investment Policy Statement Monitoring
• Search and evaluation of investment alternatives Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 13 of 45
• Ongoing monitoring and due diligence by BFE of investment manager(s)
• Ongoing performance monitoring
• Past performance review
• Fee Billing
• Execution of transactions
• Custody of assets
• Performance Monitoring Reports
• Participate in Periodic Meeting Benjamin F. Edwards Non-Discretionary Investment Advisory Strategies BFE’s current non-discretionary investment advisory strategy is also a BFE legacy investment advisory program. BFE will continue to support clients who opened accounts prior to April 1, 2023 in accordance with the terms outlined in their original Investment Advisory Agreement, which remains in full effect. The following represents BFE’s current non-discretionary strategy in which the client’s BFE financial advisor serves as portfolio manager. Characteristics and additional services for this advisory strategy are as follows: Benjamin F. Edwards Client Portfolios Benjamin F. Edwards Client Portfolios is an advisory program where portfolio management services are provided to the client on a non-discretionary basis for a wrap fee based on the value of the account. As a non-discretionary account, the client retains final decision-making authority with respect to opening and closing transactions. BFE can convert mutual funds into equivalent ETFs when the option exists with the issuer, is a tax-free event, and is deemed to be appropriate option for the client. The financial advisor and client will work together to identify an appropriate investment strategy. The financial advisor will monitor the account to ensure it remains consistent with the strategy and make recommendations as needed. Additional Services:
• Recommendation of customized asset allocation
• Recommendations by the financial advisor to invest, reinvest, sell or retain assets, if appropriate
• Ongoing monitoring of the account by the financial advisor
• Advice by the financial advisor on the client’s proposed unsolicited transactions Benjamin F. Edwards Legacy Investment Advisory Programs The following represents BFE’s legacy advisory programs that are currently closed to new business. Characteristics and additional services for these programs are as follows: Benjamin F. Edwards Custom Mutual Fund Portfolios BFE discontinued this program on April 1, 2021. BFE will continue to support clients who opened accounts prior to April 1, 2021 in accordance with the terms outlined in their original Investment Advisory Agreement, which remains in full effect. Benjamin F. Edwards Custom Mutual Fund Portfolios is a limited discretion model-based advisory program in which accounts are comprised of mutual funds and/or ETFs (collectively “Investment Funds”). The financial advisor and client will work together to identify an appropriate investment model. The client retains final decision-making authority with respect to the Investment Funds used, and the percentage allocated to each fund in the model. BFE can to convert mutual funds into equivalent ETFs when the option exists with the issuer, is a tax-free event, and is deemed to be an appropriate option for the client. Limited discretion is granted to the financial advisor to: Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 14 of 45
• Rebalance the account on a discretionary basis to the model’s baseline allocation
• Invest cash deposits
• Sell and reinvest deposits of securities
• Sell funds for fees and requested withdrawals The financial advisor will monitor the account to ensure it remains consistent with the strategy and make recommendations for changes as needed. BNY Mellon Target Risk Portfolios (formerly Lockwood Asset Allocation Portfolios) BFE discontinued this program on April 1, 2023. BFE will continue to support clients who opened accounts prior to April 1, 2023 in accordance with the terms outlined in their original Investment Advisory Agreement, which remains in full effect. BNY Mellon Target Risk Portfolios is a discretionary, multi-discipline managed portfolio product. BFE is the sponsor of BNY Mellon Target Risk Portfolios, and BNY Mellon Advisors serves as the portfolio manager. As portfolio manager, BNY Mellon Advisors determines the asset allocation strategy and selects investment vehicles for each investment style component of BNY Mellon Target Risk Portfolios based on proprietary models. These models may consist of open and closed-end mutual funds, exchange traded funds and other securities, as determined by BNY Mellon Advisors, at its sole discretion. Additional Services:
• BNY Mellon Advisors shall invest, reinvest, sell or retain assets in its sole discretion for this account
• Ongoing monitoring, due diligence, and research by BFE on BNY Mellon Advisors
• Ongoing monitoring, due diligence, and research by BNY Mellon Advisors on the securities and allocations
• Maintenance and trade implementation of the models
• As needed, rebalancing of the securities to conform to the investment allocations and for deposits/ withdrawals
• Proxy voting by portfolio manager, as applicable o If client elects the manager to vote the proxies, clients may contact their financial advisor to request information regarding how the proxies were voted Financial Planning BFE provides investment advisory financial planning services. Financial plans are individually tailored analyses of a client’s current portfolio and projected financial needs, together with a recommended approach to meeting those needs. Individual securities recommendations are not typically included as part of a financial plan. Depending on the client’s individual situation, financial plans may include an overview of investment objectives, risk tolerance, time horizon, net worth, cash flow analysis, college cost and savings estimates, and asset allocation analyses. Part of the portfolio analysis may include in-depth assessment of the client’s securities such as equity, bond or mutual fund holdings. The assessment may show historical return, yield, market value, sector breakout, bond rating, yield-to- maturity, and percentage that each category comprises of the total portfolio. It may also include an analysis of investments managed by third party asset managers. Retirement planning analyses may include a hypothetical wealth accumulation table that compares lifetime income needs to portfolio resources, together with an assessment of the probability of achieving the desired financial outcome based on those resources. Estate planning analyses may include an assessment of estate tax estimates, survivor income projections, long-term care coverage and estate planning strategies for consideration. A financial plan may include product analysis, such as an analysis of equity, fixed income, mutual funds and other financial products. Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 15 of 45 The financial planning relationship ends upon delivery of the agreed-upon financial plan. A client may choose to implement the plan with any financial services firm, including BFE or others, or not to implement the plan at all. If updates or reassessments of the financial plan are desired, they would generally be prepared pursuant to a new financial planning arrangement. Retirement Plan Consulting The Retirement Plan Consulting Program is a service whereby BFE may, based on a negotiated scope of services, consult with retirement plan administrators, other fiduciaries to retirement plans, plan participants and other parties. BFE will not actually manage plan assets as part of the Retirement Plan Consulting Program. Depending on the negotiated scope of services between the parties, BFE may participate in enrollment meetings, provide supplemental educational materials to the plan or plan participants, conduct education and provide investment materials for participant-directed plans, search and evaluate investment alternatives for the plan, review past performance of the plan’s current investment options, provide one-time, ongoing or periodic performance monitoring reports for the plan’s current investment options. Services provided to plan participants may be provided at a group level, or to individual plan participants. Unless otherwise specified in the agreement between BFE and the plan, any education and investment materials provided are intended to constitute “education” and not individualized “investment advice.” BFE may also negotiate other services based on the needs of the plan. In certain circumstances, BFE provides non-fiduciary educational services directly through non-affiliated third-party investment advisors. When BFE serves in this capacity, the non-affiliated third parties will subcontract directly with BFE. As such, BFE will not contract directly with retirement plan administrators and the non-affiliated third parties will be responsible for providing fiduciary services and notifying the plan administrators of the subcontracted relationship. Investment Management Consulting The Investment Management Consulting Program is a service whereby BFE may, based on a negotiated scope of services, consult with clients with respect to any or all of the services below, either on an ad-hoc or ongoing basis. BFE will not actually manage client assets as part of the Investment Management Consulting Program. Depending on the negotiated scope of services between the parties, BFE may prepare, review and/or monitor an Investment Policy Statement, search and evaluate investment alternatives, perform ongoing monitoring and due diligence of investment managers, perform ongoing performance monitoring, review past performance of the client’s investments, provide fee-billing services, custody assets through our clearing firm, provide performance monitoring reports, and participate in periodic meetings as needed. BFE may also negotiate other services based on the needs of the client. Plan Participant Advisory Services BFE offers clients ongoing advisory services for plans held outside of BFE through the Plan Participant Advisory Services (“PPAS”) program. This means the plans are not custodied at BFE or BFE’s qualified custodian but are rather held on the platform chosen by the plan administrator or the client, sometimes referred to as “held away” accounts. For the purposes of this program, the term “Plan” could refer to a held away retirement plan, a held away 529 plan or a similar held away plan. The term “Plan Participant” refers to the clients invested in said plans. Clients who enroll in BFE’s PPAS program have the option of choosing discretionary investment management services or non-discretionary consulting services. The discretionary PPAS option is an advisory service whereby BFE will agree to provide plan participants with discretionary investment management services. Alternatively, the non-discretionary PPAS option is a consulting service in which BFE will agree to provide plan participants with non-discretionary investment advice. Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 16 of 45 For each option, BFE’s financial advisors will review the investment options available to the Plan Participant within the Plan. financial advisors will then work with clients to identify their needs, objectives and risk tolerance. From the information obtained, the financial advisor will proceed in one of the following ways, depending on which program option is selected:
• For clients who select discretionary investment management services, the financial advisor will develop an asset allocation and implement the necessary trades to align the account with the allocation. The financial advisor will meet with the client to discuss whether changes to the account allocation may be appropriate. The client will permission their BFE financial advisor to directly trade with full discretion in the Plan account through capabilities provided by a third-party order management platform.
• For clients who select non-discretionary consulting services, the financial advisor will provide a written security level asset allocation recommendation. The financial advisor will meet with the client to discuss whether changes to the initial recommendation may be appropriate. It is the sole responsibility of the client whether or not to implement the advice provided. Conflict of Interest Conflict of interests can arise with respect to a variety of business and other relationships in almost any investment advisory program. Please refer to the “Other Financial Industry Activities and Affiliations” for information on conflicts of interest relating to relationships and product-specific compensation that is received by BFE. Tailoring of Advisory Programs and Reasonable Restrictions For all wrap advisory programs, the BFE clients select the financial advisor with whom they wish to work. The financial advisor will assess the client’s prior investment experience, financial goals, time horizon, risk tolerance, and investment objectives to determine the appropriate program for the client. Clients may request reasonable restrictions on the management of their discretionary accounts. Such restrictions may include imposition of limitations or preferences concerning transactions in certain securities, frequency of rebalancing, tax-loss selling, frequency of distributions and similar matters. Security-specific restrictions in the Discretionary Investment Advisory Program are individually negotiated between the client and financial advisor. With respect to all other programs involving transactions in individual equity securities, clients may request security-specific restrictions on equities or restrictions based on the following categories: Alcohol, Cosmetic, Defense/Military/ Weapons, Entertainment, Foreign Securities, Gambling, Finance, Trucking, Meat Products, Nuclear Power, Oil Stocks, Textiles, Drugs, Tobacco, Public Utilities, Paper/Forest Products, and Healthcare/Medical Industries. Depending on the strategy employed, BFE will consider requests for reasonable restrictions on the management of the account. Such restrictions may be placed on mutual funds or ETFs from the model selected but cannot restrict the individual securities held within the mutual funds or ETFs. If such investment restrictions are implemented, the client will experience a different investment return than what will be realized by the model itself. Such performance may be better or worse than the model. For these reasons, if a client wishes to make a request concerning restrictions based on specific securities, it may be more appropriate for the client to participate in other BFE advisory strategies that are not so uniquely positioned. It should be noted; any standardized reports of model performance will not reflect the performance of the model with restrictions applied. Quarterly performance reports of the client’s account will accurately reflect the client’s actual account performance with restrictions. With respect to Financial Planning, the financial advisor will prepare a tailored assessment and plan that is designed to meet the particular needs of the individual client. With respect to Retirement Plan Consulting, the financial advisor will determine with the appropriate retirement plan administrator, fiduciary, or other authorized person, the specific consulting services that are needed. BFE will not provide individualized investment advice to particular plan participants. Benjamin F. Edwards & Co. | ADV Part 2A Firm Brochure Page 17 of 45 With respect to Investment Management Consulting, the financial advisor will work with the client to determine the specific consulting services that are needed. Legal and Tax Advice BFE financial advisors do not provide legal or tax advice. It is recommended that clients discuss their personal situation with a tax or legal advisor.