Introduction Stratos Wealth Partners, Ltd. (“SWP”) is an SEC registered investment adviser wholly owned within the Stratos Wealth Holdings, LLC family of companies and has been a registered investment adviser since 2010. Stratos Wealth Holdings, LLC is a holding company which owns, among other companies, two other registered investment advisers and a limited purpose broker-dealer, member FINRA/SIPC. Please see Item 10 for more information. SWP’s advisory services are made available to clients primarily through individuals associated with SWP as investment advisor representatives (“IARs”). IARs are independent contractors of SWP and may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials and/or client statements. The client should understand that the businesses are legal entities of the IAR and not of SWP. The IARs are under the supervision of SWP, and the advisory services of the IAR are provided through SWP. SWP has these arrangements with the business entities listed in Schedule D of Form ADV. For more information about the IAR providing advisory services, clients should refer to the Brochure Supplement (also called the ADV Part 2B) for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this disclosure brochure before or at the time client engages the IAR. If the client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or SWP at (440) 519-2500. As of December 31, 2023, SWP had approximately $11,808,000,000 in assets under management on a discretionary basis and approximately $725,200,000 in assets under management on a non-discretionary basis. Types of Advisory Services SWP offers various types of advisory services and programs, including but not limited to: advisor- managed wrap and non-wrap programs, asset allocation programs, advisory programs offered by third party investment advisor firms, and financial planning services. Not all services are available to all clients, through all advisers, or in all states. In addition, services may not be available at all custodians. SWP currently has agreements with the following broker-dealer custodians:
• LPL Financial (“LPL Financial” or “LPL”), Member FINRA/SIPC;
• Fidelity Brokerage Services, LLC and National Financial Services, LLC (collectively “Fidelity”), Member FINRA/SIPC; and
• Charles Schwab (“Schwab”), Member FINRA/SIPC. A separate disclosure brochure is provided for services offered through the Retirement Plan Consulting Program offered through LPL Financial. If the IAR participates in the Retirement Plan Consulting 5 | P a g e Program, the IAR will be dually registered with the LPL Financial Registered Investment Advisor firm. If clients would like more information on this program, clients should contact the IAR for a copy of the program brochure that describes this program, or go to www.adviserinfo.sec.gov for LPL Financial. SWP provides non-wrap accounts through each of the above custodians. Not all custodians or products are available to all clients or IARs, or in all states. Accounts at the custodians listed above are also available under a wrap fee program. Please see the separate SWP Wrap Fee Brochure for further information. There is no significant difference between the way IARs manage wrap fee account and non-wrap fee accounts. However, if a client determines to engage SWP on a wrap fee basis, the client will pay a single fee for investment management and transaction fees. The services included in a wrap fee agreement will depend upon client needs. If the client determines to engage SWP on a non-wrap fee basis, the client will select services on an unbundled basis, paying for each service separately. Note: when managing a client’s account on a wrap fee basis, SWP will receive, as payment for its investment advisory services, the balance of the wrap fee after all other costs incorporated into the wrap fee have been deducted. Inasmuch as the execution costs for transactions effected in the client account will be paid by the IAR, a conflict of interest exists in that the IAR may have a disincentive to trade securities in the client account. In addition, the amount of compensation received by SWP as a result of the client’s participation in the wrap program may be more than what SWP would receive if the client paid separately for investment management and transaction fees. SWP offers customized individually managed portfolios or management based on model accounts. IARs will determine and present to clients an asset allocation specific to the client based upon a client’s individual investment goals, objectives, risk tolerance, and investment time horizon. Strategic Wealth Management (“SWM”) SWM Accounts are unbundled or non-wrap accounts that are custodied at LPL Financial. The client pays an advisory fee to SWP and ticket or transaction charges on each transaction executed in the account. The exception is that there may be a select listing of securities (typically reserved to mutual funds) for which no transaction fees will be assessed. However, the security may be subject to a holding period to avoid early liquidation fees. For securities with holding periods, clients are not prevented from liquidating during the holding periods, however, there is a fee associated with liquidations during the holding period. SWM is a comprehensive, open-architecture, fee-based investment platform where multiple investments can be aggregated into one account with one consolidated statement for the client. Clients’ portfolios may consist of stocks, bonds, Exchange Traded Funds (“ETFs”)/Exchange Traded Notes (“ETNs”), no-load and/or load mutual funds and cash or cash equivalents, or other securities deemed by the IAR to be appropriate and suitable for the client. SWM Accounts are offered on a discretionary and non-discretionary basis as agreed to between the client and the IAR. Non-discretionary accounts require the IAR to discuss all changes in the client’s portfolio with the client, and receive client approval, prior to execution of the transactions. For discretionary accounts, the IAR will make changes within the client’s portfolio as deemed appropriate by IAR without delay and without contacting the client prior to the transaction. Clients will receive confirmations and statements from LPL Financial reflecting all transactions in their account. SWP or IAR will not have the discretionary authority to close the account or withdraw funds or securities, with the exception of SWP’s advisory fees on a quarterly basis. The IAR will determine and present to clients an asset allocation specific to the client based upon a client’s 6 | P a g e individual investment goals, objectives, risk tolerance, and investment time horizon. Clients may have a customized individually managed portfolio managed by the IAR or participate in various model portfolios designed by IAR(s) consistent with the client’s stated investment objective. A model portfolio will be managed similar to other clients utilizing the model. There are no guarantees a portfolio based on a model will ensure positive results. Past performance is no guarantee of future results. In either case, the IAR provides ongoing advice on the selection or replacement of a portfolio based on the client’s individual needs. The IAR may choose more than one portfolio to be managed for the client’s account. SWP also offers an advisor-managed wrap fee program called the SWP Wealth Management II Program. Please see the SWP Wrap Fee Program Brochure for further information on this program. SWP provides asset management services on an ongoing basis based on the individual needs of the client. The management program through SWP offers clients flexibility among payment structures, custodians, and management styles. Management will be on an active basis. Thus, IARs will actively monitor the assets in the account and make changes or recommendations the IAR deems appropriate in light of the circumstances in the market. SWP does not take custody of SWM Accounts except under two conditions which are considered by the SEC to be custody because of our authority and ability to transfer funds. 1. SWP is deemed to have custody because of our ability to deduct our fees from your account. You will receive a statement at least quarterly direct from the account custodian showing the deduction of our fees from your account. Authorization to deduct our fees from your account is given in the agreement you execute with SWP. 2. SWP is deemed to have custody if you establish a standing letter of authorization to direct us to transfer funds or securities from your account to a specified third party and you give us the authorization to change the timing and or the amount of the transfer. SWP does not have the ability to change the third party without your written authorization. A minimum account value of $10,000 is required for SWM Accounts; however, in certain instances, the minimum account size may be lower. Advisor-Managed, Non-Wrap Accounts For SWP’s additional advisor-managed, non-wrap accounts, the client pays a management fee to SWP and ticket or transaction charges on each transaction executed in the account. The exception is that there may be a select listing of securities (typically reserved to mutual funds) for which no transaction fees will be assessed. However, the security may be subject to a holding period to avoid early liquidation fees. For securities with holding periods, clients are not prevented from liquidating during the holding periods, however, there is a fee associated with liquidations during the holding period. The IAR will determine and present to clients an asset allocation specific to the client based upon a client’s individual investment goals, objectives, risk tolerance, and investment time horizon. Clients may have a customized individually managed portfolio managed by the IAR or participate in various model portfolios designed by IAR(s) consistent with the client’s stated investment objective. A model portfolio will be managed similar to other clients utilizing the model. There are no guarantees a portfolio based on a model will ensure positive results. Past performance is no guarantee of future results. In either case, the IAR provides ongoing advice on the selection or replacement of a portfolio based on the client’s individual needs. The IAR may choose more than one portfolio to be managed for the client’s account. SWP also offers 7 | P a g e an advisor-managed wrap fee program called the Advisor Wealth Management II Program. Please see the SWP Wrap Fee Program Brochure for further information on this program. The IAR provides asset management services on an ongoing basis based on the individual needs of the client. The management program through SWP offers clients flexibility among payment structures, custodians, and management styles. Management will be on an active basis. Thus, IARs will actively monitor the assets in the account and make changes the IAR deems appropriate in light of the circumstances in the market. These non-wrap accounts are custodied at Fidelity or Schwab. SWP does not take custody except under two conditions which are considered by the SEC to be custody because of our authority and ability to transfer funds. 1. SWP is deemed to have custody because of our ability to deduct our fees from your account. You will receive a statement at least quarterly from the account custodian showing the deduction of our fees from your account. Authorization to deduct our fees from your account is given in the agreement you execute with SWP. 2. SWP is deemed to have custody if you establish a standing letter of authorization to direct us to transfer funds or securities from your account to a specified third party and you give us the authorization to change the timing and or the amount of the transfer. Stratos does not have the ability to change the third party without your written authorization. Clients’ portfolios may consist of stocks, bonds, ETFs/ETNs, no-load and/or load mutual funds and cash or cash equivalents, or other securities deemed by the IAR to be appropriate and suitable for the client. If the SWP account is opened containing existing securities previously purchased through or is opened with cash proceeds from the sale of securities sold through Fidelity, Schwab, or the IARs, Fidelity, Schwab, and/or the IAR may have already received commissions on the purchase. Additional commissions will not be charged, however, the fees discussed below will be charged. Clients are advised that transactions in the account, account reallocations and rebalancing may trigger a taxable event for the client, with the exception of transactions in IRA accounts, 403(b) accounts and other qualified retirement accounts. SWP does not offer tax advice and clients are urged to consult with their tax advisers. A minimum account value of $10,000 is required for advisor-managed, non-wrap accounts; however, in certain instances, the minimum account size may be lower. Discretion on Held-Away Assets When requested by the client, IARs of SWP can provide discretionary investment management and periodic monitoring by leveraging the order management system provided by Pontera with respect to certain accounts (primarily 401(k) participant accounts, health-savings accounts and other assets identified by the client) held with custodians other than those referenced in Item 12. In such instances, the IAR will regularly review the available investment options in these accounts, monitor them, and rebalance and implement its strategies as necessary in the same manner as if such accounts were held with a custodian referenced in Item 12. 8 | P a g e Sub-Advisory Services through SWP Some IARs of SWP may act as subadvisor to other non-affiliated registered investment advisers (“RIAs”). SWP will manage such accounts in accordance with the investment objective applicable to the end client. SWP will rely on the primary RIA to determine the needs of the client and recommend the investment objective to the client. SWP will typically require discretionary authority in order to select securities and execute transactions without permission from the client prior to each transaction. SWP recommends Fidelity, to maintain custody of clients’ assets and to effect trades for their accounts. SWP seeks to provide investment decisions that are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWP’s economic, investment or other financial interests. To meet its fiduciary obligations, SWP attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWP’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. Stratos Investment Management, LLC SWP sponsors the Stratos Wealth Partners, Ltd. Wrap Fee Program and hires Stratos Investment Management, LLC (“SIM”), an affiliate of SWP, to act as its portfolio manager for that program. SIM also provides subadvisory services to IARs of SWP on a non-wrap fee basis. SIM offers ongoing portfolio management based on the individual goals, objectives, time horizon, and risk tolerance of each client. The wrap fee program allows the investor to pay one stated fee that includes management fees and transaction costs. SIM primarily acts as a subadvisor. Its portfolio management services include, but are not limited to, the following:
• Investment strategy
• Asset allocation
• Portfolio construction
• Risk tolerance
• Regular portfolio monitoring SIM will typically require discretionary authority in order to select securities and execute transactions without permission from the client prior to each transaction. However, the firm may also provide non- discretionary portfolio management if needed. Advisors working with SIM often recommend Fidelity to maintain custody of clients’ assets and to effect trades for their accounts but may also recommend that Schwab or LPL maintain custody of clients’ assets and effect trades for their accounts. SIM seeks to provide investment decisions that are made in accordance with the fiduciary duties owed to its accounts and without consideration of SIM’s economic, investment or other financial interests. To meet its fiduciary obligations, SIM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios. It is SIM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis to avoid favoring one client over another over time. Clients should refer to Items 10 and 14 below for more information about conflicts of interest that may arise when using SIM as a portfolio manager. SIM is under common control with SWP and Stratos Wealth Advisors, LLC (“SWA”). SWP and SWA have overlap in personnel with SIM and use SIM as a subadvisor for many client accounts. SIM complies 9 | P a g e at all times with its fiduciary duty as an investment adviser. Please see Item 10 below for more information about conflicts of interest that may arise when using SIM as a portfolio manager. For more information regarding SIM, including more information on the advisory services and fees that apply, the types of investments available in the programs, and the conflicts of interest presented by the programs, please see both the SWP Wrap Fee Program Brochure and the SIM Form ADV Part 2A Firm Brochure. Financial Planning Services As part of its financial planning services, SWP (through its IARs) provides personal financial planning tailored to the individual needs of the client. The services described below may not be available through all IARs. SWP offers Financial Planning Services under the following structures: Financial Plans for a Flat Fee With this structure, the engagement terminates upon delivery of the financial plan. SWP offers various types and levels of financial planning. The level and type of services will vary among IARs and will depend on the needs of the client. Subscription Financial Planning Services Clients seeking to receive ongoing financial planning advice may choose to pay a recurring subscription fee for such services. Recurring fees are negotiated between the IAR and the client and reflect the service(s) provided. Hourly Consulting Services SWP, through its IARs, provides consulting services on an hourly basis. The IAR tailors the hourly consulting services to the individual needs of the client, and the engagement terminates upon final consultation with the client. The Employer Sponsored Account Recommendations (“ESAR”) Service IARs may also provide financial planning advice to plan participants regarding their retirement plans under all financial planning service structures. IARs may provide advice for qualified plan participants. They will provide specific recommendations to clients if they are not being provided under a separate Stratos program. With this service, an IAR may provide clients with specific investment recommendations for their retirement plan assets that are not managed by a Stratos IAR. It is up to the client to decide whether or not to implement the recommendations made by the IAR. The IAR may provide these services for free, or charge either a flat fee or an hourly fee. The IAR may also provide these services through the Financial Wellness Program or as part of a Subscription Financial Planning Service, however the IAR’s fiduciary status changes as listed below. When providing ESAR services through a one-time engagement (free, flat fee or hourly fee structure) services are not provided on a regular or ongoing basis. The IAR will not be deemed to be a fiduciary under the Employee Retirement Income Security Act of 1974 (“ERISA”) with respect to the participant’s 10 | P a g e plan assets. To maintain the non-fiduciary status under ERISA, the program limits the number of engagements with any client to one per calendar year. When providing ESAR services as part of a Subscription Financial Planning Service the services are considered to be provided on a regular or ongoing basis. The advisor assumes the role of fiduciary under the ERISA with respect to the participant’s plan assets. The following information applies to all Financial Planning services offered by SWP: SWP and the IAR do not have any discretionary investment authority when offering financial planning services. The IAR makes recommendations as to general types of investment products or securities that may be appropriate for the client to consider and may also provide recommendations regarding specific investments or securities. Planning and consulting services are based on the client’s financial situation at the time and are based on financial information disclosed by the client to SWP. Clients are advised plans may contain certain assumptions that may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. SWP cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. Further,

clients must continue to review any plan or analysis and update the plan based upon changes in the client’s financial situation, goals, or objectives, or any changes in the economy. Should a client’s financial situation or investment goals or objectives change, the client must notify SWP promptly. Clients are advised that fees for financial planning and/or consulting services are strictly for the planning and/or consulting services. Therefore, clients may pay fees and/or commissions for additional services obtained (e.g., asset management) or products purchased (e.g., securities or insurance). Financial Planning Services may include, but not be limited to, the following examples of services:
• Retirement Planning
• General, Segmented and Comprehensive Financial Planning
• Educational Planning
• Cash Flow Analysis
• Estate Planning
• Budget Planning
• Tax Planning
• Insurance Needs Analysis
• Business Continuity, Succession and Exit Planning
• Asset Allocation Services
• Sports and Entertainment Management
• Executive Planning
• Corporate Benefit Consulting
• Other planning and consulting services as requested by the client and agreed to by the IAR SWP will gather financial information and history from clients, which may include, among other things, retirement and financial goals, risk tolerance, investment horizon, financial needs, cost of living needs, education needs, savings tendencies, and other applicable financial information required by SWP in order to provide the investment advisory services requested. 11 | P a g e As stated above, the level and type of services will depend upon the needs of the client. Depending on the services requested, clients may receive a written analysis, summary or plan. One or more meetings may be necessary with the client and may involve other professionals, as invited and agreed to by the client (e.g., attorneys and/or certified public accountants). The financial plan may be constructed or prepared by a Stratos party other than the IAR, SWP and the IAR do not have any discretionary investment authority when offering financial planning. Conflicts of Interest for Financial Planning and Consulting Services Under all Financial Planning programs offered by SWP, IARs have a conflict of interest to recommend their own services for asset management and/or insurance. Clients are under no obligation to use SWP or the IAR for the services, or to take action as recommended by the IAR. Third Party Investment Adviser (“TPIA”) Account Management Services SWP offers the following TPIA account management programs. Not all of these programs are available to all clients, all IARs, or are offered in all states. Under these TPIA programs, SWP (through its IARs) provides ongoing investment advice to clients that is tailored to the individual needs of the client. SWP IARs may interact with each TPIA as a promoter, a subadvisor, or a dual contract adviser. The IAR’s responsibilities will be different under each of these arrangements. The specifics of the IAR’s role and payment of fees will be governed by the TPIA Investment Management Agreement with SWP, and the client’s agreement with the TPIA. As part of these TPIA services, the IAR obtains the necessary financial data from the client and assists the client with: determining the suitability of the program; setting an appropriate investment objective; and opening an account with the TPIA. In addition, depending on the type of program, the IAR may assist the client in selecting a model portfolio of securities designed by the TPIA or selecting a portfolio management firm to provide discretionary asset management services. The IAR may have discretionary authority to select the TPIA or to make changes to the TPIA. It is the TPIA (and not the IAR) that has client authority to purchase and sell securities on a discretionary or non-discretionary basis pursuant to the investment objective chosen by the client. This authorization will be set out in the TPIA client agreement. The disclosure brochure for the particular TPIA will explain whether clients may impose restrictions on investing in certain securities or types of securities. SWP offers the following programs utilizing TPIA managers: LPL Financial Sponsored Advisory Programs SWP may provide advisory services through certain programs sponsored by LPL Financial, a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory program available through SWP. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs, and the conflicts of interest presented by the programs, please see the LPL Financial Form ADV Part 2A or the applicable program’s ADV Part 2A and the applicable client agreement. 12 | P a g e Personal Wealth Portfolios Program (“PWP”) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. IARs have discretion for selecting the asset allocation model portfolio based on the client’s investment objective. They also have discretion for selecting third party money managers (PWP Advisors), mutual funds and Exchange Traded Funds (“ETFs”) within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds, ETFs, and equity and fixed income securities. A minimum account value of $250,000 is required for the PWP. In certain instances, LPL will permit a lower minimum account size. Optimum Market Portfolios Program (“OMP”) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, the client authorizes LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. The IAR assists the client in: determining the suitability of OMP for the client, and setting an appropriate investment objective. The IAR has discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (“MWP”) MWP offers clients a professionally managed mutual fund asset allocation program. SWP obtains the necessary financial data from the client and assists the client in: determining the suitability of the MWP program, and setting an appropriate investment objective. The IAR initiates the steps necessary to open an MWP account and has discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department or third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client authorizes LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client also authorizes LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Manager Access Select (“MAS”)/Managed Access Network (“MAN”) Program MAS/MAN provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. The IAR assists the client in identifying a third party portfolio manager (“Portfolio Manager”) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages the client’s assets on a discretionary basis. The IAR provides initial and ongoing assistance regarding the Portfolio Manager selection process. 13 | P a g e A minimum account value of $100,000 is required for the MAS/MAN Program, however, in certain instances, the minimum account size may be lower or higher. Small Market Solution (“SMS”) Program Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a series of different investment menus (“Investment Menus”) consisting of a mix of different asset classes and investment vehicles (“investment options”) for clients that sponsor and maintain participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it believes is appropriate based on the demographics and other characteristics of the Plan and its participants. LPL Research is responsible for the selection and monitoring of the investment options made available through Investment Menus (“Fiduciary Selection Services”). The investment options that are offered through SMS are limited to the specific investments available through the recordkeeper that the Plan Sponsor selects. The Plan Sponsor may only select an Investment Menu in its entirety and does not have the option to remove or substitute an investment option. If the Plan is subject to ERISA, LPL will be a “fiduciary” and serve as “investment manager” (as that term is defined in section 3(38) of ERISA) in connection with the Fiduciary Selection Services. None of the services offered under SMS other than the Fiduciary Selection Services will constitute “investment advice” under 3(21)(A)(ii) of ERISA, or otherwise cause LPL or SWP to be deemed a fiduciary. In addition to the Fiduciary Selection Services, the Plan Sponsor may also select from a number of non- fiduciary consulting services available under SMS that are provided by SWP. These consulting services may include, but are not limited to: general education, and support regarding the Plan and the investment options selected by Plan Sponsor; assistance regarding the selection of, and ongoing relationship management for, recordkeepers and other third-party vendors; Plan participant enrollment support; and participant-level education regarding investment in the Plan. These consulting services do not include any individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets, and LPL and SWP do not act as fiduciaries under ERISA in providing such consulting services. Guided Wealth Portfolios (“GWP”) GWP offers clients the ability to participate in a centrally managed investment program, which is made available to users and clients through LPL’s Account View, a web-based interactive account management portal. The Program generates investment recommendations based upon model portfolios constructed by LPL and selected for the account. Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through such portal), although SWP will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Proposal Tool”) is provided to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL and SWP by enrolling in the advisory service (the “Advisory Service”). The Proposal Tool and Advisory Service are described in more detail in the GWP Program Brochure. Users of the Proposal Tool are not considered to be advisory clients of LPL or SWP, do not enter into an advisory agreement with LPL or SWP, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. Investors participating in the Advisory Service complete an account application and enter into an account agreement with LPL and SWP. Based on information provided by the client in a client profile, LPL selects 14 | P a g e an appropriate investment allocation track and model portfolio for a client. The SWP IAR is required to review and accept the account, including the investment allocation track and model portfolio, prior to account opening. The model portfolios have been designed and are maintained by LPL Research and include a list of ETF holdings and may in the future include mutual funds holdings and include relative weightings and a list of potential replacement securities for tax harvesting purposes. LPL Research currently serves as the sole Portfolio Strategist and does not charge a fee for its services. Only one Model Portfolio is permitted per account. A minimum account value of $5,000 is required to enroll in the Managed Service. Conflicts of Interest Transactions in LPL advisory program accounts are effected through LPL as the executing broker-dealer. The IAR receives management fees as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, ability to negotiate fees or commissions, historical or expected size or number of transactions, and number and range of supplementary advisory and client-related services provided to the client, the amount of this compensation may be more or less than what SWP would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. In addition, SWP has a fee arrangement with LPL related to assets held on one of the LPL advisory programs. Under this arrangement, LPL pays SWP a rebate based on the amount of assets invested in that LPL program. This results in a conflict of interest between clients and SWP because receipt of the rebate gives SWP an incentive to recommend that clients invest assets in the program; however, this conflict is mitigated insofar as the rebate payments SWP receives are not shared with the IAR who selects or recommends the program for its clients. The account fee for GWP may be higher than the fees charged by other investment advisors for similar services, and clients could generally pay a lower advisory fee for algorithm-driven, automated (“robo”) investment advisory services through another robo provider. However, clients using such direct robo services will forgo opportunities to utilize LPL-constructed model portfolios or to work directly with a financial advisor. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with SWP. With regard to accounts utilizing third-party portfolio managers under aggregate, all-in-one account fee structures (including MAS, PWP and the legacy MWP fee structure), because the portion of the account fee retained by SWP varies depending on the portfolio strategist fee associated with a portfolio, SWP has a financial incentive to select one portfolio instead of another portfolio. Fidelity Advisory Programs SWP may also provide advisory services through Fidelity as the broker-dealer custodian. Below is a brief description of advisory programs available at Fidelity. Fidelity Separate Account Network® (“SAN”) – Fidelity offers a Separate Account Network program (“SAN Program”), a unified platform for managed portfolios. The SAN Program enables the IAR to have the ability to build separately managed account portfolios from a vast network of managers to meet client needs which will be managed as a wrap fee program by designated SAN Managers on a discretionary basis. The minimum investment required by each individual SAN Manager must be met. Please refer to 15 | P a g e the SAN Manager’s Form ADV Part 2A or the comparable disclosure document and the Form ADV Part 2A, Appendix 1 provided to clients by their SWP IAR. Some managers under the SAN program may require an additional client advisory agreement in addition to the agreement signed with SWP. For a complete description of the services offered, the programs, the fees charged and minimum account requirements, please refer to the separate disclosure brochure (such as Part 2A of Form ADV) maintained by the Manager as provided by the IAR. Clients should carefully review these additional disclosure brochures for important and specific details including, among other things, fees, experience, investment objectives, and risk guidelines, and disclosure of the money manager’s conflicts of interest. The client and IAR together determine which program is appropriate for the client. Clients will receive confirmations and statements reflecting all transactions in their account. SWP will not have the discretionary authority to close the account or withdraw funds or securities, with the exception of SWP’s advisory fees on a quarterly basis. Clients should refer to the disclosure brochure, client agreement and other account paperwork for each TPIA for more detailed information about the services available under the program. Envestnet Envestnet provides broad access to financial products, including institutional money managers. In addition, IARs can select from Envestnet’s portfolio consulting group and Fund Strategist Network. Fund Strategist Network Envestnet’s Fund Strategist Network provides IARs with access to institutional managers to develop unique strategies for their client’s portfolios. IARs can access asset allocation and investment management assistance from fund strategists who can deliver multi-asset solutions for their clients. The IAR will recommend an appropriate model portfolio. Once the model portfolio is selected, the strategist will be responsible for monitoring the performance of the holdings in their model portfolios and will adjust and rebalance the model portfolio in accordance with their investment strategy. The fund strategist will manage on a discretionary basis. The client may be somewhat restricted in their ability to directly contact and consult with the fund strategists, but the IAR is available to address any questions, issues or concerns about the performance of their accounts. The minimum investment required by each fund strategist, which will vary from $5,000 to $50,000. Envestnet ONE, Unified Managed Account (UMA) The Envestnet UMA program offers a single portfolio that can access multiple asset managers to address a variety of asset classes. This investment model seeks to deliver the benefits of a traditional separately managed accounts in a single, broadly diversified portfolio by combining institutional money managers, ETFs and mutual funds into a single portfolio and custodial account. Envestnet also provides overlay management services to seek tax efficiencies and appropriate asset allocation across the portfolio. The minimum investment required for a UMA is $250,000, but may be negotiated lower at account opening. 16 | P a g e Schwab Advisory Programs SWP may also provide advisory services through Schwab as the broker-dealer custodian. Below is a brief description of advisory programs available at Schwab. Managed Account Select This wrap fee program sponsored by Schwab includes brokerage, custody and money manager services. The IAR has access to professional money managers that have been evaluated by Schwab. The money managers will manage the accounts on a discretionary basis. The IAR will have access to ongoing research and comparative reports regarding the money manager selected for clients. The account minimum for the Managed Account Select program is typically $100,000 for accounts utilizing equities but may be more for fixed income. Managed Account Access This wrap fee program sponsored by Schwab also provides access to professional money managers. The IAR will select from an array of money managers and hundreds of investment strategies. The money managers will manage the accounts on a discretionary basis. The account minimum for the Managed Account Access program is typically $100,000 for accounts utilizing equities but may be more for fixed income. Managed Account Marketplace In this program, the IAR will work with the client to negotiate directly with money managers of the client’s choosing. Marketplace allows the IAR and the client to use money managers based on their own negotiated arrangements. Account minimums will be as negotiated with the money manager selected. Referral Services for Investment Advisors SWP and its IARs may act as referral agents on behalf of TPIAs pursuant to a referral agreement. In such case, SWP provides services to the TPIA related to the referred client. The IAR provides the referred client a disclosure statement regarding the role of SWP and the IAR as a referral agent, but the IAR does not enter into an agreement with the client to provide ongoing investment advice. Instead, the client engages the TPIA for advisory services. Please see Item 14 below for more information about these referral services and the related compensation. Clients should refer to the disclosure brochure, client agreement and other account paperwork for each TPIA for more detailed information about the services available under the program.