A. Description of Your Advisory Firm Regal Advisory Services, Inc. (“Regal” and/or “the firm”) is a Delaware corporation established in 2001 and approved as a Registered Investment Adviser in 2001. George Bokios is a shareholder with 56.67% ownership, and the Bokios 2012 Dynasty Trust has 43.3% ownership. B. Description of Advisory Services Offered The client’s Financial Advisor will develop an investment program that will meet the client’s goals, objectives, and tolerance for risk. The Financial Advisor will analyze the client information and recommend an appropriate strategy based on the client’s needs and objectives, investment time horizon, risk tolerance, liquidity, and any other relevant factors. Currently, Regal offers the following programs: ▪ RBC Correspondent Advisory Programs
• RBC Advisor
• RBC Consulting Solutions
• RBC Unified Portfolio ▪ Regal Discretionary Investment Management (“RDIM”) (non-wrap) ▪ Regal Non-Discretionary Investment Management (“RNIM”) (non-wrap) ▪ Hilltop Securities Advisory Programs
• Regal Separately Managed Accounts
• Regal Fund Strategist Portfolios
• Regal Unified Managed Accounts
• Regal Advisor as Portfolio Manager ▪ Regal Free Form Advisor (non-wrap) ▪ Financial Planning Services ▪ Retirement Plan Advisory Services Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals, and tolerance for risk. Regal will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Regal’s advisor representative will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. B.1. Regal Discretionary Investment Management (“RDIM”) Financial Advisors of Regal provide investment advisory services to clients that participate in the RDIM Program on a discretionary basis. The Financial Advisors develop portfolios based on certain established guidelines and the client’s investment objectives and individual needs. Regal uses both fundamental and quantitative research as well as other independent research. Regal may develop a specific investment philosophy using the mix of these analysis methods. Quality and concentration requirements are established to provide an overall discipline and quality element of the program. Such strategies ordinarily include long- and short-term purchases of securities and, depending on the client’s objectives and the Regal’s investment philosophy, supplemental covered option writing. In special circumstances, the strategies may also include margin transactions, other option strategies, and trading or short sale transactions. Further detail is provided in Item 8 of this brochure. B.2. Regal Non-Discretionary Investment Management (“RNIM”) Financial Advisors of Regal provide investment advisory services to clients that participate in the RNIM Program on a non-discretionary basis. Clients have the option of accepting the Financial Advisor’s recommendations or selecting alternative investments for the account. All investments shall be at the exclusive risk of the client. Regal does not guarantee any return on the investments recommended or advised upon and may not be responsible for any losses resulting from such trading or for any transaction. Regal offers periodic rebalancing of the mutual funds in the client’s account, at the client’s request. Rebalancing is available at predetermined intervals (e.g., annually) or upon the client’s direction. IARs may recommend stocks, bonds, or other assets of any kind, consistent with the client’s investment objectives and restrictions established by the client. Financial Advisors provide non-discretionary recommendations on the basis of research the Financial Advisor reasonably deems to be reliable. Financial Advisors may recommend alternative investments in Regal accounts on a non- discretionary basis. The term “alternative investments” refers to securities products that serve as alternatives to more traditional investment asset classes, and may include products such as private placements, real estate investment trusts, hedge funds, private equity funds, preferred stock offerings, interval funds, and various forms of structured products. Alternative investments can be part of an overall strategy for certain investors given the potential for the level of investment returns over time, notwithstanding the higher degree of risk compared to traditional investment strategies. Regal has determined that certain carefully selected alternative investments may be appropriate for inclusion within investment advisory accounts when such investments are suitable based upon client investment profiles. See Item 5 for fees and Item 8 for risks associated with these types of investments. The information contained in this ADV is not an exclusive list of potential or actual risks in any alternative product. Potential investors in alternative investments should review the specific offering documents for more complete details, including an in-depth review of risk factors and fees. B.3. Regal Free Form Advisor The Regal Free Form program is a fee-based program that allows the advisor to act as portfolio manager. This program allows a more open, flexible architecture compared to the structure of the Regal Advisor as Portfolio Manager (APM) offering. Trading is handled through the HTS brokerage platform, and not through Envestnet platform. Investment portfolios are customized for each client and may substantially deviate from other model portfolios. Financial Advisors of Regal provide investment advisory services to clients that participate in the Regal Free Form Program on a discretionary or non-discretionary basis. Clients have the option of accepting the Financial Advisor’s recommendations or selecting alternative investments for the account. All investments shall be at the exclusive risk of the client. Regal does not guarantee any return on the investments recommended or advised upon and may not be responsible for any losses resulting from such trading or for any transaction. HTS provides performance and billing at an additional cost and is required for all Free Form accounts. B.4. RBC Correspondent Advisory Programs B.4.a. RBC Advisor The RBC Advisor Program is a customized investment consulting program through which accounts of Regal clients receive non-discretionary advice for investing in eligible securities. The Financial Advisor may recommend eligible securities, including mutual funds offered at their net asset value without any front-end or deferred sales charge, which may also include no-load funds that Regal believes possess investment characteristics that are consistent with the client’s risk profile. If the investment strategy will be implemented with mutual funds only, the client selects from the various eligible mutual funds and specifies, in writing, the mutual funds in which account assets are to be invested and the allocation among those funds. This written fund allocation may subsequently be modified by the client by notifying Regal. It is the client’s responsibility to advise Regal at such times as client determines rebalancing should occur. Neither RBC Capital Markets, RBC Clearing & Custody (together herein referred to as “RBC”), nor Regal has discretionary authority with respect to the program account; however, if the client’s investment allocation includes a mutual fund share class we deem to be ineligible for the program, we may update the allocation to include the equivalent, eligible share class of the same mutual fund without notification to client. Client has sole discretion to accept or reject an investment strategy or any specific recommendation to purchase, sell, or redeem securities. Client receives investment advice from Regal and Regal’s Financial Advisor, and not RBC. B.4.b. RBC Consulting Solutions Consulting Solutions is an advisory program through which accounts of Regal clients are managed by one or more professional Investment Managers participating in the Program. Your Financial Advisor may provide you with information on Investment Managers whose investment philosophy and objectives may be compatible with your Risk Profile. In the Single Account Program Agreement with us, you select the Investment Manager. RBC makes available Investment Managers who meet its eligibility requirements for participation in the Program. See Item 6: Portfolio Manager Selection and Evaluation. In the Consulting Solutions Program, client signs a Single Program Agreement with RBC and Regal. Client does not sign a separate agreement with the Investment Manager. Client Selection of Investment Manager Based on the Financial Advisor’s understanding of the client’s risk profile (and any additional written investment guidelines established by the client) and the consultative process, the Financial Advisor provides the client with information on participating Program Investment Managers. These Investment Managers have demonstrated an investment philosophy which the Correspondent Firm and Financial Advisor believe are compatible with the client’s risk profile. The client then chooses one or more Investment Managers to provide investment management services. We notify RBC, and RBC provides the Investment Manager with a copy of the risk profile and all amendments, as well as any additional investment guidelines established by the client. The client will select or change the Investment Manager(s). Neither RBC nor Regal has discretionary authority with respect to the account. B.4.c. RBC Unified Portfolio (“RBC UP”) RBC UP is a unified managed account “UMA” program through which the client’s account is professionally managed by RBC as Overlay Manager or a third-party Overlay Manager, Envestnet. The Overlay Manager manages the account through investments in mutual funds, ETFs, and/or in accordance with one or more model portfolios provided by Model Providers or RBC, all in a single account. The Financial Advisor may provide the client with information on mutual funds, ETFs, and/or model portfolios representing different investment styles and strategies that may be compatible with the client’s risk profile. The management of the account may include tax overlay management services and/or personal conviction overlay screens. If the client elects either or both of these additional services, the account will be managed by Envestnet; otherwise, RBC will act as Overlay Manager. Recommendation of Investment Strategy Based on our understanding of the client’s risk profile (and any additional written Investment Guidelines established by the client), the Financial Advisor will recommend an appropriate investment strategy. If the strategy includes an asset allocation, it will also include an investment allocation—that is, an assignment of a percentage of the overall value of the asset class to one or more mutual funds, ETFs, or model portfolios. The client selects from the eligible investments and specify the investments in which account assets are to be invested and the allocation among those investments. The investment allocation may subsequently be modified by the client by notifying Regal, which will in turn notify RBC, of the changes. Any such changes will be effective only upon confirmation by RBC and the Overlay Manager. However, if the investment allocation includes a mutual fund share class RBC deems to be ineligible for the Program, RBC may update the allocation to include the equivalent, eligible share class of the same mutual fund without notification to the client. The Overlay Manager will affect the securities transactions required to conform to revisions in the model portfolios as soon as practicable after they are received, subject to any written client- specific investment guidelines such as security restrictions, personal conviction overlay screens, or tax overlay management services; however, delays may occur between the communication of model revisions and the execution of securities transactions for the account. The Overlay Manager intends to manage an account so that the estimated investment performance does not substantially deviate from the model portfolio(s), provided client-specific investment guidelines make it practicable to do so. Rebalancing of Assets The client may choose between two rebalancing frequencies (quarterly or annually) to bring an account back to its targeted investment allocation. The Overlay Manager will rebalance the account either quarterly or annually, as selected, affecting the trades necessary to rebalance the account as closely as practicable to the client’s target investment allocation. The initial rebalance date will be based on the account start date. The account may be rebalanced at any time when deemed appropriate by the Overlay Manager due to other factors that include, but are not limited to, contributions, withdrawals, model portfolio changes, etc. Any unscheduled rebalance of the account will reset the next rebalance date to the next quarter or a year, as applicable. If the client has elected to receive tax overlay management services (described below), Envestnet will evaluate the trade-off between rebalancing the account and the tax consequences of any client constraints or tax mandates. If the account is not tax-exempt, the sale, redemption, or exchange of investments may result in taxable gains or losses. RBC will not

be liable for any tax consequences or mutual fund redemption fees (see the fund’s prospectus) as a result of rebalancing. Alternatively, the client may elect to not have the account rebalanced, in which case the account will only be rebalanced upon client’s request. In addition, if the Overlay Manager deems a rebalance is necessary to implement the allocation and investments selected, they may rebalance the account at its discretion. In general, material (generally $10,000 contribution or withdrawal) contributions and withdrawals of assets to or from the account will be applied to the target investment allocation. Tax Overlay Management Services Tax Overlay Management Services are available as an option for accounts utilizing model portfolios. These services are provided by Envestnet for an additional fee (“Tax Management Fee”). Envestnet will develop a tax strategy for the account based on the information and instructions provided by the client in the Tax Overlay Management Services Enrollment Form. Tax Overlay Management Services in an investment account offer benefits and limitations, as described below. The tax strategy developed by Envestnet is provided solely in connection with the account, and Envestnet does not provide general tax planning services. If client elects the tax overlay management services option, please consider the following: ▪ Tax Overlay Management Services are limited in scope and are not designed to eliminate taxes in the account. ▪ If tax Overlay Management Services are selected for the account, information provided may result in Envestnet making substantial deviations from the investment allocation on a more than temporary basis. ▪ Envestnet intends to manage the account so that the estimated investment performance does not substantially deviate from the model portfolio(s), provided client-specific mandates make it practicable to do so. ▪ When providing Tax Overlay Management Services to the account, short-term gains are avoided where possible, but long-term gains are not limited. Limits can be set by the client in the Tax Overlay Management Services Enrollment Form. ▪ If the client subsequently disables tax overlay management after enrolling in the Tax Overlay Management Service, Envestnet will begin managing the account as if it is not tax managed, which may result in the recognition of significant gains. ▪ Clients should only complete the Tax Overlay Management Services Enrollment Form after consulting with a tax advisor. Any tax loss carryover specified for the current calendar year may be taken into consideration by Envestnet in managing the account. Clients should update this information annually. On an ongoing basis, any losses taken in the account may be taken into consideration in managing the account. If the client recognizes gains outside the account that result in the use of the specified losses, client must notify Correspondent Firm, which will in turn notify RBC, and RBC will in turn notify Envestnet, so that the loss carryover amount may be reduced accordingly. Mandates or the use of limits to restrict the amount of gains realized or the total tax bill may severely restrict trading in the account and could result in substantial deviations from the investment allocation. Mandates and limits should only be imposed on the account after the client has consulted with client’s tax advisor. Amounts specified will be used annually until client specifies otherwise. For more information on Tax Overlay Management Services, please refer to Envestnet’s ADV. Personal Conviction Overlay Screens Clients may restrict their accounts from investing in certain securities or industries. These services are provided by Envestnet for an additional fee (“Personal Conviction Overlay Screen Fee”). Envestnet relies on third-party providers for data of the industry classification and socially responsible classifications of individual securities, and Envestnet and RBC make no guarantee as to the accuracy of such third parties’ classification. Changes may occur that affect the industry classification of a firm, and Envestnet will make reasonable efforts to implement those changes in a timely manner. In general, Envestnet may implement restrictions by taking one or more of the following actions: increasing the relative proportions of other securities to replace the restricted securities; increasing cash in the account; and selecting alternate securities. Many of the personal conviction overlay screens have both a Best in Class and Strict restriction. Best in Class restrictions are designed for investors aiming to achieve alignment between their values and their need to ensure the prudent management of their investments, while Strict restrictions are designed for investors who want to integrate more stringent environmental/social criteria into their investments by further evaluating sources of revenue and employing tighter revenue thresholds. They seek to minimize exposure to companies with specific products, services, and operations that do not meet the personal convictions criteria set by the client. Opening a Program Account The client must sign an advisory agreement with RBC prior to enrollment in the Programs. Upon signing an RBC Advisory Master Services Agreement (the “Master Agreement”), client is granting Regal and RBC the authority to affect certain investment advisory transactions or make updates to the RBC Unified Portfolio account(s) with verbal instruction to client’s Financial Advisor, including, but not limited to: ▪ Program enrollment ▪ Establishing account fees ▪ Program changes ▪ Risk profile ▪ Investment Manager or allocation changes, if applicable ▪ Changes to program fees ▪ Rebalancing frequency ▪ Adding/removing account restrictions ▪ Advisory program termination RBC will provide in writing any changes made to the client’s Program Account(s). In certain circumstances, RBC may require the client to sign a separate Client Agreement or additional documentation relating to client’s program account(s). B.5. Hilltop Securities Advisory Services (“HTS”) B.5.a. Regal Separately Managed Accounts (“SMA”) The Regal SMA program provides the Advisor access to a selection of separate account managers who typically invest in a portfolio of individual equity and/or fixed income securities depending upon that manager’s stated strategy. The cost of utilizing this program is the HTS platform fee, plus the Manager Fee set by Envestnet and the third-party manager. Manager fee will vary based on SMA. B.5.b. Regal Fund Strategist Portfolios (“FSP”) The Regal FSP program provides the Advisor access to a selection of ETF and Mutual Fund portfolios that are managed by third party strategists. Each strategist typically offers a selection of portfolios that range from conservative to aggressive, allowing the client and advisor to select the best portfolio for the client’s risk tolerance. The cost of utilizing this program is the HTS platform fee, plus the Manager Fee set by Envestnet and the third-party strategist. Manager fee will vary based on strategist selected. B.5.c. Regal Unified Managed Accounts (“UMA”) A Regal UMA allows the combination of two or more SMA Managers or FSP Strategists to manage an allocated portion of the assets (each allocation is a “sleeve”) within a single account. The Advisor may also serve as portfolio manager for one or more sleeves within the UMA. The cost of utilizing this program is the HTS platform fee, plus the Manager Fee set by Envestnet and the third-party Manager or Strategist. This fee will vary. (NOTE: The UMA platform fee applies to all sleeves within a UMA, including those that are an FSP, or advisor managed). B.5.d. Regal Advisor as Portfolio Manager (“APM”) The Regal Advisor as Portfolio Manager program may be offered for discretionary and/or non- discretionary accounts. The non-discretionary program allows the Advisor to apply an asset allocation model to an account then trade that account through the platform. The discretionary version of the tool allows the Advisor to create specific model portfolios, attach clients to those models, and manage one or more accounts by administering the model. The cost of utilizing this program is the HTS platform fee. B.6. Financial Planning Services Regal may provide financial planning advice and services with respect to various financial planning topics as mutually agreed upon between the client and Regal. Such topics may include one or more of the following: ▪ Personal: Family records, budgeting, personal liability, estate information, and financial goals. ▪ Investments: Analysis of investment alternatives and their effect on a client's portfolio. ▪ Cash Flow: Income and spending analysis and planning for past, current, and future years. Regal will illustrate the impact of various investments on a client's current income tax and future tax liability. ▪ Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. ▪ Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning, and disability income analysis. Regal gathers required information through in- depth personal interviews. Regal’s financial planning recommendations shall include information pertaining to a client's current financial status, future goals, and attitudes toward risk. Documents supplied by the client, such as trusts, codicils, wills, tax returns, questionnaires concerning financial goals, investment objectives, tolerance for risk, and related information are carefully reviewed to determine a recommended course of action, all of which will be memorialized in a comprehensive written financial plan. As Regal does not provide tax, accounting, or legal advice, clients should consult with their tax, accounting, and/or legal advisors. Although Regal provides investment recommendations within the written financial plan, the client is under no obligation to implement the recommendations, or to utilize Regal’s investment advisory services if such Regal recommendations are implemented. B.7. Retirement Plan Advisory Services Regal may provide education and support services to pension, 401(k), profit sharing, and similar plans commonly known as ERISA (Employment Retirement Income Security Act) plans that are administered by Third-Party Administrators and that are not custodied at RBC or Hilltop Securities. These services include:
• Employee Education and Support: For pension, profit sharing, and 401(k) plan clients, Regal provides education and support for plan participants through telephone conversations, video conferencing and in-person group meetings. The investment education will not involve individualized, tailored investment advice or individualized, tailored asset allocation recommendations to the Plan or its Participants. For ERISA plans that are custodied at RBC or Hilltop Securities, Regal may provide 3(21) investment advice as co-fiduciary, to Plans and/or its Participants. Regal does not exercise discretionary authority over Plan assets and does not act as administrator of the Plan. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Within the advisory programs listed above, Regal offers several wrap fee program options including: ▪ RBC Correspondent Advisory Programs:
• RBC Advisor
• RBC Consulting Solutions
• RBC Unified Portfolio (RBC UP) The RBC Correspondent Advisory Programs are sponsored by RBC Capital Markets, LLC (CRD #31194). The client will be provided the wrap fee brochure from RBC Capital Markets, LLC, where more information can be found regarding these programs. ▪ Hilltop Securities Advisory Programs:
• Regal Separately Managed Accounts
• Regal Fund Strategist Portfolios
• Regal Unified Managed Accounts
• Regal Advisor as Portfolio Manager The Hilltop Securities Advisory Programs are sponsored by Hilltop Securities Inc. (CRD #6220). The client will be provided the wrap fee brochure from Hilltop Securities Inc., where more information can be found regarding these programs. In a wrap fee program, clients are charged an all-inclusive wrap fee on program assets that covers advisory, execution, custodial, and reporting services on eligible assets. A portion of these fees will be paid to Regal for advisory services. Clients may incur certain charges imposed by custodians, brokers, third-party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. In some cases, a portion of service- related fees (i.e., wire transfer or account transfer fees) may be paid to our affiliated broker dealer, Regal Securities, Inc., to cover processing costs. No portion of these fees are paid to Regal Advisory Services. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Regal’s fee, and Regal shall not receive any portion of these commissions, fees, and costs. E. Client Assets Under Management As of December 31, 2023, Regal held $38,632,007 in discretionary assets and $70,204,218 in non-discretionary assets.