Kestra Private Wealth Services, LLC (“Kestra PWS”) offers both wrap fee and non-wrap fee investment advisory services. This wrap fee program brochure describes the investment advisory services we provide through our wrap fee program. Other advisory services offered by Kestra PWS are described in our firm ADV Part 2A brochure (non-wrap brochure) which contains the information required by Part 2A of Form ADV. As an investment adviser, we provide advice regarding securities products and manage the investment assets of our clients. We provide investment advice through investment adviser representatives registered with our firm. We refer to these investment adviser representatives as “Advisors” in this brochure. Most of our Advisors are also registered representatives of our affiliated broker-dealer, Kestra Investment Services, LLC (Kestra IS), which makes available securities such as stocks, bonds, mutual funds and variable insurance products. In addition, many of our Advisors also act as insurance agents independent from our firm. We generally do not provide fixed insurance products or services. To the extent your Advisor provides fixed insurance products or services to you, he or she does so outside of our firm and supervision. We have entered into an agreement with Envestnet Asset Management, Inc. (Envestnet) that enables our Advisors to offer the AdvisorEnterprise wrap fee program and the services, tools and resources described below (AdvisorEnterprise Platform). This platform includes the ability to produce an investment proposal, model building, overlay portfolio management, trading research tools and performance reporting. You will pay more for this platform than you will for our other advisory platforms, which do not offer our Advisors the same resources and technology as the AdvisorEnterprise Platform. We earn more on assets managed on the AdvisorEnterprise than through other available platforms which serves as an incentive to place your assets on this platform and is therefore a conflict of interest. The cost Kestra PWS and its affiliates pay Envestnet is based on the number of accounts and the amount of client assets we have on the AdvisorEnterprise Platform. Our costs will decrease as our Advisors put more assets on the AdvisorEnterprise Platform. When our costs decrease, the savings are not shared with you or our Advisors. As a result, we have an incentive to recommend the AdvisorEnterprise Platform and therefore a conflict of interest. An Advisor receives additional economic benefit as a result of placing business with us in the form of reduced charges for the platforms and services we make available to the Advisor for use with their clients, as well as additional compensation from Kestra PWS in the form of an increased payout. For example, we assess a Program Fee for accounts participating in the wrap program on the AdvisorEnterprise Platform. The Program Fee includes fees for Kestra PWS and its affiliates’ maintenance of the advisory platform, custody and trading services. An Advisor receives additional economic benefit in the form of lower Program Fees, as a result of placing client assets on the AdvisorEnterprise Platform; as the Program Fees decrease, the Advisor retains a greater portion of the Advisor Fee. Your Advisor therefore has a financial incentive to recommend programs on the AdvisorEnterprise Platform over other platforms, programs, or services we offer which is a conflict of interest. Advisors receive firm-level pricing to determine their Program Fee on the AdvisorEnterprise Platform. A firm is defined as those financial professionals with a shared firm name and financial structure. The pricing level of an Advisor is based on their firm’s assets under management on the AdvisorEnterprise Platform and in Horizon accounts. Some Advisors will have higher Program Fees than other Advisors. The process for engaging us to provide you services begins with our Advisor obtaining financial information from you in order to develop investment recommendations that meet your goals and objectives. Our Advisor will review your information and analyze it in order to recommend appropriate products and service based on your investment objectives, investment time horizon and risk tolerance. You will enter into a contract with our company setting forth terms and conditions of the advisory services relationship for the AdvisorEnterprise Program. You will also enter into separate custodial/clearing agreements with the applicable custodian. We typically place securities transactions through our affiliated broker-dealer, Kestra IS, which utilizes the clearing and custodial services of NFS; however, we reserve the right to designate alternative broker- dealers or clearing and custody companies. National Financial, and not our firm, maintains custody of funds and securities in your account. Additional Information regarding National Financial is described below. In addition to this Brochure, you will also receive a copy of our Privacy Policy. You will also receive the Envestnet Brochure that further describes their services as an investment adviser. Our Advisors will contact you, and typically meet with you, at least annually to review the performance of your AdvisorEnterprise account and any changes to your financial situation and investment goals and objectives. You are required to provide your Advisor with updated information regarding your financial condition and changes that may have occurred in your objectives, time horizon or risk tolerance. You are encouraged to contact your Advisor should you have questions about the management of your account on the AdvisorEnterprise Platform. If you have multiple accounts, you are eligible to consolidate account assets by “household” for fee billing purposes. Generally, householding your accounts will reduce overall management fees and should be considered where applicable. Clients should discuss with their advisor which accounts will be included within a household for purposes of fee billing. Some of the third party money managers and strategists we make available can be accessed through different advisory platforms and programs we offer, and your Client Fee will vary depending on the platform or program selected to access the manager or strategist. While we have an incentive to recommend a higher priced platform because we earn additional fees, the cost of a particular platform or program used to access a specified manager or strategist is only one component of the overall cost and, therefore, the total fees you pay could be higher or lower in the aggregate. Program Services and Fees Institutional Money Management Envestnet has entered into agreements with various Model Providers that will manage your assets either directly or through pooled investment vehicles. Through this service, our Advisors recommend managers to invest your assets based on your investment objectives and risk tolerance. You may be restricted in your ability to directly contact and consult with managers or Envestnet, but our Advisors are available to address any questions, issues or concerns regarding these managers or their recommendations. The primary ways an Advisor provides access to a manager through the AdvisorEnterprise Program are described below. Fund Strategists Portfolios (FSP) Wrap Accounts A Fund Strategist Portfolio is typically a risk-based asset-allocated model consisting of mutual funds and/or exchange traded funds. The Model Provider is responsible for security selection and allocation. We have, or Envestnet has, entered into agreements with various Fund Strategist Portfolio (FSP) Model Providers that provide models for investments in mutual funds and/or exchange-traded funds (ETFs). Advisors use the models of these providers to recommend an allocation of your assets across mutual funds and/or ETFs. Envestnet is responsible for the actual trading and investment of your assets based on the recommendation of your Advisor and strategist model. You may be restricted in your ability to directly contact and consult with the FSP Model Provider or Envestnet, but your Advisors are available to address any questions, issues or concerns regarding the provider and/or their models. The result is an account portfolio comprised of selected mutual funds and/or ETFs based on your investment objectives and risk tolerance. Accounts invested in the FSP Program typically have a minimum account size requirement between $5,000 and $50,000. In the FSP Program, you will pay a Client Fee, which is the sum of the Advisor Fee and the Manager Fee. We collect the Advisor Fee in connection with investment advice and ongoing account monitoring provided by your Advisor and a Manager Fee in connection with the investment management of the account. We Charge Advisors a Program Fee to access the AdvisorEnterprise Platform. The Program Fee is deducted from the Advisor Fee you negotiate with your advisor. The Program Fee is based on the amount of client assets the Advisor’s firm places on the AdvisorEnterprise Platform and in Horizon accounts. . The Program Fee includes fees to support Kestra PWS and its affiliates’ maintenance of the advisory platform, custody and trading services. This payment structure incentivizes your Advisor to increase the Advisor Fee by an amount sufficient to offset the Program Fee, which is a conflict of interest The Program Fee is calculated on a blended basis. For the first $5M of an account/household, the Program Fee ranges from 0.17% to 0.13%. Any amount above $5M is charged a Program Fee of 0.05%. Therefore, any account or household above $5M will have a blended Program Fee. You will also pay account maintenance costs, which are documented in the NFS Client Fee Disclosure document. You are also responsible for paying any charges imposed by the issuers of investments in your account or their affiliates. An Advisor receives additional economic benefit in the form of lower Program Fees, as a result of placing client assets on the AdvisorEnterprise Platform; as the Program Fees decrease, the Advisor retains a greater portion of the Advisor Fee. Your Advisor therefore has a financial incentive to recommend programs on the AdvisorEnterprise Platform over other platforms, programs, or services we offer. In order to better support our Advisors, we make available a curated list of FSP Model Providers representing over 200 models in the FSP program. Most of the FSP Model Providers on the Curated List are Select Providers. We receive both financial and nonfinancial support from Select Providers. We receive more compensation for the sale of products of Select Providers than for the products of other providers we sell and thus have a financial incentive to sell the products of Select Providers. More information on The Curated list can be found below in Item 6. Also, please visit our website https://www.kestrafinancial.com/disclosures/company-information for more information regarding the companies and amounts and types of compensation we receive. If you do not have access to our website, you may contact your Advisor or our home office for additional information. FSP Models outside the Curated List are available upon request. We are affiliated with Kestra Investment Management, LLC (Kestra IM). The recommendation of Kestra IM as Portfolio Manager creates a conflict of interest since our affiliate receives compensation for managing your assets in addition to the advisory fee we receive. You are under no obligation to use Kestra IM as a Portfolio Manager. All fees are negotiable, subject to the maximum amount set forth below. Manager Fee Advisor Fee Client Fee Assets Min Max Min Max Min Max $5,000+ 0.02% 0.45% 0.00% 2.48% 0.02% 2.50%
• Client Fee is the sum of the Advisor Fee plus the Manager Fee. In instances where the maximum Advisor Fee plus the Manager Fee would exceed 2.5 percent, the Advisor fee is reduced so as to not exceed a 2.5 percent.
• Manager fees may vary based upon FSP manager chosen. Separately Managed Wrap Accounts (SMAs) A Separately Managed account is typically a model consisting of individual stocks or bonds in one asset class. The Model Provider is responsible for the security selection and allocation. SMA Model Providers invest in individual stocks and bonds providing you direct ownership of the individual securities within the SMA portfolio. This structure provides more control over the underlying securities, allowing both you and your Advisor to customize an investment solution that reflects your individual goals and objectives. SMA Model Providers typically have a minimum account size requirement of $100,000, though some managers may require a minimum account size as high as $1,000,000. In the SMA Program, you will pay a Client Fee, which is the sum of the Advisor Fee and the Manager Fee. We collect the Advisor Fee in connection with investment advice and ongoing account monitoring provided by your Advisor and Manager Fee in connection with the investment management of the account. We charge Advisors a Program Fee to access the AdvisorEnterpise Platform.The Program Fee is deducted from the Advisor Fee you negotiate with your Advisor. The Program Fee is based on the amount of client assets the Advisor’s firm places on the AdvisorEnterprise Platform and in Horizon accounts. Platforms. The Program Fee is calculated on a blended basis.For the first $5M of an account/household, the Program Fee for equity SMAs ranges from 0.17% to 0.13%. Any amount above $5M is charged a Program Fee of 0.05%. Therefore, any account or household above $5M will have a blended Program Fee. For the first $5M of an account/household, the Program Fee for fixed income SMAs ranges from 0.09% to 0.05%. Any amount above $5M is charged a Program Fee of 0.05%. Therefore, any account or household above $5M will have a blended Program Fee. You will also pay account maintenance costs, which are documented in the NFS Client Fee Disclosure document. You are also responsible for paying any charges imposed by the issuers of investments in your account or their affiliates. An Advisor receives additional economic benefit in the form of lower Program Fees, as a result of placing business on the AdvisorEnterprise Platform; as the Program Fees decrease, the Advisor retains a greater portion of the Advisor Fee. Your Advisor therefore has a financial incentive to recommend programs on the AdvisorEnterprise Platform over other platforms, programs, or services we offer. We are affiliated with Kestra IM. The recommendation of Kestra IM as Portfolio Manager creates a conflict of interest since our affiliate receives compensation for managing your assets in addition to the advisory fee we receive. You are under no obligation to use Kestra IM as a Portfolio Manager. All fees are negotiable, subject to the maximum amount set forth below. Equity SMA Schedule Manager Fee Advisor Fee Client Fee Assets Min

Max Min Max Min Max $100,000 + 0.02% 0.77% 0.00% 2.48% 0.02% 2.50% Fixed Income SMA Schedule Manager Fee Advisor Fee Client Fee Assets Min Max Min Max Min Max $100,000 + 0.02% 0.5% 0.00% 1.98% 0.02% 2.50%
• Client Fee is the sum of the Advisor Fee plus the Manager Fee. In instances where the maximum Advisor Fee plus Manager Fee would exceed 2.5 percent, the Advisor fee is reduced so the Client Fee does not exceed 2.5%.
• Manager fees may vary based upon SMA Model chosen. Unified Managed Wrap Accounts (UMAs) UMAs are accounts that combine one or more l SMAs, FSP, and/or Advisor Models consisting of mutual funds, ETFs, or individual equities into sleeves within a single account. Your assets are directly invested within each sleeve by an overlay manager that is typically responsible for initially allocating assets within each sleeve and monitoring and rebalancing among the sleeves. The minimum account size in the UMAs Program is $5,000 but will vary based on the models and managers you select. The Program Fees will be higher for Advisor Models in the UMA Program than if your Advisor used the same Advisor Model in one of our other Advisor as Portfolio Manager (APM) Programs In the UMA Program, you will pay a Client Fee, which is the sum of the Advisor Fee and the Manager Fee. We collect the Advisor Fee in connection with investment advice and ongoing account monitoring provided by your Advisor and Manager Fee in connection with the investment management of the account. We charge Advisors a Program Fee to access the AdvisorEnterprise Platform. The Program Fee is deducted from the Advisor Fee you negotiate with your advisor. The Program Fee is based on the amount of client assets the Advisor’s firm places on the AdvisorEnterprise Platform and in Horizon accounts. The Program Fee includes fees for Kestra AS and its affiliates’ maintenance of the advisory platform, custody and trading services. This payment structure incentivizes your Advisor to increase the Advisor Fee by an amount sufficient to offset the Program Fee. The Program Fee is calculated on a blended basis. For the first $5M of an account/household, the Program Fee ranges from 0.17% to 0.13%. Any amount above $5M is charged a Program Fee of 0.05%. Therefore, any account or household above $5M will have a blended Program Fee. You will also pay account maintenance costs, which are documented in the NFS Client Fee Disclosure document. You are also responsible for paying any charges imposed by the issuers of investments in your account or their affiliates. An Advisor receives additional economic benefit in the form of lower Program Fees as a result of placing client assets on the AdvisorEnterprise Platform. As he Program Fees decrease, the Advisor retains a greater portion of the Advisor Fee. Your Advisor therefore has a financial incentive to recommend programs on the AdvisorEnterprise Platform over other platforms, programs, or services we offer. The FSP Models available in the UMA Program are the same as the Models in the FSP Program. A subset of the of Models in the SMA Program are available in the UMA Program. We are affiliated with Kestra IM. The recommendation of Kestra IM as Portfolio Manager creates a conflict of interest since our affiliate receives compensation for managing your assets in addition to the advisory fee we receive. You are under no obligation to use Kestra IM as a Portfolio Manager. All fees are negotiable, subject to the maximum amount set forth below. UMA Schedule ManagerFee Advisor Fee Client Fee Minimum Maximum Minimum Maximum Minimum Maximum $5,000 + 0.02% 0.77% 0.00% 2.48% 0.02% 2.50%
• Manager fees may vary based on the FSP or SMA Model chosen.
• Client Fee is the sum of the Advisor Fee plus the Manager Fee. In instances where the maximum Advisor Fee plus Manager Fee would exceed 2.5 percent, the Advisor fee is reduced so the Client Fee does not exceed 2.5 percent. Advisor as Portfolio Manager Wrap (APM-Wrap) In the APM-Wrap Program, your Advisor generally invests your assets in Advisor Models consisting of individual equity or fixed income securities, as well as pooled investment vehicles such as mutual funds and/or ETFs available through the AdvisorEnterprise Platform. The APM-Wrap program allows us to charge one consolidated fee for investment advisory services and transaction fees rather than separately charging advisory and transaction fees as we do in the APM Tickets program. The wrap fee is assessed as a percentage of the value of your account. Because the wrap fee does not change in relation to transaction volume, you will generally derive greater benefits from a wrap program when your account is actively traded. If, over time, your trade volume is low, we generally recommend you consider converting your account to the APM Tickets program or terminating your advisory agreement. Likewise, if your accounts are in the APM Tickets program and the trading activity in your account is high, we generally recommend you consider converting to the APM Wrap program in order to avoid individual transaction charges applicable to the APM Tickets program. Depending on the advisory fee charged by your Advisor, the size of the account, and the number of trades placed in your account, the APM-Tickets program may cost more or less than the APM- Wrap program. When your Advisor chooses to pay your transaction charges, the APM-Tickets program is the lowest cost program, providing your Advisor does not adjust their advisory fee to account for their additional expense. In the APM-Wrap Program, you will pay a Client Fee which is comprised of a Program Fee we collect in connection with our maintenance of our advisory platform and an Advisor Fee we collect in connection with the investment advice provided through your Advisor. The maximum client fee is 2.5%. We charge Advisors a Program Fee to access the AdvisorEnterprise Platform. The Program Fee is deducted from the Client Fee you negotiate with your Advisor. The Program Fee is based on the amount of client assets your Advisor’s firm places on the AdvisorEnterprise Platform and in Horizon accounts. The Program Fee includes fees for Kestra PWS and its affiliates’ maintenance of the advisory platform, custody and trading services. This payment structure incentivizes your advisor to increase the Client Fee assessed by an amount sufficient to offset the Program Fee, which is a conflict of interest. The Program Fee is calculated on a blended basis. For the first $5M of an account/household, the Program Fee ranges from 0.14% to 0.10%. Any amount above $5M is charged a Program Fee of 0.02%. Therefore, any account or household above $5M will have a blended Program Fee. You will also pay account maintenance costs, which are documented in the NFS Client Fee Disclosure document. You are also responsible for paying any charges imposed by the issuers of investments in your account or their affiliates. Ticket charges on certain security types still apply, but the fees will generally be passed to your Advisor. An Advisor receives additional economic benefit in the form of lower Program Fees, as a result of placing business on the AdvisorEnterprise Platform; as the Program Fees decrease, the Advisor retains a greater portion of the Client Fee. Your Advisor therefore has a financial incentive to recommend programs on the AdvisorEnterprise Platform over other platforms, programs, or services we offer. APM-Wrap accounts require a minimum account size of $5,000. Because in the APM-Wrap program we absorb ticket charges for trades in your account, we have an incentive to limit trading in the account which creates a conflict of interest. While there is no cap on the number of trades in your account, the APM-Wrap program is priced to accommodate approximately 120 trades per account annually. We reserve the right to assess your Advisor the cost of trades that exceed this amount which creates an incentive for the Advisor to limit trading in your account to avoid this cost. All fees are negotiable, subject to the maximum amount set forth below. APM Wrap Fee Schedule Maximum Client Fee: 2.5% Ticket charges on certain security types still apply, but the fees will generally be passed to your Advisor. The Program Fee is deducted from the Client Fee you negotiate with your Advisor. This payment structure incentivizes your Advisor to increase the Client Fee assessed by an amount sufficient to offset the Program Fee, which is a conflict of interest. Additional Information about Fees As noted above, if there is little or no trading activity in your advisory account, or if the trades would not otherwise be subject to a transaction fee, a wrap fee arrangement may cost more than separately paying for advisory fees and transaction charges. You should review your account statements and periodically talk to your Advisor about the level of trading in your account, the fees involved, and the type of account that makes sense for you. There may be considerations other than cost, like access to certain managers that make one program more attractive than another. All AdvisorEnterprise Program fees are negotiable, subject to the maximum amount set forth above and are charged on a per account basis. The cost of the services provided to you through the AdvisorEnterprise Program may be more or less than the cost of purchasing similar services separately. Among the factors impacting the cost of the program are the trading volume, account size, type of account registration (e.g., retirement), nature of services we provide you, amount of assets specific to a particular strategy and the particular service or third-party manager selected. If the Program Fee does not meet at least the specified minimums of $60 for APM accounts with tickets (APM-Tickets), $95 for APM accounts with wrap (APM-Wrap), $75 for Fund Strategist Portfolios, and $350 for Separately Managed Accounts (SMA) and Unified Managed Accounts (UMA) a minimum annual account fee will be assessed to your Advisor. Your Advisor receives an economic benefit because of your participation in the AdvisorEnterprise Platform. The amount of this economic benefit is generally more than what your Advisor would receive if you participated in our other platforms or programs or separately paid for investment advice, brokerage and other services. Your Advisor receives an economic benefit because of your participation in the AdvisorEnterprise Platform. The amount of this economic benefit is generally more than what your Advisor would receive if you participated in our other platforms or programs or separately paid for investment advice, brokerage and other services. An Advisor receives additional economic benefit as a result of business with us in the form of reduced Program Fees. Your Advisor therefore has a financial incentive to recommend our APM programs on AdvisorEnterprise over other platforms, programs, or services we offer. We pay our Advisors a percentage of the fees we receive. Our affiliated broker-dealer, Kestra IS, pays its registered representatives a percentage of the commissions it receives. Our Advisors receive a higher percentage of the fees we receive as their production of fees and their production of commissions in their separate capacity as a registered representative of Kestra IS increases. We will also aggregate the production of several Advisors in the same branch or firm which can allow these Advisors to reach higher payouts more quickly than if the payout were based on individual production. The practice of providing a tiered payout and aggregation of production creates a conflict of interest as your Advisor is incentivized to increase their production with us and our affiliate to obtain higher compensation percentages and additional compensation. In addition, certain Advisors that meet internal criteria that include production receive additional benefits such as practice management consulting or producer trips. Other costs may be assessed to you that are not part of the AdvisorEnterprise Platform. These may include execution charges on international and non-listed securities, dealer mark-ups, spreads paid to market-makers, and transactions executed away from National Financial. All brokerage account fees, including annual maintenance on retirement accounts, cash management, mailing, and termination fees apply to each account. There is a minimum annual account fee for each program on AdvisorEnterprise that may be assessed to your account. The above fees do not include other costs that you may be subject to, including the initial and ongoing expense of third party-investments or third-party pooled investment vehicles, including mutual funds, annuities, or alternative investments. Such expenses are usually set forth in the applicable offering document of the investment and are payable or borne by you in addition to other fees outlined above. Our Chief Compliance Officer is available to address any questions that a client or prospective client may have regarding its prospective engagement and the corresponding conflict of interest presented by such an engagement. Investment and Brokerage Discretion By choosing to participate in the AdvisorEnterprise FSP, SMA, or UMA programs, , you are required to grant discretionary investment authority to us so that we may take all necessary steps for providing advisory services for your account, such as determining the securities and amount to be bought or sold and recommending any appropriate third-party strategist or third-party manager. By choosing to participate in the AdvisorEnterprise Platform, you have designated Kestra IS as broker-dealer and National Financial as the clearing broker-dealer and custodian for your assets. By designating National Financial as your broker/custodian, we will not have authority to negotiate commissions among various brokers or to obtain volume discounts, and best execution may not be achieved. You may pay higher commissions and transaction cost and receive less favorable net prices than other clients. Third-party managers may have policies to aggregate trades with their own trades or trades for other clients as disclosed in more detail in each third party’s disclosure Brochure. Not all investment advisers require directed brokerage. Kestra IS introduces accounts on a fully disclosed basis to National Financial. For advisory accounts, we do not typically act in a principal capacity when initiating any trade order; however, National Financial or underlying managers may act in a principal capacity when executing a trade order. Any principal trades in an advisory account will be handled in accordance with applicable law. Agency cross transaction take place when we cause a security to be transferred from one account to another. Agency cross transactions are not permitted in Advisory Accounts.