Introduction In this brochure, references to “we,” “us,” “our,” or “our firm” refer to Concorde Asset Management, LLC. Individuals who serve as our directors, officers, employees, and investment advisor representatives are referred to as our “representatives.” Our firm’s clients and prospective clients are referred to as “you,” “your,” or “our clients.” Headquartered in Ann Arbor, Michigan, we have been in business since September 2006. On March 12, 2021, Concorde Holdings, Inc. (“CH”), the holding company that owns our firm, completed a stock purchase agreement with Concorde Investment Partners, LLC (“CIP”) where CIP purchased 100 percent of the outstanding shares of CH. This transaction does not affect the costs and services your receive from, or your relationship with, your investment advisor representative. Additionally, there have been no changes in the management of or the representatives affiliated with CH’s subsidiaries, including Concorde Asset Management LLC, as a result of this transaction. We offer discretionary and nondiscretionary investment management services, financial planning services, and third-party investment managers. Prior to engaging us to provide services, we will require you to enter into a written agreement with us, setting forth the terms and conditions under which we will provide our services. Our specific services, terms of our compensation, method of payment, and other important information are explained in more detail below. Financial Planning Services We offer tailored financial planning and consulting services. These consist of a wide range of topics you choose based on the level of service that you desire. You may decide to engage us to perform comprehensive financial planning or a narrower approach to consult with you on a limited basis. Further, you may select from a wide menu of financial topics in our Investment Advisory Services Agreement, including, but not limited to, retirement planning, retirement income projection and analysis; periodic investment reviews; insurance planning, and estate planning (other than legal services). Our engagements for these services are tailored to your specific circumstances and requests and will be specified in our Investment Advisory Services Agreement that we will enter with you. In providing financial planning services, our representatives will meet with you to learn your investment objectives, your investment timeline, your risk tolerance, and other information about your personal circumstances so that we can assist you in developing realistic goals and objectives. Depending on the level of expertise you need, we may involve more than one of our representatives to develop your plan. If needed, and with your permission, we may also request assistance from your legal and accounting professionals. However, when you engage outside professionals, you will be responsible for their fees to provide services. If desired, your representative will prepare a written report on a specific project or a comprehensive plan within the scope you request. Our reports usually include the steps to take to implement the advice we provide, and we can aid in purchasing and selling securities or insurance products if needed. You are under no obligation, however, to implement your plan through us. During the interview process with our representative, you should take care to ensure that the information you provide is accurate and complete as it will play a key role in our ability to properly assess your investment objectives and tolerance for risk. We do not independently verify or update the information you provide. You may, of course, engage us for specific projects that require annual or more frequent reviews if more complex long-term planning is needed. In those cases, we will review your plan with you within the scope and frequency agreed upon in advance in our Investment Advisory Services Agreement with you. If you have an ongoing agreement with us, promptly inform us of any material change in your personal information, financial circumstances (including cash flow needs), investment objectives, or risk tolerance. We will assume you have not had any material change in your circumstances unless you tell us. While we will use our best efforts to recommend investments and plans that are designed to address your investment objectives and risk tolerance, we cannot assure you that our recommendations will achieve your objectives. Past performance of investments is not necessarily indicative of their future performance. Investment Management Services With our Investment Management Services, we will actively manage your investment portfolio based upon your individual financial and personal needs in your qualified retirement, non-qualified individual, Trust, joint, and other types of accounts. We gather information through meetings at a frequency and method determined with each client. This may include one or more in-person meetings and/or telephone calls. We may gather your investor profile information that typically includes your current financial position, future goals, attitudes toward risk, and your investment objectives. We ask you to fill out a client profile questionnaire or similar document that we will carefully review, along with all other documentation and information you supply (collectively referred to as your “investor profile”). Because we only rely upon the information you provide us and do not independently verify it, you should provide us with accurate information that we ask you to update whenever it changes. Based on the information you provide, we will develop a personalized portfolio designed to meet your investment goals and objectives through strategies and services such as asset allocation, portfolio monitoring, consolidated reporting, and, most importantly, individualized portfolio management. Individualized portfolio management and a tailored investment strategy will help us choose among various kinds of investments available in the market. Investments may include equity securities (stocks), warrants, corporate debt securities (bonds and notes), certificates of deposit, municipal securities, investment company securities (mutual funds, including money market funds), exchange-traded funds, closed-end funds, and United States government securities. If appropriate, we may allocate your investments in accordance with model portfolios we make available from many sources. A model portfolio is how we communicate to you what specific investments you should have in your portfolio at any given time. Non-Discretionary Investment Management Services – Concorde Advisor In the Concorde Advisor program, we will manage your assets on a non-discretionary basis, which means that we will first consult with you and obtain your specific approval for buy or sell transactions before we can implement any investment decision on your behalf and any limitations stated in the Investor Profile. Even though we will not place trades or rebalance your account without prior approval of each proposed transaction, a limited power of attorney may still be required by the broker-dealer or custodian for your account for us to place approved trades on your behalf. You should also understand that our having to obtain your prior approval for each transaction will often delay the implementation of our recommendations until we reach you, which could result in different market conditions and prices than may be available for accounts managed on a discretionary basis. Discretionary Investment Management Services – Professional Management In our Professional Management program, your representative will provide portfolio management for your account on a discretionary basis, which means that we will buy or sell securities on your behalf without your prior permission for each specific transaction. However, the selection of securities or other investments will be in accordance with your investor profile, goals, and risk tolerance as described above in the section entitled, “Investment Management Services.” We will also accept and note investment restrictions you may impose on your account if they are reasonable and as long as they do not hinder our ability to execute our investment strategies on your behalf. If you do impose such restrictions (for example, if you instruct us not to purchase certain securities involved in businesses to which you object), you should be aware that such restrictions may result in your account not being as diversified as our other client accounts, which could cause your account to underperform or perform differently than other client accounts that are managed without such restrictions. If you choose our professional management of your account on a discretionary basis, we will obtain your prior written authorization in our agreement with you.
Variable Annuity Separate Accounts – Professional Management We also offer professional management of the separate accounts within variable annuity contracts using the financial information you provide to us. On a discretionary basis, we will periodically review and reallocate your investments as we deem appropriate based on your investor profile, goals, and risk tolerance as described above in the section entitled, “Investment Management Services.” Sawtooth and all related model portfolio managers are investment advisers registered with the U.S. Securities and Exchange Commission and you will be provided with any applicable disclosure documents, as required, prior to engaging their services. Also, refer to Item 10 below for additional information on certain back-office operations support services that we receive from Sawtooth. Discretionary Investment Management Services We offer the Concorde UMA Program, which is our own private-labeled program currently using the platform of Envestnet, Inc. (“Envestnet”). Through the Concorde UMA Program, Envestnet offers investment models and advisory services through a select group of third-party investment advisers that act as Strategists and Managers for your account. Additionally, Envestnet provides related research to your representative regarding the investment disciplines and/or approaches used by the approved Strategists and Managers on Envestnet’s platform to identify and select those who best fit your specific investment objectives and risk tolerance to manage your assets in one unified account. In the Concorde UMA Program, we act as the Overlay Manager for your account on a discretionary basis and assume the responsibility for asset allocation, Strategist and Manager selection, and termination, portfolio management, as well as communicating trading instructions to your custodian. We also offer other third-party service providers, like Orion Portfolios, SEI Investments, and AssetMark Envestnet. Our third-party service providers allow us, with your agreement, to select third-party, non- affiliated investment managers, sub-advisors, models, funds, and strategies (“Services”) to design and manage portfolios for your assets on their platforms on a discretionary basis. Your representative will assist you in completing a profile questionnaire and review the information you provide. Based on the information you provide; we will recommend or select Services aligned with your risk tolerance and investment objectives as outlined in your profile. The third-party service provider may also act as an Overlay Manager that is responsible for overseeing all trading in your account and communicating trading instructions to the custodian for your account to help ensure that all allocations in your account are harmonized. The third-party service providers provide background information to your representative who in turn provides advice to you regarding the Services used on the platform. Generally, the third-party service provider is responsible for model portfolio construction and additional research services. However, your representative can create their own portfolios on some platforms. Further, the availability of Services will vary based upon the third-party service provider selected. Your representative will be available to answer questions that you may have regarding your account. We will generally retain the ability to select, terminate, and reallocate between the Services in accounts over which you have granted us discretionary authority. Envestnet and other third-party services providers, as well as the related sub-advisers and managers are investment advisers registered with the U.S. Securities and Exchange Commission and you will be provided with any applicable disclosure documents, as required, prior to engaging their services. Please refer to Item 10 for additional information on certain back-office operations support services that CAM receives from Envestnet and other third-party service providers. Our Wrap Fee Programs We offer many of the same discretionary and non-discretionary portfolio management services through three separate wrap fee programs that we sponsor and where you are charged a single all-inclusive fee for such services. In our wrap fee programs, you are not charged separately for transaction costs imposed by the custodian of your account as we will absorb such costs on your behalf. Please refer to our sponsored wrap fee program brochures for further details on our portfolio management services and fees. Third-Party Asset Management Programs We make available advisory services and programs of a variety of third-party investment advisers who create portfolios with varying levels of risk. We will act in either a promoter (formerly known as, solicitor) or subadviser capacity when making this program available to clients. Under these programs, your representative or the third-party adviser may provide ongoing investment advice tailored to your individual needs. As part of these services, your representative will typically obtain the necessary financial data from you to assist in determining appropriate investment objectives and selecting the program whose style and talent appears to best fit your individual needs and circumstances, including assistance in opening an account. The programs offered by these firms may not be available to all clients because of account minimums, client objectives, and manager restrictions. Unless directed otherwise, your agreement with us gives us the authority to hire or fire these managers on your behalf. Once you and your representative select a program, your representative will continue to monitor their performance. Additionally, we will meet with you in person, via telephone, or via electronic means, at least annually, to determine whether any changes in your financial status warrant adjustments to your investment objectives with the third-party adviser. We will also be happy to meet with you more frequently if requested. You should understand that third-party advisers are not affiliated with us, and we are not responsible for their services, actions, omissions, or performance. Our responsibility is limited to initially evaluating and recommending investment advisers and portfolios based upon the reasonably available information at the time and periodically reporting on the program’s investment performance for your account. From time to time, we review other managers and reserve the right to make additional programs available to our clients as, at our discretion, that we deem appropriate and consistent with our investment strategies. If you are interested in learning more about any of these providers, a complete description of their programs, services, fees, payment structure, and termination features are found in their respective service disclosure brochures (or wrap fee disclosure brochures), investment advisory agreements, and account opening documents, all of which your representative will provide you prior to engaging their services. Promoter When we act as a promoter, the third-party investment adviser (and not us or your representative) has the authority to purchase and sell securities on a discretionary or non-discretionary basis pursuant to the investment objective you choose. This authorization will be set out in the client agreement. We currently offer a variety of third-party managers, including but not limited to programs sponsored by Stonebridge. We receive compensation from a third-party manager for making a referral, and you will receive a specific disclosure brochure describing the referral, the relationship, and the compensation arrangement as described in the “Item 14 - Client Referrals and Other Compensation” section below. Subadvisor Depending on the type of program selected, your representative may assist you in selecting a model portfolio of securities designed by the subadvisor or select a subadviser to provide discretionary asset management services. If you select a subadviser to provide discretionary asset management services, the subadviser (and not us or your representative) has the authority to purchase and sell securities on a discretionary basis pursuant to the investment objective you choose. If you select a model portfolio of securities designed

by the subadvisor, you will provide us with the authority to purchase and sell securities on a discretionary basis pursuant to the investment objective you choose. Your authorization will be set out in the applicable client agreement. We currently offer a variety of subadvisors, including but not limited to programs sponsored by Envestnet and Orion. For these and other services, we will receive a portion or all the fees paid by you as described in the “Fees and Compensation” section below. Retirement Services All our financial planning and investment management services can be offered to clients with retirement accounts, such as Individual Retirement Accounts (“IRAs”), a Rollover from an IRA or Retirement Plan, like a 401(k) Plan, and advice to Retirement Plan participants. Department of Labor Acknowledgement of Fiduciary Duty Concorde Asset Management, LLC (“CAM”) is an investment adviser registered under the Investment Advisers Act of 1940. Our firm provides or seeks to provide investment advisory services to various types of clients including, but not limited to, employee benefit plans and individual retirement accounts (IRAs), collectively referred to as Retirement Investors. Pursuant to the Employee Retirement Income Security Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), CAM (hereinafter "Financial Institution" or "FI") and individuals providing investment advice on our behalf (hereinafter "Fiduciary Advisers" or "FAs") will be deemed to be investment advice fiduciaries (hereinafter "ERISA Fiduciaries") when we render individualized investment advice to a plan, plan fiduciary, plan participant or beneficiary, IRA, or IRA owner, Health Savings Accounts ("HSAs"), Archer Medical Savings Accounts and Coverdell Education Savings Accounts (together, "Retirement Accounts") for a fee or other compensation, whether direct or indirect. While we are already fiduciaries for all of your advisory accounts under the Investment Advisers Act of 1940, we are required to acknowledge this new ERISA Fiduciary status. Acknowledgement of Fiduciary Status: Effective January 31, 2022, pursuant to the recommendations we provide to your Retirement Account(s) and your acceptance thereof, CAM acknowledges that together with our FAs we are acting as Fiduciaries under ERISA or the Code, or both with respect to the recommended transaction(s) covered by this document. As ERISA Fiduciaries to our clients, CAM and our FAs have an affirmative duty of undivided loyalty to always serve our clients' best interests and act in utmost good faith, placing our clients' interests first and foremost without regard to the financial interests of our employees, affiliates, and any related entities or other parties. Further, as Fiduciaries we are required to act prudently on our clients' behalf, exercising care, skill and diligence when providing our services. As ERISA Fiduciaries, CAM and our FAs are committed to these Impartial Conduct Standards: (i) providing prudent advice that is, at the time of the recommendation, in the Best Interest of our client, (ii) receiving no more than reasonable compensation, and (iii) statements made regarding the recommended transaction, fees and compensation, Material Conflicts of Interest and other matters relevant to the Retirement Investor's investment decisions, will not be materially misleading at the time they are made. Material Conflicts of Interest: Identifying CAM’s Material Conflicts of Interest has been and remains fundamental to our development of reasonable and prudent policies and procedures which are designed to prevent such conflicts from causing violations of the Impartial Conduct Standards, among other considerations. A Material Conflict of Interest exists when a Financial Institution or Fiduciary Adviser has a financial interest that a reasonable person would conclude could affect the exercise of its best judgment as an ERISA Fiduciary in rendering advice to a Retirement Investor. FIs are therefore required to mitigate the impact of any Material Conflicts of Interest, and to provide a description of such conflicts to an existing or prospective Retirement Investor. Furthermore, FIs must designate a person or persons responsible for addressing such Material Conflicts of Interest and monitoring FAs' adherence to the Impartial Conduct Standards. Accordingly, CAM has designated our chief compliance officer, Danielle Delongchamp, as the firm's ERISA Conflict Officer. CAM has identified the following Material Conflicts of Interest: Compensation Arrangements: We have the following potential compensation-related Material Conflicts of Interest: Variable Asset-Based Fees: CAM’s fees are calculated based on the nature of the services and/or securities being recommended and the composition of the Retirement Investor's portfolio. For example, fee rates for fixed income securities are lower than those for equity securities and fee rates for larger accounts are lower than smaller accounts. Negotiability of Fees: CAM retains the authority to negotiate our fees based on a variety of factors, such as the size of a client's account, the agreed upon level of services to be provided, grandfathering of pre-existing fee arrangements, and preferential fee arrangements not generally available to clients (e.g., fees reduced or waived for related persons, family and friends), among others. Fiduciary Adviser Compensation Arrangements: One or more of CAM FAs are separately licensed as registered representatives of an affiliated broker-dealer and/or insurance agent. When engaged in this separate capacity, typically he or she may receive separate compensation for the sale of securities products. As the receipt of such compensation creates a Material Conflict of Interest, CAM’s fee policy is structured to eliminate the conflict by offsetting such third-party compensation. There may be a waiting period until fees may be charged on your retirement accounts if separate compensation is received or this compensation is taken into consideration when negotiating the applicable fee. In some instances, third-party compensation is rebated to the plan, participant or beneficiary account, or IRA. Consequently, our firm and the FA retain only the compensation set forth in our fee schedule, which is not in excess of reasonable compensation. Receipt of Third-Party Payments: Concorde Asset Management has arrangements with affiliated entities pursuant to which our affiliates, firm and/or FAs receive additional compensation for the sale, promotion or placement of such entities' products, or services or both. Consequently, these arrangements create an incentive to prefer these offerings over similar products and services when formulating recommendations for Retirement Investors. Consistent with Concorde Asset Management’s fiduciary duty to our clients and mandatory adherence to the Impartial Conduct Standard, Concorde Asset Management has not limited the consideration of the selection of products or services to those which generate additional compensation. While we have no restrictions or limitations on the selection of products or services which may be offered to Retirement Investors, to mitigate the inherent risks resulting from these arrangements, our procedures include rigorous documentation, oversight and monitoring of the recommendations being made to verify they are consistent with the client's best interests. Recommendations (e.g., recommendations regarding rollovers, switching accounts from brokerage to advisory fee-based accounts or vice versa, among others) Rollover Recommendations. A Retirement Investor or prospective Retirement Investor leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer's plan, if permitted, (ii) roll over the assets to the new employer's plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account ("IRA"), or (iv) cash out the account value (which could, depending upon the Retirement Investor's age, result in adverse tax consequences). If the FA recommends that a client or potential client roll over their retirement plan assets into an account to be managed by Concorde Asset Management, such recommendation creates a Material Conflict of Interest insofar as the firm will earn an advisory fee on the rolled over assets. Concorde Asset Management has adopted reasonable and prudent procedures to facilitate and document the consideration of the Retirement Investor's investment alternatives that require an assessment of the existing plan and available options. As applicable, such assessment will evaluate the fees and expenses of each option, including whether the employer pays for some or all of the plan's administrative expenses, and the different levels of services and investments available under each option, among other considerations. Level Fee Fiduciary Recommendation. A recommendation that a Retirement Investor (i) roll money out of a plan into a fee-based account that will generate ongoing fees for the FA that would not otherwise be received, even if those fees do not vary with the assets recommended or invested, or (ii) switch from a commission-based account to an account that charges a fixed percentage of assets under management on an ongoing basis creates a Material Conflict of Interest. To mitigate such conflicts, Concorde Asset Management’s policies and procedures require an assessment of whether a commission-based or fee-based account is more appropriate for the particular client (e.g., a review of trading activity, requirements for ongoing monitoring and/or investment advice, among other considerations). Furthermore, in the event the FA recommends that the Retirement Investor rollover from another IRA or switch from a commission-based account to a level fee arrangement, the specific fee must be disclosed to the Retirement Investor in advance. Concorde Asset Management maintains the required documentation reflecting the reason(s) such arrangement is considered to be in the Best Interest of the Retirement Investor, and specifically details the services that will be provided for the stated fee. Supervision: Pursuant to industry studies, financial services regulators have noted that a firm's failure to provide employee training or providing inadequate training to employees regarding the firm's Impartial Conduct Standards and the policies and procedures adopted to implement and ensure compliance with these standards creates an increased potential for violations. Concorde Asset Management’s policies and procedures and incentive practices, when viewed as a whole, are reasonably and prudently designed to avoid a misalignment of the interests of our FAs with the interests of the Retirement Investors they serve as ERISA Fiduciaries. Our firm's supervisory procedures include careful screening of potential hires including verification of industry qualification and employment history, and an assessment of past misconduct and disciplinary history, if any. Firm procedures include initial and ongoing training of employees based on the nature of their responsibilities, mandating periodic reporting and/or certification of their adherence to the firm's policies and procedures, and conducting periodic monitoring and testing of our policies to prevent or detect any violations of them. Individuals found to have violated procedures will be subject to disciplinary action by our firm based on the nature of the infraction. Recruitment Bonuses Paid to Fiduciary Advisers: From time to time, Concorde Asset Management and or its affiliates may provide recruitment assistance to a prospective Fiduciary Adviser (FA) as a further incentive to join our firm. FA’s are not incentivized by the movement of accounts or assets to our firm, nor is this assistance based on achievement of particular asset targets. The assistance paid is a fixed amount contingent upon the FA's continued service 'in good standing' at our firm. Due to the nature of such an arrangement, this practice does not represent a Material Conflict of Interest. Furthermore, as disclosed above, Concorde Asset Management has adopted policies and procedures governing our hiring and ongoing supervision of employees, particularly with respect to individuals responsible for providing investment advice to our clients. Such monitoring seeks to identify, review and remediate improper sales practices or account transfers; any such findings of advisor wrongdoing may result in discipline and/or nullification of awards. Services Provided to ERISA Retirement Plan Sponsors We provide investment management services to qualified retirement plans that are subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). As part of our services to qualified plans, we will act as either an ERISA 3(21) fiduciary adviser or an ERISA 3(38) fiduciary manager. The key difference between these two types of fiduciaries is whether you engage us as a discretionary manager. As a 3(38) manager, you give us discretionary authority to manage your plan’s assets. This means that you shift your fiduciary responsibility to us for the selection of your investments. If you hire us as a 3(21) adviser, we will make recommendations, but it is ultimately up to you, as the plan sponsor, to decide whether and how to act. As a 3(21) adviser, we will not have the discretion to invest and reinvest your assets without your prior consent. Thus, as a 3(21) adviser, we will share responsibility for the selection of investments. For qualified plan clients, we generally start by assisting you with the creation and maintenance of an investment policy statement, which may place restrictions on the types of investments in which the plan may invest. We identify specific asset categories to be represented in your plan’s investment menu. We then use our investment process to select and advise on mutual funds and other securities that comprise your plan’s investment menu. We ensure that the investment options are permitted under your investment policy statement. We continually monitor the performance of all investment options. We review each fund manager by utilizing a comprehensive qualitative process. We prepare a quarterly, comprehensive fiduciary review that documents performance results of each fund over various time periods and benchmark results of each fund against an applicable peer group, target, and index benchmarks. We provide a variety of risk-based asset allocation models that allow participants to invest according to their specific goals, objectives, time to retirement, as well as risk tolerance. We create our models by assigning a weighted allocation to the mutual funds in our investment menu depending upon the objective of the model. We rebalance investments in our models based upon market conditions. Participants of plans are permitted to choose to invest in one or more of our models or individual funds. If we provide individual investment advice to participants as described below, we will only recommend investments that meet the investment objectives, time horizon to retirement, anticipated retirement income needs, and risk tolerance of the participant. Participant Advice We believe that our individualized participant advice services tend to increase participant retirement plan contributions and help to close the gap between what a participant needs for retirement and what he or she may have. Therefore, in addition to the investment supervisory services we provide to plan sponsors, the plan sponsor may engage us to provide one-on-one investment advice to the participants of the plan. Generally, we start this process by providing education to employees in group meetings. We then meet individually with the participant. The participants will provide information to us about their financial situation, risk tolerance, time horizon to retirement, anticipated retirement income needs, and investment objectives. We also provide information to the participants on how various levels of wage deferral or contributions to their retirement plan will impact their take-home pay. Taking all this information into consideration, we will recommend investment in an appropriate model or other plan menu investments. We meet with newly eligible participants generally on a quarterly basis and we offer to meet with all participants on a semi-annual basis or more or less frequently as requested by the plan sponsor. Please note that we require separate investment advisory agreements with each plan participant who utilizes our advice, which we may provide on a discretionary or nondiscretionary basis. Assets Under Our Management As of December 31, 2023, the total assets we manage were $395,111,244.58, which comprises our regulatory assets under continuous discretionary management of $384,091,239.61 of client assets on a discretionary basis and $11,020,004.97 assets on a non-discretionary basis. Additionally, we have $136,768,943.31 of assets under advisement.