Arbor Point Advisors, LLC (“APA”) is registered as an investment adviser with the Securities and Exchange Commission (“SEC”), SEC File No. 801-77135, in order to offer investment advisory products and services to its advisory clients. Securities America, Inc. (“SAI”), APA’s broker-dealer affiliate, is registered with the SEC as a broker-dealer engaged in the offer and sale of securities products and is a member of the Financial Industry Regulatory Authority (“FINRA”). Advisory products and services are offered through certain Financial Advisers (“FAs”) who have registered as Investment Adviser Representatives (“Advisory Representative”). Registration does not imply a certain level of skill or training. APA and SAI are wholly owned subsidiaries of Securities America Financial Corporation (“SAFC”). SAFC is a wholly-owned subsidiary of Osaic Holdings, Inc., which is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P. and The Berlinski Family 2006 Trust. Securities America, Inc. the broker-dealer, will henceforth be referred to as “SAI”. APA will henceforth be referred to as “we”, “us”, “our” or the “Firm”. We have been an SEC Registered Investment Adviser since 2012 and manage, as of December 31, 2023, $6,929,575,682of assets on a discretionary basis.. Each of our Advisory Representatives is permitted to offer all or any combination of the advisory programs described below to our clients ("you” or “your”). ASSET MANAGEMENT SERVICES PROGRAM The Asset Management Services Program provides comprehensive investment management of your assets through highly customized and individualized investment strategies crafted to focus on your specific goals and objectives. We provide this investment management service through accounts maintained through Schwab Advisor Services (“Schwab”) and Fidelity Institutional Wealth Services (“Fidelity/IWS”). The Asset Management Service Program is a program where the Advisory Representative is the portfolio manager. Your Advisory Representative has the option to allocate your portfolio amongst a mix of stocks, bonds, options, exchange-traded funds, mutual funds, cash and other securities (“Program Investments”) which are based on your individual needs, investment goals, objectives, and risk tolerance. Additionally, you can elect to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions can include requiring your Advisory Representative to avoid investing in certain industries, companies, securities, or types of securities. There is no additional charge for applying these types of restrictions to your Ally or Counsel Programs. If you would like to impose reasonable restrictions on the management of your Ally or Counsel Portfolio, or modify reasonable restrictions that you have previously imposed, please contact your Advisory Representative. Clients should expect that the performance of advisory accounts with restrictions will differ from, and may be lower than, the performance of advisory accounts without restrictions. In addition, the account’s risk profile, sector weights and other characteristics may differ from advisory accounts without restrictions. The Advisory Representatives and the Firm do not assume responsibility for investment restrictions that are imposed by the client or any non-client individual or entity, including clients’ employers, or that are not communicated in writing to and accepted by the Advisory Representative. For further Asset Management Services Program details, please see the Asset Management Services Program Brochure. We provide this brochure to you prior to or concurrent with your enrollment in the Asset Management Services Program. Please read it thoroughly before investing. PARTICIPANT RETIREMENT PROGRAM Through the Participant Retirement Program, APA and Advisory Representatives offer investment advisory services to participants in tax-exempt retirement account assets in employer sponsored retirement plans (“Plan”). Under the Participant Retirement Program, you elect to have your Advisory Representative manage your contributions to the Plan, any contributions by your employer or Plan sponsor on your behalf and any other additions to the Plan on behalf of or attributable to you (collectively, “Plan Assets”). Through your Advisory Representative, the Firm provides advice with respect to Plan Assets in your account only including additions, substitutions and proceeds. the Firm is not responsible for the actions or non-actions of predecessor investment advisors, managing any assets other than the Plan Assets allocated to your account or administration of the Plan. In managing your account, the Firm will, but is not required to, consider any other securities, cash or other investments owned by you. You maintain the ability to impose reasonable restrictions on management of your account, including the ability to instruct us to not purchase certain investments or securities. Your Advisory Representative will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance, investment objectives, investment time horizon or restrictions you may wish to impose on the account. At no time will the Firm act as custodian of the Plan or have direct access to the Plan’s funds and/or securities. Fidelity/IWS maintains custody of all Plan Assets in your account and will process the orders for securities transactions in your account in its broker-dealer capacity when your Advisory Representative enters such orders. TRANSFERRED SSN ADVISORY, INC. ACCOUNTS In September 2020, certain accounts at SSN Advisory, Inc. (“SSNAI”), were acquired and merged into the Firm. The Firm replaced SSNAI as the registered investment adviser on any non-wrap Fidelity/IWS program accounts transferred due to the acquisition. The non-wrap Fidelity/IWS program accounts (“Transferred SSNAI Accounts”) are only available to clients who are already invested in them and are not being offered to new clients or accounts. Through this legacy program, we provide comprehensive investment management of your assets through highly customized and individualized investment strategies crafted to focus on your specific goals and objectives. We provide this investment management service through accounts maintained through Fidelity/IWS. In this legacy program, the Advisory Representative is the portfolio manager. Your Advisory Representative has the option to allocate your portfolio amongst a mix of stocks, bonds, options, exchange-traded funds, mutual funds and other securities (“Program Investments”) which are based on your investment goals, objectives, and risk tolerance. Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Each of our Advisory Representatives negotiates his or her own account fee schedule. The account fees paid by you include portions paid to your Advisory Representative, as well as to the Firm. Mutual funds and ETFs invested in the account also have their own internal fees (“internal fund expenses”) which are separate and distinct from the program account fees (for more information on these fees, see the applicable fund prospectus). TRANSFERRED KMS FINANCIAL SERVICES, INC. ACCOUNTS In November 2020, certain accounts at KMS Financial Services, Inc. (“KMS”), were acquired and merged into the Firm. The Firm replaced KMS as the registered investment adviser on any Schwab and Fidelity/IWS program accounts transferred due to the acquisition. These program accounts (“Transferred KMS Accounts”) are only available to clients who are already invested in them and are not being offered to new clients or accounts. Through this legacy program, we provide comprehensive investment management of your assets through highly customized and individualized investment strategies crafted to focus on your specific goals and objectives. We provide this investment management services through accounts maintained through Schwab and Fidelity/IWS. In this legacy program, the Advisory Representative is the portfolio manager. Your Advisory Representative has the option to allocate your portfolio amongst a mix of stocks, bonds, options, exchange-traded funds, mutual funds and other securities (“Program Investments”) which are based on your investment goals, objectives, and risk tolerance. Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Each of our Advisory Representatives negotiates his or her own account fee schedule. The account fees paid by you include portions paid to your Advisory Representative, as well as to the Firm. Mutual funds and ETFs invested in the account also have their own internal fees (“internal fund expenses”) which are separate and distinct from the program account fees (for more information on these fees, see the applicable fund prospectus). THIRD-PARTY ADVISORY SERVICES The Firm can also offer you the services of various Third-Party Money Managers (“Third-Party Money Managers” or “TPMMs”) for the provision of certain investment advisory programs including mutual fund wrap and separately managed account programs. In doing so, we act in a “co-advisory” or, in certain circumstances, “promoter” capacity. TPMMs typically maintain their own custodial relationships and do not leverage the custodial relationship the Firm has with Schwab or Fidelity except for certain TPMMs detailed below. When acting in a co-advisory capacity, the Firm and the Third-Party Money Manager are jointly responsible for the ongoing management of your account. In connection with this agreement, your Advisory Representative will provide assistance in the selection and ongoing monitoring of a particular Third-Party Money Manager. Factors we consider in the selection of a particular Third-Party Money Manager include, but are not limited to: i. our assessment of a particular Third-Party Money Manager; ii. your risk tolerance, goals, objectives and restrictions, as well as investment experience; and iii. the assets you have available for investment. The Firm’s role in these relationships is limited as one that monitors Third-Party Money Managers’ investment strategies generally as part of its initial and annual diligence of Third-Party Money Managers. In this case, the Firm does not exercise discretion in selecting, holding or selling portfolio investments. Third-Party Money Managers have differing minimum account requirements and a variety of fee ranges. Each manager’s advisory services, fees and expenses, program termination and other information are set forth in their disclosure brochures, client agreements, account opening documents and applicable fund prospectuses. The fees charged by Third-Party Money Managers who offer their programs directly to you may be more or less than the combined fees charged by the Third-Party Money Manager and us for our participation in the investment programs. Your Advisory Representative will assist you in opening an account and, when doing so, you will execute an agreement directly with the selected TPMM. Most TPMMs assume limited discretionary authority over your account, meaning that the selected TPMM has the authority to purchase and sell securities in your account without contacting you or your Advisory Representative first. Some TPMMs may allow you to impose restrictions on investing in specified securities or types of securities. In addition to the advisory relationship that you will have with these Third- Party Money Managers, you will also enter into an advisory relationship with us by signing our client agreement. If you are interested in learning more about these services, please note that a complete description of the programs, services, fees, payment structure and termination features are available via the applicable Third-Party Money Manager’s disclosure brochures, investment advisory contracts, and account opening documents. You should know that the services provided by us through the use of Third-Party Money Managers are under certain conditions directly offered by them to you. Not all TPMMs are open to all Advisory Representatives, as some are available on a limited basis, for the most part, as the result of transitions and our Firm’s growth. Your Advisory Representative can also act purely in a promoter capacity when referring you to a TPMM. When acting as a promoter for the TPMM program, the Firm and your Advisory Representative do not provide advisory services in relation to the TPMM program. Instead, your Advisory Representative will assist you in selecting one or more TPMM programs. The TPMM will be responsible for assessing the suitability of their investment recommendations against your risk profile. Your Advisory Representative is compensated for referring you to the TPMM program. This compensation generally takes the form of the TPMM sharing a percentage of the advisory fee you pay to the TPMM. When we act as a promoter for a TPMM program, you will receive a written promoter disclosure statement describing the nature of our relationship with the TPMM program, if any; the terms of our compensation arrangement with the TPMM program, including a description of the compensation that we will receive for referring you to the TPMM program. Please consult the applicable Third-Party Money Manager’s agreement for further information. The amount of compensation received by the Firm and your Advisory Representative from a particular TPMM could be higher than the compensation received from another TPMM. This is because compensation structures vary by product type as well as TPMM programs provided. This results in a conflict of interest because your Advisory Representative has a financial incentive to recommend one TPMM over another in order to receive greater compensation. There can be other suitable TPMM programs that are more or less costly. If you would like additional information on costs of TPMM programs chosen for you, please discuss with your Advisory Representative. Trading by Third-Party Money Managers can trigger wash sale rule implications. A wash sale occurs when a security is sold at a loss and then the same or substantially identical security is repurchased within a short time period. The Third-Party Money Manager cannot necessarily manage accounts in a manner to avoid wash sale implications. You are encouraged to consult with a tax advisor to discuss any tax implications involving your portfolios in these and in all advisory programs. Envestnet Asset Management, Inc. The Firm has an agreement with Envestnet that allows its Advisory Representatives to offer third party money managers to clients through the Envestnet Private Wealth Management Program. The Private Wealth Management Program allows you to establish an account using Fund Strategist Portfolios (“FSP”), Separately Managed Account Portfolios (“SMA”) and Unified Managed Account Portfolios (“UMA”). Envestnet acts as the platform manager and provides overlay management of the investment models by performing administrative services and trading services. APA and its Advisory Representative act in a co-advisory capacity under this agreement. As a co-adviser, the Advisory Representative will assist you in determining which Third-Party Money Managers are best suited for you, gather information from you about your financial situation, investment objectives, and other information you need to open your account. The fees you pay for will be designated in the agreement with Envestnet. You pay an annual account fee, payable quarterly or monthly and calculated as a percentage of account assets under management for advisory services provided. Both APA and your Advisory Representative take a portion of this fee. The advisory fee you pay does not cover certain custodial fees that are charged to clients by the custodian. A custodian can charge a minimum account fee. Clients are also charged for specific account services, when applicable, such as ACAT transfers, electronic fund and wire transfer charges, and for other optional services elected by Clients. Accounts are subject to transaction-based ticket charges assessed by the custodian for the purchase of certain mutual funds, as applicable. Similarly, the Program Fee does not cover certain non-brokerage- related fees such as individual retirement account (“IRA”) trustee or custodian fees and tax-qualified retirement plan account fees and annual and termination fees for retirement accounts (such as IRAs). For certain accounts, APA passes these transaction charges to your Advisory Representative. The Firm and your Advisory Representative utilize multiple broker-dealer custodians for brokerage and clearing services. Refer to the Item 12: Brokerage Practices for more details. A complete description of the programs, services, fees, payment structure and termination features are available via Envestnet’s Form ADV 2A and/or applicable wrap fee brochures, investment advisory contracts, and account opening documents. Ladenburg Thalmann Asset Management Inc. The Firm has an agreement with Ladenburg Thalmann Asset Management Inc. (LTAM) that allows our Advisory Representatives to offer the LTAM sponsored Investment Consultant Services (ICS) Program and the Ladenburg Asset Management Program (LAMP) through the Firm’s custodial relationship to clients. Through the ICS program, Firm’s Advisory Representatives assist the client in selecting one or more managers available through the Program (“ICS Managers”), which may include LTAM, to provide discretionary management services for the client’s account from those available through ICS. Through the LAMP Program, Firm’s Advisory Representatives gather information from the client regarding their investment objectives, risk tolerance, investment time horizon, and any investment policies, guidelines, or reasonable restrictions applicable to the assets. Based on the information provided, the Advisory Representative assists the client in determining if there is an appropriate LAMP solution for their investment needs and helps select an investment strategy for the client’s account from those available through LAMP. A team of investment managers employed by LTAM (LAMP Managers) manage the accounts in LAMP on a discretionary basis in accordance with the investment strategy that the client selects and information provided by the clients on the Agreement. LTAM is affiliated with the Firm. Refer to Item 10, Other Financial Industry Activities and Affiliations, for additional information. A complete description of the programs, services, fees, payment structure and termination features are available via LTAM’s Form ADV 2A and/or applicable wrap fee brochures, investment advisory contracts, and account opening documents. FINANCIAL PLANNING AND CONSULTING SERVICES Arbor Point Advisors and your Advisory Representative offer advice through the presentation of financial plans.

Clients using these services can receive a written financial plan providing them with a financial blueprint designed to achieve their stated financial goals and objectives. Plans can be comprehensive or focus only on specific areas of concern to you. In general, a financial plan can address any or all of the following areas:
• Cash management
• Insurance coverage
• Death and disability planning
• Divorce planning
• College planning
• Investment portfolio review
• Estate and retirement planning
• Income distribution In addition, Arbor Point Advisors and your Advisory Representative provide financial planning consultation services on specific areas of concern to you. These services can also include retirement plan consulting services provided to the plan sponsor or to individuals wanting advice on how their plan investments should be allocated. Additionally, APA and your Advisory Representative can provide financial planning services to business entities and groups requesting educational services and financial planning seminars or individual consulting and planning services for employees or members. If individual planning or consulting services are provided, each participating employee or member will be required to execute a separate agreement with us. These services will be advice-only services; APA and your Advisory Representative will not implement transactions on your behalf as part of these services. If you want APA or your Advisory Representative to implement transactions on your behalf, you need to contract with APA and your Advisory Representative for our investment management services described elsewhere in this section. In the alternative, your Advisory Representative may also be a SAI registered representative and, if so, you can engage him or her in this separate capacity to establish a brokerage account and implement transactions. When providing financial planning and financial planning consultation services, your Advisory Representative gathers information through interviews concerning your current financial status, goals and objectives, risk tolerance and time horizon. We may also request that you complete a questionnaire and provide additional documentation. Depending on the level of services requested, your Advisory Representative can prepare a written report. Implementing any recommendation can require you to work closely with your attorney, accountant and/or insurance agent. Implementation is entirely at your discretion. Your Advisory Representative can also provide advice on non- securities matters. Generally, this is in connection with rendering estate planning, college planning and insurance and/or annuity advice. Financial planning and consulting services are provided pursuant to a separate agreement for a fee agreed upon in that agreement. RETIREMENT PLAN CONSULTING SERVICES The Firm offers retirement consulting services to employee benefit plans (collectively, “Plans”) and their fiduciaries. The services are designed to assist the plan sponsor (the “Company”) in meeting its management and fiduciary obligations to the Plan under the Employee Retirement Income Security Act (“ERISA”). Retirement consulting services are provided pursuant to a retirement plan consulting services agreement, and will consist of general or specific advice, that includes services other than investment advisory services. Retirement plan consulting services include one or more of the following: 1. Plan Set Up: Your Advisory Representative will assist you with the initial set up of a new Plan on a record-keeping platform. 2. Plan Conversion: Your Advisory Representative will assist you with converting a Plan from an existing record-keeping platform to a new record-keeping platform. 3. Recommend and monitor investment options: Your Advisory Representative will assist you by periodically reviewing (at least annually) the investment options of the Plan’s investment menu and, when warranted, recommend possible change in investment option(s). 4. Plan Performance Review: Your Advisory Representative will assist you by conducting a periodic review (at least annually) to assist you with determining whether the terms of the Plan and the design are meeting your needs and those of the Plan’s participants. 5. Benchmarking of the platform, fees and services: Your Advisory Representative will assist you by periodically reviewing and benchmarking the Plan’s fees, services and investments. 6. Plan Compliance Review: Your Advisory Representative will conduct a periodic review (at least annually) of specific Plan items as determined by the Plan and advise the Plan whether it is operating in accordance with Plan documents and applicable provisions of ERISA as it relates to the specific items. 7. Participant Education Services: Your Advisory Representative will coordinate and/or conduct periodic investment, enrollment and/or retirement education meetings for Plan participants as determined by the Plan. 8. Self-Directed Brokerage Account (“SDBA”) Education: Your Advisory Representative will, to the extent directed by the Responsible Plan Fiduciary, conduct periodic employee investment education meetings with respect to implementing trades through the SDBA. There is opportunity for the Company to engage us to provide a review of executive benefits, for separate compensation. We will determine with the Company in advance the scope of services to be performed and the fees for all requested services. Prior to engaging us to provide consulting services, the Company will be required to enter into a written agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the relevant fees and fee-paying arrangements. The services outlined above that we provide are explained in more detail in the written agreement. We will also provide additional disclosures about our services and fees, where required by ERISA. When we perform the agreed upon services, we will not be required to verify the accuracy or consistency of any information received from the Company. We will serve in a non-discretionary ERISA fiduciary capacity with respect to some but not all of the services that we provide which will be further explained in the written agreement we sign with the Company. The Company is always free to seek independent advice about the appropriateness of any recommendations made by us. The agreement we sign with the Company includes the disclosures required of Advisory Representative under Section 408(b)(2) of ERISA, in particular, (i) the services to be provided by Advisory Representative, (ii) the extent to which Advisory Representative is acting as a fiduciary, (iii) the compensation to be received by Advisory Representative, and the manner of receipt of that compensation, and (iv) any fees payable on termination of the agreement. Advisory Representative receives no indirect compensation in respect of the services provided pursuant to the agreement. We retain a portion of the compensation described in the agreement for our services in connection with the agreement, the amount of which varies with our arrangement with each Advisory Representative. Pursuant to the agreement, Advisory Representative neither provides recordkeeping services nor makes available any designated investment alternative for the plan nor advises any investment contract, fund or entity in which the plan has a direct equity investment, and no disclosures under Section 408(b)(2) are thus required to be provided in respect of those matters. Our Fiduciary Acknowledgement When the Firm and your financial professional provide “investment advice” within the meaning of Title 1 of the Employee Retirement Income Security Act and/or the Internal Revenue Code (“Retirement Laws”) to you regarding your retirement plan account or individual retirement account (“Retirement Account(s)”), we are fiduciaries under the Retirement Laws with respect to such investment advice. The way we make money creates certain conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under these requirements, when providing certain investment recommendations, we must:
• Meet a professional standard of care (give prudent advice);
• Not put our financial interests ahead of yours;
• Avoid misleading statements about our conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than what is reasonable for our services; and
• Give you basic information about our conflicts of interest. Rollovers and Transfers from an Employer Sponsored Plan We may provide (1) general information and education to you about the factors to consider when deciding whether to move retirement assets to the Firm, or (2) a recommendation that you roll or transfer assets out of an employer sponsored plan to the Firm. If we provide you with a recommendation to roll assets out of an employer plan, you understand and agree that our analysis of the costs and services of your retirement plan, as compared to the costs and services the Firm provides, depends on the information you provide to us (or in certain circumstances, information we obtain from third parties about the plan (or similar types of plans)). You are responsible for updating us promptly if your investment objectives, risk tolerance, and financial circumstances change. Transfer of Individual Retirement Account (“IRA”) to IRA If your financial professional makes a recommendation that you move assets from an IRA at another financial institution to the Firm, he or she is required to consider, based on the information you provide, whether you will be giving up certain investment-related benefits at the other financial institution, such as the effects of breakpoints or rights of accumulation, and has determined that the recommendation is in your best interest because (1) greater services and/or other benefits (including asset consolidation and holistic advice and planning) can be achieved with the Firm IRA; and (2) the costs associated with the Firm IRA are justified by these services and benefits. Limitations to our Acknowledgment of Fiduciary Status This acknowledgment of status under the Retirement Laws does not create or expand any “fiduciary” relationship, capacity or obligations of the Firm and your financial professional under any federal or state laws, other than the Retirement Laws. There are many communications and recommendations that are not considered to be fiduciary “investment advice” under the Retirement Laws (which are subject to change). For additional information please refer to our Fiduciary Acknowledgement available at www.arborpointadvisors.com/disclosures. Our Material Conflicts of Interest Our material conflicts of interest are described in this brochure. Investment advisory, financial planning, or retirement service recommendations as described above may pose a conflict between the interests of the Firm and the interests of clients. For example, a recommendation to engage the Firm for investment advisory services or to increase the level of investment assets with the Firm, including through rollovers or other transfers of retirement plan accounts or IRAs, would pose a conflict, as it would increase the advisory fees paid to the Firm. A conflict exists if your Advisory Representative is a SAI registered representative and you choose to buy product(s) through him or her in this separate capacity. In this separate capacity, he or she receives a commission on the product(s) sold in addition to the fees charged for financial planning and/or financial planning consultations. This means there is a financial incentive for your Advisory Representative to recommend investments to you in which you pay management fees and/or broker/dealer commissions if SAI, our broker/dealer affiliate, processes the transaction. You are under no obligation to act upon APA’s or your Advisory Representative’s recommendations, and you have sole discretion whether or not to implement any recommendations. If you elect to act on any of the recommendations, you are under no obligation to effect transactions through APA or SAI. You are not obligated to implement any recommendations made by the Firm or maintain an ongoing relationship with the Firm. If a client elects to act on any of the recommendations made by the Firm, the client is under no obligation to execute the transaction through the Firm. Certain of our Advisory Representatives, in addition to being investment adviser representatives of the Firm, may also be registered representatives of SAI. We encourage you to review the Securities America, Inc. Broker-Dealer Firm Brochure located at www.securitiesamerica.com/disclosures which describes the material conflicts of interest associated with those brokerage services. Advisory Services vs. Brokerage Services In most cases, the total compensation that our Firm receives for providing investment advisory services is more than it receives for providing brokerage services. Also, the advisory fees you would pay to us in an investment advisory account do not decrease even where the level of investment trading activity in your advisory account is low. Both our Firm and our individual Advisory Representatives typically make more money if you choose an advisory account over a brokerage account with the Firm. Thus, we have a financial incentive to encourage you to select an advisory account over a brokerage account with the Firm. Rollovers and Account Type Changes Regardless of the investments and services you select, the Firm will make more money if you roll over assets from a retirement plan or IRA for which we do not provide services, to a retirement plan or IRA for which we do provide services, whether the rollover is from (1) a plan to an IRA, (2) an IRA to an IRA, (3) a plan to another plan, or (4) an IRA to a plan (as those terms are described above). As noted above, Advisory Representatives are typically compensated in part based on the total advisory fee and commission revenues they generate for our Firm. Therefore, both our Firm and Advisory Representatives have financial incentives to recommend plan and/or IRA rollovers to plans and IRAs serviced by us. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. Some of Advisory Representatives are not licensed to provide brokerage services (i.e., through SAI or otherwise) at all. Thus, our Firm and such Advisory Representatives often have additional incentives to recommend that clients roll over or transfer (or otherwise convert) brokerage accounts held at other financial institutions (which may be IRAs, retirement plan accounts or otherwise types of brokerage accounts) to advisory accounts with our Firm. ALTERNATIVE INVESTMENTS AND CAIS The Firm has contracted with CAIS Capital, LLC and Capital Integration Systems LLC (collectively “CAIS”) and has granted Advisory Representatives access to the CAIS alternative investment platforms. CAIS and its affiliates conduct the initial and on-going due diligence (investment and operational) on private equity and hedge fund offerings available on their platform. The Firm relies on the due diligence provided by CAIS related to the offerings available on the platform. Only Firm-approved alternative investment are available on the CAIS platform. Our agreement with CAIS provides for a payment to us of up to 10 basis points (.10%) on the sale amount of alternative investment products sold through the CAIS platform to our clients. CAIS also pays a fee to attend our Firm’s conferences for our Advisory Representatives. Please note that with privately held alternatives valuations can lag a month or more and are received from the issuer’s or offerings’ third-party administrator. The fee billing calculation uses this data to calculate the Program Fee (as defined below in Item 5 Fees and Compensation). Please refer to Item 5 Fees and Compensation for additional information on fee calculation. LENDING SERVICES Securities Backed Line of Credit (SBLOC) / Non-Purpose Loans The Firm offers you SBLOCs offered through participating third-party banks. SBLOCs are loans whereby an investor borrows against the assets in his or her investment portfolio without having to liquidate these securities. These loans require monthly interest-only payments, and the loan remains outstanding until it is re-paid. SBLOCs are non- purpose loans, which means the loan proceeds can be used for purposes other than to purchase or trade securities. An SBLOC allows you the opportunity to avoid potential capital gains taxes because you don’t have to liquidate securities for access to funds. You might also be able to continue to receive the benefits of your holdings, like dividends, interest and appreciation. However, as with virtually every financial product, SBLOCs have risks and downsides. For instance, if the value of the securities you pledge as collateral decreases, you may need to come up with extra money fast, or your positions could be liquidated. Prior to establishing a SBLOC, you should carefully review the disclosure form provided by the Firm. Margin Loans The Firm can arrange for its clearing brokers/custodian for your account to loan you money against the value of certain stocks, bonds and mutual funds that are held in your account at that clearing broker. That borrowed money is called a margin loan and can be used to purchase additional securities. Margin loans are not available in retirement or custodial accounts. There’s no set repayment schedule with a margin loan—monthly interest charges accrue to the account, and the borrower has the option to repay the principal at their convenience, subject to margin calls as discussed below. Margin loans can be profitable when securities in an account increase in value and the increase in value exceeds the interest you pay on the margin loan. However, the magnifying effect works the other way as well. The marginable investments in the portfolio provide the collateral for the margin loan. While the value of that collateral fluctuates according to the market, the amount borrowed stays the same. If the value of the margined securities decline to the point where they no longer meet the minimum equity requirements for the margin loan, there will be a margin call. When this happens, the Firm or its clearing brokers/custodian for your account will ask that more cash or marginable securities be deposited into the account to meet the minimum equity requirement or they may sell securities in the account as needed. Please remember:
• Margin loans increase an account’s level of market risk;
• The clearing broker/custodian for your account may initiate the sale of any security in the account without contacting the account owner, to meet the margin call; and
• Account owners are not entitled to an extension of time on a margin call. Please refer to your margin agreement for additional details regarding your margin loan.