Vanderbilt Advisory Services (hereafter “VAS”) is an SEC registered investment advisory firm operating under the umbrella company called, Vanderbilt Financial Group. VAS provides comprehensive investment services after a careful review of a client’s financial position and an analysis of their investment objectives. Strategic asset allocation decisions are used to make investments in individual equity securities, bonds, mutual funds, ETFs, and other securities. VAS is an investment adviser that consists of independent contractors who have affiliated with VAS as Advisor Representatives to offer the advisory programs described within this brochure. The Advisor Representatives each have their own businesses and offices which they conduct not only advisory business but also provide other financial services. Some of our Advisor Representatives operate under their own business name as a “dba”. Information regarding your Advisor Representative may be found in the Representative’s Part 2B (Brochure Supplement). Advisor Representatives may offer some or all of the advisory services and programs disclosed in this brochure. The education, experience and skills of the Advisor Representative vary, and the fees charged by the various Advisor Representatives are not directly tied to their education, experience, or skill. Therefore, you are advised, your selected Advisor Representative may charge you more or less for similar services than another Advisor Representative who may have more training, education, and experience in the financial services area. Please refer to the Brochure Supplement for more information regarding your Advisor Representative. You are advised the investment recommendations and advice offered by VAS and the Advisor Representative are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform VAS, or your Advisor Representative, promptly with respect to any changes in your financial situation, investment goals or investment objectives. Failure to notify VAS, or your Advisor Representative, of any such changes could result in investment recommendations not meeting your needs. As of 10/31/2023, VAS has approximately $1,103,544,071 of client assets under management of which $1,048,366,868 is discretionary and $55,177,203 is non-discretionary. Vanderbilt Advisory Services Programs VAS Managed Account Program VAS offers a discretionary or non-discretionary managed platform. In both instances, a portfolio is customized to the individual needs, investment objectives and risk profile of the client. Each client’s account is individually managed by an Advisory Representative (“Advisor”) of VAS. In the discretionary account, your VAS Advisor will manage the account and will make changes to the allocation as deemed appropriate. The Advisor will determine the securities to be purchased and sold in the account and will alter the securities holdings from time to time without prior consultation with you. VAS may actively trade securities and hold such positions for periods of 30 day or less or maintain positions for longer- or shorter-term periods. Discretionary authority will be granted by you via the execution of the Investment Advisory Agreement. If you elect to have your accounts managed on a non-discretionary basis, no changes will be made to the account investment positions without prior consultation with you and your expressed consent. Typically, managed portfolios may consist of equities, mutual funds, bonds, exchange traded funds (ETFs), and other securities as initially agreed to between you and the Advisor Representative. In both discretionary and non-discretionary accounts, the advisory services are tailored to your individual needs. You may impose restrictions and/or limitations on the investing in certain securities or types of securities. Dorsey Wright Tactical Solutions("DWT") Program The DWT Program provides an asset allocation service related to investments utilizing asset allocation models developed by Dorsey Wright and Associates. The services are customized for each Client to meet their personal investment goals and objectives by choosing among different types of investments to be placed into the account and allocation model guidelines with the assistance of the Advisor Representative. The DWT Program, through the Advisor Representative, will provide to Clients various monitoring, supervision, consolidated reporting, and periodic recommendation services. The DWT Program invests mainly in exchange traded funds (ETFs) however there may also be investments in equities. Financial Planning/Consulting Services If a client elects Financial Planning/Consulting Services, the client will have the choice of: Hourly Financial Planning/Consulting Annual Planning Services Financial Planning/Consulting may or may not be investment related. Typical services range from income tax/cash flow analysis, estate planning services, business valuation, buy-sell analysis, executive benefit analysis, government benefit analysis and more. Annual Planning Services which will include a financial analysis, any updates in the financial analysis as requested by the client, and consultation services upon the client's request during a one- year period. Third-Party Investment Advisors Separately Managed Accounts VAS has contracted with Third-Party Investment Advisors who provide sophisticated investment management and client relationship tools for advisory clients of VAS. The Advisor Representative may recommend the client allocate a portion of a client’s investment assets among unaffiliated independent third-party Investment Advisors / separately managed account platforms (“Independent Third-Party Advisor(s)”) in accordance with the client’s designated investment objectives according to the terms and conditions of a separate agreement between the client and the Independent Third-Party Advisor(s). In such situations, the Independent Third-Party Advisor(s) acting in a sub-advisor capacity shall have day-to-day responsibility for the active discretionary management of the allocated assets. The VAS Advisor Representative shall continue to render investment advisory services to the client relative to

the ongoing monitoring and review of account performance, client investment objectives, and the investment assets not allocated to the Third-Party Advisor. The Advisor Representative generally considers the following factors when recommending to allocate investment assets to Independent Third-Party Advisor(s): the client’s designated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The applicable advisory management fee charged by the Third-Party Advisor(s), any related platform fee, and the VAS Advisor Representative’s advisory fee will be reflected in the executed VAS Investment Advisory Agreement and/or the Third-Party Advisor’s Agreement executed by the client. Third-Party Advisor(s) may impose more restrictive account requirements and varying billing practices than VAS. In such instances, VAS may alter its corresponding account requirements and/or billing practices to accommodate those of the Third-Party Advisor(s). Betterment For Advisors Program Betterment for Advisors is a digital wealth management platform generally serving independent investment advisory firms, such as Vanderbilt Advisory Services (“Advisor” or “VAS”) and the VAS investment advisor representative (“IAR”). Betterment LLC (“Betterment”), a registered investment advisor, serves as sub-advisor to Vanderbilt Advisory Services clients (“Clients”). MTG LLC, dba Betterment Securities (“Betterment Securities”), a registered broker-dealer and member of FINRA and SIPC, serves as broker-dealer and custodian. Betterment and Betterment Securities are not a “Related Person” or “Affiliate” of Vanderbilt Advisory Services. TYPES OF SERVICES The services provided by Betterment include: ● Goal-Based Investment Management: Betterment’s goal-based investment platform allows IAR and Clients to identify multiple investment goals for each Client, each with specific portfolio allocations; ● Portfolio Construction Tools: Advisor, IAR and Advisor’s Clients have access to a set of Betterment constructed portfolio strategies, third-party model portfolio strategies, or, if applicable, Advisor constructed custom portfolio strategies (described below), each of which is comprised of low cost, index-tracking exchange-traded funds or mutual funds (the latter only for advisors/IARs who are approved to construct portfolios with Dimensional Fund Advisors mutual funds), and are able to customize the risk-level for each investment goal (collectively “traditional securities portfolios”); ● Automated Investment Management Services: Betterment’s algorithms automate back-office tasks such as trading, portfolio management, and account rebalancing; ● Website and Mobile Application: Betterment’s website and mobile application provide a platform for account access and monitoring and delivery of account documentation and notices; and
• Advisor Dashboard: Advisor/IARs have access to a dashboard for purposes of monitoring and managing Client accounts. Certain Advisors offer to their Clients through Betterment’s platform custom portfolio strategies (“Custom Portfolios”). If Advisor chooses to participate in this offering, Advisor may construct Custom Portfolios using Advisor's own investment methodologies, and Advisor’s Clients are able to use Betterment’s automated advice features, including automatic rebalancing, dividend reinvestment, tax loss harvesting, and asset location services. Advisor, and not Betterment, is responsible for managing any goal for which a Custom Portfolio is elected on the basis of a Client’s financial situation and investment objectives. Betterment will not evaluate whether any Custom Portfolio is suitable for any Client’s individual investment objectives, either at the time of election or on an ongoing basis. In addition, Advisor, and not Betterment, is responsible for disclosing to Advisor’s Clients any limitations to Betterment’s features caused by the election of a Custom Portfolio strategy. Betterment for Advisors offers several account types to Advisors and their Clients, such as taxable investing accounts, individual retirement accounts (IRAs), and cash management accounts (Cash Reserve). If Advisor’s Client also is employed by a company that utilizes Betterment’s 401(k) offering, Betterment at Work, Advisor may also manage Client’s Betterment 401(k) account if Client delegates investment management authority of their 401(k) to Advisor. Advisors can also view Clients’ Betterment checking account in their Advisor Dashboard, and Advisors can also view Clients’ health savings accounts (HSAs), if the Client has a Betterment HSA through their employer. TAILORED SERVICES AND INVESTMENT RESTRICTIONS To use Betterment for Advisors’ services, Clients and/or their Advisors must inform Betterment of their financial situation and preferences through Betterment’s online application. To set up an investing account through the Betterment platform, Advisors and/or their Clients must select an investment goal, select a portfolio strategy (or follow the Advisor’s pre-set default portfolio strategy), and set an allocation (the risk level of the portfolio which corresponds to a ratio of stock to bonds), and may provide additional details about the Client’s investment objectives within Betterment’s interface. Guidance provided by Betterment is available in the online application, but Advisors are ultimately responsible for ensuring that Advisor’s Clients are placed in suitable investments. Advisors are also responsible for ensuring that the information they provide to Betterment about their Clients is accurate and up-to-date. Advisors can also restrict the securities purchased for Client accounts by electing Betterment’s Flexible portfolio strategy or Advisor’s Custom Portfolio strategy to choose their own asset classes and adjust allocation weights. Clients and/or their Advisors can influence Betterment’s discretionary management of their account by turning on or off several of Betterment automated portfolio management features. WRAP PROGRAM Betterment for Advisors offers its investment sub-advisory services for traditional securities portfolios through a wrap fee program that includes custody and trading services provided by its affiliate, Betterment Securities.