Description of Firm Integrated Advisors Network, LLC is an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act"). The Firm, located at 8117 Preston Road, Suite 300, Dallas, TX 75225, and organized as a Limited Liability Company in the state of Delaware in 2014, has been SEC-registered since May 11, 2015. Integrated’s Principal Owner is TX-HI, LLC. Jeffrey J. Groves, Co-Founder & Managing Partner, Linda M. Pix, Co- Founder & Chief Relationship Officer, and Michael A. Young, President & Managing Partner, are control person and undertake all of the Adviser's significant strategic and administrative decisions. (Please refer to each Owner's individual Form ADV Part 2B brochure supplement for additional details on their formal education and business background.) As used in this brochure, the words "we," "our," "us," or “the Firm” refer to Integrated Advisors Network, LLC ("Integrated," " or “the Adviser”) and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term Associated Persons (or "Associates") refers to Integrated’s Covered Persons and Supervised Personnel, the Officers, Employees, and individuals providing investment advice or advisory services on behalf of the firm. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Advisor Representatives (“Advisor Representatives”). Each advisory relationship at Integrated is managed by one or more Advisor Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Advisor Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Advisor Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Advisor Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Advisor Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Advisor Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. "Co-Branding" Disclosures Integrated offers services through its network of Advisor Representatives. Some Advisor Representatives have other business interests, as described in their Form ADV disclosure brochures, and may have established their own legal business entities to conduct their advisory practices (a "doing business as" or "DBA" firm), whose trade names and logos are used for marketing purposes and may appear on their brochures, marketing materials or client statements. Clients should understand that these businesses are the Advisor Representatives' legal entities and not of Integrated Advisors Network, LLC, the registered investment adviser with the SEC. Advisor Representatives are under the supervision of Integrated, and the investment advisory and financial planning services they offer through their separate and independent entities are provided through Integrated. Persons engaging in any “doing business as” firm’s services must know that each business is operated separately; business models and advisory services will vary among DBA entities, and the protections afforded when doing business with one legal entity may not necessarily exist if entering into a relationship with another. When engaging in the services of one DBA entity’s advisory practice, clients are not affected by the fees, practices, or activities of another. The services provided by one regulated entity will only be provided concerning that entity and are not for services provided by another. Further, the fees of one advisory practice group may be higher or lower than another. Integrated does not make any representation that any fees, products, services, or those of any referred third party are offered at the lowest available cost for similar services; clients may be able to obtain the same at a lower price from other providers. Integrated advisory clients should also be aware that any other business lines offered by DBA entity professionals, such as brokerage and insurance products and services, may be offered through unaffiliated or affiliated firms and are separate and distinct from the advisory services provided through Integrated. Other business lines offered are (1) unrelated to the client's relationship and agreements with Integrated, (2) not part of Integrated's advisory or management services, and (3) subject to separate contractual arrangements. Further, the protections afforded to a client under applicable investment advisory laws and regulations generally do not apply to those provided by any non-advisory contract. For specific details, clients and prospective clients are encouraged to carefully refer to each advisory group's disclosure brochures and ask their Advisor Representative questions about any item they may be unclear about or desire additional information. (See Item 10 - Other Financial Industry Activities & Affiliations for additional disclosures regarding Associate outside business activities.) As of the date of this Brochure, the following (co-branded/DBA) independent businesses and their registered investment professionals offer their advisory services through Integrated:
• Abundantia Capital Corporation
• All Source Investment Management
• Andersen Capital Management, LLC
• APEX Quantitative Group, LLC
• Archer Bay Capital
• Auctum Wealth Management. LLC
• B&B Strategic Management, LLC
• Burns - Blackburn Group
• Candid Financial
• Capital City Financial Partners
• Copper Crest Capital
• Echelon Investment Management
• Ely Prudent Portfolios, LLC
• Evoque Investments, Inc.
• Financial Foundations, Inc.
• JC Investment Management
• Lattice Wealth Management Group, Inc.
• Lienart Family Asset Management
• Long Course Capital, LLC
• Longview Investment Advisors
• MDK Private Wealth Management
• Menlo Oaks Capital Group
• Militello Wealth Management
• Miller Pacific Financial Advisors
• Mosaic Financial Solutions
• Nspire Wealth
• Open Network Financial Consulting
• Rama Financial, LLC
• ReDefine Wealth Management
• SF-IAN
• Sand Creek Investment Partners, Inc.
• Sawyer Capital Investment Advisors
• Select Wealth Advisers
• Shields Capital
• Sztrom Wealth Management, LLC
• Vineyard Asset Management, LLC
• Vineyard Global Advisors
• Vineyard Wealth Advisors
• Yorkshire Wealth Management
• Zimmerman Wealth Advisory Group, LLC Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s investment professionals emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers) services, a Wrap Fee Program and educational seminars and workshop services. Clients may choose from the following specific services:
• Investment Management & Supervisory Services, including: - ERISA - Retirement & Employee Benefit Plan Services - Managed Account Solutions (“MAS”) Program Services
• Financial Planning Services
• Hourly & Fixed Fee Consulting Services
• Educational Seminars & Workshops Services
• Wrap Fee Program Services Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Advisor Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, Integrated may recommend the services of other professionals for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as- needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Integrated is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities Integrated's advisory services depend on and rely upon the information received from clients. The adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Advisor Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation - Integrated will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify Integrated in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. Integrated reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Following is a summary description of the specific advisory services covered by this Brochure and the nature of the services. Please consult the applicable client Agreement and fee schedules for additional information regarding each service. Investment Management & Supervisory Services Investment management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Integrated will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Integrated does not maintain physical custody of client funds or securities other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission. Integrated primarily recommends that its clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Integrated will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client and Advisor Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, Integrated provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)), for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our financial interests ahead of yours when making recommendations (give loyal advice),
• avoid misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that we provide advice that is in your best interest,
• charge no more than is reasonable for our services, and
• give you basic information about conflicts of interest. Integrated benefits financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our Firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated. Integrated will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer.” IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Integrated, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: → leaving the funds in the employer's/former employer's plan, → moving the funds to a new employer's retirement plan, → cashing out and taking a taxable distribution from the plan, and → rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: - Employer retirement plans generally have a more limited investment menu than IRAs, and - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Consider plan fees - your current plan may have lower fees than Integrated's fees: - if you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA, and - you should understand the various products and services you might take advantage of at an IRA provider and the potential costs. 3. Integrated's strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plans assets that comprise the client's account. The plan fiduciaries will confirm the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge Integrated has no responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Advisor Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Integrated is not responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Integrated's Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access – after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Integrated will refer only those individuals or entities suitable for its MAS Program services. MAS Program advisers are subject to review by Integrated's standards for inclusion and subject to future change from time to time. Integrated Advisor Representatives act in a Promoter capacity when referring MAS Program clients for this service. Integrated's role is to verify that clients are appropriate to become MAS Program clients, determine if the potential referred client has assets to invest, confirm the client has a minimum understanding of financial investing, and aid in their understanding of the referred manager's services and advisory contract (the “MAS Program Services Agreement” or “Program Agreement”). Any additional solicitation information provided by Integrated to a referred investor will be prepared and supplied to Integrated for distribution by the referred third-party manager. These materials may include (1) written presentations or oral statements that do not purport to meet the objectives or needs of the specific investor, (2) statistical information containing no expressions of opinions as to the investment merits of particular securities, or (3) other general advisory services. Clients wishing to engage in this service will execute two (2) advisory account management agreements. Firstly, an Investment Management Agreement with Integrated and an additional but separate MAS Program Services Agreement with the referred manager. As such, the client, as detailed within each referred manager’s Program Agreement, will enter an investment advisory, management, or other investment-related arrangements with their selected referred manager. The client, who will sign an acknowledgment receipt, will receive copies of all material operative documentation and disclosures related to such arrangements detailing the nature of the relationship, compensation to Integrated and the TPM, and other general terms of the referred TPM’s Program. Integrated does not maintain the authority to accept any client on behalf of any referred TPM, and referred managers are not responsible for accepting any prospective investor (and possible future client) referred to them by Integrated. Each manager has the right to reject any referred client for any reason or no reason at all. In selecting a referred manager, the client is responsible for understanding the fee and Program Agreement they are executing with the TPM. Referred clients typically pay the TPM manager a fee between 0.10 and 2.95%, not including referral fees, which vary based on the executed Promoter agreement. Integrated’s referral payout is in addition to client fees. Integrated will receive revenue from any fees paid when acting in this capacity. Fees shared will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. Integrated and referred MAS Program managers are separate, non-affiliated entities. (See Item 5: Fees & Compensation for additional details on Integrated’s advisory fees for this service, Item 14: Client Referrals & Other Compensation for further information on Promoter relationships, and the independent third-party manager’s Program Agreement and separate Program prospectus and related disclosure documents for complete information on any fees charged by the independent third- party advisers providing this service.) Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. (See Item 16: Investment Discretion of the referred manager’s Form ADV 2A for additional information on this topic.) For all Programs, the client and their Advisor Representative will compile pertinent financial and demographic information to develop an investment program that strives to meet the client’s goals and objectives. Data will be compiled to complete the Program’s New Account Application and

Risk Tolerance Questionnaire, and the client will timely provide other supporting documents and financial information that may be reasonably requested. A MAS Investment Strategy Proposal or Investment Policy Statement (“IPS”) will be generated based on the information provided, summarizing recommended investment strategies and setting out objectives and restrictions in managing the client’s account. According to the TPM's Agreement, clients may impose reasonable investment restrictions on managing the assets in their accounts. (Note: For detailed information about Program information and the investment strategies employed in a Program account, please refer to the referred manager’s ADV 2, under Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss.) Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred-manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes but is not limited to:
• assessment assistance of the client’s investment needs and objectives,
• investment policy planning assistance,
• assistance in the development of an asset allocation strategy designed to meet the client’s objectives,
• recommendations on appropriate style allocations,
• identification of appropriate managers and investment vehicles appropriate for the client’s goals,
• evaluation of asset managers and investment vehicles meeting style and allocation criteria,
• engagement of selected asset managers and investment vehicles on behalf of the client,
• ongoing monitoring of individual asset manager’s performance and management for “approved” investment strategies,
• automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation,
• recommendations for account rebalancing, if necessary,
• online reporting of the client account’s performance and progress,
• fully integrated back-office support systems to Advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation, and
• access to third-party platforms and strategies through the EPS Platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and select from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - the SMA Program is an actively managed or index-ed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - this Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - for clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third-party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by selecting the specific, underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives, but the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategis UMA Program (“Strategist UMA”) - portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated receives compensation from third-party advisers, who we recommend that you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated can allocate assets among private funds, including funds of funds, managed by third parties. With respect to fund of funds, Integrated recommends funds on an alternative investment platform which manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents which each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Integrated does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Services Integrated offers broad-based personal financial planning services tailored to the client's needs and differentiated by the scope and depth of the areas to be addressed, analysis complexity, recommendations developed, deliverables created, and presentation. The scope of services is determined between the client and Advisor Representative. Financial planning services can take the form of one-on-one advice on investment matters or other guidance as contracted by the client and will range from comprehensive financial planning to consulting on a particular issue, including a focus on topics such as lifestyle objectives, retirement planning, planning for major purchases, long-term care needs, estate planning issues or other financial planning or consulting services needs as designated. A financial plan may include but is not limited to a net worth statement, cash flow statement, review of investment accounts - including reviewing asset allocation and providing repositioning recommendations, strategic tax planning, a review of retirement accounts and plans - including recommendations, insurance policy analysis and recommendations for changes, if necessary, one or more retirement scenarios, estate planning evaluation and recommendations, and education planning with funding guidance. Clients will execute a Financial Planning Agreement setting forth the terms and conditions of the engagement, including termination, describing the services' scope and the fixed or hourly fees due before Integrated commencing services. The final fee structure will be documented within the executed Agreement. Depending on the scope of the assignment and the complexity of the planning to be performed or advice to be given, financial planning services can take approximately one week to two months. Financial plans are based on the client's financial situation when the plan is presented and the financial information disclosed by the client to Integrated. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's case differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for review and acceptance. When a fee increase is necessary, the client must approve and agree to the scope change before any additional work is performed. In such cases, we will notify the client to obtain this approval. (See Item 5: Fees & Compensation for additional details.) As with all Integrated advisory services, the expectation is that the client will promptly notify the Adviser in writing of any material changes in assets, net worth, indebtedness, or planning objectives that the Adviser would not otherwise know. The client or their successor shall also promptly notify Integrated in writing of (a) the dissolution, termination, merger, or bankruptcy of the client if the client is other than a natural person and (b) the occurrence of any other event which might affect the validity of their Financial Planning Agreement or Integrated's authority thereunder. Financial planning engagements terminate upon delivery of the written plan. Additional reviews may be conducted upon request, and written updates to the financial plan may be provided in conjunction with the review. Updates to financial plans may be subject to our then-current hourly rate, which the client must approve in writing and before the update. Financial planning services may be the only service provided to the client. Executing a Financial Planning Agreement neither constitutes an agreement for nor requires that the client use or purchase investment advisory or other services offered by Integrated, or any insurance or other products or services offered by any advisory Associate as a result of any business activities in which they may participate outside their advisory activities with the Adviser. Neither Integrated nor the Advisor Representative will have discretionary investment authority when offering financial planning or consulting services. The services do not include implementing or monitoring the Advisor Representative's recommendations to the client. If the client receives a written financial plan, the plan will not include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, the client shall be responsible for obtaining them from one or more third parties. Integrated reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Clients should consult their Financial Planning Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Hourly & Fixed Fee Consulting Services Integrated provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Integrated may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's s recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Advisor Representative and placing any resulting transactions. After engagement completion, Integrated and the Advisor Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshops Services Integrated provides complimentary investment educational seminars and workshops services on various investment topics " as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Advisor Representatives will not provide personalized investment advice to attendees during such events. Integrated provides investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser or its Advisor Representatives an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received rather than client needs. Integrated mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Advisor Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in the Adviser's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Integrated will generally provide investment and portfolio asset allocation advice and management on the following investment types:
• equities (stocks),
• corporate debt securities,
• exchange-traded funds
• investment company securities - variable life insurance, variable annuities, and mutual funds shares (no- load/ low-load),
• warrants, and
• U.S. government securities. Although Integrated provides advice predominately on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated avoids market timing but will increase cash holdings when necessary. Although we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. We reserve the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost – typically, institutional share class. Integrated avoids market timing but will increase cash holdings when necessary. (Please note that an investment in money market funds is not insured or guaranteed by the FDIC or other government.) Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Integrated will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. In no event and regardless of the advisory service provided is the Adviser obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. If client-imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. Wrap Fee Program As part of its services, Integrated and certain of its independent investment professional DBA entities that offer their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program, a transaction fee rebate program that differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Generally, Integrated considers its Managed Account Solutions (“MAS”) Program services a Wrap Fee Program. Integrated receives a portion of the wrap fee for the services we provide. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement and describes the scope of services to be provided and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assets Under Management As of February 29, 2024, the Adviser's assets under management total is $4,214,775,861. The following represents client assets under management by account type: Account Type Assets Under Management Discretionary $ 3,275,044,397 Non-Discretionary $ 266,922,074 Total $4,214,775,861