Principal Advised Services is a member company of Principal Financial Group® a diverse family of financial services companies offering businesses, individuals and institutional customers a wide range of financial products and services, including retirement, insurance, and asset management. Principal Advised Services was formed in 2017. Its principal place of business is in Des Moines, Iowa. Principal Advised Services is a subsidiary of Principal Financial Group, Inc. (NASDAQ: PFG), through intermediate holding companies. Description of Services Offered Principal Advised Services offers discretionary investment advisory services through the Principal® SimpleInvest Wrap Fee Program (“Program”). This Brochure is meant to help understand the Program and customers ("Customer," "you," or "your") should review it carefully. The primary focus of the Program is to provide Customers with discretionary investment advisory services implemented with the assistance of proprietary algorithms. Principal Advised Services uses the services of its affiliates in several capacities in offering the Program. The trading engine used in the Program and all the model portfolios available through the Program are provided by affiliates of Principal Advised Services. In addition, generally the underlying investment products offered through the Program, except for an FDIC-insured deposit bank account, are proprietary investment products managed by affiliates of Principal Advised Services. As a discretionary adviser, Principal Advised Services has the authority to modify, in its sole discretion and without prior notice to Customers, the selection of investment products that comprise each of the portfolios and the relative weighting of investment options and allocation to cash within the model portfolios. A Customer may independently determine whether the Program is appropriate for their use, or our investment adviser representatives (“IARs”) may assist Customers by conducting interviews to determine their financial needs and objectives. Please see the Principal Advised Services Advice Form ADV Part 2A Brochure for information regarding the non-discretionary investment advice provided. To begin receiving services through the Program, a Customer must complete the digital account opening process, enter into an investment advisory agreement with Principal Advised Services (“Advisory Agreement”) and other related agreements governing the Customer’s account in the Program (“Customer Account”), invest a minimum of $5,000 total in one or more Customer Accounts, and maintain a balance of at least $1,000 in each Customer Account. Initial and subsequent deposits will generally not be invested for up to five business days to allow for settlement of funds. Participation in the Program also requires Customers to consent to electronic delivery of communications. Customers may inquire about the services offered through the Program and obtain information about the management of their Customer Account at any time by contacting Principal Advised Services through one of its representatives over the phone, email or online chat. The discretionary investment management services offered through the Program are goal-based investing driven by either a risk-based or time-based asset allocation. The risk-based allocations are driven by the Customer’s risk tolerance, which is determined based on a risk tolerance questionnaire (“RTQ”). The time-based asset allocations are driven by the Customer’s identified goal retirement age, which a Customer chooses when accessing the service. Each Customer Account can only have one goal-based investment portfolio, either a risk-based allocation or a time-based allocation. There cannot be multiple allocations for the same account. The risk-based investment portfolios that Principal Advised Services offers are based on Customer responses to an RTQ. The Program’s five risk-based model portfolios (Conservative, Moderately Conservative, Balanced, Moderately Aggressive, and Aggressive) have asset allocations aligned to risk tolerances. The risk component remains consistent over time and the algorithm will automatically adjust the weighting of the holdings to the target portfolio asset allocation. The time-based investment goals that Principal Advised Services currently provides are “save for retirement” and “use my retirement savings.” The Program allocates your investments based upon your target retirement year, financial goals and the risk preference you select. If you choose the “save for retirement” goal, you will have access to investment portfolios focused on accumulation of assets. If you choose the “use my retirement savings” goal, you will have access to investment portfolios focused on investment of assets during your retirement. After the retirement age set by the Customer in the “save for retirement” goal is met, we automatically transition the Customer Account to a more conservative asset allocation through the “use my retirement savings” goal. Upon enrollment in the Program, your account will be invested in portfolios developed by Principal Global Investors, LLC d/b/a Principal Asset Management (“Principal Asset Management”), a registered investment adviser and affiliate of Principal Advised Services. The specific portfolio that Principal Advised Services recommends to a Customer is based on information that the Customer provides through the Program website (“Customer Inputs”), including, but not limited to: the Customer's current age, proposed retirement age (“goal age”), and risk score, which is determined by the Customer’s answers to risk tolerance questions. The recommended portfolio represents a mixture of asset classes designed to help the Customer achieve their investment goals. Risk-Based Model Portfolios: Each risk-based model portfolio offered through the Program will adhere to the applicable risk tolerance asset allocation assigned. Each Customer Account will be reviewed on an ongoing basis with the assistance of proprietary algorithms during days in which the underlying investments trade and rebalanced as needed to minimize portfolio drift. Portfolio drift refers to circumstances where the allocation of the portfolio moves out of the target range due to various factors, including market volatility, account contributions and withdrawals. Time-Based Model Portfolios: Each time-based model portfolio offered through the Program follows a “glide path” that will cause a Customer’s investment allocation gradually to become more conservative as a Customer with a “save for retirement” goal gets closer to their goal age, or as a Customer with a “use my retirement savings” goal gets further into retirement. The Customer’s risk score will adjust the risk level of their model portfolio up or down (more or less risky) relative to the “glide path” associated with their selected portfolio. After the model portfolio has glided for a pre-determined number of years relative to a Customer’s goal date, the investment allocation will reach its most conservative allocation and remain static. Each Customer Account will be reviewed on an ongoing basis with the assistance of proprietary algorithms during days in which the underlying investments trade and rebalanced as needed to maintain the glide path for the portfolio and to minimize portfolio drift. Portfolio drift refers to circumstances where the allocation of the portfolio moves out of the target range due to various factors, including the Customer aging and glide path progression, market volatility, account contributions and withdrawals. As part of the Program, Principal Advised Services will make general financial material, including budgeting, planning, general savings tips, and similar educational materials available to Customers. In addition, Customers have access to an optional financial wellness tool (“My Hub”), allowing them to view account information for accounts held both at Principal and with unaffiliated third parties. This enables the Customer to see an overall, aggregated view of their financial situation. Principal Advised Services offers My Hub through an arrangement with an unaffiliated service provider. To utilize My Hub, Customers must first agree to the My Hub Terms and Conditions of Use. There is no additional fee for My Hub. Customers must log into My Hub periodically to keep the aggregated account information current. While Customers may receive guidance on a broad range of subjects, IARs do not monitor accounts in My Hub with an aggregated view or provide guidance related to those accounts held outside of Principal. Only Customer Accounts held with the Program will receive ongoing discretionary portfolio management from Principal Advised Services. Additionally, Principal Advised Services does not take account information in My Hub into consideration in managing Customer Accounts. Principal Advised Services does not verify the valuations, accuracy, or completeness of information for accounts held with unaffiliated third parties in the aggregated view. Only as it relates to My Hub, by electing to use this tool and as further explained in the My Hub Terms and Conditions of Use, you agree that Principal Advised Services and our service provider can also use, sell, license, reproduce, distribute and disclose aggregated information that is derived through your use of My Hub. Any aggregated information that is used will not include personally identifiable information. Principal Advised Services does not currently offer comprehensive financial planning services. Portfolio Construction A critical part of the Program’s time-based portfolio construction methodology is the range of differences between Customers’ ages and their selected goal retirement ages. Because the retirement goals available in the Program are tied to retirement savings, the time-based model portfolios available in the Program are designed to help Customers address a number of risks associated with saving for retirement, including shortfall, longevity, capital and inflation risks. Shortfall risk is the risk of an individual not having enough savings to last throughout retirement. Longevity risk is the risk of an individual outliving their savings, either because they live longer than planned or have a savings shortfall. Capital risk is the risk that an individual will abandon their investment choice because of a negative investment experience. Inflation risk is the risk that an individual will not have sufficient savings in retirement to purchase as much in the future because of the increase in cost of goods and services over time. Customers should understand that because these risks are taken into account during portfolio construction, there often will be a variance between the risk level of a Customer’s portfolio and their risk score. Specifically, time-based model portfolios available in the Program will be weighted—in some cases significantly—to comparatively riskier investments (e.g., equity funds over fixed income funds), despite a Customer’s conservative risk score to account for these risks and the operation of the glide path. This is particularly the case when there is a larger difference between a Customer’s current age and their goal retirement age. In reviewing assets for portfolio construction, Principal Advised Services evaluates historical returns across a variety of asset classes and uses the expected volatility of returns on these asset classes to anchor the risk of a portfolio. Principal Advised Services analyzes the historical performance and risk attributes of a strategy to both understand the consistency of the strategy as well as evaluate the return profile and expected volatility (risk) of future returns. Principal Advised Services then translates the asset classes and target exposures for the asset classes through a selection of mutual funds and exchange-traded funds (“ETFs”) to build a portfolio. While Principal Advised Services attempts to maintain broad based diversification based on its assessment of historical returns and correlation, past performance does not guarantee of future results. Additionally, in periods of significant market volatility diversification may not help reduce exposure to market loss. Principal Advised Services reviews the performance and risk profile of the underlying investments on an ongoing basis and uses its discretion to add or modify investments within the portfolio as appropriate. Principal Advised Services also intends for the portfolios to include a minimal allocation to cash to facilitate payment of the account management fee. The cash currently is held by the Program Custodian, Apex Clearing Corporation (“Apex”) in an FDIC-insured deposit bank account selected by Apex. Principal Advised Services has the authority to remove or change the use of the Apex bank deposit account at any time. The cash in the Apex bank deposit account may earn you interest. Customers should review the Apex FDIC- Insured Sweep Program Disclosure Document for important terms and conditions of the Apex bank deposit account, available on the Apex website or upon request from us. Customer Information The Program uses an algorithm that recommends a portfolio to you and provides ongoing discretionary investment management from Customer Inputs. The Customer Inputs include answers to questions designed to assess the Customer’s desire to take risk, which is determined by an algorithm that analyzes answers to the RTQ and calculates a risk score. For risk-based model portfolios, this risk score is used as the basis for an investment portfolio recommendation. For time-based model portfolios, this risk score is combined with the Customer’s investment time horizon and used by us as the basis for an investment portfolio recommendation. The recommended time-based portfolio is based primarily on age, then on savings goals and lastly, RTQ responses. Each portfolio is designed with an approach that focuses on an appropriate asset allocation. For time-based model portfolios, this approach, especially for longer-term savings needs, means that the portfolios may be significantly weighted to riskier investments (such as equity funds over fixed income funds) despite a Customer’s conservative risk score, depending on the difference between the Customer’s goal retirement age and current age. Customers are not bound by the recommended model portfolio and can select an alternative portfolio by adjusting their goal retirement age or by overriding their calculated risk score. Customers should understand that their selection of a portfolio other than the portfolio that Principal Advised Services recommends may not be suitable based on their risk score or investment time horizon. Such selected portfolios may perform worse over any time period than the portfolio recommended by Principal Advised Services based on the information initially provided by the Customer. Principal Advised Services’ recommendations and the investment advice offered through the Program is limited based on the information Customers provide through the website or that the Customer modifies with the assistance of our IARs. Customers should take into account the limited nature of the Program in evaluating the investment advice and recommendations provided through the Program. Principal Advised Services does not verify the completeness or accuracy of information provided by Customers. Inaccurate or incomplete information provided by Customers will affect the investment recommendations and advice provided through the Program. While Principal Advised Services may collect additional information about your financial background or outside assets, Principal Advised Services will only provide asset allocation and investment advice on assets held within the Program. Principal Advised Services’ recommendations and investment advice does not consider any outside assets, concentrated positions, debt or other accounts that a Customer may have with Principal Advised Services’ affiliates or with any third party. Customer Restrictions You may request reasonable restrictions on the management of your Customer Account by designating specific ETFs or mutual funds that should not be purchased for your Customer Account or directing your Customer Account to be out of allocation, for example, a large cash holding for an upcoming purchase. Requested restrictions are subject to the review and approval of Principal Advised Services. Principal Advised Services may reject a requested investment restriction if it deems the request unreasonable, including because the request is clearly inconsistent with the Program’s investment strategy or philosophy or the Customer's stated investment objective, or is fundamentally inconsistent with the nature or operation of the Program. Customers may not impose restrictions on the underlying investments of any mutual fund or ETF available through the Program. Principal Advised Services will continue to manage accounts that are subject to reasonable restrictions in accordance with the terms of the Program, but Customer Accounts with restrictions will produce different performance results as compared to a Customer Account without restrictions using the same underlying investment portfolio, and ultimately, Customer Accounts with restrictions may have a lower return. Depending on the nature of the reasonable restriction it is possible that Customer Accounts with restrictions will trade after and will as a result receive better or worse pricing than, unrestricted Customer Accounts invested in accordance with the same portfolio. Customers should discuss the impact of reasonable restrictions on the management of their Account with an IAR of Principal Advised Services prior to imposing reasonable restrictions. Updates to Customer Information It is the Customer’s responsibility to promptly update their Customer Account online or by contacting Principal Advised Services if there is a change to their risk tolerance, financial situation or investment objectives that could affect the advisory services Principal Advised Services provides under the Program, or if a Customer would like to impose or modify a reasonable restriction. Principal Advised Services will periodically, typically quarterly, prompt its Customers through electronic statements to notify us if there have been any changes in their financial situation or investment objectives or if the Customer wishes to impose or modify reasonable investment restrictions on their Customer Account. Additionally, Principal Advised Services will contact Customers on at least an annual basis via automated message, email, or phone to request that Customers review, update or confirm that that their responses to the RTQ and account information remain accurate. Investment Services Principal Advised Services has engaged Principal Asset Management to develop model investment portfolios for the Program that are designed to allocate assets among mutual funds and ETFs representing different asset classes, with a minimal allocation to cash. Principal Asset Management has developed the model portfolios to pursue specific investment objectives, time horizons, savings goals and risk tolerances associated with different possible Customer profiles. These investment models are generally comprised exclusively of mutual funds and ETFs managed by affiliates of Principal Advised Services, with a minimal allocation to cash held in a nonaffiliated bank deposit account. Principal Asset Management provides ongoing services to us by assisting in the review of the models, asset class weightings, portfolios’ glide paths and investment options underlying the portfolios. Principal Asset Management is not responsible for implementing the models for any Customer Account or rendering any investment advice to Customers. Principal Advised Services’ Investment Committee considers the recommendations made by Principal Asset Management and is responsible for reviewing, approving, adjusting as desired, and implementing any recommendations of Principal Asset Management related to the composition of the model investment portfolios offered through the Program and the specific mutual funds and ETFs used in the models. Mutual Funds and Exchange-Traded Funds Principal Advised Services determines the universe of mutual funds and ETFs that are made available to Customers through the Program. The Program offers portfolios comprised of mutual funds and ETFs only of affiliates of Principal Advised Services. We intentionally have a minimal allocation to cash, held in an unaffiliated FDIC-insured bank deposit account for Customers of the Program. Although mutual fund companies typically offer multiple share classes of each mutual fund with varying levels of fees and expenses, we generally choose a single share class of each mutual fund available through the Program. These are generally Institutional share classes (“I-shares”), which typically have a lower expense ratio in comparison to retail share classes. An expense ratio is the annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for fund expenses, including management fees, administrative fees, operating costs, and all other fees and expenses incurred by the fund. This expense ratio is prorated and deducted from the investments in your accounts on an ongoing basis. You will bear a proportionate share of each fund’s expenses, including investment management fees, distribution, administration, transfer agency, shareholder services and other fees paid to our affiliates. The compensation received by our affiliates as fund expenses varies among funds and share classes utilized within the Program. Please refer to the “Material Relationships with Related Persons and Potential Conflicts of Interest” section of this Brochure for more information about the conflicts of interest associated with the selection of particular funds and share classes. We seek to address these conflicts of interest through a combination of disclosing them to you, our policies and procedures and related controls designed to review whether the fees we charge are fair and reasonable, and our program fee approach, as explained below. If Principal Advised Services’ affiliates did not receive compensation from the underlying funds in the Program, Principal Advised Services might charge higher fees or other amounts to you for the services we provide. Despite this conflict, however, Principal Advised Services’ selection of funds and share classes does not affect the overall fee (described below) that you pay for the Program. Principal Advised Services has

the ability to use and offer mutual funds with multiple share classes, including but not limited to shares designated as I-shares and comparable share classes. Generally, I-shares and comparable shares are for institutional and other investors and therefore are not always available for a retail advisory account. For certain mutual funds and ETFs, I-shares or comparable shares may not be available for investment for certain Program accounts because (i) I-shares and/or comparable shares are not available for a specific mutual fund family, or (ii) certain mutual funds restrict access to I-shares and comparable shares. In addition, there may be other limitations on the use of I-shares or other share classes with lower expense ratios. Those share classes may have specific eligibility requirements described in the mutual fund's or ETF's prospectus or the statement of additional information. Such eligibility requirements could include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts that the fund considers qualified fee-based programs. Other funds and share classes have different fees and expenses that are lower than the fees and expenses of the funds and share classes we make available through the Program. Customers should not assume that they are invested in the lowest available share class. An investor who holds a less-expensive share class of a fund will pay lower fees over time – and earn higher investment returns – than an investor who holds a more expensive share class of the same fund. It is the policy of Principal Advised Services to assess the fees and expenses Customers will incur in connection with the formulation of Principal Advised Services’ recommendations and the management of Customer Accounts on an ongoing basis. This includes an assessment of the available share classes. Over time, certain funds may offer share classes with lower fees. In these instances, we will determine, from time to time in our discretion, whether and in what manner to offer these share classes to our Customers. This may result in shares you own being bought and sold or converted to a share class with lower fees or such lower fee share classes being available only for new purchases. Additionally, there will be a period of time when a new share class becomes available that the Customer will remain in the more expensive share class until we are able to take the administrative and operational steps necessary to make the new share class available through the Program and adequately test them in accordance with the algorithm and implementation process. Fractional Share Trading Principal Advised Services may elect to trade fractional shares of ETFs within your account. The ETF shares purchased or sold on behalf of Customers may be either whole shares or fractional shares, depending upon the asset allocation selected for that Customer Account. Principal Advised Services invests Customer Accounts in dollar-based quantities, whereby transactions are based on a fixed dollar amount rather than whole shares. Customers who hold fractional shares in their Customer Account will receive proxy materials showing the number of fractional votes that they are eligible to vote. Principal Advised Services and Apex each reserve the right, at any time and each in its sole discretion, without prior notice to Customers, to limit or stop trading fractional shares. Fractional shares are typically unrecognized and illiquid outside of a Customer Account. Therefore, Customers cannot transfer fractional shares when closing their Customer Account. Fractional shares will be converted to cash upon account closing. Trading Services Principal Advised Services has retained Principal Asset Management, a registered investment adviser and an affiliate of Principal Advised Services, to act as a sub-adviser for the Program and provide trading, rebalancing, and associated services. Principal Asset Management has limited discretionary authority over trading, which includes intelligent rebalancing and target asset allocation services for Customer Accounts. These services, some of which are provided using algorithms managed by Principal Asset Management, are further described below. Principal Advised Services’ Investment Committee oversees the services it receives from Principal Asset Management, including approving the parameters that trigger rebalancing and trading. 1. Trading: Principal Asset Management places orders for buying, selling, exchanging, holding, and/or converting the mutual funds and ETFs in Customer Accounts based on instructions provided by Principal Advised Services. 2. Target Asset Allocation: Principal Asset Management’s algorithm uses the Customer Inputs to determine the target portfolio on any given date, including fractional shares when appropriate. 3. Intelligent Rebalancing: Principal Asset Management’s algorithm considers trading costs and rebalancing costs when rebalancing a portfolio. Rebalancing seeks to keep a Customer’s assets invested consistently in line with the Customer’s target asset allocation, so rebalancing will occur if the allocation among mutual funds, ETFs, and cash deviates by more than a specified threshold from the target asset allocation. Rebalancing transactions can occur frequently and potentially daily under a variety of market conditions. This means that rebalancing could occur in both significantly declining and appreciating market conditions, when securities prices may be significantly lower or higher, respectively. Principal Asset Management has implemented rules to limit rebalancing activity during periods of high trading costs, which can occur during periods of market-wide or specific security volatility, including events such as market circuit-breaker points being applied by the exchange. Circuit breakers are thresholds wherein trading is halted market-wide for any single-day dramatic drops in an underlying index. Principal Asset Management implements the target asset allocation and directs trading through an algorithm to align the Customer Account with the target asset allocation, subject to Principal Advised Services’ direction. Although not required, Principal Advised Services generally aggregates multiple Customer orders in the same securities to obtain the most favorable price and/or lower execution costs at the time trading occurs. When an order requires more than one execution, participating accounts will receive the average price for transaction in their particular block order. Principal Asset Management’s trading process is designed to give fair and equitable treatment to Principal Advised Services relative to its other similarly situated customers, its own accounts, and the accounts of affiliates or any of their directors, officers, agents or employees. Depending on the circumstances, Principal Asset Management may recommend changes or execute transactions for its other customer accounts before directing trading for Customers of Principal Advised Services. Principal Asset Management, in its sole discretion, may not be able to direct trades or otherwise take certain actions for Customers due to (i) regulatory requirements; (ii) Principal Asset Management’s internal policies and procedures; (iii) actual or potential conflicts of interest or the appearance of such conflicts; or (iv) any other reason in Principal Asset Management’s sole discretion. Trade Errors Trade errors and other operational mistakes occasionally occur in connection with the management of Customer Accounts. Errors can result from a variety of situations, including portfolio management (e.g., inadvertent violation of investment restrictions), trading, processing, or other functions (e.g., miscommunication of information, such as: incorrect number of shares, wrong price, wrong account, calling the transaction a buy rather than a sell and vice versa, etc.). All such errors affecting a Customer Account will be resolved promptly and appropriately upon discovery. Under certain circumstances, Principal Advised Services and Principal Asset Management may consider whether it is possible to adequately address an error through cancellation, correction, reallocation of losses and gains or other means. The intent is to restore a Customer Account to the appropriate financial position considering all relevant circumstances surrounding the error, generally by correcting any erroneous allocation to the Customer Account or reimbursing the Customer Account for any investment losses and costs resulting from the error. Principal Advised Services and Principal Asset Management make their determinations on a case-by-case basis, in their discretion, based on factors they consider reasonable. The policies and procedures governing the Program generally do not require perfect implementation of investment management decisions, trading, processing or other functions performed by Principal Advised Services or Principal Asset Management. Therefore, not all mistakes will be considered compensable to the Customer. Imperfections in the implementation of investment decisions, trade execution, cash movements, portfolio rebalancing, processing instructions or facilitation of securities settlement, issues relating to corporate actions for securities held in a Customer Account, or imperfection in the generation of cash or holdings reports resulting in trade decisions may not constitute compensable errors, depending on the facts and circumstances. For example, imperfections in the implementation of investment strategies, including quantitative strategies (e.g., coding errors), that do not result in material departures from the intent of Principal Advised Services will generally not be considered compensable errors. In addition, in offering the Program and managing Customer Accounts, Principal Advised Services may establish non-public, formal or informal internal targets, or other parameters that may be used to manage risk, manage affiliated service providers or otherwise guide decision-making, and a failure to adhere to such internal parameters will not be considered an error. Algorithm Management One of the primary benefits of a digital investment adviser is the automatic rules governing trading and other aspects of the advisory services. Therefore, Principal Advised Services does not plan to override the algorithms used in the Program as a routine business practice. However, Principal Advised Services or Principal Asset Management may override an algorithm in the event of instances where the algorithm is not performing as expected or an error is discovered in a file used by the algorithm. In addition, in volatile or stressed market conditions or market halts, in response to certain types of operational or technological errors, and under other circumstances that Principal Advised Services or Principal Asset Management determines may negatively affect Customer Accounts, Principal Advised Services or Principal Asset Management may override the algorithms, including electing to not trade during periods of market volatility. The Principal Advised Services Investment Committee oversees these procedures and may also choose to override an algorithm, including electing to not trade during periods of market volatility, until the circumstances that triggered the decision to override the algorithm are resolved. Customers may continue to request withdrawals from their Customer Accounts during times when Principal Advised Services or Principal Asset Management overrides an algorithm, and Principal Advised Services will seek to continue to process requests based on underlying market conditions, including declining markets. Customers should note, liquidating assets during a period of significant market volatility may be difficult and redeeming assets during a period of market volatility could result in significant losses within the account. Principal Advised Services will execute distribution requests and will seek to obtain the most favorable execution possible during these limited periods. Clearing and Custodial Services Clearing and custody services are provided by Apex, an unaffiliated broker-dealer offering clearing, custody, trade execution and related services. Customers must enter into a service agreement with Apex to participate in the Program. Under the terms of the Program and its related agreements, the Customer authorizes and directs Principal Advised Services to execute orders for all Customer portfolio transactions through Apex. Customers will bear the risk of such transactions. Customers should understand that Principal Advised Services will trade through Apex even if the use of a different broker-dealer may result in lower prices or more favorable execution. Online Nature of the Program To receive investment advisory services through the Program, prospective Customers will be required to complete an online account application and enter into the Advisory Agreement and other account agreements electronically through the Program website. These agreements along with other disclosures and notices will be delivered to Customers primarily in electronic format by posting the information on the Program website where Customers can access their Customer Accounts and through email or other electronic means. Principal Advised Services will not send paper versions of documents to Customers as part of the Program unless required by applicable law or in Principal Advised Services’ sole discretion. Customers must be willing to accept the terms of a global electronic consent, which will require that the Customer agrees to electronic delivery of all current and future Program documents and communications, to enroll in the Program. Customers must provide Principal Advised Services with a valid email address to enroll in the Program. Customers are required to notify Principal Advised Services immediately in the event their email address changes, or becomes inaccessible, by visiting the Program website or by contacting Principal Advised Services at 866-412-0770. Customers will be alerted by email when a new or amended agreement or document is available; therefore, it is important that Customers always maintain an accurate email address. If a Customer fails to provide or maintain accurate contact information through the Program website, including an email address, or otherwise revokes consent to electronic delivery, Principal Advised Services reserves the right to terminate that Customer’s participation in the Program. Please refer to the Customer Disclosure and Consent Regarding Conducting Business Electronically document, which is provided at account opening and accessible online thereafter, for additional terms and conditions regarding electronic delivery of Program communications. Fees and Compensation A Customer pays a level annualized fee equal to 0.85 percent of the Customer Account balance (the “program fee”), which represents the sum of two fees: (1) an investment advisory fee for Principal Advised Services’ advice and management of Customer Accounts (the “account management fee”), and (2) the underlying mutual fund and ETF management fees paid to our affiliates (the “investment expenses”). Investment expenses are inclusive of the investment management, distribution, administration, transfer agency, shareholder services and other fees charged by the affiliated mutual funds and ETFs held in the Customer Account. The program fee is not negotiable. However, any portion of the account management fee may be waived or discounted at the sole discretion of Principal Advised Services. Although the annualized program fee is always 0.85 percent, the investment expenses differ for each Customer Account based upon the particular fees and expenses associated with the affiliated mutual funds and ETFs held in the Customer Account, and the account management fee for each Customer Account varies because it is based on the difference between the overall program fee and the Customer’s investment expenses. Customers should understand that the account management fee varies among Customers in the Program depending upon the specific investment portfolio that they have selected. However, the total amount of compensation that Principal Advised Services and its affiliates receives from any Customer in connection with the Program is always 0.85 percent, or the program fee. The account management fee we debit from a Customer Account may vary from month to month as a result of changes to the investment composition and associated investment expenses of the Customer Account. We calculate the investment expenses by weighting the market value held in each mutual fund or ETF in a Customer Account by the total expense ratio published in the most recent prospectus for each mutual fund and ETF. Investment expenses are subject to change by the fund managers. Further information about investment expenses can be found in the prospectus provided for each mutual fund and ETF. The account management fee is less than the program fee. We calculate the account management fee daily as a prorated amount of a Customer Account’s daily closing balance. Monthly, Principal Advised Services will determine the total amount of investment expenses paid by each respective Customer Account, and an account management fee that reflects the difference between the monthly investment expenses and the program fee will be automatically debited. The account management fee is assessed monthly in arrears. We do not charge the account management fee in a month where the Customer Account is closed, and assets are distributed before that month’s end. Principal Advised Services retains the right to liquidate assets in a Customer Account if there are insufficient funds to pay the account management fee or other account maintenance fees. We receive more in fees when you invest more assets in your advisory account. That means we have an incentive to encourage you to increase the amount of assets in your account. Fees and costs will also reduce any amount of money you make from your investments over time. Please make sure you understand what fees and costs you are paying. Principal Advised Services compensates Principal Asset Management and Apex for its services to the account. Customers may incur additional fees from Apex as described below. Additionally, Principal Asset Management receives compensation from Customers for its investment management services to the affiliated mutual funds and ETFs within the portfolios through the investment expenses. Miscellaneous Fees The program fee does not account for miscellaneous fees charged by Apex. Please refer to the Apex Clearing Corporation Schedule of Miscellaneous Account Fees for Principal® SimpleInvest, which is provided at account opening and accessible online thereafter, for a complete list of these miscellaneous fees, including annual service fees, maintenance fees (e.g. a transfer, rollover, or termination fee) and other fees required by law. Apex automatically deducts these miscellaneous fees from your Customer Account. In certain circumstances disclosed in the Advisory Agreement, Principal Advised Services may charge Customers for special requests or other irregular services. Certain termination or transfer fees may be waived in a variety of circumstances, at PAS’s sole discretion. This may include termination and transfer fees if moving from the Program to an investment with an affiliate of Principal Advised Services. Relative Cost of the Program The program fee charged for the Program may cost the Customer more or less relative to similar services purchased separately or from other advisory firms. Customers should consider that, depending on the amount of activity in the Customer Account and the value of custodial, trade execution, advisory, and other services that are provided under the arrangement, the program fee may or may not exceed the aggregate cost of such services if they were to be provided separately. To compare the costs of the Program to purchasing the services separately or from other firms, a Customer should consider the trading activity within their Customer Account, the investment strategy, the relative cost of the strategy, the program fee and other additional fees applicable to Customer Accounts and weigh this against the brokerage commissions and/or advisory fees that would be charged by other investment advisers or by broker-dealers. Compensation for Persons Recommending the Program Principal Advised Services' IARs are available by phone or email to answer questions about the Program, the investment strategies, mutual funds, and ETFs available through the Program, and Customer Account performance. IARs that make a recommendation or assist you in enrolling in the Program or regarding your Customer Account do not receive any portion of the program fee as compensation nor are they compensated based on the model portfolio selected. However, the compensation payable to Principal Advised Services in connection with your participation in the Program may be more than what PAS would receive if you participated in programs or services available through other affiliates, or if you paid separately for investment advice, brokerage and other services. Therefore, Principal Advised Services may have an incentive to recommend the Program over other programs or services available from our affiliates. Call center staff are paid a salary, including benefits, and do not receive commissions. Call center staff are eligible to receive an annual and periodic bonuses based on individual and company performance. Factors considered in assessing the call center staff’s individual performance include goals for the retention of investor assets in Principal-affiliated products, call quality, adherence to policies and procedures, and other factors. Call center staff are also eligible for periodic awards based on progress towards asset retention goals. This compensation is considered a conflict of interest because call center staff have an incentive to retain assets in Principal- affiliated products to maximize annual bonus potential and the potential for periodic awards. To mitigate these conflicts of interest, compensation programs are reviewed to ensure they do not prevent call center staff from providing best interest recommendations. Additionally, transactions proposed by call center staff are reviewed and analyzed by supervision teams to ensure they are in your best interest.