Wealthspire Advisors LLC (“Wealthspire Advisors” or “Wealthspire”) is an SEC-registered investment adviser providing wealth management, investment advisory and financial consulting through its state-registered Investment Advisor Representatives (“Advisor Representatives”) to individuals, businesses, non-profit organizations and foundations. Our role is to listen, inform and advise. We take a well-rounded, relationship-driven approach to helping our clients develop customized solutions that address a full range of financial issues. Our investment strategy is focused on each client’s long- term goals and risk tolerance. Sontag Advisory LLC (“Sontag”) was founded in 1995 by Howard Sontag and has been wholly owned by NFP Corp. (previously known as National Financial Partners, Corp.) (“NFP”) since 2015, NFP was acquired by Aon plc on April 25, 2024. On May 1, 2019, Sontag acquired Bronfman E.L. Rothschild, L.P., an SEC-registered investment advisor (“Bronfman Rothschild”). Bronfman Rothschild was formed in May 2013 as the successor by conversion from Baker Tilly Investment Advisors, LLC, an investment adviser providing services since August 1997. Following the acquisition, Bronfman Rothschild became a subsidiary of Sontag. Beginning in October 2019, Bronfman Rothschild was renamed Wealthspire Advisors, LP. Wealthspire Advisors, L.P. and Sontag, both separate registered investment advisers and subsidiary companies of NFP, began doing business under the common brand and trade name of Wealthspire Advisors. Wealthspire Advisors, L.P. merged with and into Sontag as of December 31, 2020, and the surviving entity was renamed Wealthspire Advisors LLC. On November 13, 2020, Wealthspire acquired Strategic Wealth Management Group, LLC (“StratWealth”), a SEC-registered investment advisor and Maryland limited liability company formed on February 14, 2001. StratWealth became registered with the Securities and Exchange Commission on May 17, 2002. Following the acquisition, StratWealth became a subsidiary of Wealthspire Advisors LLC and began doing business as Wealthspire Advisors on January 11, 2021. StratWealth merged with and into Wealthspire as of September 30, 2021. On November 12, 2021, Wealthspire acquired Private Capital Group, LLC (“PCG”), a SEC-registered investment advisor and Connecticut limited liability company that has been providing investment advisory services as an SEC-registered investment adviser since 2003. Following the acquisition, PCG became a subsidiary of Wealthspire Advisors LLC and began doing business as Wealthspire Advisors on February 14, 2022. PCG merged with and into Wealthspire as of September 30, 2022. On December 31, 2021, Wealthspire acquired Private Ocean, LLC (“Private Ocean”), a SEC-registered investment advisor and California limited liability company that has been providing investment advisory services as an SEC-registered investment adviser since 1983 (as Salient Financial Corp.). Following the acquisition, Private Ocean became a subsidiary of Wealthspire Advisors LLC and began doing business as Wealthspire Advisors on May 23, 2022. Private Ocean intends to maintain a separate client brochure until such time as the operations of Wealthspire Advisors LLC and Private Ocean are sufficiently integrated to merit a combined client brochure. On January 24, 2022, Wealthspire announced that it will integrate Lenox Wealth Advisors, LLC (“LWA”), a SEC-registered investment advisor, New York limited liability company, and subsidiary of NFP that has been providing investment advisory services as an SEC-registered investment adviser since 2011. Following the announcement, LWA began doing business as Wealthspire Advisors on January 24, 2022. LWA merged with and into Wealthspire on June 30, 2022. On December 30, 2022, Wealthspire acquired Sage Financial Advisors, LLC (“Sage”), a SEC-registered investment advisor and Nevada limited liability company that commenced operations in January 1996. Following the acquisition, Sage became a subsidiary of Wealthspire Advisors LLC and began doing business as Wealthspire Advisors on April 24, 2023. Sage merged with and into Wealthspire as of August 31, 2023. On April 3, 2023, Wealthspire acquired Heron Financial Group, LLC (“Heron”), a SEC-registered investment advisor and New York limited liability company that has been providing investment advisory services as an SEC-registered investment adviser since 2008. Following the acquisition, Heron became a subsidiary of Wealthspire Advisors LLC and began doing business as Wealthspire Advisors on July 31, 2023. Heron merged with and into Wealthspire as of November 1, 2023. On July 17, 2023, Wealthspire acquired ACG Advisory Services, LLC dba ACG Wealth Management (“ACG”), a SEC-registered investment advisor and Delaware limited liability company that has been providing investment advisory services as an SEC-registered investment adviser since 1991. Following the acquisition, ACG became a subsidiary of Wealthspire Advisors LLC and began doing business as Wealthspire Advisors on October 30, 2023. ACG intends to maintain a separate client brochure until such time as the operations of Wealthspire Advisors LLC and ACG are sufficiently integrated to merit a combined client brochure. On November 1, 2023, Wealthspire acquired GM Advisory Group, LLC (“GMAG”), a SEC-registered investment advisor and Delaware limited liability company that has been providing investment advisory services as an SEC-registered investment adviser since 2004. Following the acquisition, GMAG became a subsidiary of Wealthspire Advisors LLC. GMAG intends to maintain a separate client brochure until such time as the operations of Wealthspire Advisors LLC and GMAG are sufficiently integrated to merit a combined client brochure. NFP also owns other registered investment advisers, broker-dealers, insurance agencies and other product and service providers. Wealthspire Advisors is under no obligation to sell any products or recommend any services to our clients as a result of NFP’s ownership. Mike LaMena is the firm’s Chief Executive Officer; Eric Sontag is the firm’s President and Chief Operating Officer; Hoyt Stastney is the firm’s General Counsel; Michael Moriarty is the firm’s Chief Investment Officer; Michael Del Priore is the firm’s Chief Compliance Officer; and Brian Powers is the firm’s Chief Financial Officer. Assets Under Management As of December 31, 2023, Wealthspire Advisors has the following regulatory assets under management: Clients Assets Discretionary 6799 $ 18,529,313,855 Non-discretionary 357 $ 343,065,458 Total 7156 $ 18,872,379,313 Services to Individual Clients Wealthspire Advisors offers a suite of wealth management services, which may include one or more of the following, depending on each client’s specific engagement: Investment Advisory  Evaluation of current portfolio  Assessment of investment objectives and financial goals  Asset allocation planning  Separate Account Manager research and selection  Investment program implementation and rebalancing  Portfolio monitoring and risk management  Performance measurement Financial Planning and Consulting  Portfolio monitoring and advice regarding assets not managed by Wealthspire Advisors  Insurance planning  Estate and wealth transfer planning  Retirement planning  Education planning  Philanthropic and charitable gift planning Comprehensive Reporting  Unique reporting service complementing standard statements provided by the account custodian  Customized periodic statements aggregating all invested (and sometimes fixed or illiquid) assets - even those not managed by Wealthspire Advisors  Portfolio performance, asset class returns, annual income and investment flows are consolidated on one easy-to-understand page Tax Reporting  Tax reporting service to assist our clients’ tax professionals  Firm provides annual “tax packages” to clients and/or their accountants  Tax packages include reports and summaries detailing: cost basis, fees, gain/loss, interest, dividends, distributions and charitable contributions, among other information Asset Allocation and Account Customization Advisory services begin with determining each client's financial circumstances and investment objectives and are followed by continuous investment management services to the client's investment account (“Account(s)”) based on the client's needs and objectives. Wealthspire Advisors tailors its services to the individual investment needs of its clients by determining each client’s investible assets, investment experience, specific goals, objectives, risk tolerance, time horizon, investment restrictions and other considerations (collectively, “Investment Information”) that might impact the client’s investment needs. Investment Information is generally gathered using a questionnaire followed by an interview process. To comply with applicable laws and internal procedures when opening new Accounts, Wealthspire Advisors may request proof of identification from a prospective client and may utilize third party agencies to verify the client's identity. Based on this determination of a client’s Investment Information, Wealthspire Advisors develops an investment policy for the Account and generally implements an investment program grounded on one of its various portfolio guidelines. As agreed with each client individually, this program may take into account the allocation of the client’s assets not placed under Wealthspire Advisors’ management (e.g. cash holdings, 401k balances, assets placed with other investment advisors/managers, limited partnerships, business interests, individual securities holdings, employee stock options, real estate, etc.). Generally, Wealthspire Advisors’ intention is to manage investments to provide the client with an overall asset allocation (including assets outside Wealthspire Advisors’ investment purview, if agreed) matching as closely as possible the client’s investment profile. Wealthspire Advisors has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Wealthspire Advisors will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s Investment Information. Based upon these factors, there may be extended periods of time when Wealthspire Advisors determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Wealthspire Advisors will be profitable or equal any specific performance level(s). Investment Selection - Separate Account Managers Wealthspire Advisors may recommend the allocation of a portion of a client’s investment assets among one or more unaffiliated independent investment managers (“Separate Account Manager”) in accordance with the client’s designated investment objectives. In such situations, the Separate Account Manager shall have day-to-day responsibility for the active discretionary management of the allocated assets. Wealthspire Advisors shall continue to render Investment Advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Wealthspire Advisors shall consider in recommending Separate Account Managers include the client’s designated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. Wealthspire Advisors maintains a disciplined research and due diligence process to identify Separate Account Managers suitable for client investment and also maintains ongoing annual due diligence and review over the recommended firms. Before a client establishes an account with a Separate Account Manager, the client shall also receive the Separate Account Manager’s written disclosure statement specifying its fees and services. Wealthspire Advisors maintains sub-advisory arrangements with most of the Separate Account Managers it recommends for client portfolios. This means that Wealthspire Advisors has authority to hire and/or fire the Separate Account Manager on behalf of its discretionary Clients and also results in some operational efficiencies regarding the opening and closing of accounts as well as communicating transaction details. Separate Account Managers charge their own advisory fees, which are typically deducted directly from the Client’s custodial account at customary billing intervals, separate from Wealthspire Advisor’s fee, and do not separately pay a referral fee to Wealthspire Advisors. The assets invested with a recommended Separate Account Manager are included with the client’s other assets managed directly by Wealthspire Advisors for the purpose of calculating and billing in accordance with the client’s fee schedule. Individual Managed Accounts include the following service and fee categories: Wealthspire Advisors Wealth Management, recommended for accounts with assets under management over $2,000,000, includes semi-annual or quarterly meetings with a service team which may consist of two or three Wealthspire Advisors employees. Wealthspire Advisors utilizes an "institutional" asset allocation model based on investing principals used by the largest endowments and foundations in the world. By utilizing the methodology used by institutional money managers, Wealthspire Advisors aims to achieve consistent returns with less volatility than traditional portfolios. Once a client's allocation is in place, Wealthspire Advisors employs a rigorous due diligence process to select the appropriate mutual funds, exchange-traded funds (“ETFs”), private investment funds, and/or investment managers. Wealthspire Advisors Wealth Solutions, recommended for accounts with assets under management between $500,000 and $2,000,000, includes annual or semi-annual meetings with an Advisor Representative. Investments consist of mainly mutual funds and ETFs. Wealthspire Pathways, which utilizes Charles Schwab and Co., Inc.’s Institutional Intelligent Portfolios® Platform, recommended for accounts with assets under management between $100,000 and $500,000, includes annual meetings with an Advisor Representative. Investments consist of ETFs and a cash allocation. Wealthspire Advisors Institutional, recommended for institutions with assets under management exceeding $5,000,000, includes quarterly or semi-annual meetings with a service team which consists of three Wealthspire Advisors employees. It is managed in line with the Wealthspire Advisors Wealth Management program discussed above. Wealthspire Advisors has established account services relationships with, and typically recommends the custodial services of, Charles Schwab & Co., Fidelity Brokerage Services (“Fidelity”), and Pershing Advisor Solutions (“Pershing”). These firms maintain custody of Account assets and process transactions ordered by Advisor Representatives and Separate Account Managers. Reports of Account transactions and positions are prepared and sent to each client no less than quarterly by each custodian. Wealthspire Advisors is responsible for the management of investments within client Accounts and adjusts client portfolios by buying and selling investments from time-to-time based on current investment objectives and client needs. The firm may also manage Accounts on a non-discretionary basis from time-to-time, and, when it does so, Advisor Representatives obtain permission for Account transactions from the client prior to placing the trades. Accounts are continuously monitored, and investments are made based on changes to economic and market conditions or to realign the portfolio to be consistent with the client's current allocation plan, investment objectives, time horizon, and risk tolerance. Clients may place reasonable restrictions or constraints on the way their Accounts are managed, where practicable, and retain the right to modify Account restrictions at any time by providing written notice of such changes to Wealthspire Advisors. Advisor Representatives will periodically request updates to a client's Investment Information to assist in managing and supervising the client's Account and to make any necessary changes to the investment decisions and recommendations being made for the client's Account. However, clients remain ultimately responsible for informing Wealthspire Advisors of material changes to Investment Information as it occurs. Wealthspire Advisors generally does not accept Accounts maintained at a custodian with which the firm does not have an established services relationship. Clients may contact their Advisor Representative any time they wish to confer about any aspect of the Account or services being, or to be, provided. Wealthspire has entered into an agreement with Flourish Digital Assets LLC (“Flourish Digital Assets”) to offer certain eligible clients the opportunity to invest in cryptocurrency basis through Flourish Crypto accounts offered on the Flourish platform. A Flourish Crypto account is a cryptocurrency investment account custodied by Paxos Trust Company, LLC (“Paxos”) through which investors can trade cryptocurrencies and maintain custody of cryptocurrencies and U.S. dollars. Clients that invest through a Flourish Crypto account will manage their own accounts and execute agreements with Flourish Digital Assets and Paxos. Investment Consulting Services Wealthspire Advisors assists other organizations with asset allocation strategies, investment manager research and selection, performance reporting, marketing support and other services in exchange for a flat fee. The representatives of the organization retain the authority to approve or reject all asset allocation strategies, investment manager recommendations or other materials that result from Wealthspire’s services. In addition, each representative of the organization retains sole responsibility for determining their needs, and in choosing which strategies or managers may be appropriate for them. Unaffiliated Private Investment Funds In certain cases, Wealthspire Advisors may recommend investment in certain unaffiliated private investment funds. Wealthspire Advisors’ role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client decides to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Wealthspire Advisors calculating its investment advisory fee. Wealthspire Advisors’ clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). All clients that determine to become investors in a fund, will generally receive an Offering Memorandum prepared by the fund sponsor (discussing the fund's investment objectives, risk factors, conflicts, etc.) and shall generally be required to enter into a Subscription Agreement acknowledging the terms and conditions of the fund and/or venture and the corresponding risk factors, including loss of principal and liquidity constraints. Wealthspire Advisors will only recommend private funds to those clients for whom it reasonably believes such an investment to be suitable, given the client’s total portfolio, risk parameters and liquidity needs. Wealthspire Advisors shall not exercise any discretion as to whether or not a client shall invest in any private fund. Rather, the ultimate investment decision shall remain with the client. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Because of the above factors associated with a private fund investment, the Firm must make a determination as to whether a specific private fund is appropriate for the client. In so doing, the Firm shall consider the following factors:
• The type of offering-including risks, time horizon, and liquidity issues;
• The client's investment objective(s)-realizing that for certain clients, a private fund of any kind may not be suitable;
• The client's current portfolio allocation;
• The client’s available cash to commit to the private fund;
• The private fund's investment minimum per investor; and
• The client's current allocation to private investment funds. Please Note: Valuation. In the event that Wealthspire Advisors references private investment funds owned by the client on any supplemental account reports prepared by Wealthspire Advisors, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The most recently available value will continue to be reflected on this report until the fund provides a further updated value. Please Also Note: As a result of the valuation process, the report may reflect an initial purchase price or an updated value subsequent to purchase, and the current value(s) of an investor’s fund holding could be significantly more or less than the value reflected on the report. The client’s advisory fee shall be based upon the value reflected on the report. Wealthspire Pathways Wealthspire Pathways, which utilizes Schwab Institutional Intelligent Portfolios®, is an automated investment program through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of ETFs and a cash allocation. The client may instruct us to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate Wealthspire Pathways. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to Wealthspire Pathways. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of Wealthspire Pathways for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for Wealthspire Pathways. The Platform enables us to make Wealthspire Pathways available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of Wealthspire Pathways. Schwab does receive other revenues in connection with Wealthspire Pathways. We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co. that are not enrolled in Wealthspire Pathways. If we do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of our clients’ assets in Wealthspire Pathways. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in Wealthspire Pathways be maintained with CS&Co. Trustee Services Certain of Wealthspire Advisors’ employees (or employees of affiliates) may, upon client request, serve as

trustee for various types of trusts set up by clients. The employees offer these services at their sole discretion on a limited, case-by-case basis. The firm’s trustee services include the execution of trust duties, as well as the administrative functions necessary to support the fiduciary responsibilities of the trustee. This service is separate and apart from the investment advisory services and is subject to a separate fee. Trustee services include (as applicable):  Maintaining calendar for trust distributions and payments, including: mandatory distributions of income and/or principal to beneficiaries, tax payments, tax estimates, trustee and administrative fee payments  Ensuring timely distribution of assets or monies required under the terms of the trust  Communication with beneficiaries to ensure a smooth administrative process  Making tax payments and estimated payments as required  Distributing K-1s to beneficiaries  Coordinating with other trusted advisors to create comprehensive tax and financial planning  Maintaining debt schedules for promissory notes as required  Monitoring the Trust’s investment portfolio to ensure proper implementation given the time horizon and risk profile of the trust  Reviewing tax returns prepared by trust’s accountant  Acting as Agent for Trust or General Partner  Power of Attorney (“POA”) Services  Check writing authority on accounts Trust Administration and Reporting Services Through its relationship with its custodians, the firm is able to provide trust administration and reporting services to the trusts where one of its employees serves as trustee or those trusts it manages for trustees not affiliated with the firm. Trust administration and reporting services are an important tool to eliminate manual processes for trust accounting, and include:  Detailed trust accounting, including automated separation of principal and income  Calculation and facilitation of distributions to beneficiaries and third parties  Recordkeeping of illiquid assets owned by the trust  Review and facilitate filing of trust tax returns prepared by the trust’s accountant, tax payments, and delivery of K-1s to trust beneficiaries, as directed by the trustee  Furnish trust reports, accountings, and information to beneficiaries as directed by trustee or if otherwise required Client Retirement Plan Assets Wealthspire Advisors also provides investment advisory services relative to the client’s 401(k) plan assets upon request. In such event, Wealthspire Advisors shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Please Note: Wealthspire Advisors’ services shall be limited to the allocation of the client’s assets among the investment alternatives available through the plan. Wealthspire Advisors will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Wealthspire Advisors of any changes in investment alternatives, restrictions or other relevant or material information pertaining to the retirement account. IRA Rollovers In appropriate circumstances, Wealthspire Advisors may recommend that a client roll over an account held in a former employer's retirement plan to Individual Retirement Account ("IRA") for Wealthspire Advisors to manage. When providing investment advice to clients regarding retirement plan accounts or IRAs, Wealthspire Advisors is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Wealthspire Advisors makes money creates some conflicts with the client’s interests, so Wealthspire Advisors operates under a special rule that requires it to act in the client’s best interest and not put the firm’s interests ahead of the clients. If the client elects to rollover assets into an IRA account subject to Wealthspire Advisors’ management, the account will be subject to Wealthspire Advisors’ advisory fee per the client’s Investment Advisory Agreement. Conflict of Interest: A financial advisor’s recommendation to roll over retirement plan assets into an IRA creates some conflict of interest because such a recommendation can create an incentive to recommend the rollover for the purpose of generating additional compensation rather than solely based on the client’s needs. When Wealthspire Advisors recommends a rollover IRA, the recommendation is given in the client’s best interest and with the client’s interests ahead of the firm’s, and the client is never under any obligation, contractually or otherwise, to complete a rollover to have the rollover IRA assets managed by Wealthspire Advisors. Many employers permit former employees to keep their retirement assets in the company plan. Also, some retirement plans may permit current employees to move assets out of the company plan before retiring or leaving the company. In determining whether to complete an IRA rollover, and to the extent the following options are available, Wealthspire Advisors clients should consider their costs and benefits. An employee will typically have four options:  Leave the assets in the employer/former employer's plan;  Transfer the funds to a new employer’s retirement plan;  Cash out and take a taxable distribution from the plan; or  Roll the funds into an IRA account. Each of these options has advantages and disadvantages, and Wealthspire Advisors recommends that a client communicate with their CPA/tax attorney to consider them before making a change. Each client should consider the following relevant issues together with their Wealthspire Advisors advisor, as well as their tax and/or legal professional, before initiating a retirement plan rollover:  Determine whether the investment options in the employer's retirement plan address client’s needs or whether other types of investments are needed.  Employer retirement plans generally have a more limited investment menu than IRAs.  Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds.  The employer plan may have lower fees than Wealthspire Advisors’ fees.  If interested in investing only in mutual funds, client should understand the cost structure of the share classes available in employer's retirement plan compared to those available in an IRA.  Client should understand the various products and services that may be available through a Rollover IRA and the potential costs of those products and services.  Wealthspire Advisors’ recommended strategy may entail higher risk than the option(s) provided in client’s plan.  Client’s current plan may also offer financial advice.  Keeping assets titled in a 401k or retirement account may potentially delay a required minimum distribution.  For clients concerned about protecting assets from creditors, an existing 401k plan may offer more liability protection than a rollover IRA. Such legal protection varies by state.  Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there may be some exceptions to these general rules so an attorney should be consulted if concerned about protecting retirement plan assets from creditors.  Loans may be available from the employer plan (although generally not to ex-employees); no loan available from an IRA.  IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless qualifying for an exception such as disability, higher education expenses or the purchase of a home.  If you own company stock in your 401k plan, you may be able to liquidate those shares at a lower capital gains tax rate. Client’s existing retirement plan may allow Wealthspire Advisors to be hired as the investment manager and to keep the assets titled in the plan name. It is important that clients understand the differences between these types of accounts and to evaluate whether a rollover is best under the circumstances. Insurance While Wealthspire Advisors routinely provides insurance planning as part of a client’s financial plan, Wealthspire Advisors does not sell insurance. Wealthspire Advisors may provide Client with recommendations of licensed insurance agents (some of whom may be affiliated with parent company NFP) for the purchase of various types of insurance. Wealthspire Advisors does not accept or receive referral compensation from any of the firms to whom it refers clients. Although Wealthspire is affiliated with Lenox Advisors, a licensed insurance agency, Wealthspire is not an insurance agency and does not sell fixed or general account life insurance products or annuities. Wrap Fee Program Wealthspire Advisors does not offer a wrap fee program. A "wrap fee program" is a program under which Investment Advisory and brokerage execution services are provided for an annualized "wrapped" fee that is not based on the number of transactions in a client's account. From time to time, Wealthspire Advisors may recommend investment with a Separate Account Manager which has its own wrap fee program. No Legal Services Certain of Wealthspire Advisors’ employees may be licensed to practice law. However, no such persons provide legal services to any of Wealthspire Advisors’ clients, and no corresponding attorney- client relationship is established. This foregoing is provided for purposes of full disclosure and to emphasize that the fact that certain of Wealthspire Advisors’ employees may be licensed to practice law is not material to Wealthspire Advisors’ investment advisory business or services. Services Offered to ERISA Plans Wealthspire Advisors provides advisory services to retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), including participant-directed defined contribution plans, such as 401(k) plans, defined contribution plans that are not participant- directed and defined benefit plans (“ERISA Plan Clients”). Each ERISA Plan Client is required to enter into an investment advisory or investment management agreement with Wealthspire Advisors describing the services that Wealthspire Advisors will perform for the ERISA plan and its participants (the “ERISA Plan Services Agreement”). Wealthspire Advisors provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. Please Note: As of March 2019, Wealthspire Advisors intends to introduce future ERISA plan clients to NFP Retirement, Inc. (“NFP-R”), an affiliated company specializing in working with plan sponsors. Wealthspire Advisors believes that, in most cases, NFP-R will be better equipped to service our current and future 401k plan sponsor clients. Conflict of Interest: NFP-R and Wealthspire Advisors are affiliated firms, as both are owned by NFP Corp. Therefore, Wealthspire Advisors has a conflict of interest where it recommends the services of an affiliated firm. Wealthspire Advisors has addressed this conflict of interest as outlined more fully below in “Item 14--Client Referrals and Other Compensation.” Fiduciary Services for ERISA Plan Clients Wealthspire Advisors provides fiduciary services either as a discretionary investment manager or a non- discretionary investment adviser. Discretionary Investment Management Services Wealthspire Advisors provides investment management services to ERISA Plan Clients on a discretionary basis as an investment manager under ERISA Section 3(38) and in that capacity, Wealthspire Advisors’ investment decisions are made in its sole discretion without the ERISA Plan Client’s prior approval. Each ERISA Plan Client who engages Wealthspire Advisors to perform investment management services is required to enter into an investment management agreement. Wealthspire Advisors’ investment management services include developing and implementing an investment policy statement, selecting a broad range of investment options consistent with ERISA Section 404(c), making decisions about the selection, retention, removal and addition of investment options and if the ERISA Client has determined that the Plan should have a qualified default investment alternative (a “QDIA”) for participants who fail to make an investment election, selecting the investment that will serve as a QDIA. Non-Discretionary Investment Advisory Service Wealthspire Advisors also provides investment advisory services on a nondiscretionary basis and in that capacity, the ERISA Plan Client retains, and exercises, final decision-making authority and responsibility for the implementation (or rejection) of Wealthspire Advisors’ recommendations or advice. Each ERISA Plan Client who engages Wealthspire Advisors to perform nondiscretionary investment advisory services is required to enter into an investment advisory agreement. Wealthspire Advisors’ nondiscretionary investment advisory services include assisting the ERISA Plan Client in developing and implementing an investment policy statement and assisting the ERISA Plan Client in making decisions about the selection, retention, removal and addition of investments. Non-Fiduciary Services for ERISA Plan Clients Wealthspire Advisors’ non-fiduciary services provided to ERISA Plan Clients include assisting in group enrollment meetings, educating plan participants about general investment principles and the investment alternatives under the plan and educating the ERISA Plan Client as to its fiduciary responsibilities. Wealthspire Advisors’ non-fiduciary services also include assisting the ERISA Plan Client in monitoring, selecting and supervising service vendors and performing benchmarking studies and fee analysis. For a more detailed description of Wealthspire Advisors’ fiduciary and non-fiduciary services, the ERISA Plan Client should refer to the ERISA Plan Services Agreement. ERISA / IRC Fiduciary Acknowledgment. If the client is: (i) a retirement plan (“Plan”) organized under ERISA; (ii) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or her Plan account or to take a distribution; (iii) the beneficial owner of an IRA acting on behalf of the IRA; or (iv) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code: then Wealthspire Advisors represents that it and its representatives are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by the Registrant or its representatives or with respect to any investment recommendations regarding an ERISA Plan or participant or beneficiary account. Financial Planning Wealthspire Advisors also offers comprehensive and limited financial planning and consulting services depending on each client's needs. Our comprehensive evaluation of a client's current and anticipated future financial state is accomplished by using currently known variables to assess future cash flows, asset values, and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written summary which provides the client with a detailed financial outline designed to assist the client in achieving his or her financial goals and objectives. Our limited financial planning services are based on specific recommendations outlined by our clients. Our clients will receive an appropriate evaluation based on the parameters agreed to in the services agreement. We seek to develop comprehensive or limited financial plans that include any or all of the subject areas as defined by the Certified Financial Planning Board:  Financial Statement Preparation and Analysis: We review family records, budgets, assets, liabilities, and cash flow to create a clear picture of the current financial status of our clients in order to determine opportunities and priorities. Specific topics that may be addressed include, but are not limited to: (i) personal financial planning; (ii) asset liability ownership; (iii) debt management/structuring; (iv) home purchase analysis; (v) analysis/comparison of debt pay-off options; (vi) cash flow; (vii) calculation of liquidity and cash reserve needs; (viii) budget monitoring; and (ix) inflation projection of living expenses.  Investment Planning: We analyze investment alternatives and their effect on the client's portfolio. We communicate our economic and investment outlook via a quarterly Investment Philosophy that is available to all advisory clients. Specific topics that may be addressed include: (i) asset allocation; (ii) retirement income strategies; (iii) education goal analysis; (iv) potential tax ramifications of various investment strategies; (v) computation of the length of time, money, or other asset will last given a specified rate of withdrawal and expected rate of return; (vi) calculation of a lump sum amount of money needed to be invested to receive a specified level of income per year for a certain number of years; and (vii) portfolio optimization/rebalancing.  Insurance Planning, Risk Management, and Employee Benefits: We analyze the impact of the client's death, disability, or incapacity on his or her financial strategy. We evaluate existing policies and determine ways to cost-effectively meet family needs that can be addressed through life, disability, and long-term care insurance. Specific topics that may be addressed include: (i) survivor income needs; (ii) capital needs; (iii) estate liquidity needs; and (iv) buy-sell analysis.  Income Tax Planning: We analyze the client's income tax history and spending patterns to plan for the current and future years then model the potential impact of various investment and financial strategies on the client's net worth and liquidity. Specific topics that may be addressed include: (i) income tax projections including general and specific techniques for reducing tax liability; (ii) tax deduction and tax credit maximization opportunities; (iii) alternative minimum tax considerations; (iv) business structure alternatives including compensation methodology; (v) intergenerational asset transfers; (vi) capital gain/loss harvesting; (vii) Roth conversion analysis; and (viii) net investment income considerations.  Retirement Planning: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. For individuals who are already retired, we analyze the impact of changing income and expense amounts and timing, gifting, and risk tolerance with the objective of maintaining financial independence. Specific topics that may be addressed include: (i) analysis of retirement needs; (ii) early retirement analysis; (iii) pension maximization; (iv) social security optimization; and (v) rollovers/transfers.  Estate Planning: We assist the client in assessing and developing long-term strategies, including (as appropriate), trusts, wills, powers of attorney, asset protection plans, and estate tax exposure. We carefully evaluate the impact of various gifting and wealth transfer strategies. Specific topics that may be addressed include: (i) estate/death tax estimate including general and specific techniques for reducing taxes, probate, and transfer costs; (ii) estate liquidity and survivor income analysis; (iii) gifting strategies; (iv) estate planning for minor children or special needs dependents; and (v) charitable planning strategies. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax circumstances, future goals, investment objectives, and attitudes towards risk. We carefully review documents supplied by the client and prepare a written report. The financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Additionally, Wealthspire Advisors provides advice on non-security matters. Generally, this is in connection with the rendering of estate planning, fixed insurance, and/or fixed annuity. Should a client choose to implement the recommendations contained in the financial plan, Wealthspire Advisors suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of the recommendations contained in the financial plan is entirely at the client's discretion. To the extent that Wealthspire Advisors or an affiliate offers legal, accounting, insurance, or brokerage services recommendations, a client is not obligated to use a Wealthspire Advisors affiliate to obtain any such services. If a client chooses to use a Wealthspire Advisors affiliate for any such services, Wealthspire has a conflict of interest when evaluating product recommendations involving advisory services or products offered by the firm or its affiliate. While certain individuals associated with Wealthspire Advisors are registered representatives of a broker-dealer and licensed as insurance agents/brokers of various insurance companies, financial plan recommendations are generally of a generic nature and do not typically involve the recommendation of specific investment products. Recommendations are not limited to any specific product or service offered by a particular broker-dealer or insurance company. Cash Positions. All cash positions (money markets, etc.) may be included as part of assets under management for purposes of calculating Wealthspire‘s advisory fee. Please Further Note: When the account is holding cash positions, those cash positions may be subject to the same fee schedule as set forth below unless otherwise agreed upon. Please Note: Our services are not intended to replace any tax, legal or accounting advice from a tax/legal/accounting professional. As an accommodation when asked, Wealthspire Advisors may recommend the services of qualified professionals for certain non-investment implementation purposes (e.g. attorneys, accountants, insurance agents, etc.). Clients are encouraged to make their own decisions and are under no obligation to engage the services of any such recommended professional. Although we have experience with these service providers, Wealthspire has not performed due diligence on these service providers and is not responsible for the services provided by these services providers. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Wealthspire and/or its representatives. Please Also Note: If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional(s), and not Wealthspire, shall be responsible for the quality and competency of the services provided. Please Further Note: Wealthspire believes that it is important for the client to address financial planning issues on an ongoing basis. Wealthspire’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Wealthspire. Please Also Note: It remains the client’s responsibility to promptly notify Wealthspire Advisors of any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Wealthspire Advisors’ previous recommendations and/or services. Held Away Assets We use a third-party platform, Pontera Order Management System (“Pontera”), to facilitate management of held away assets, such as 401(k) or defined contribution plan participant accounts, over which we have discretion. Pontera allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with Pontera in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to Pontera, Wealthspire will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed periodically, and allocation changes will be made as deemed necessary.