Introduction This Brochure describes the financial planning, investment management, and related advisory and supporting services offered by United Capital Financial Advisors, LLC (herein referred to as “United Capital” or “Firm”). For purposes of this Brochure, United Capital’s advisory personnel will be collectively referred to herein as “Financial Advisors.” Financial Advisors are, to the extent required, registered investment advisor representatives of United Capital. Some Financial Advisors are also broker-dealer registered representatives of Lion Street Financial, LLC (“LSF”). LSF is an unaffiliated broker-dealer registered with the SEC and a member of FINRA / SIPC. Not all Financial Advisors provide the same services to clients. United Capital provides financial planning (“Financial Planning”) and/or investment management (“Investment Management”) services nationally to a wide-ranging client base. Clients engage with United Capital through various channels including through arrangements with affinity or membership associations and organizations, plan recordkeepers or other organizations through which United Capital may offer their services to the affinity or membership associations and organizations’ members and participants, or to their clients or users, as applicable. United Capital has been a registered investment advisor with the SEC since 2005. United Capital’s headquarters is located in Irving, Texas. United Capital has regional office locations throughout the United States (“Regional Offices”) described in more detail at www.unitedcapitalwealth.com. United Capital also provides a technology platform and related consulting to independent investment advisors under the name FinLife Partners. United Capital’s principal owner is Creative Planning Holdco, LLC (“CP Holdco”), a privately held holding company. CP Holdco, United Capital, and their respective affiliates, directors, partners, trustees, managers, members, officers, and employees are referred to collectively herein as “CP.” Financial Planning United Capital offers Financial Planning to clients as an independent service or as part of another service offering based on their relationship with their Financial Advisor. Certain aspects of Financial Planning include delivery of investment advice as defined by the Investment Advisers Act of 1940, as amended (“Advisers Act”), in which United Capital may act as fiduciaries under the Advisers Act. Not all clients receive Financial Planning. For United Capital clients or those clients who transfer to United Capital, Financial Planning (which may also be referred to as “Financial Guidance”) generally focuses on development of a client’s financial plan, including an assessment and review of goals, financial needs, capacity for risk, retirement, cash flow, cash management, investment and insurance planning, savings, and other aspects as applicable to a client’s specific needs and as agreed to between the Financial Advisor and the client. United Capital typically makes Financial Planning services available together with Investment Management, but clients may also decide to only engage United Capital for either Financial Planning or Investment Management services. In the case where a client engages United Capital in Financial Planning only, a separate agreement will be executed outlining the included services. When clients engage United Capital only for Financial Planning, clients are not required to implement their financial plans through products and services offered by United Capital or its affiliates. United Capital does not have discretion over client assets when engaging United Capital for Financial Planning only. You are never required or obligated to implement our recommendations. United Capital’s Financial Planning services, whether provided as part of an Investment Management relationship or provided as a separate service, are usually provided to the client through meetings whereby the Financial Advisor and the client will work together to develop a written or verbal financial plan. For ongoing services, with client cooperation, the Financial Advisor will endeavor to meet with clients no less than annually to review their risk profiles and objectives and update the Financial Plan previously provided to the client for changes in the client’s situation. If clients choose not to meet with their Financial Advisor, United Capital will attempt to provide services based on information received during prior meetings when possible. United Capital relies on the accuracy and completeness of information provided by the client, and we do not assume responsibility to independently verify the accuracy or completeness of such information. It remains the responsibility of the client to promptly notify United Capital of any change in their financial situation or investment objectives to review, evaluate or revise our previous recommendations. United Capital may offer clients access to GuideCenter, a web-based platform that enables clients to collaborate with their Financial Advisor and receive information about their assets and goals. The platform may also provide the results of the Financial Planning exercises clients conducted with their Financial Advisor. United Capital does not provide tax advice or tax preparation services to clients. While United Capital may include tax planning services as part of its Financial Planning services, including the provision of an annual tax projection or an interpretation of the effect of applicable tax laws on a client’s portfolio, this service is not tax advice and the client should consult with its own tax advisor as tax planning provided in conjunction with the provision of Financial Planning is more limited than the tax advice that a client would receive from a tax advisor. United Capital is neither providing tax advice nor should these referrals be considered an advisory service. Investment Management Services When United Capital acts in an investment advisory capacity, they have a fiduciary obligation to act in their advisory client’s best interests in accordance with the Advisers Act. Client Investment Management accounts for which United Capital serves as the registered investment advisor are referred to as “Advisory Accounts” herein. Financial Advisors work with clients to understand each client’s risk tolerance, investment objectives, and investment attribute preferences, and to determine an appropriate asset allocation and portfolio construction. Based on the investment goals clients have discussed and agreed upon with their Financial Advisors, Financial Advisors will select, or recommend that the client select, one or more Managers, as defined below, to manage the client’s assets in one or more Advisory Accounts. Advisory Accounts may be invested in a variety of asset classes and investment vehicles that may include mutual funds, exchange traded funds (“ETFs”), exchange traded notes, equity securities, options, fixed income securities, or other types of securities. Advisory Accounts may also hold investments in private equity or other private funds. It remains the responsibility of the client to promptly notify United Capital of any change in their financial situation or investment objectives to review, evaluate or revise our previous recommendations. Depending on how a client’s assets are allocated, Advisory Accounts are managed in different ways. Further, product offerings are consistently changing. For example, products that are made available to some clients through one Advisor may not be made available to clients of one or more of the Advisor’s affiliates or investment offerings made available at a particular time may be removed from an Advisor’s offerings. United Capital will add or remove product offerings to or from United Capital’s platforms without prior notice to clients. Further, depending on the custodian selected and the services offered by United Capital, the investment selection available to clients may differ. Sub-Advisory Services United Capital may offer investment products managed by third party managers (“Unaffiliated Managers”). United Capital may provide advisory services by evaluating and selecting mutual funds and ETFs that are managed, sponsored or advised by investment managers that are not affiliated with United Capital or their affiliates (“Third-Party Funds”). Generally, Managers’ responsibilities vary and include the authority to: x exercise discretion to determine the types of securities bought and sold, along with the percentage allocation; x exercise discretion as to when to buy or sell securities; x exercise discretion on the timing of securities transactions; x select the broker-dealer for execution of securities transactions, if appropriate; and x take other portfolio management actions that United Capital may delegate, including the ability to vote proxies. United Capital does not monitor transactions directed by Managers for conformity with stated investment objectives, risk tolerance, financial circumstances, or investment restrictions, if any. In addition, United Capital will not evaluate each transaction executed by Managers for compliance with the Managers’ disclosed policies or style. However, if United Capital manages the accounts directly, they will undertake such monitoring with respect to any restrictions to which United Capital and the client agree in writing. United Capital has a conflict of interest to offer certain investment products to certain Unaffiliated Managers because of an economic incentive. For those certain Unaffiliated Managers, United Capital will place, if in the best interest of our clients, these investment products will generate revenue for the Unaffiliated Manager which then will reduce the amount that United Capital may pay to the Unaffiliated Manager. United Capital also receives research from unaffiliated Advisors to assist with the Investment Management of client assets. When providing research services, unaffiliated Advisors do not have any authority to exercise discretion over the management of client assets. Clients should receive a copy of the sub-advisor’s ADV Part 2A brochure directly from the sub-advisor that outlines their investment style, an explanation of the portfolio and any additional fees. Upon request, United Capital can provide the client with the sub-advisor’s ADV Part 2A brochure. Investment Management Services United Capital primarily provides discretionary Investment Management services to United Capital clients. United Capital clients generally elect to custody their United Capital Advisory Accounts with Fidelity Brokerage Services LLC and National Financial Services, LLC (together, “Fidelity”) and Charles Schwab & Co. Inc. (“Schwab”), although other custodian options may be available and some clients have elected to custody their assets with other unaffiliated custodians (collectively, “Third-Party Custodians”). Clients are encouraged to talk to their United Capital Financial Advisors about all custodian options available to them prior to opening an account. It will remain the client’s responsibility to negotiate terms with Third-Party Custodians and understand that they may not get the best execution or prices that other United Capital clients receive. ŝƐĐƌĞƟŽŶĂƌLJĐĐŽƵŶƚDĂŶĂŐĞŵĞŶƚ Where the client authorizes United Capital to provide discretionary investment services, the Financial Advisor will select, appoint and remove Managers and/or allocate and reallocate assets to individual securities or managed strategies in a client’s account without the client’s prior approval or consent. Depending on the applicable account type, Financial Advisors can choose to manage a client’s portfolio directly by selecting individual unaffiliated mutual funds, ETFs, certain types of Alternative Investments (if the client is qualified), separately managed accounts (“Separately Managed Accounts”), and/or other securities for client accounts from United Capital’s investment platform available at the custodians (“Locally Managed Strategies”) or by selecting a Manager to manage a client’s assets using model investment strategies developed and implemented by the Manager (“Centrally Managed Strategies”). Centrally Managed Strategies can take various forms including United Capital managing certain asset allocations. In addition to strategies managed and implemented by Goldman Sachs Asset Management (“GSAM”), United Capital can allocate assets towards a third-party model strategy managed and implemented by The Ayco Company, LLC’s Portfolio Management Group (“Ayco PMG”). Financial Advisors can also allocate assets toward Unaffiliated Manager model strategies that are implemented externally by the Unaffiliated Manager third-party technology platforms, using Third-Party Funds or Separately Managed Accounts. For these model strategies, neither United Capital nor its affiliates manage or trade the client’s account. Accounts in the same Centrally Managed Strategies are generally invested according to the same strategy with similar allocations. However, there are a number of scenarios or individual circumstances whereby a client could have a different implementation of Centrally Managed Strategies. EŽŶͲŝƐĐƌĞƟŽŶĂƌLJĐĐŽƵŶƚDĂŶĂŐĞŵĞŶƚ Clients may hire United Capital to provide non-discretionary investment advisory services in limited circumstances in United Capital Advisory Accounts. Those services will usually include transactions that require a client to sign third- party documents prior to entering into a transaction, such as the purchase of alternative investment products made available through United Capital or an affiliate, including hedge funds, private equity funds, venture capital funds, private real estate funds, private credit funds, and other private investments (“Alternative Investments”). Additionally, United Capital supports limited non-discretionary account management whereby, pursuant to an Investment Management agreement with United Capital, a client may direct those transactions be pre-cleared by the client before United Capital makes changes to a portfolio. While some clients may continue to have this arrangement with United Capital, United Capital no longer offers these types of arrangements to new clients except under limited circumstances. ^ƵďͲĚǀŝƐŽƌLJͬŽŶƐƵůƟŶŐ^ĞƌǀŝĐĞƐ United Capital provides discretionary management and customized investment advisory consulting services to other investment advisors and/or to broker-dealers. United Capital provides these sub-advisory and consulting services doing business as United Capital or FinLife Partners. When providing these services, United Capital charges a fee that is either individually negotiated for each consultation or based upon a percentage of client assets that United Capital manages as the subadvisor. Third-party advisors on the FinLife Platform are entitled to receive a credit on their advisory fees based on the assets under management with United Capital and amounts invested in registered mutual funds or ETFs managed by United Capital or Third-Party Managers. Sub-advisory services may be different from the services provided to clients of United Capital and certain strategies may be comprised of different funds or other securities than those of other clients for execution, availability, tax or other reasons. The fees that United Capital charges for sub-advisory services are typically different from fees charged to clients of United Capital. The specific services provided to the third-party advisors and broker-dealers are documented in a written agreement executed with each firm. Retirement Accounts and Retirement Plans United Capital provides discretionary and non-discretionary Investment Management services to individual retirement accounts (“IRAs”) under IRC Section 408 or 408A, Coverdell Education Savings Accounts, tax-qualified retirement plans (including Keogh plans) under IRC Section 401(a), pension plans and other employee pension benefit plans subject to ERISA (collectively, “Retirement Accounts”) through various managed strategies. This includes investment advice on (1) managed program selection, (2) manager and strategy selection, including Affiliated Managers and Unaffiliated Managers, and (3) asset allocation across the client’s managed program Retirement Accounts. United Capital may also offer investment education to Retirement Accounts regarding manager and strategy selection. Where Financial Advisors provide investment advisory or Investment Management services to Retirement Accounts pursuant to a written agreement, United Capital acts as a fiduciary pursuant to ERISA and/or the IRC. Any advice or recommendations made by United Capital with respect to assets that are not Retirement Account assets do not apply to and should not be used by the client for any decision with respect to any Retirement Account assets, which present different considerations. United Capital, in their sole discretion, can impose limitations on the investment services and strategies offered to Retirement Accounts. United Capital also offers education and consulting services to plan sponsors of employer-sponsored plans and/or plan participants of employer-sponsored plans. Department of Labor Acknowledgement of Fiduciary Duty – when we provide advice and recommendations to your retirement plan account or an individual retirement account, we are fiduciaries within the meaning of Title 1 Employment Retirement Income Security Act and/or the IRC. How we are compensated on these accounts creates a conflict of interest so we are under a special rule in which we must put our client’s interests ahead of our own. Under the provision, we must: x Meet a professional standard of care when making investment recommendations (give prudent advice); x Never put our financial interests ahead of yours when making recommendations (give loyal advice); x Avoid misleading statements about conflicts of interest, fees, and investments; x Follow policies and procedures designed to ensure that we give advice that is in your best interest; x Charge no more than is reasonable for our services; and x Give you basic information about conflicts of interest. 529 Plans United Capital provides discretionary and/or non-discretionary investment advice to clients on the selection of investments in 529 Plans. These 529 Plans typically are limited to advisor-assisted 529 Plans or classes of those plans. Once a client selects a 529 Plan, United Capital provides non-discretionary investment advice on selection of available investment options within the 529 Plan and, with the client’s agreement, will direct the 529 Plan sponsor to invest the client’s assets accordingly. Advice on 529 Plans available through United Capital is subject to advisory fees, which are separate and apart from any fees and expenses applicable to the 529 Plans and their investment options (including any funds that are available as investment options, as discussed elsewhere in this brochure). Less expensive plans or classes (including those not designed for use with a Financial Advisor) can be expected to be available elsewhere. Securities Class Actions and Proofs of Claims United Capital is not obligated to file, nor will it act in any legal capacity with respect to, class action settlements or related proofs of claim. If requested by the client, United Capital will endeavor to provide the client with the required documentation, if available, as an accommodation to the client and at United Capital’s sole discretion. For some clients, United Capital has made available the services of Chicago Clearing Corporation (“CCC”), a company that specializes in the field of class action claims, or another vendor. This service is no longer available for new clients. Legacy clients and those branch offices utilizing CCC will continue to do so. If requested, United Capital periodically provides CCC with the transaction history for the client’s United Capital Advisory Accounts and CCC subsequently monitors for any claim’s activity related to the securities that have been purchased in the client's United Capital Advisory Account. CCC will monitor each claim that applies to the client, collect the applicable documentation, interpret the terms of each settlement, file the appropriate claim form, interact with the administrators and distribute any award due for the client’s benefit. For their services, CCC charges a contingency fee of 20%, which is subtracted from the client’s award when it is paid. The net proceeds are deposited directly into the client’s United Capital Advisory Account or paid to the client by check. When a claim develops, CCC communicates directly with the claims administrator to file the claim on the client’s behalf. CCC warrants that any specific private client information they receive will be maintained as confidential and will not be used or disclosed for any reason, except for the completion of the claim itself. Other Offerings Alternative Investments If engaged by the client, United Capital will provide the client with non-discretionary advice with respect to buying, holding, selling, and trading interests in Alternative Investments that the client has personally chosen. Clients who choose to invest in Alternative Investments do so based on their own independent assessment of the investment opportunity. Alternative Investments are subject to a high degree of risk, are not suitable for all investors, and typically have limited liquidity. By themselves, Alternative Investments do not constitute a balanced investment portfolio.

Clients should carefully review and consider potential risks before investing in Alternative Investments, including carefully reviewing all disclosure documents, private offering memoranda, prospectuses, or other offering materials provided by the Alternative Investments or by United Capital and any separate manager or third-party service provider of an Alternative Investments and/or consulting tax or legal counsel, if appropriate. It will remain the responsibility of the client to monitor the Alternative Investments that they personally chose for their portfolio. United Capital will also provide discretionary advice with respect to buying, holding, selling, and trading interests in Alternative Investments that United Capital has vetted and chosen. United Capital makes available Alternative Investments through iCapital Advisors, LLC (“iCapital”) and its affiliates. United Capital may also make available Alternative Investments through other third-party platform providers or directly by an Alternative Investment fund manager. These types of investments may be offered to eligible clients only. A client will sign a Private Fund Acknowledgment Agreement before transacting in Alternative Investments. United Capital will provide periodic monitoring and advice on these investments. In addition to the advisory fee and/or management fee, United Capital clients pay additional dealer management fees, access fund management fees or similar servicing fees to iCapital or other Alternative Investment service providers. Fixed and Variable Insurance and Annuities United Capital will, if appropriate based on the client’s financial needs, advise certain clients to include insurance as part of their portfolio. However, United Capital will not exercise discretionary control over Advisory Accounts to purchase an insurance product. United Capital is affiliated with the insurance agency United Capital Risk Management, LLC (“UCRM”). Certain Financial Advisors are also licensed as insurance agents with UCRM and receive compensation related to fixed life insurance policies and annuity contracts (together, “Fixed Products”) as described in Item 10. Certain Financial Advisors are also licensed with LSF and receive compensation related to variable life insurance products and variable annuity contracts (together, “Variable Products”), as described below under Brokerage Activities in Item 10. Financial Advisors will, based on a client’s interest and financial planning needs, refer clients to one or more of United Capital’s affiliates (including UCRM), or to an unaffiliated third-party general insurance agency for the placement of Fixed Products or to LSF for the distribution of Variable Products. Unless otherwise agreed by United Capital in writing or through a separate notice to or from an affiliate, in cases in which insurance products or annuities are made available to clients who do not receive advisory services, such engagement does not result in an investment advisory relationship with United Capital or any affiliate, and United Capital (including any affiliates) does not have a corresponding fiduciary duty with respect to such clients. When United Capital refers clients to affiliates for Fixed Products or Variable Products, commissions may be paid subject to applicable law and such commissions will, in general, be paid to its employees if they hold appropriate state insurance licenses and, if applicable, securities licenses. When Financial Advisors recommend that a client include an insurance product as part of the client’s portfolio or makes a referral of a client for the purchase of an insurance product, Financial Advisors are generally paid a commission or other compensation for such sale. See Item 10 for more information. This creates a conflict of interest, as Financial Advisors have an incentive to place the insurance product as they will earn additional compensation as a result of the sale. If a recommendation is made or a client is referred to UCRM or LSF related to the purchase, redemption or exchange of an insurance policy, clients are not obligated in any way to execute through UCRM or LSF and/or any insurance agent affiliated with United Capital and/or any insurance agency with which its Financial Advisors may be licensed. Clients should understand that recommendations by insurance agents to purchase an insurance product is not made by United Capital in their investment advisory capacity, is not subject to the Investment Management agreements with United Capital, and is not subject to the same standard of care as investment recommendations provided by investment advisors. Clients are not required to open and/or maintain accounts or purchase insurance or annuities through United Capital or their affiliates. Clients have the option to purchase insurance and annuities through brokers or agents that are not affiliated with United Capital. Currently, United Capital accepts discretion to allocate Variable Subaccounts (as defined in Item 8 – Variable Subaccounts) on a limited basis as part of their broader Investment Management services. Except as described herein, United Capital does not provide advice or recommendations on the selection of Variable Subaccounts. Existing clients of United Capital may grant United Capital discretion to: (a) select Variable Subaccounts as defined above for clients’ existing variable annuities and (b) allocate and reallocate any premiums among the Variable Subaccounts available from the specific annuity sponsor (collectively (a) and (b) are referred to as the “Variable Subaccount Allocation Services”). In performing Variable Subaccount Allocation Services, United Capital will only consider the Variable Subaccount options available within the specific annuity purchased by the client. United Capital does not determine which Variable Subaccount options are made available by insurance companies. In certain legacy arrangements, United Capital may also provide, for a fee, advice regarding the selection and reallocation of index investment options available under certain non-commission, fixed annuity products. Insurance carriers offer certain types of annuity products for which no sales commissions are paid, but rather are only subject to an advisory fee for Variable Subaccount Allocation Services as agreed pursuant to the terms of the advisory agreement with the client (“Advisory Annuities”). In the event Advisory Annuities are offered for sale and/or service by LSF, United Capital will expand the circumstances in which they provide Variable Subaccount Allocation Services to include such Advisory Annuities. Fees for investment advice related to Advisory Annuities, generally a percentage of assets invested in the Advisory Annuity, may differ from fees otherwise agreed by United Capital for other investment advice. The fees for the Advisory Annuities are commensurate with the services provided and generally will not exceed 1.5%. Advice for fixed annuity index allocations may also be expanded through this initiative. United Capital will not exercise discretionary control over retirement assets to purchase an insurance product. Any changes in a client’s Variable Products (re-allocations among Variable Subaccounts or otherwise) are subject to the terms and conditions imposed by the applicable variable annuity sponsor. The cash or surrender value of any variable annuity for which United Capital is providing Variable Subaccount Allocation Services is included in the total assets on which the advisory fee is calculated. The advisory fee is separate from, and in addition to, the management fees and expenses charged on a continuing basis by the variable annuity sponsor, insurance company, and/or associated investment manager. If a client has not granted discretion regarding Variable Subaccounts as described above, United Capital may provide clients with education regarding asset allocation principles or examples of model portfolios. External Products From time to time, certain Legacy External Products may be held in Advisory Accounts if the client previously held the position prior to becoming a client of United Capital. These Legacy External Products are not part of United Capital’s platform and if they do not meet certain criteria, they will be classified as a Legacy Security as defined in United Capital’s Investment Management agreement and be subject to United Capital’s management fee. It will remain the client’s exclusive ongoing responsibility for monitoring and taking other action with regard to such Legacy Security, including the disposition thereof. United Capital will not be responsible for the investment performance and/or adverse financial consequences of such Legacy Securities. After investment products have been approved for offering by United Capital, Financial Advisors determine which products to select or recommend to clients. When considering potential investment products for a particular Advisory Account, Financial Advisors give different weights to different factors depending on the nature of the client. Such factors include quantitative considerations (such as the investment product’s returns and performance consistency over specified time periods) and qualitative considerations (such as the investment product’s investment objective and process), which are inherently subjective and include a wide variety of factors. Financial Advisors generally consider, for example, without limitation: (i) product-related factors, such as track record, index comparisons, risk and return assumptions; (ii) the Financial Advisors’ experience and familiarity with particular potential investment products, and, if applicable, the Investment Management teams managing such investment products or their organizations; (iii) client- driven factors, such as the client’s investment objective, the effect on the client’s portfolio diversification objectives, consistency with the client’s asset allocation mode and investment program, and the projected timing of implementation; and (iv) other factors, such as capacity constraints and minimum investment requirements. It should be expected that consideration of such factors will not be applied consistently over time or by a particular Financial Advisor across all Advisory Accounts or across different products and may play a greater role in the review of certain strategies or products while others play no role at all, and the factors are subject to change from time to time. It should be expected that Financial Advisors will not review the entire universe of External Products that are appropriate for an Advisory Account. As a result, there may be one or more External Products that would be a more appropriate addition to the Advisory Account than the investment product selected by Financial Advisors. Such External Products may outperform the investment product selected for the Advisory Account. Securities-Based Loans and Margin Clients may, if the use of leverage is determined to be a suitable investment strategy and legally permissible, be able to pledge account assets as collateral for loans obtained through certain affiliated and unaffiliated lenders (“Securities- Based Loans”). The Securities-Based Loans can be offered through Goldman Sachs Bank USA or other third-party banks. The Securities-Based Loan programs available to clients of the Advisor will depend on the Advisor and custodian selected by the client. There are risks, costs, and conflicts of interests associated with Securities-Based Loans and Margin loans made available to United Capital clients through Third-Party Custodians with the loans being provided on self- directed basis. United Capital does not recommend, monitor, or service such loans and any custodian communication facilitated from United Capital to clients regarding their margin loans is done so as a courtesy. Clients should regularly monitor their loan activity and market values of their pledged accounts at their custodian. Interest or other fees charged for margin are paid to the custodian. Brokerage Activities Certain Financial Advisors are registered with an unaffiliated broker dealer, LSF. These persons, in their capacity as registered representatives of LSF, can refer clients to LSF for brokerage services or effect securities transactions in brokerage accounts. Financial Advisors also refer clients to LSF for brokerage related services and United Capital refers clients to unaffiliated broker/dealers for other brokerage related services, including individually directed, non- discretionary brokerage accounts. Financial Advisors registered with LSF can also refer clients to LSF for Variable Products, as discussed above. Financial Advisors generally will receive commissions for these transactions. Clients are under no obligation to effect brokerage transactions through LSF. Because of the potential for Financial Advisors to generate a commission, Financial Advisors have an incentive to recommend insurance and investment products based on the potential compensation received, rather than the client’s needs. See Item 10 – Other Financial Activities and Affiliations below. LSF’s primary role is to execute trades for the client based on the client’s instructions and to place variable insurance products. The brokerage firm’s obligations to the client are different when it acts as broker as compared to when United Capital acts as investment advisors. In brokerage relationships, the brokerage firm’s interests will not always be aligned with the clients’ interests, and any advice the brokerage firm gives is incidental to the brokerage services it provides. The client does not pay a separate fee for advice in brokerage transactions but compensates the brokerage firm for trade execution only by payment of a commission or, in the case of placement of an insurance product, the brokerage firm is paid a commission by the insurance company. In the brokerage account context, United Capital is not acting as a fiduciary investment advisor with respect to the assets held in a brokerage account (including an IDA). However, broker-dealers are subject to a best interest standard when recommending securities transactions or investment strategies to retail customers in brokerage accounts. Referrals to Third Parties United Capital also provides referrals to unaffiliated third-party professionals (“Third-Party Professionals”) to assist clients with recommendations, advice, financial planning strategies (including tax return preparation, household payment administration and bill payment), and services not directly related to United Capital’s services. Unless otherwise indicated by United Capital in writing, United Capital does not undertake to, nor do they perform, specific due diligence regarding Third-Party Professionals and such referrals do not constitute recommendations by United Capital of the Third-Party Professional or their services. Referrals to Third-Party Professionals are made as an accommodation. United Capital does not undertake any fiduciary obligation when providing referrals to Third-Party Professionals. Services provided by Third-Party Professionals are distinct from those provided by United Capital and their affiliates and typically involve additional terms of service and related fees. Third-Party Professionals may be different from the service providers that United Capital and their affiliates use to provide the same or similar services due to regulatory limitations or other reasons. In instances where United Capital maintains a business relationship with a Third-Party Professional, such a relationship should not influence the referral or the service received by the Third-Party Professional. Legal, Tax, and Accounting Advice and Services United Capital may, upon request, provide to clients various estate, insurance, tax, retirement, and investment planning that may include investment advice. The scope of such services will vary among clients and when limited to episodic and educational consultations, such services are not and should not be viewed as legal, tax, or accounting advice. United Capital may review with clients the general tax consequences of their investments, estate planning, philanthropic endeavors, real estate holdings, and certain other activities that may affect income tax, but any such review does not constitute tax advice. United Capital will refer clients to its affiliates for these types of services, for which the client will pay a fee that is different from the management fee that United Capital charges. See Item 10 for more information on United Capital’s affiliates. United Capital may refer clients to non-affiliated companies offering tax preparation services. United Capital makes no representations as to the quality, accuracy, or results of any provider’s tax return preparation services and is not liable for a client’s ultimate selection and utilization of any particular provider. There may be other service providers offering the same or similar products and services, either through United Capital, their affiliates, or the marketplace generally, that are more or less expensive. United Capital may provide documents and information or, if appropriate, facilitate payment to a provider in combination with the tax return preparation services provided by that provider to clients. The Advisor’s limited involvement is not intended nor does it constitute an accountant-client relationship or tax advice. FinLife Partners FinLife Partners, which is available through United Capital, provides a technology platform and related consulting services to third-party investment advisors, trust companies, and broker-dealers, including training, use of a certain technology platform, related marketing content and assistance in preparing certain client deliverables. The technology platform services do not include individual investment management or guidance provided directly to retail clients. Third-party advisors pay FinLife Partners an onboarding fee and a flat fee for its services for each financial advisor who uses the technology. FinLife Partners may also make available United Capital’s sub-advisory services or mutual funds and ETFs managed by United Capital or other third parties. Depending on how third-party advisors structure their agreement with their retail clients, their retail clients will pay a portion of the investment management fees paid to FinLife Partners. Some retail clients pay different fees depending on the third-party advisor’s arrangement with FinLife Partners. Such arrangements are negotiated between United Capital and the FinLife Partner. The FinLife Partner may also receive discounts towards the cost of technology platform based on their use of United Capital’s sub-advisory services or mutual funds and ETFs managed by GSAM. Wrap Fee Programs United Capital historically has offered certain managed strategies or accounts under a wrap fee whereby Execution Charges (custodian transaction fees and execution charges, including commissions, commission equivalents, mark-ups, mark-downs and spreads, unless waived by a third party (collectively, “Execution Charges”), custodian costs, technology platform fees, and/or other operational costs were included in the advisory fee. While some legacy clients may still have accounts under this arrangement, such fee structures are no longer available for new United Capital clients. For more information, please refer to United Capital’s Wrap Fee Program Brochure located at www.adviserinfo.sec.gov. Persons Residing Outside of the United States Before engaging United Capital to provide services to a person residing outside of the United States, clients are required to enter into an Investment Management Agreement that sets forth the terms and conditions of the engagement (including termination) describing the scope of services to be provided. The client understands that some services may be restricted or limited due to custodial rules and other factors. Investment models and strategies may differ from our typical recommendations including, but not limited to, the foreign tax treatment of transactions in the United States. Foreign jurisdictions and requirements may also impact our ability to service accounts or provide additional disclosures depending on the country. It will be the responsibility of the client to satisfy all legal and tax reporting requirements of the United States and all applicable foreign governments. Each custodian will have their own policies regarding the country the client resides in and the custodian has the right to decline to open or maintain the account. The custodian also has policies regarding applicable customer identification and anti-money laundering regulations. It will remain in the sole discretion of United Capital to decline engagement with any prospective client living outside the United States or terminate an engagement with an existing client if they move outside the United States. Assets Under Management Clients may elect to have assets in account(s) managed by the Financial Advisors, United Capital or Unaffiliated Managers. The figures below include those assets as well as investments in pooled vehicles reflected in Advisory Accounts that are managed by a third party. Excluded from the figures below are assets tied to clients of third-party investment advisors who utilize FinLife Partners. Assets managed by United Capital is approximately $17,693,379,042.29 as of December 31, 2023 which $16,760,952,184.95 is managed on a discretionary basis and $932,426,857.34 is managed on a non-discretionary basis.