Description of Firm Lebenthal Diversified Asset Management Inc. ("LDAM, we, us, our, ours"), located in Hauppauge, New York, is a corporation formed in 2011 under the laws of New York. Dominick Tavella is the President and principal owner. LDAM is registered as an investment adviser with the SEC.
Our investment advisory services are limited to Sub-Advisory services offered to investment advisers and Portfolio Management services offered to Qualified Retirement Plan Services.
Sub-Advisory Asset Management Services LDAM offers sub-advisory services to affiliated and unaffiliated third party money managers (the "Primary Investment Adviser"). As part of these services, we will manage assets delegated to our firm by the Primary Investment Adviser. While we are responsible for the overall management of the assets delegated to our firm, we will not communicate investment recommendations or selections directly to the Primary Investment Adviser's individual clients (the "Client" or the "Investor").
Discretionary Portfolio Management Services Our sub-advisory services include discretionary portfolio management services. Our investment advice and strategies are tailored to meet each Investor's needs and investment objectives. In order to provide tailored services, we rely on the Primary Investment Adviser to provide us with each Investor's investment objectives, risk tolerance, and other relevant information that will assist us in developing a strategy that enables our firm to provide continuous and focused investment advice and/or to make investments on the Investor's behalf.
As part of our portfolio management services, we may customize an investment portfolio for the Investor in accordance with their risk tolerance and investing objectives. We may also invest the assets according to one or more model portfolios or strategies developed by our firm. Once we construct an investment portfolio for the Investor, or select a model portfolio, we will monitor the portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and or upon notice from the Primary Investment Adviser of any changes in Investor's financial circumstances.
Primary Investment Advisers that utilize our discretionary portfolio management services will be required to grant us discretionary authority to manage the Investor's account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on the Investor's behalf.
Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining the Primary Investment Advisers' or the Investor's approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for the Investor's account) by providing our firm with your restrictions and guidelines in writing.
As referenced above, we may invest Investor assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Assets that are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, the Primary Investment Adviser may impose restrictions on investing in certain securities or types of securities in the Investor's account. In such cases, this may prevent us from investing in certain models that are managed by our firm.
4 Qualified Retirement Plan Services LDAM provides portfolio management services

to sponsors of qualified retirement plans. These services are offered on both a discretionary and non-discretionary basis. The Advisory Representative will work with the plan sponsor accordingly under the terms of the advisory agreement. As part of those services, the Advisory Representative may also provide education and limited advisory assistance to qualified plan participants upon request.
LDAM also provides the following services to sponsors and participants of qualified retirement plans: ERISA 3(38) Portfolio Management Services Under this arrangement, LDAM manages "model portfolios" which are unitized and offered as investment alternatives to participants of qualified retirement plans. LDAM does not charge any portfolio management fees for this service. These model portfolios are typically only offered in conjunction with one of the fiduciary services described below.
ERISA 3(38) Fiduciary Investment Advisory Services Under this arrangement, LDAM enters into an agreement with the qualified plan sponsor under which LDAM will have full discretion over the selection, monitoring and replacement of investments at the plan level. LDAM also provides participant education and investment advice (for no additional fee) but does not have discretion over the investment selection at the participant level.
ERISA 3(21) Fiduciary Investment Advisory Services: Under this arrangement, LDAM acknowledges a fiduciary role in the investment decision making process but does not have discretion over the selection or replacement. Such authority remains with the plan sponsor. LDAM also provides participant education and investment advice (for no additional fee) and does not have discretion over the investment selection at the participant level.
Wrap Fee Program We are a portfolio manager of a wrap fee program sponsored and administered by Lebenthal Global Advisors, LLC ("LGA"). A wrap fee program is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee that includes administrative fees, management fees, and commissions. We manage wrap fee accounts on a discretionary basis. Wrap fee accounts are typically more appropriate for active accounts and are managed accordingly. If you participate in a wrap fee program, you will pay a single fee, which includes our money management fees, certain transaction costs, and custodial and administrative costs. You will also receive a separate Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1) from LGA explaining the program and costs associated with the program. You should also review this Part 2A thoroughly to evaluate any differences between our portfolio management services offered through LGA's Wrap Fee Program versus the portfolio management services that are available on a non-wrap basis. The overall cost you will incur if you participate in a wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the program.
Types of Investments We primarily offer advice on mutual funds and exchange-traded funds ("ETFs"). Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
However, in addition to mutual funds and ETFs, we may also advise on various types of investments based on the stated goals and objectives. We may also provide advice on any type of investment held in the portfolio at the inception of our advisory relationship.
5 Since our investment strategies and advice are based on each account's specific financial situation, the investment advice we provide may be different or conflicting with the advice we give to another account regarding the same security or investment.
Assets Under Management As of December 31, 2023, we provide continuous management services for $643,879,807 in client assets on a discretionary basis