DELTA ASSET MANAGEMENT, LLC

FORM ADV 2A ITEM 1 ‐ COVER PAGE 700 Colonial Road, Suite 220, Memphis, TN 38117 901‐767‐4791, Fax 901‐767‐1224 delta@deltaasset.com www.deltaasset.com March 31, 2025 This brochure provides information about the qualifications and business practices of Delta Asset Management, LLC (“Delta” or the “Firm”). If you have any questions about the contents of this brochure, please contact us at 901‐767‐4791 or at delta@deltaasset.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Delta Asset Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search for our firm by using our CRD number which is 113688. Delta is registered with the SEC. However, this registration, while required by law, does not indicate any established or set level or skill or training on our part. 1  ITEM 2 ‐ MATERIAL CHANGES This section only discusses any material changes to this Form ADV Part 2A disclosure document since the date of our last annual update to this brochure which was on March 18, 2024. • • • • Item 4 – Advisory Business: We updated this section to note that the principal owner of the firm is WT Acquisition, LLC, which is owned by Hightower Holding, LLC. Item 5 – Fees and Compensation: We removed the annual minimum fee of $3,000 per client relationship. Item 10 – Other Financial Industry Activities and Affiliations: We added language regarding our affiliates and any conflicts of interest. Item 14 – Client Referrals and Other Compensation: We updated this section to note that we do not pay referral fees to independent solicitors for the referral of clients to our firm. 2  ITEM 3 ‐ TABLE OF CONTENTS Item 4 ‐ Advisory Business .................................................................................................................. 4 Item 5 ‐ Fees and Compensation… ...................................................................................................... 5 Item 6 ‐ Performance‐Based Fees and Side‐By‐Side Management… ................................................. 6 Item 7 ‐ Types of Clients… ................................................................................................................... 6 Item 8 ‐ Methods of Analysis, Investment Strategies and Risk of Loss… ............................................ 6 Item 9 ‐ Disciplinary History… ............................................................................................................. 8 Item 10 ‐ Other Financial Industry Activities and Affiliations… .......................................................... 8 Item 11 ‐ Code of Ethics, Participation or interest in Client Transactions and Personal Trading ......... 9 Item 12 ‐ Brokerage Practices… .......................................................................................................... 10 Item 13 ‐ Review of Accounts ............................................................................................................. 13 Item 14 ‐ Client Referrals and Other Compensation… ........................................................................ 13 Item 15 ‐ Custody… ............................................................................................................................. 14 Item 16 ‐ Investment Discretion… ..................................................................................................... 14 Item 17 ‐ Voting Client Securities… .................................................................................................... 15 Item 18 ‐ Financial Information… ....................................................................................................... 15 3  ITEM 4 ‐ ADVISORY BUSINESS Delta has been in business since 1989. We provide our clients with investment advisory services consisting primarily of ongoing, discretionary asset management through use of equity, fixed income and balanced (between equity securities such as stocks, fixed income securities such as municipal and government bonds and exchange traded mutual funds) portfolios. Our services and processes are designed to determine and address each client’s specific investment needs through formulation of an asset allocation strategy tailored to meet the client’s investment circumstances, objectives, time horizon objectives and risk tolerance. You may also impose restrictions on our ability to implement particular types of investments on your behalf if that is your preference. We maintain a model portfolio which we use as an allocation guide for managing our clients’ accounts and in determining when to sell a particular security in a client’s account taking into account the client’s specific investment and tax considerations. Our model portfolio may limit the total number of individual securities held by our clients although a client’s account may be composed of securities not included in our model portfolio depending upon the client’s specific investment needs. We can also provide a financial plan at no additional cost. We do not provide legal, tax or accounting advice or services and you should not assume that we are providing you such services at any time. Also, you should understand that, generally speaking, securities or other investments for which we provide advice to you are not deposits or obligations of any bank, are not endorsed or guaranteed by any bank and are not insured by the Federal Deposit Insurance Corporation, the Federal Reserve Board or any other governmental agency and that neither Delta nor any of its affiliated companies is a trust or banking institution. Delta has entered into “wrap fee” arrangements sponsored by LPL Financial Corporation, which is unaffiliated with Delta. Under a wrap fee arrangement, a brokerage firm may recommend retention of Delta to manage all or a portion of your assets; pay us our fee for our services; monitor and evaluate our services in managing your assets; execute securities transactions which we implement on your behalf; and provide you with custodial services for your assets, or the brokerage firm may provide any combination of these services, for a set fee to be paid by you to the brokerage firm. Under a wrap fee arrangement, your assets would be managed by us in the same manner as assets managed by us for our clients not in a wrap fee arrangement although this would be subject to your particular investment needs and objectives and we may have limited or minimal contact with you where the brokerage firm maintains the direct and primary relationship with you. You should understand that, depending upon the amount of the wrap fee the brokerage firm charges you, the number of securities transactions in your account, the value of custodial or other services you will receive under the arrangement, the amount of the wrap fee may or may not be less than the total cost for such services added together if you obtained them separately and therefore such arrangements may not be suitable for all clients based on the client’s individual financial circumstances and investment goals. You can find more specific information on each wrap fee arrangement in the Wrap Fee Program Brochure which should be available to you from the wrap fee arrangement sponsor. Delta does not act as a sponsor of any wrap fee arrangements. 4  The principal owner of Delta is WT Acquisition, LLC, which is owned by Hightower Holding, LLC. The amount of client assets we manage as of December 31, 2024 on a discretionary basis and non‐ discretionary basis is $1,440,457,835 and $0, respectively. ITEM 5 ‐ FEES AND COMPENSATION Delta is solely compensated for its ongoing investment advisory services by charging you a management fee based on the market value of your assets under our management based upon the fee schedule set forth below: Market Value First $ 2,000,000 Over $ 2,000,000 to $ 5,000,000 Over $ 5,000,000 to $10,000,000 Over $10,000,000 Stock Rate 1.00% .70% .50% .35% Bond Rate .50% .35% .25% .15% For clients who want to maintain legacy positions in an account (for example, stocks from a previous investment account), we will monitor them and charge .25% on the value of these positions. Fees are billed quarterly in arrears based upon the market value of the assets at the end of the preceding quarter. If your relationship with us began or ended during a calendar quarter, your fee will be prorated for the appropriate number of days completed or remaining in the quarter and, where applicable, you will be issued a refund for any portion of your quarterly fee paid in advance (such as in a wrap fee arrangement) or which was otherwise unearned. Fees are rounded to the nearest dollar. We may negotiate the amount of your fee depending upon circumstances including, but not limited to, account composition and complexity, other client, employee or family relationships, etc. which may result in different fees being charged by us for client accounts similar in composition and objectives. Our employees and their family related accounts may be charged a reduced fee, or no fee, for our services. You may pay your fee to us directly upon receipt of an invoice from us or you may authorize your custodian to allow us to directly debit our fee from your account or accounts. If you choose the latter method, your custodian will not confirm our fee but will pay the amount based on the fee amount communicated to the custodian by us. You will receive a periodic statement from your custodian which will show the amount of the fee which has been sent to us. You should confirm the accuracy of our fee calculation upon receipt of your custodian’s statement. 5  The fees you pay us do not include brokerage commissions or other fees or charges associated with securities transactions implemented with or through a brokerage firm, mark‐ups or mark‐downs in principal transactions, deferred sales charges, stock exchange fees, wire transfer or related processing fees, transfer taxes or other charges mandated by law or regulation all of which will be charged to you in addition to our fee. We do not receive any portion of any of the foregoing expenses or fees. You should go to the section on Brokerage Practices in our brochure for more information on how we select or recommend brokerage firms for your securities transactions and information related to that process. You should understand that funds, including exchange traded funds (“ETFs”) and mutual funds, in which your assets are invested by us or by others, impose separate investment management fees and other operating expenses, described in the fund’s prospectus, for which you, the client, will be charged separately from the fee paid to us for our services. As we discussed in the section on Advisory Services in our brochure, we have entered into “wrap fee” arrangements with certain brokerage firms where you pay the brokerage firm an agreed upon fee for investment management by us or other investment advisory firms such as us, brokerage commissions, custodial services and possibly consulting services. We receive a portion of the “wrap fee” you pay the brokerage firm for our services. Our portion of the fee averages .75% of your assets managed by us depending upon our arrangement with the brokerage firm which sponsors the wrap fee arrangement. Clients should be aware that similar or comparable services may be available from other firms including other investment management firms at a cost higher or lower than that available through us. ITEM 6 ‐ PERFORMANCE‐BASED FEES AND SIDE‐BY‐SIDE MANAGEMENT This section does not apply to Delta. ITEM 7 ‐ TYPES OF CLIENTS Our clients include individual persons, banks or thrift institutions, pension and profit‐sharing plans, trusts, estates, charitable organizations, corporations or similar business entities, and state or municipal government entities. We do not have a minimum account size. ITEM 8 ‐ METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Delta’s methods of analysis and investment strategies incorporate the client’s needs and investment objectives, time horizon, and risk tolerance. Delta is not bound to a specific investment strategy for the management of investment portfolios, but rather considers the risk tolerance levels gathered at the account opening, as well as on an on‐going basis. Although not bound to a specific method or strategy, our primary method of investment analysis and investment strategies to provide services to our client involves the use of fundamental analysis which is the analysis of a company’s financial statements, its management, competitive advantages, markets, etc. Our primary investment strategy is the use of long‐term purchases (securities generally held for at least a year). 6  Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. These risks include market risk, interest rate risk, issuer risk, and general economic risk. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks and be prepared to bear these risks. Below are some more specific risks of investing: Market Risk. The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by the client or an underlying fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long‐term perspective and be able to tolerate potentially sharp declines in market value. Management Risk. Delta’s investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or underlying fund is not realized in the expected time frame, the overall performance of client’s portfolio may suffer. Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small‐ and mid‐cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may be affected 7  by adverse political, legislative and tax changes, as well as by financial developments that affect the municipal issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds generally are traded in the “over‐the‐ counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de‐listed from the exchange, or the activation of market‐wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Delta has no control over the risks taken by the underlying funds. ITEM 9 ‐ DISCIPLINARY HISTORY This section does not apply to Delta or any of its employees. ITEM 10 ‐ OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Brokerage Delta is affiliated through common ownership with Hightower Securities, a broker‐dealer registered with the SEC. Hightower Securities is also a licensed general insurance broker and agency, a member of FINRA, the Municipal Securities Rulemaking Board, the Securities Investor Protection Corporation (“SIPC”) and registered in various states as required. Hightower Securities operates as a full‐service introducing broker‐ dealer. Registered Investment Advisers Delta is also affiliated with certain other registered investment advisers through Hightower Holding, LLC’s ownership of such entities. Such affiliates include: Duncker Streett & Co., LLC; WealthTrust Axiom, LLC; HighTower Advisors, LLC; Harvey Investment Company, LLC; Kanawha Capital Management, LLC; Madison Avenue Financial Solutions, LLC; Rikoon Group, LLC; NEPC, LLC; and Grant Tani Barash & Altman, LLC. Though Delta shares a common holding company and certain corporate resources with these entities, 8  each of the above entities are discrete and separate investment advisers registered with the SEC. Trust Hightower Trust Company, NA is a wholly owned subsidiary of Hightower Holding, LLC and an affiliate of Delta. Hightower Trust Company, NA provides personal trust services, and can serve in multiple capacities that offer or may include administrative services, tax services and investment management services. Hightower Trust Company, NA may delegate investment advisory responsibilities for its clients to affiliates. Trust Company of Illinois is a subsidiary of Hightower Holding, LLC and an affiliate of Delta. Trust Company of Illinois is an Illinois state‐charted trust company that delivers trust and estate planning, administration, guardianship, executor and co‐executor services and retirement plan services. Trust Company of Illinois may delegate investment advisory responsibilities to its affiliates. Insurance Hightower Securities sells whole life insurance, term life, health insurance, long term care insurance and variable and fixed annuities. Accounting and Related Services GMS Surgent is a subsidiary of Hightower Holding, LLC and an affiliate of Delta. GMS Surgent is a tax and advisory firm that provides clients with tax advice and advisory services, including accounting, tax preparation and other tax and wealth planning capabilities. Affiliates and Fees Fees and expenses paid to a Hightower affiliate are predominantly separate from and in addition to the fees charged by Delta. Delta’s parent company, Hightower Holding, LLC, and its members (direct or indirect) may receive a portion of any distributions made by affiliates to Hightower Holding, LLC. Clients are not obligated to use the services of Delta affiliated entities. ITEM 11 ‐ CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Delta has adopted a written Code of Ethics under which all our access persons are generally restricted from effecting transactions in securities for their personal accounts absent written pre‐ approval by our chief compliance officer or designee in order to seek to avoid conflicts of interest with transactions being effected in client accounts. Our employees may buy or sell the same securities that we recommend that our clients invest in or that we purchase or sell on our clients’ behalf. This presents a conflict of interest between our employees’ own financial interest and the best interest of our clients. We have addressed this conflict of interest by imposing trading restrictions under the Code of Ethics 9  which include restrictions on our employees’ personal trading based upon investment activity occurring in, or being contemplated for, our clients’ accounts. There are certain exceptions from the pre‐ clearance requirements for transaction which we do not believe present a conflict of interest between our employees and our clients such as where our employees receive the same averaged price and incur the same proportional transaction costs as our clients through a block order of equity securities. Pre‐approval must also be obtained by employees before investing in certain securities. Our employees are required to submit quarterly reports relating to their personal transactions and an annual report of their personal securities holdings to us. Our Code of Ethics also contains policies and procedures which are intended to prevent the misuse of material non‐public information. A copy of our Code of Ethics is available to you upon request by contacting us through the contact information provided on the Cover Page of this brochure. ITEM 12 ‐ BROKERAGE PRACTICES Delta considers the following factors in selecting or recommending brokerage firms for your transactions and in determining the reasonableness of the compensation or other remuneration paid to the brokerage firms: Investment Styles (compatibility between Delta and the brokerage firm) • Quality of Support Services and Technology • Trade Implementation Costs • Value of Research and Related Information and Products Provided • Market Liquidity Provided • Confidentiality of Trading Intentions • • Financial Stability • Trade Error Resolution Process • Ability to Execute Difficult Trades • Value of soft dollar arrangements and products provided; • Other Factors Which May Be Identified by Delta from Time to Time We have established an Execution Review Committee which periodically reviews our brokerage practices and the reasonableness of compensation or other remuneration paid to brokerage firms and monitors our efforts to seek best execution of client transactions. Research and Other Soft Dollars Benefits: Where more than one brokerage firm satisfy our criteria, preference may be given to brokerage firms which provide us with certain brokerage and research services and products as allowed by law under Section 28(e) of the Securities Exchange Act of 1934, which Delta may use to execute client transactions even though the commissions or similar costs for particular transactions may be higher than the commissions or costs incurred by using another brokerage firm which does not provide Delta with these brokerage and research services or products. Payments to brokerage firms for these services through commission revenue rather than direct cash payments are referred to as “soft dollars”. Under these circumstances, we will make a good faith determination that the amount of commission is reasonable in relation to the value of the brokerage and research services or products provided by the brokerage firm(s) which we consider to be a 10  significant benefit to our clients. We may use these brokerage and research services and products to benefit all of our clients’ accounts, not just those whose transactions paid for the services. The brokerage and research services or products received by us under the arrangement described above include general investment research. Our use of client brokerage commissions or similar costs for transactions to obtain brokerage or research services and products presents a conflict of interest to us because we do not have to internally produce the service or product or purchase it directly elsewhere. This also means that we will have a financial incentive to select or recommend brokerage firms which provide us such brokerage and research services or products rather than based on a consideration of the lowest commission cost to our clients. To address these conflicts, Delta uses a commission comparison report to review the reasonableness of commission amounts and rates used to obtain brokerage and research services and products described above. This review is conducted during meetings of our Execution Review Committee. Charles Schwab & Co., Inc.: We may recommend that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc. (Schwab), a FINRA registered broker‐ dealer, member SIPC, to maintain custody of their assets and to effect trades for their accounts. Although we may recommend or require that clients establish accounts at Schwab, it is the client’s decision to custody assets with Schwab. Delta is independently owned and operated and not affiliated with Schwab. Schwab provides us with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors such as Delta on an unsolicited basis, at no charge so long as a total of at least $10 million of the advisor’s clients’ assets are maintained in accounts at Schwab Institutional but are not otherwise contingent upon our committing to Schwab any specific amount of business such assets in custody or trading commissions. These services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders such as our clients through commissions and other transaction‐related or asset‐based fees for securities trades that are executed through Schwab or that settle into Schwab accounts maintained by our clients. Schwab Institutional also makes available to us other products and services that benefit us but may not directly benefit our clients’ accounts. Many of these products and services may be used to service all or some substantial number of our accounts, including accounts not maintained at Schwab. Schwab’s products and services that assist us in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate 11  payment of our fees from its clients’ accounts; and (v) assist with back‐office functions, recordkeeping and client reporting. Included in the products and services provided by Schwab to us is Reuters which is a platform to access sell side research and financial news. Schwab Institutional also offers other services intended to help us manage and further develop our business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third‐party vendors for the types of services rendered to us. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third‐party providing these services to us. Schwab Institutional may also provide other benefits to our employees such as educational events or occasional business entertainment. In evaluating whether to recommend or require that our clients custody their assets at Schwab, we may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely base our evaluation on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a conflict of interest since our recommendation that our clients maintain accounts at Schwab may be based in part on the availability to Delta of all or some of the products or services described above. Directed Brokerage: We will execute transactions through a particular brokerage firm as a result of your decision to direct us to execute transactions through a particular brokerage firm or as a result of your decision to participate in a “wrap fee” arrangement in which case trades are generally executed through the brokerage firm with which you have entered into the “wrap fee” arrangement. In this situation, you will be responsible for negotiating the commission rates you pay, not us. You should be aware of our inability to negotiate commissions, obtain volume discounts and that best execution may not be achieved for transactions in your account(s). As a result, transactions in accounts directed by you to a particular brokerage firm may result in higher commissions, greater spreads or less favorable net prices than would be the case if we were authorized to choose the brokerage firm through which to execute transactions for your account(s). You should also be aware that disparities in commission charges for similar transactions in accounts in different clients of ours may exist and that there is a conflict of interest arising from such directed brokerage practices. You should be aware that transactions for accounts which we have been instructed by you, or by the brokerage firm in the event of a wrap fee arrangement, to direct to a specified brokerage firm may be placed subsequent to transactions we enter for client accounts where we determine the brokerage firm through which to execute transactions for clients. This may result in less favorable execution for those accounts where we have been instructed by you to direct trades to a specified brokerage firm for execution. You should be aware that you have brokerage options which you should consider other than instructing us to direct to your transactions to a particular brokerage firm including the use by us of other brokerage firms we determine to use for execution of client transactions possibly at a lower commission cost and that this option may be available through us. 12  Blocked Transactions: We may group or block orders from time to time for the same security for more than one client account at the same custodian in order to more effectively execute the orders. This is what is known as a “block transaction”. This process can create trading efficiencies, prompt attention to the order and improve price execution since the block transaction may be executed at various prices but averaged as to price. Personal transactions of our employees may be included in such block transactions. Where such block transactions are not fully executed, we will seek to allocate the executed portion of the block transaction on a basis which we consider fair to our clients over time. Generally, this will mean a pro rata allocation or allocation on a rotational basis although we may, in certain circumstances, allocate purchases or sales on some other basis, after consideration of factors such as taxability of the account, cash available for investment, asset mix of the account, objectives and restrictions of the account, company and industry concentrations, broker designations specified by the client, size of the execution versus the total order size, and partial positions versus full positions. Any employee transactions will be excluded from block transactions which are not fully executed. Trade Errors: Errors in executing client transactions may occur from time to time which we will seek to correct on a timely basis so that you will not incur a loss or other costs as a result of any such errors. Any loss or costs incurred as a result of the correction of such errors will be borne by us or by your broker/custodian while any market gains result from the correction of such errors will usually be retained by your broker/custodian or by you. ITEM 13 ‐ REVIEW OF ACCOUNTS Our clients’ accounts are reviewed on a continuous basis by the individual portfolio manager with primary responsibility for the particular account. Factors which may trigger more frequent reviews include change in client investment objectives or circumstances such as retirement or a large contribution or withdrawal to or from an account, significant developments or events specific to a particular security held in the account, or significant market, economic or political developments. We will provide you written reports concerning your account(s) with us on at least a quarterly basis. These quarterly reports will include total cost basis for each security, market value and income yield, the current and historical performance for the account. These reports may be grouped with other accounts related to you. This report will also include an invoice for our quarterly fee. If you are involved in a wrap fee arrangement as described in the section on Advisory Business, you may receive reports from the brokerage firm which created the wrap fee arrangement. You should also receive written reports directly from your custodian concerning your account(s) which generally contain information relating to all transactions and other account activity. ITEM 14 ‐ CLIENT REFERRALS AND OTHER COMPENSATION The Firm does not pay referral fees to independent solicitors for the referral of clients to our firm. Clients of ours who maintain custody of their accounts at Schwab will not be charged separately for custody, but Schwab will receive compensation from our clients in the form of commissions or through transaction related compensation on securities transactions executed through Schwab. Schwab also will receive a fee (generally lower than the commissions on transactions it executes) for clearance and 13  settlement of transactions executed through brokerage firms other than Schwab. Schwab’s fees for transactions executed at other brokerage firms are in addition to the other brokerage firm’s fee. Thus, we will have an incentive to cause transactions to be executed through Schwab rather than through another brokerage firm although we understand we have a duty to seek best execution of our clients’ transactions. Transactions for client accounts maintained in custody at Schwab may be executed through a different brokerage firm than trades for our other clients so transactions in accounts maintained in custody at Schwab may be executed at different times and different prices than transactions in client accounts that are executed at other brokerage firms. Please refer to the section on Brokerage Practices in our brochure for information on other economic benefits we may receive for providing services to you. ITEM 15 ‐ CUSTODY Delta is deemed to have custody of those client assets held in accounts for which the client has authorized Delta to directly debit its management fees from the client’s custodial account although the assets in those accounts are maintained separately with a qualified custodian. Some clients may execute limited powers of attorney or other standing letters of authorization that permit Delta to transfer money from their account with the client’s independent qualified Custodian to third parties. This authorization to direct the Custodian may be deemed to cause our firm to exercise limited custody over your funds or securities and for regulatory reporting purposes, we are required to keep track of the number of clients and accounts for which we may have this ability. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker‐dealer, or other independent, qualified custodian. In addition to any account statements you may receive from us, you will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate any transfers that may have taken place within your account(s) each billing period. You should carefully review these statements for accuracy and compare these statements to statements you receive from us for any discrepancies. You should also remember that the statements you receive from your custodian are your official record of your accounts and assets for tax purposes. ITEM 16 ‐ INVESTMENT DISCRETION We will accept discretionary investment authority over your assets if you agree to such an arrangement. This is typically accomplished through execution of a limited trading authority contained in your client agreement with us or through similar authority contained in a wrap fee arrangement you may execute with the brokerage firm which established the wrap fee arrangement. When executing your client agreement with us, you can further limit the extent of discretionary investment authority to be granted to us although this may impact the level of services, we can provide you. You may also place restrictions on our authority such as instructions not to make investments in certain industries or to not sell certain investments you may have due to possible adverse tax consequences to you. 14  ITEM 17 ‐ VOTING CLIENT SECURITIES We have policies and procedures in place for voting proxies relating to certain investments in your account(s) with us designed to vote in our clients’ best interests. We generally adhere to predetermined voting guidelines and will typically vote with recommendations from the management of the particular investment in your account. Proxies relating to securities held in our Model Portfolio are reviewed by our research department prior to voting by us, which will generally adhere to the predetermined voting guidelines unless the Investment Committee determines that a vote contrary to the guidelines is in the best financial interest of our clients. Any such vote will be agreed to by all members of the Investment Committee and documented in writing. We have adopted policies and procedures designed to prevent conflicts of interest from influencing proxy voting decisions made on behalf of client accounts, and to verify that our decisions are in compliance with our fiduciary obligations to clients. Generally, we do not allow clients to instruct us how to vote specific proxies although we will consider such instructions upon request. You may obtain a complete copy of our policies and procedures for voting proxies and a record of how we have voted the proxies for your investments by contacting us through the contact information we included on the Cover Page of this brochure. ITEM 18 ‐ FINANCIAL INFORMATION This section does not apply to Delta as we have never filed for bankruptcy nor are we subject to any financial conditions which could impair our ability to meet our obligations to you. In addition, we do not require nor solicit the prepayment of any advisory fees. 15