LADENBURG THALMANN ASSET MANAGEMENT INC

Ladenburg Thalmann Asset Management Inc. LAMP – MANAGED ANNUITY PROGRAM BROCHURE SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 www.ltam.com This brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”). Ladenburg is registered with the Securities and Exchange Commission (“SEC”) as a registered investment adviser. Registration does not imply any level of skill or training. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ladenburg Thalmann Asset Management Inc. is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 03/28/2025 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 28th, 2024. Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604. Material Changes: • Item 10: Other Financial Industry Activities and Affiliations: This section was amended to reflect changes to and renaming of certain related persons and affiliates. 2  Table of Contents Item 2 – Summary of Material Changes ............................................................................................ 2 Item 3 - Table of Contents................................................................................................................... 3 Item 4 - Advisory Business ................................................................................................................. 4 Ladenburg Advisory Services ............................................................................................................ 4 Item 5 - Fees and Compensation ......................................................................................................... 4 Item 6 - Performance-Based Fees and Side-By-Side Management .................................................... 5 Item 7 - Types of Clients ..................................................................................................................... 5 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................. 5 Item 9 - Disciplinary Information ....................................................................................................... 5 Item 10 - Other Financial Industry Activities and Affiliations ........................................................... 6 Payments from Third Parties .............................................................................................................. 8 Conflicts of Interest ............................................................................................................................ 9 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 9 Item 12 - Brokerage Practices ............................................................................................................11 Item 13 - Review of accounts .............................................................................................................11 Item 14 - Client Referrals and Other Compensation ..........................................................................11 Item 15 - Custody ...............................................................................................................................11 Item 16 - Investment Discretion .........................................................................................................11 Item 17 - Voting Client Securities......................................................................................................12 Item 18 - Financial Information .........................................................................................................12 Ladenburg Thalmann Asset Management – Privacy Notice ..............................................................13 Item 3 - Table of Contents 3  Item 4 - Advisory Business Ladenburg Advisory Services Each client has a Financial Adviser, who may be a Financial Adviser of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”), Osaic Advisory Services, LLC., or Osaic Wealth, Inc. all of which are affiliates of Ladenburg, as described in “Other Financial Industry Activities and Affiliations” below. The Financial Adviser may also be registered as, or a Financial Adviser of, an investment adviser that is not affiliated with Ladenburg. The Financial Adviser may also be a broker-dealer representative of Ladenburg Thalmann & Co. Inc., (“LTCO”), Triad Advisors, LLC., or Securities America, Inc. Clients who wish to participate in the LAMP – Managed Annuity Program will enter into a LAMP-Managed Annuity Program agreement. The agreement will set forth which investment advisory entity is providing consulting services in connection with the client’s account. In addition to signing the LAMP-Managed Annuity Program agreement, clients must complete documentation necessary under the applicable variable annuity contract to grant the applicable adviser and Ladenburg the authority and access to information necessary to perform the services set forth in the agreement. Clients inform their Financial Advisers of the investment objectives, risk tolerance, and investment time horizon, and any investment policies, guidelines, or reasonable restrictions applicable to the assets under the variable annuity contract that they want managed in the LAMP–Managed Annuity Program. Based on the information provided, the Financial Adviser assists the client in selecting an investment strategy for the client’s account from those available through the program. A team of investment managers employed by Ladenburg Thalmann Asset Management Inc. (“LAMP Managers”) manage the accounts in LAMP on a discretionary basis by allocating the assets between available sub-accounts in accordance with the investment strategy that the client selects and information provided by the client. Any restrictions on the management of an account imposed by a client may cause the LAMP Managers to deviate from the investment decisions they would otherwise make in managing the account. Ladenburg will not have the discretion to select a different investment strategy without the client’s written authorization. Ladenburg provides various other types of advisory services in addition to and separate from the services described in this brochure. These services are described in other Ladenburg brochures. More information about these services is available upon request. Item 5 - Fees and Compensation Each account of the program will generally be charged an asset-based fee (“Fee”) on a quarterly basis in arrears. The Fee will be calculated based on the value of the assets in the program. The rate used to calculate the Fee is subject to negotiation between the Financial Adviser and each client. The actual fee rates paid by the client will be set forth in the client’s agreement. The maximum annual Fee rate is 1.50%. In the agreement, clients will choose to have the Fee deducted either from their annuity contract or an alternative non-retirement brokerage account, or in some instances, the client may choose to receive a bill. Deduction of fees directly from the client’s annuity contract can cause the client’s contract riders to be reduced, forfeited or trigger a contingent deferred sales charge. In addition, Program Fees drawn directly from a non-qualified variable annuity account can be considered constructive income to the extent of the contract gain, and therefore can be subject to income tax and penalties if the client is under age 59 ½. Ladenburg does not provides tax advice, and Client should consult a tax professional for information about potential tax consequences related to the Program Fee and other aspects of the variable annuity contract. Either party at any time upon written notice can terminate the program agreement and a pro rata portion of the Fee will be due by the client based on the number of days elapsed during the quarter prior to receipt of the notice of termination. 4  The Fee covers the advisory services provided by the applicable adviser, and investment management services provided by Ladenburg, as described in the agreement. The Fee does not cover any other costs in connection with the variable annuity contract. Clients will typically pay a commission and other fees in connection with the purchase of the variable annuity contract. The Fee is not offset by the receipt of such compensation by an affiliate of Ladenburg. A broker-dealer affiliated with Ladenburg can receive compensation in connection with a client’s purchase of the variable annuity contract and in connection with certain sub-accounts under the contract. This compensation will typically be shared with the investment adviser, if the adviser is also a registered representative of the affiliated broker-dealer. Thus, investment adviser can receive compensation in connection with both the sale of the variable annuity contract and the provision of investment advice in the program. Thus, the investment adviser can have an incentive to recommend this type of investment or other types of investments. The affiliated broker-dealers have procedures in place to ensure that the purchase of the variable annuity contract is suitable. Ladenburg and the affiliated adviser review each new account to ensure that the provision of investment advice in connection with the account is suitable. Item 6 - Performance-Based Fees and Side-By-Side Management Neither Ladenburg nor any of its supervised persons receives performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 - Types of Clients Ladenburg provides program services to individuals and retirements accounts. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Ladenburg does not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Ladenburg cannot offer any guarantees or promises that any client’s financial goals and objectives will be met. Past performance is in no way an indication of future performance. Ladenburg uses several strategies utilizing the sub-accounts that are available for selection under the client’s variable annuity contract. Each strategy will consist of a targeted, strategic allocation. Ladenburg selects sub- accounts for each asset class in each strategy. The selection is based on due diligence conducted by Ladenburg, which evaluates the sub-accounts on a variety of performance measures and selects those with the above average ratings for inclusion in the strategies. Ladenburg periodically reviews each strategy and removes or replaces those sub-accounts that no longer meet the qualifications necessary for inclusion in the applicable strategy. At its discretion, Ladenburg may also add additional asset classes and funds to each strategy as well as replace sub-accounts to correspond to any changes made to the applicable strategy. Ladenburg also rebalances accounts periodically if the accounts’ asset allocations move beyond acceptable variance levels set for each strategy due to market movements. Ladenburg when managing the contract may not necessarily know the ancillary riders associated with the contracts. If the client and/or adviser effect one of these riders or annuitize the contract, this can impede Ladenburg’s ability to effectively manage the contract or terminate Ladenburg’s management completely. Investing in securities involves the risk of loss of principal that the client should be prepared to bear. Item 9 - Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements 5  for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. For more information about any disciplinary events that are material to an evaluation of Triad Advisors, LLC, Osaic Advisory Services, LLC, Securities America Advisors, Inc., or Arbor Point Advisors, LLC, or a separately registered investment adviser, please see their disclosure brochure. Item 10 - Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is an investment advisory firm and has been in business since October 29th, 1982. Ladenburg is a wholly owned subsidiary of Osaic Holdings, Inc. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2006 Trust. Osaic Holdings, Inc. owns 100% of both Ladenburg and LTCO, a registered broker-dealer. As such, LTCO, Triad Advisors, LLC, and Securities America, Inc. may execute trades on behalf of clients who receive advisory services from Ladenburg. Other Industry Affiliates Ladenburg has the following affiliates, which are wholly owned by Osaic Holdings, Inc. or wholly owned subsidiaries of one of Osaic, Inc.’s affiliates. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. Ladenburg Thalmann & Co. Inc. (LTCO) Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Highland Capital Brokerage Insurance Company 100% owned by Osaic Holdings, Inc. Ladenburg has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. However, these related persons are not wholly owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (BDF) Registered Investment Advisor 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. Philip Blancato and Jaime Desmond function as CEO and COO of Ladenburg respectively. In certain circumstances, BDF recommends Ladenburg’s advisory services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts and no client is under any obligation to engage the services of Ladenburg. 6  Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the Related Persons, which are wholly owned subsidiaries of Osaic, Inc., which is a wholly owned subsidiary of Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic Holdings, Inc 100% owned by OIHI 100% owned by Osaic, Inc. Osaic, Inc. Holding Company Vision2020 Wealth Management Corp. Registered Investment Advisor Osaic Institutions Holdings, Inc. (OIHI) Holding Company Osaic Institutions, Inc. Registered Investment Advisor, Broker/Dealer & Insurance Osaic Services, Inc. Broker/Dealer Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Related Persons. In that case we or our Related Persons can receive compensation when doing so which results in a conflict of interest. Your Financial Adviser, however, does not receive a portion of the compensation paid to us or our Related Persons and therefore does not have a conflict of interest in recommending the use of one of our affiliated companies. As a result of the fact your Financial Adviser is not compensated for directing you to products or services offered by our Related Persons, we believe that the Firm’s conflict of interest is mitigated. Certain principal executive officers of Ladenburg may be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg because they will not be devoted exclusively to the business of Ladenburg and can have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Ladenburg Financial Advisers can recommend that clients invest in the Ladenburg Funds for which Ladenburg acts as investment adviser, and LTCO acts as distributor. Transactions for the funds are generally executed through LTCO. For more information see the prospectus. These recommendations create a conflict of interest because Ladenburg and LTCO generally receive more compensation in connection with the purchase of these investments than they do in connection with the purchase of other investments. In addition, these funds pay fees in connection with services or distribution, such as 12b-1 fees. These fees are paid to LTCO as broker-dealer. Ladenburg Financial Advisers can recommend Premier Trust to provide trust and administrative services. Premier Trust provides full disclosure with respect to its trust and administrative services and related costs. As explained above, LTCO acts as a dealer with respect to certain securities, and as such, may execute transactions for Ladenburg clients as principal. As a dealer, LTCO can receive a "mark-up," "mark-down," and/or spread in the net price at which principal transactions are executed. This compensation is in addition to other compensation that client pays to Ladenburg and its affiliates. Thus, Ladenburg has a conflict of interest in recommending or deciding to execute trades through LTCO on a principal basis. Ladenburg addresses this 7  conflict of interest in the following ways. After receiving disclosures about a specific principal transaction with LTCO, clients have the opportunity to reject the transaction before it is completed, to the extent required by applicable law. In addition, Ladenburg has policies and procedures in place to assure that clients receive best execution with respect to principal trades, regardless of whether the trade is executed by LTCO or an unaffiliated dealer. Ladenburg can also recommend that clients invest in securities issued in an initial public and/or secondary offerings (“new issues”) for which LTCO acts as a manager, underwriter and/or a member of the selling group. Ladenburg has a conflict of interest in recommending these securities for several reasons. First, LTCO receives all or a portion of the gross spread – the difference between the price that the client pays for the security and the price that LTCO purchases the security for -- in connection with such sales. This gross spread is generally 7% but can be higher or lower in connection with certain offerings. Ladenburg Financial Advisers generally receive a portion of this compensation as broker-dealer representatives of LTCO. In addition, LTCO has a substantial interest—both financially and with respect to its reputation—in assuring that the offering is successful by having a large number of the securities purchased. Finally, in connection with certain offerings, LTCO has an obligation to purchase and resell a certain number of securities. Thus, because of its affiliation with LTCO, Ladenburg has incentives to recommend investments in these offerings for these reasons, rather than based on a client’s needs. To address these conflicts, Ladenburg has policies and procedures in place to make sure that securities in initial public offerings are recommended only to clients for whom they are suitable given the client’s investment objectives and assets. In addition, clients are generally given transaction specific disclosure prior to the client’s decision to invest in such securities. Securities acquired in initial public and secondary offerings may be oversubscribed and Ladenburg has policies and procedures in place for the allocation process. Ladenburg can also compensate its Financial Advisers for the costs of marketing, distribution, business and client development and educational enhancement incurred by the Financial Adviser for the promotion of Ladenburg’s services. This compensation can be based on based on assets under management or otherwise advised. Reverence Capital Partners manages the private investment funds that indirectly own a majority of Osaic Holdings, Inc., which in turn owns the Firm, as well as private investment funds that hold a minority investment in Envestnet. In addition, select management and Financial Advisors own less than 0.5%, indirectly through a Reverence Capital Partners-controlled entity, in Envestnet. As a result, Financial Advisors associated with Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp in particular, have an incentive to offer and recommend to you programs that use Envestnet’s services. Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp have procedures designed to mitigate this conflict. Payments from Third Parties In addition to the various types of compensation Ladenburg’s affiliates can earn from clients in connection with effectuating the investment advice Ladenburg renders to clients, these affiliates can also receive payments from third parties in connection with services rendered to Ladenburg’s clients. For example, LTCO and other affiliated broker-dealers can receive distribution or service (“trail”) fees from the sale of certain unaffiliated mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services. These fees are distributed from the fund’s total assets. LTCO can pay a portion of the distribution fees it earns to Ladenburg’s Financial Advisers in their capacity as broker-dealer representatives of LTCO. For certain accounts custodied at NFS, LTCO credits 12b-1 fees received for Ladenburg financial consultants back to the client accounts. Ladenburg’s affiliated broker-dealers can also participate in revenue-sharing arrangements based on fees paid by mutual funds to participate in no-transaction-fee (NTF) platforms made available by custodians. 8  Ladenburg’s affiliates can also receive payments called “revenue sharing payments” and/or “marketing allowances” from certain product sponsors (“Strategic Partners”) including mutual funds, insurance companies, and Non-Traded products such as Real Estate Investment Trusts (“REITS”). These payments are not shared with Ladenburg’s Financial Advisers. For more detailed information about the products in the Strategic Partners program, you can request the complete disclosure document from your Financial Adviser. Qualified custodians are another source of revenue to Ladenburg’s affiliated broker-dealers. Specifically, NFS and Pershing provide significant compensation to our affiliated broker-dealers in their capacity as introducing broker/dealer to offset its general operating expenses based on the number of accounts and/or account assets held by our affiliated broker dealers. The specific terms of this compensation differ between NFS and Pershing. Certain custodian fees can apply to your brokerage accounts. In some instances, the affiliated broker-dealers pays a portion of the fee charged. In other instances, the affiliated broker-dealers apply a markup to these fees. In this regard, Ladenburg’s affiliates broker-dealers can receive revenue based upon client activity, as well as the amount of assets custodied with these firms. The types of revenue include, but are not limited to, margin interest charges, IRA fees, inactivity fees, 12b-1 trails and other fees set forth in the custodian’s Schedule of Client Fees and Charges. Our affiliated broker-dealers exercise no discretion, nor provide any advice or recommendation in the selection of the Custodian for any specific account or client. As a result, any difference in compensation to our affiliated broker-dealers is based solely on the contracts with the Custodians and your Financial Adviser’s election of a Custodian. Secondly, Financial Advisers do not share in any compensation paid by the custodians to our affiliated broker-dealers. As a result, Financial Advisers have no financial conflict of interest in any recommendation of a Custodian to clients. For more information regarding custodial fees and the above forms of compensation, please see the Disclosures section of the respective affiliated broker-dealer at our Parent Company’s website: https://osaic.com/disclosures for the Pershing and NFS Schedule of Client Fees and Charges. Conflicts of Interest The various compensation arrangements discussed in this section of the Brochure present conflicts of interest for Ladenburg, because they incentivize the firm and its Financial Advisers to select or recommend products that provide such payments. To mitigate these conflicts, Ladenburg prohibits its Financial Advisers and other supervised persons from selecting or recommending any product based solely on payments that Ladenburg, its employees or its affiliates can receive in connection with the promotion of that product. Instead, Ladenburg requires Financial Advisers and other supervised persons to advise and make recommendations in clients’ best interests, taking into account clients’ needs, investment objectives and risk tolerances. Ladenburg maintains policies and procedures to ensure recommendations are suitable and require that its Financial Advisers always acts in the client’s best interest. Ladenburg also maintains a supervisory structure to monitor the advisory activities of its Financial Advisors to reduce conflicts of interest. Ladenburg offers a number of investment advisory programs that can include the Ladenburg Funds, a series of mutual funds that are managed by Ladenburg. Since Ladenburg receives an internal management fee from the funds, a conflict of interest exists. To mitigate this conflict, Ladenburg has policies and procedures governing the programs that include an allocation to the Ladenburg Funds. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. All supervised persons at Ladenburg must acknowledge the 9  terms of the Code of Ethics and personal securities transactions and holdings annually, or as amended. The Code of Ethics sets forth detailed policies and procedures regarding the personal trading of its personnel. The Code of Ethics also contains policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. A copy of the Ladenburg Code of Ethics may be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. Ladenburg personnel are required to conduct their personal investment activities in a manner that is not detrimental to its advisory clients. Ladenburg personnel are not permitted to transact in securities except under circumstances specified in the Code of Ethics. Ladenburg may give advice, take action, or hold or deal in securities for some clients or accounts, including Ladenburg’s own accounts, which differs or may be similar at times from the advice it gives, action it takes, or securities it holds or deals for other clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Ladenburg will: (a) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (b) at all times place the interests of clients first while, at the same time, allowing employees to invest for their own accounts; (c) disclose all actual and potential conflicts; (d) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (e) conduct all personal trading consistent with the Rules and in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility; and (f) not use any material non-public information in securities trading. The Code of Ethics also establishes policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Ladenburg’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. These pre-clearance requirements and the exceptions are defined in the Code of Ethics. Ladenburg and its employees may not enter orders for accounts in which they have a beneficial ownership interest to benefit from their knowledge of clients’ orders in a particular security (“front-running”). Ladenburg defaults to LTCO’s front running and personal trading policies as the affiliate broker dealer. In addition to those requirements, Ladenburg Access Persons will not be approved to trade in securities that are ETFs and/or Mutual Funds that are held in Ladenburg’s discretionary portfolios within 5 days of a rebalance by Ladenburg. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Ladenburg and its clients. Certain clients also can maintain accounts at LTCO for which Ladenburg does not act in an advisory capacity. In providing execution services to these accounts separate and apart from the client’s advisory accounts, LTCO may enter into transactions as principal. These activities are separate and apart from Ladenburg’s advisory services. The Code of Ethics is enforced through compliance monitoring activities and surveillance. In cases where the firm discovers that an employee has violated a firm policy and/or procedure, the firm’s code of business conduct or code of ethics, a state or federal law, regulation of the SEC, or other regulatory agency, the Compliance Department will take appropriate steps to investigate the circumstances and will take action commensurate with the manner of the violation. Such actions could take the form of a written warning to the employee in conjunction with the firm’s Legal Department or be as serious as disciplinary action up to and including termination. Any such investigations will be brought to the appropriate regulator’s attention, if 10  necessary, which can result in a disclosure of the violation on the employee’s U-4 form, if required. Item 12 - Brokerage Practices With respect to the program, Ladenburg generally does not aggregate orders. None of Ladenburg’s affiliated broker-dealers acts as broker-dealer with respect to the trading of sub-accounts in the program. A broker-dealer affiliate of Ladenburg can earn a commission in connection with the sale of the variable annuity contract to the client. Ladenburg does not generally receive research or other products or services, otherwise known as “soft dollars” in connection with the program. Item 13 - Review of accounts Ladenburg reviews the accounts in the program periodically. These investment reviews are part of the ongoing investment review process which includes peer analysis, performance ranking, risk analysis, investment manager conference calls, and model rebalancing. Ladenburg does not independently verify information provided by a variable annuity sponsor, client or other third party, nor does Ladenburg guarantee the accuracy or validity of such information. Ladenburg is not liable in connection with its use of any information provided by a client, a variable annuity sponsor, or other third-party in any performance reviews it provides to clients. Certain Ladenburg Financial Advisers can provide written reports to their clients. Item 14 - Client Referrals and Other Compensation Ladenburg does not enter into agreements with third parties that will solicit clients for this program. Item 15 - Custody Ladenburg does not take custody of any client assets. However, certain clients have the option of authorizing Ladenburg to debit advisory fees from their custodial account. All client assets are held by an independent qualified custodian, which may be a broker-dealer, bank or trust company. Clients will receive account statements from the broker-dealer, bank or other qualified custodian holding the clients’ assets at least on a quarterly basis. Clients should carefully review those statements. Clients who also receive account reviews from Ladenburg should compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of clients’ accounts. Any account information provided by Ladenburg is for informational purposes only. Ladenburg may have standing letters of authorization granting it first-party asset movement authority on its clients’ accounts at certain of Ladenburg’s qualified custodians. Ladenburg provides the qualifying Custodian with the client’s authorization in writing. The qualifying Custodian has a record that the client has identified the accounts for which the transfer is being effected as belonging to the client (both sending and receiving accounts). Ladenburg’s authority to transfer client assets between clients’ accounts at the same qualified custodian or between another independent qualified custodian, (which may be a broker-dealer, bank or trust company) in which both have access to the sending and receiving account numbers and client account name(s) are deemed to be first party asset movement and does not constitute custody. Item 16 - Investment Discretion As described in “Advisory Business” above, clients engage Ladenburg to manage their assets on a discretionary basis. Before Ladenburg assumes discretionary authority over any account, the client must sign an investment management agreement with Ladenburg. As set forth in the agreement, Ladenburg 11  will trade sub-accounts available through the variable annuity contract on a discretionary basis in accordance with the investment strategy selected by the client and any limitations set by the variable annuity sponsor. Ladenburg will not have the discretion to select a different investment strategy without the client's written authorization. Item 17 - Voting Client Securities Ladenburg is expressly precluded from taking any action or rendering any advice with respect to the voting of proxies solicited by, or with respect to, the issuers of any securities in the program. The client expressly retains the authority and responsibility with respect to voting proxies for the account(s) or will delegate discretion with respect to voting such proxies to a third party. If Ladenburg receives any proxy materials that pertain to securities held in the Account, Ladenburg will forward the materials to the person designated by the client. Item 18 - Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 12  Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice FACTS What does Ladenburg Thalmann Asset Management Inc. do with your personal information? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 1  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO Yes Yes  If your financial professional terminates his or her relationship with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic Holdings, Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 2  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. Ladenburg Thalmann Asset Management Inc., is an SEC registered investment adviser. 03/2025 © Ladenburg Thalmann Asset Management • 640 5th Avenue, 4th Floor • New York, NY 10019 • 800-995-5267 • ltam.com 3 

Ladenburg Thalmann Asset Management Inc. Investment Consultant Services (ICS) Wrap Fee Program Brochure SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 www.ltam.com This wrap fee program brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ladenburg Thalmann Asset Management Inc. is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 03/28/2025 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 28th, 2024. Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604. Material Changes: • Item 9: Additional Information: Other Financial Industry Activities and Affiliations: This section was amended to reflect changes to and renaming of certain related persons and affiliates. 2  Table of Contents Item 2 – Summary of Material Changes ....................................................................................................... 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Services, Fees and Compensation .................................................................................................. 4 Item 5 – Account Requirements and Types of Clients ................................................................................ 10 Item 6 – Portfolio Manager Selection and Evaluation ................................................................................ 10 Item 7 – Client Information Provided to Ladenburg ................................................................................... 14 Item 8 – Client Contact with Ladenburg ..................................................................................................... 14 Item 9 – Additional Information ................................................................................................................. 15 Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice ................................................ 21 Item 3 – Table of Contents 3  Item 4 – Services, Fees and Compensation Consulting Services Each client has an adviser, who may be a Financial Adviser of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”), Osaic Advisory Services, LLC, or Osaic Wealth, Inc. Osaic Advisory Services, LLC, and Osaic Wealth, Inc., are affiliates of Ladenburg, as described in “Other Financial Industry Activities and Affiliations” below. The adviser may also be registered as, or a Financial Adviser of an investment adviser that is not affiliated with Ladenburg. The adviser may be a broker-dealer representative of Ladenburg Thalmann & Co Inc. (“LTCO”) or Osaic Wealth, Inc. Clients who wish to participate in the Ladenburg Thalmann Asset Management Investment Consultant Services Program (“ICS”) will enter into an ICS agreement. The ICS agreement will set forth which investment advisory entity is providing consulting services in connection with the client’s account. Clients inform their advisers of the investment objectives, risk tolerance, and investment time horizon, and any investment policies, guidelines, or reasonable restrictions applicable to the assets they designate for investment through the ICS Program. Based on the information provided, the adviser assists the client in selecting one or more managers available through the Program (“ICS Managers”), which may include Ladenburg, to provide discretionary management services for the client’s account from those available through ICS. Portfolio Management ICS Managers manage ICS accounts on a discretionary basis in accordance with the investment strategy that the client selects, and information provided by the client. Certain ICS Managers and/or investment strategies have account minimums that may preclude clients from having their accounts managed directly by the manager selected. If applicable, the selected ICS Manager will provide their investment model to Ladenburg for direct account management. Any restrictions on the management of an account imposed by a client may cause the ICS Managers to deviate from the investment decisions they would otherwise make in managing the account. Client’s initial selection of ICS Manager(s) and the designation of which assets will be managed by each manager shall be set forth in the ICS agreement. For eligible accounts, Ladenburg shall notify each ICS Manager of the client’s designation and shall notify manager about any reasonable investment restrictions the client has placed on the investments in the accounts. The selection of each ICS Manager will not be effective until accepted by that manager. The ICS Manager is entitled to decline management of an account for any reason. Client understands that an account may be unmanaged for a period of time before the account is both accepted by the ICS Manager and funded to meet the minimum account size. Client understands that each ICS Manager selected to manage account assets may have investment discretion over the applicable Account. For those accounts following a Manager’s investment model, Client understands that Ladenburg will have investment discretion over those accounts. In addition to the manager having investment discretion over the investments in the account, the client grants Ladenburg discretionary authority to replace any ICS Manager selected, add one or more additional ICS Managers, or reallocate assets among selected ICS Managers at any time. Clients may also replace or add a manager by notifying their adviser or Ladenburg in writing of both the new manager and the manager to be replaced, if applicable, subject to acceptance by Ladenburg. For any period between terminating an old manager and acceptance of the account by a new manager an account will not be managed, but the Wrap Fee will continue to be charged to the account as described below. Execution of Trades A broker-dealer affiliated with Ladenburg, and the adviser typically executes trades for accounts in ICS. The specific broker-dealer will be named in the ICS agreement. If a Ladenburg adviser is providing consulting services, the broker-dealer will generally be Ladenburg Thalmann & Co. Inc. If an Osaic Wealth, Inc. adviser is providing consulting services, Osaic Wealth Inc. will generally act as broker-dealer. If a registered broker-dealer representative who is registered separately as an investment adviser is 4  providing consulting services, one of the affiliated broker-dealers will generally act as broker-dealer. In certain cases, client may direct that transactions for the client’s ICS account be executed through an unaffiliated broker-dealer named by the client in the ICS agreement. In accordance with applicable law and regulation, broker-dealers can execute principal trades for the account(s). In addition, the broker-dealer has the authority to effect “agency-cross” transactions (i.e. transactions for which a broker-dealer acts as broker for both the client and the counterparty to the transaction) for the account(s) in accordance with applicable law and regulations. In both a principal and agency-cross trade, the affiliated broker-dealer of Ladenburg can receive compensation from the other party for such a transaction and, thus, Ladenburg can have a potentially conflicting division of loyalties and responsibilities. Client can revoke authorization to effect agency cross transactions at any time by written notice to Ladenburg. In certain cases, the adviser can recommend/require that clients establish brokerage accounts to maintain custody of clients’ assets and to effect trades for their accounts with a broker-dealer that is not affiliated with the adviser or Ladenburg (“Unaffiliated Broker”). The Unaffiliated Broker will be named in the ICS agreement. The final decision to select an Unaffiliated Broker is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA account holder. The Unaffiliated Broker may provide adviser or Ladenburg with access to its institutional trading and customer services, which may not be available to retail investors. These services are generally available to independent advisers on an unsolicited basis; however, certain Unaffiliated Brokers only provide the services at no charge as long as a designated amount of the adviser’s clients’ assets are maintained in accounts with the Unaffiliated Broker. This creates a conflict of interest as the adviser has an incentive to recommend an Unaffiliated Broker over other broker-dealers. Unaffiliated Brokers may make available other products and services that benefit the adviser or Ladenburg but may not benefit the clients’ accounts. These benefits can include national, regional or Ladenburg/investment adviser specific educational events organized or sponsored by the Unaffiliated Broker. Other potential benefits can include occasional business entertainment, software, research, support functions, and or professional services provided by the Unaffiliated Broker. Thus, an adviser’s recommendation/requirement that clients maintain their assets in accounts at a particular Unaffiliated Broker may be based in part on the benefit the investment adviser of the availability of certain products and services provided by the Unaffiliated Broker and not solely on the nature, cost or quality of custody and brokerage services provided by the Unaffiliated Broker, which creates a potential conflict of interest. Custody Ladenburg does not take custody of any client assets. However, certain clients have the option of authorizing Ladenburg to debit advisory fees from their custodial account. All client assets are held by an independent qualified custodian, which may be a broker-dealer, bank or trust company. Clients will receive account statements from the broker-dealer, bank or other qualified custodian holding the clients’ assets at least on a quarterly basis. Clients should carefully review those statements. Clients who also receive account reviews from Ladenburg should compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of clients’ accounts. Any account information provided by Ladenburg is for informational purposes only. Ladenburg may have standing letters of authorization granting it first-party asset movement authority on its clients’ accounts at certain of Ladenburg’s qualified custodians. Ladenburg provides the qualifying Custodian with the client’s authorization in writing. The qualifying Custodian has a record that the client has identified the accounts for which the transfer is being effected as belonging to the client (both sending and receiving accounts). Ladenburg’s authority to transfer client assets between clients’ accounts at the same qualified custodian or between another independent qualified custodian, (which may be a broker- dealer, bank or trust company) in which both have access to the sending and receiving account numbers and client account name(s) are deemed to be first party asset movement and does not constitute custody. 5  Fees and Compensation Each account in ICS will generally be charged an asset-based fee (“Wrap Fee”) on a quarterly basis. The Wrap Fee will be calculated based on the value of the ICS assets in the account. The rate or rates are used to calculate the Wrap Fee are subject to negotiation between the adviser, Ladenburg, and each client. The actual fee rates paid by the client will be set forth in the client’s ICS agreement. The maximum annual Wrap Fee rates are: Value of Account Assets Maximum Annual Fee Rate Up to $500,000 3.00% Next $500,000 2.75% Next $1,000,000 2.50% Assets Over $2,000,000 2.00% The Wrap Fee rate can be either a flat annual fee rate (maximum rate of 3.00%) or will be a blended fee using two or more of the rate tiers set forth above. The blended rate is calculated by charging a lower rate on the assets above the designated tiers. The Wrap Fee will generally be charged in advance. However, certain clients may be charged in arrears. Certain clients may also be charged monthly rather than quarterly. Whether the Wrap Fee is charged in advance or in arrears, or quarterly or monthly, is set forth in the client’s ICS agreement. Either party at any time upon written notice may terminate the ICS agreement and a pro rata portion of any Wrap Fee paid by the client in advance will be remitted to the client based on the number of days left in the quarter following receipt of the notice of termination by Ladenburg. When the Wrap Fee is paid in arrears, a pro rata portion of the Wrap Fee will be due by the client based on the number of days elapsed during in the quarter prior to receipt of the notice of termination. The Wrap Fee covers the consulting services provided by the adviser, the portfolio management services provided by ICS Manager(s), ICS Manager selection, other advisory and program administrative services provided by Ladenburg, execution of transactions through the broker-dealer named in the agreement and custodial services (unless otherwise agreed between the custodian and the client). Ladenburg’s portion of the Wrap Fee as program sponsor ranges from 0.05% to 0.60%. For accounts following ICS Manager models being managed by Ladenburg, a portion of Ladenburg’s Wrap Fee covers the cost associated with the investment information provided by the ICS Manager. If the adviser is independently registered as an investment adviser, the broker-dealer with whom the adviser is associated can receive a portion of the Wrap Fee for certain administrative services provided. The ICS Manager’s portion of the fee (which is retained by Ladenburg if it acts as ICS Manager) ranges from 0.20% to 0.40%. The ICS Manager can share its fee with third parties that it contracts with to provide it with services in connection with the accounts. 6  ICS Wrap Fee Components Range of Fees (Maximum Annual Program Fee) Ladenburg Sponsor Fee 0.05% - 0.60% Adviser Fee 0.25% - 1.75% ICS Manager Fee 0.20% - 0.40% Brokerage/Clearing/Custody Fee 0.05% - 0.25% Total Fee Range 0.55% - 3.00% The Wrap Fee does not cover: • Brokerage commissions or other charges resulting from transactions not effected through the broker-dealer named in the client’s ICS agreement • Compensation received by dealers executing principal trades, including any “mark-up,” “mark- down,” and/or spread in the net price at which transactions are executed • Short term redemption fees that can be charged in connection with certain funds (see below) • Any internal management operating fees or expenses imposed or incurred by a mutual fund or other pooled investment vehicle • Any additional custodial services contracted for directly by the client with the custodian • "Mark-ups" and "mark-downs" or "dealer spreads" that broker-dealers, including affiliates of Ladenburg, can receive when acting as principal in certain transactions • Certain costs or charges that may be imported by the broker-dealer or custodian named in the client’s ICS agreement or third parties, including costs associated with exchanging foreign currencies, odd-lot differentials, ADR fees, IRA fees, transfer taxes, exchange fees, wire transfer fees, postage fees, confirmation, statement, prospectus fees and other fees or taxes as required by law Further, to the extent that cash used for investment through ICS comes from redemptions of the client’s mutual fund or other investments outside of ICS, there can be tax consequences or additional cost from sales charges previously paid and redemption fees incurred. Such redemption fees would be in addition to the Wrap Fee on those assets. Certain clients who direct ICS Managers to execute transactions through an Unaffiliated Broker will not pay a Wrap Fee. These clients will pay one fee (“Program Fee”) that covers all of the services covered by the Wrap Fee except for execution of transactions and custodial services, which the client will pay for separately. The client can be charged a separate asset-based fee for execution of transactions through the broker-dealer named in the agreement and for custodial services or the client can pay separate transaction charges and custodial fees. The fee structure will be set forth in the ICS agreement or in other documents provided to the client. In addition to the Wrap Fee, each mutual fund or exchange-traded fund (ETF) in which a client may invest also bears its own investment advisory fees and other expenses. The mutual funds available through the ICS Program may be available directly from the funds pursuant to the terms of their prospectuses and without paying the Wrap Fee and exchange-traded funds are available outside of the Program without paying the Wrap Fee, subject to applicable commissions and/or transaction charges. Further, to the extent that cash used for investments through ICS comes from redemptions of client’s mutual fund or other investments outside of ICS, there can be tax consequences or additional cost from sales charges previously paid and redemption fees incurred. Such redemption fees would be in addition to the Wrap Fee on those assets. 7  The broker-dealer and/or custodian will receive payments from certain mutual funds (including money market) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services and are distributed from the fund’s total assets. These fee arrangements will be disclosed upon request of a client and are available in the applicable fund’s prospectus. LTCO and Ladenburg’s other affiliated broker-dealers receive fees in connection with the client assets participating in the Bank Deposit Sweep Program and the Insured Cash Account Program, which fees are in addition to the management fee that Ladenburg receives in connection with such assets pursuant to the client’s advisory contract. When your Program Account is maintained at one of our affiliated broker-dealer’s clearing firms, Pershing, LLC (“Pershing”) or National Financial Services, Inc. (“NFS”), your free credit balance will be automatically deposited or “swept” to a deposit account at one or more banks whose deposits are insured up to applicable limits by the Federal Deposit Insurance Corporation (“FDIC”) (the “Sweep Program”). Under the Sweep Program, our affiliated broker-dealers, maintain two FDIC-insured deposit programs, the Bank Deposit Sweep Program (“BDSP”) and the Insured Cash Account Program (“ICAP”), that create financial benefits for our affiliated broker-dealers as described below. For certain Program Account types, free credit balances are swept to a money market mutual fund product (the “Money Market Mutual Fund Program”). Please see the Sweep Program Terms and Conditions document, available from your Financial Adviser or from the website listed below, for full details about the Sweep Program. As set forth in the terms of your Customer Agreement with our affiliated broker-dealer, you may remove your Program Account from participating in the Sweep Program by notifying your Financial Adviser. If you remove your Program Account from the Sweep Program, cash balances will be held by the clearing firm as a free credit balance. In addition, there are always alternatives for the short-term investment of cash balances, including non-sweep money market mutual funds, treasury bills, and brokered certificates of deposit, that offer higher returns than the sweep options made available to you. FDIC Insured Deposit Program (BDSP & ICAP) Eligible account types: all accounts except ERISA Title 1 accounts, 403(b)(7), & Keogh plans. Free credit balances swept to a deposit account will earn interest that is compounded daily and credited to your Program Account monthly. Interest begins to accrue on the date of deposit with the banks participating in the program (“Program Banks”), through the business day preceding the date of withdrawal from the deposit account. The daily rate is 1/365 (or 1/366 in a leap year) of the posted interest rate. Bank Deposit Sweep Program-BDSP Our affiliated broker-dealers have established deposit levels or tiers which ordinarily pay different rates of interest depending on deposit balances. Generally, Program Accounts with higher deposit balances receive higher rates of interest than accounts with lower balances. The interest rate payable to you is determined by our affiliated broker-dealers and is based on the amounts paid by the Program Banks to obtain the deposits. The amount our affiliated broker-dealers retain, less a fee paid to the clearing agent and the third- party administrator, will not exceed 600 basis points (6.00%) per year (the “Maximum Program Fee”) on the average daily balances held in the BDSP. Interest paid on the deposit accounts will generally be lower than the rate of return on (i) other investment products that are not FDIC insured, such as money market mutual funds and (ii) on bank deposits offered outside of the BDSP. Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. The income our affiliated broker-dealers earn from Program Banks based on your balances in BDSP will in almost all circumstances be substantially greater than the amount of interest you earn from the same balances. As such, our affiliated broker-dealers receive a substantially higher percentage of the interest generated by deposit balances in the BDSP than the interest credited to your accounts. When evaluating whether to utilize the Sweep Program and the extent to which the fee exceeds the interest rate you receive, 8  you should assume that our affiliated broker-dealers are receiving the Maximum Program Fee as described above. Insured Cash Account Program - ICAP Our affiliated broker-dealers will receive a monthly per-account fee for services it provides in connection with maintaining and administering the Sweep Program for IRAs held in an advisory/ fee-based account (the “Sweep Account Fee”). The Sweep Account Fee that each of our affiliated broker-dealers can earn from Program Accounts participating in ICAP is subject to a maximum monthly per account fee that is between $34.25 and $36.75. Please refer to the applicable Sweep Program Terms and Conditions document, which you can obtain from your Financial Adviser or from the website listed below; refer to “Disclosures,” then to the FDIC Insured Deposit Program used in your account (ICAP), for further details about the maximum monthly per account fee. The Sweep Account Fee does not depend on or vary with (and is not affected by) the actual amounts held in any particular account or your Program Account. Thus, the compensation for Program Accounts that participate in ICAP is composed solely of the Sweep Account Fee. The fee received may differ among each Program Bank. You will have no rights to the amounts paid by the Program Banks, except for interest actually credited to your account. The Sweep Account Fee will reduce the interest you are paid on the amount of assets in your Program Account. The Sweep Account Fee will generally be paid by the Program Banks on your Program Account’s behalf; however, the Fee or any portion thereof can be deducted directly from your Program Account if, for example, the amounts paid by the Program Banks are insufficient to cover the Sweep Account Fee. In the event that we debit all or a portion of the monthly account fee from your account, each such amount will be reflected on your account statement. The amount of fees received by our affiliated broker-dealers, the clearing agent, and any other service provider reduces the interest you receive on your deposit account(s). Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. Because the Sweep Program generates significant payments from third parties (i.e., the Program Banks that participate in BDSP and/or ICAP) to our affiliated broker-dealers, a conflict of interest exists. A conflict of interest also arises because our affiliated broker-dealers earn more compensation from cash balances being swept to or maintained in the Sweep Program than if you purchase other investment funds or securities. The more client deposits held in BDSP, and the longer such deposits are held, the greater the compensation our affiliated broker-dealers, the clearing firms, and the third-party administrator receive. By investing through an advisory account, the compensation our affiliated broker-dealers receive from the BDSP or ICAP, as applicable, is in addition to the advisory fees that you pay. This means that our affiliated broker- dealers earn two layers of fees on the same cash balances in client advisory accounts with them. In addition, a conflict of interest arises as a result of the financial incentive for our affiliated broker-dealers to recommend and offer a Sweep Program over which they have control of certain functions. Our affiliated broker-dealers have the ability to establish and change interest rates paid on Sweep Program balances, to select or change Program Banks that participate in the BDSP and ICAP, and to determine the tier levels (if applicable) at which interest rates are paid, all of which generates additional compensation for our affiliated broker-dealers. Our affiliated broker-dealers maintain policies and procedures to ensure recommendations made to you are in your best interest. For additional information about the Sweep Program for accounts custodied at Pershing and NFS, please visit our website located at https://osaic.com/disclosures/cash-sweep-program. Other forms of compensation that LTCO, Ladenburg’s Financial Advisers acting in their capacity as LTCO registered representatives, and/or Ladenburg’s other affiliated broker-dealers can earn in connection with the sale of investment products recommended to clients by Ladenburg are described in the Other Financial Industry Activities and Affiliations section below. 9  Item 5 – Account Requirements and Types of Clients The minimum amount of assets required to open an account in ICS is $100,000 for equity managers and $250,000 for fixed income managers. These minimums are subject to negotiation and can vary depending on the investment manager and/or strategy. Managers may waive these minimums under certain circumstances or offer their investment models to Ladenburg for clients that might otherwise not have access to these managers due to account minimum constraints. Should the market value of an account fall below the stated minimum, Ladenburg will have the right to require that additional monies be deposited to bring the account value up to the required minimum or close the account. The following types of clients may participate in ICS: individuals, including high net worth individuals, including small business owners, pension and profit-sharing plans, including the plan participants, trusts, estates and charitable organizations, corporations or other business entities, Taft-Hartley plans, and not for profit entities. Item 6 – Portfolio Manager Selection and Evaluation Ladenburg selects the ICS Managers that are available through the ICS program. If the ICS Manager manages accounts using more than one investment strategy, Ladenburg may also select which of these investment strategies to include in ICS. Thus, portfolio managers included in ICS may manage accounts using an investment strategy that is not included in ICS. Each ICS Manager has entered into a contract with Ladenburg to manage client accounts or provide investment models as set forth in the ICS client agreement. Ladenburg reviews portfolio managers and investment strategies to determine whether they should be included in ICS. These reviews generally employ a multi-phase approach to researching and selecting suitable managers. Managers are evaluated using data and information from several sources, including the manager and, if available, independent databases. Among the types of information analyzed are historical performance, investment philosophy, investment style, historical volatility and correlation across asset classes. Also reviewed are the manager’s disclosure documents, marketing brochures, due diligence questionnaires and other relevant information that help demonstrate the manager’s investment process. Ladenburg does not, however, verify the accuracy of the information provided to our firm with outside data sources. ICS Manager performance is monitored by Ladenburg. Managers who under-perform relative to the applicable asset class and or style will likely be removed from the program. Ladenburg practices careful judgment and discretion when determining whether to include each ICS Manager in the program. However, Ladenburg does not independently verify ICS Manager returns, but rather relies on the returns presented by the ICS Manager and/or third-party sources with the exception of those ICS Manager strategies which are managed directly by Ladenburg. Ladenburg also uses a third-party database to monitor and evaluate investment managers’ performance. The data is typically updated quarterly. The system provides customizable single manager reviews and reporting tools with statistics such as rate of return, standard deviation, alpha, beta, R squared, tracking error, Sharpe ratio, information ratio, etc. It also has customizable multi-manager comparisons, covering similar statistics on a total return and rolling return basis. Advisers identify specific ICS Managers for particular clients based on asset size, any investment restrictions the client may wish to impose, any investment guidelines or policies that the client may have or other factors that may make a particular manager more desirable to the client. Clients are responsible for the initial selection of ICS Managers. 10  Ladenburg has discretionary authority to replace any ICS Manager selected by a client, add one or more additional ICS Managers, or reallocate assets among selected ICS Managers at any time. Factors that would cause Ladenburg to replace an ICS Manager can include but are not limited to the following: the ICS Manager does not perform as well as other managers with a similar investment strategy or style, a change in management personnel or a change in their strategy or discipline that is deemed no longer beneficial to Ladenburg or the client, the determination of significant risk or impairment as discovered through due diligence, a significant regulatory deficiency, or a violation of the terms of agreement held between the ICS Manager and Ladenburg. Clients may also replace or add a Manager by notifying Adviser in writing of both the new ICS Manager and the Manager to be replaced, if applicable, subject to acceptance by Ladenburg. For any period between terminating an Old Manager and acceptance of the account by a New Manager an account will not be managed, but the Wrap Fee will continue to be charged to the account. Ladenburg may provide clients with information about ICS Managers. The information may be prepared by Ladenburg or by a third party and is based on and/or incorporates information provided by ICS Managers and other third-party sources. Ladenburg believes that this information is accurate; however, Ladenburg does not independently verify or guarantee the accuracy or completeness of the information. Ladenburg shall have no liability with respect to information provided by portfolio managers. Performance information may be included in the information provided by Ladenburg or may be provided by portfolio managers. This performance is calculated by the portfolio managers themselves or by third parties. This performance is not calculated or verified by Ladenburg (except in the case of affiliated portfolio managers) or by a third party at Ladenburg's request. Thus, this performance may not be calculated on a uniform and consistent basis. Clients will receive each ICS Manager’s disclosure documents. Clients should review the portfolio manager disclosure documents carefully for important information about the portfolio manager, including risks associated with the selected strategy (if applicable). Each portfolio manager is solely responsible for the truthfulness, completeness, and accuracy of its own disclosure document. Neither Ladenburg nor the Financial Advisers are responsible for the performance of any ICS Manager or investment model. In addition, neither Ladenburg nor the advisers shall not be responsible for any act or omission of any ICS Manager or any misstatement or omission contained in any document prepared by or with the approval of any ICS Manager or any loss, liability, claim, damage, or expense, whatsoever, as incurred, arising out of or attributable to such misstatement or omission or any other action or omission by an ICS Manager. Certain ICS Managers seek to execute and fill transactions for institutional and other non-Wrap Fee/separately managed program accounts prior to those for Wrap Fee/separately managed program accounts. This could have an adverse impact on the execution price clients receive if trades for institutional and non-sponsor program accounts impact the market and trading volume of the securities sought to be purchased with respect to the client’s account. ICS Manager trading and execution practices are described more fully in each manager's disclosure document. Ladenburg can act as an ICS Manager. Ladenburg has a conflict of interest in acting as an ICS Manager and the adviser has a conflict of interest in recommending Ladenburg as an ICS Manager because if a client selects Ladenburg, Ladenburg and its affiliate will receive greater aggregate compensation. Ladenburg is not subject to the same selection and review criteria as other ICS Managers. Ladenburg addresses this conflict by limiting its portfolio management activities in connection with the ICS program to situations where Ladenburg manages accounts pursuant to a model portfolio provided by a third-party manager, where there is generally no other ICS Manager available to manage assets that have been allocated to a particular asset class or strategy, or where the client requests services with respect to certain assets in the account that no other ICS Manager can accommodate. In addition, Ladenburg may manage ICS assets when it is more appropriate for the client to fulfill part of an asset allocation with funds, 11  rather than with individual securities. ICS assets managed by Ladenburg are generally held in a separate ICS account. As with other ICS Managers, clients grant Ladenburg discretionary trading authority over the applicable ICS account. However, when the client selects a Ladenburg strategy under which Ladenburg manages accounts pursuant to a model portfolio provided by a third-party manager, Ladenburg generally limits trading in the account to trades necessary to keep the account consistent with the model portfolio. For these strategies, Ladenburg enters into a contract with the third-party money manager under which the manager agrees to provide the model portfolio to Ladenburg and to provide updates to that model portfolio to Ladenburg on a regular basis. In these cases, the third-party manager has no responsibility to manage any client accounts and does not act as investment adviser to any specific clients. Ladenburg may enter trades for accounts directly or may contract with a third party to makes trades in accordance with the model portfolio on Ladenburg’s behalf. Individual Needs of Clients and Restrictions As described in Services, Fees and Compensation above, clients inform their adviser of their investment objectives, risk tolerance, and investment time horizon and give their adviser any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, the adviser assists the client in selecting an investment manager(s). Clients can impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. A client also can request that the ICS Manager(s) manage the client's account in accordance with client-specified investment guidelines or policies or otherwise implement a strategy in the client's account in a manner that can differ from that in which the ICS Manager would otherwise implement the strategy in the account. The adviser will communicate any restrictions or guidelines imposed by the client to Ladenburg, who will communicate them to the applicable ICS Manager(s). The ICS Managers can reject the restriction or the account if the manager deems the restriction to be unreasonable. In the absence of client-specified investment restrictions, guidelines or policies and/or other modifications ICS Managers will generally manage accounts in a manner very similar to that of other clients who have selected the same manager(s). The client must promptly inform their assigned adviser of material changes in their financial circumstances or investment objectives. The adviser will periodically discuss, at least once a year, whether the management of the account continues to reflect the investment objectives and financial requirements of the client. Other Types of Accounts Ladenburg provides advice through other programs and services, which include other Wrap Fee programs. These programs and services are described in different disclosure documents which are available upon request. These programs and services generally are not managed using the same portfolio management strategies as Ladenburg use when acting as an ICS Manager. Performance-based Fees Clients in the ICS Program do not pay performance-fees- that is, fee based on a share of capital gains on or capital appreciation of the assets of a client. Methods of Analysis, Investment Strategies and Risk Each investment strategy and manager’s portfolio entail varying degrees of risk. There can be no assurance that a particular investment strategy or manager will be successful or that clients will not suffer losses. 12  Results generated for each account will differ, and the investment advice provided to an individual will differ from client to client. Investment performance is not guaranteed, and managers’ past performance with respect to a client’s account or other accounts does not predict future performance. When managing ICS assets, Ladenburg generally utilizes mutual funds, other types of registered investment companies, exchange-traded-funds, or private funds. Ladenburg can purchase shares in the Ladenburg Funds, for which Ladenburg acts as investment adviser and LTCO acts as distributor. These purchases create a conflict of interest because Ladenburg receives more compensation in connection with the purchase of these funds than it does in connection with the purchase of other funds. In addition, these funds pay fees in connection with services or distribution, such as 12(b)-1 fees to LTCO. To mitigate this conflict of interest, Ladenburg’s portion of the Program Fee is not assessed on the asset value of the Ladenburg Funds when the billing calculation is performed, and Program Fee is deducted. The risks associated with investment in funds that invest primarily in private funds entails a significant amount of risk. The types of risk include: loss of all or a substantial portion of the investment due to leveraging, short selling or other speculative practices; lack of liquidity in that there may be no secondary market for the fund or the securities that make-up the fund, and none can develop or expect to develop; volatility of returns; restrictions on transferring interests in the fund; absence of information regarding valuations and pricing; complex tax structures and delays in tax reporting; adviser risk; and less regulation and potentially higher fees than traditional mutual fund strategies. Ladenburg can also invest ICS assets in funds that invest primarily in Real Estate Investment Trusts (REITs). Investing in REITs involves additional risk due to potential adverse developments affecting the real estate industry and real property, such as economic recession, changes in interest rates, oversupply, competition from other management companies, property acquisition risks, development overruns, project completion delays, rising borrowing costs and tightening of available capital, defaults and insolvencies of major tenants, property damage, security threats, natural disasters, environmental clean-ups and liability lawsuits. The impact of these risks on the share price of funds that are concentrated in REIT investments can be high. Some ICS Managers can utilize leveraged mutual funds or ETFs and leveraged inverse mutual funds or ETFs (hereafter referred to as “leveraged funds”) as part of their investment strategy. Leveraged funds are investment vehicles that use debt and derivatives in order to magnify the returns of an underlying index on a daily basis. Trading in leveraged funds is designed to be a market timing or active trading strategy, are not as tax efficient as traditional ETFs/mutual funds and are not suitable as a long-term investment. Because leveraged funds reset each day, their performance can diverge from the performance of the underlying benchmark. Circumstances (e.g., market volatility) could result in the performance of your investment having negative returns even though the index tracked may have positive returns over the same time period. Ladenburg can also invest ICS assets in funds that invest primarily in futures. Investing in futures involves additional risk due to the use of derivatives which are often more volatile than other investments and can magnify the fund’s gains and losses. Investors considering these types of investment should have a long- term investment horizon as funds trading futures can experience immediate and substantial loss or gain due to relatively small movements in the price of a futures contract. ICS Managers providing model strategies for Ladenburg to manage, furnish rebalancing and constituent information to Ladenburg periodically. Due to unavoidable variables, such as, but not limited to, timing and trading volume, model change transactions entered by Ladenburg will be completed sometime after the ICS Manager has effected transactions for accounts under direct management of the manager. As a result, accounts managed by Ladenburg which are following an ICS Manager model, could be disadvantaged and model performance can differ from the performance achieved by clients under the investment discretion of 13  the ICS Manager. Due to securities regulation, Ladenburg reserves the right to reject or delay recommendations provided by the ICS Manager. For more information about the risks of investment in a particular fund, see the fund’s prospectus or offering document, as applicable. The client can also select Ladenburg as an ICS Manager to manage an account pursuant to a model portfolio provided by a third-party manager outside of the ICS Program. For these strategies, Ladenburg enters into a contract with the third-party money manager under which the manager agrees to provide the model portfolio to Ladenburg and to provide updates to that model portfolio to Ladenburg on a regular basis. In these cases, the third-party manager has no responsibility to manage any client accounts and does not act as investment adviser to any specific clients. Ladenburg is responsible for managing the account in accordance with the model portfolio. These strategies have varying degrees of risk that depend on the specific model portfolio involved. Ladenburg will provide clients with additional information about the risk involved in a particular model portfolio if the client is interested in, and is eligible to select, that particular strategy. Voting Client Securities The designation for voting of proxies for securities will be defined in the respective Ladenburg-ICS client agreement, under the section “Proxies”. If the Manager is delegated to vote proxies for securities in the account (as per the respective Ladenburg-ICS agreement) it will do so in accordance with the Manager’s policies and procedures regarding proxy voting. Client authorizes each Manager to vote proxies for securities held in the Account(s) managed by the Manager on Client’s behalf. If Ladenburg is acting as an ICS Manager or following an ICS provided model and if Ladenburg is delegated to vote proxies for securities in the account, (as per the respective Ladenburg-ICS client agreement) it will do so, in accordance with Ladenburg’s policies and procedures regarding proxy voting. This delegation to Ladenburg may be revoked at any time by written notice to Ladenburg. Ladenburg has proxy voting policies and procedures which contain guidelines in order to minimize conflicts of interest and to ensure that it votes proxies in a manner consistent with the best interests of its clients. A copy of these policies and procedures is available upon request. Further, clients can obtain information from Ladenburg on how their proxies were voted by submitting a written request to Ladenburg. Item 7 – Client Information Provided to Ladenburg As described in “Services, Fees and Compensation” above, clients inform their adviser of their investment objectives, risk tolerance, and investment time horizon and give their adviser any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, the adviser assists the client in selecting ICS Manager(s). The adviser informs Ladenburg which ICS Manager(s) the client has selected in the account opening paperwork. The adviser also provides Ladenburg with information about the client. The adviser is responsible for communicating any changes to the ICS Manager(s) selected or client information to Ladenburg. Ladenburg communicates the information received by the advisers to the ICS Managers. Clients may impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. The adviser will communicate any restrictions imposed by the client, or any changes to these restrictions that the client makes, to Ladenburg. Ladenburg will communicate the information to the applicable ICS Managers. The ICS Managers may reject the restriction or the account if they deem the restriction to be unreasonable. Item 8 – Client Contact with Ladenburg Clients are encouraged to contact their adviser to arrange for a consultation with Ladenburg and/or Managers. Clients are also free to contact Ladenburg or the ICS Managers directly. 14  Item 9 – Additional Information Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. For more information about any disciplinary events that are material to an evaluation of Osaic Advisory Services, LLC, Osaic Wealth, Inc. or separately registered adviser, please see their disclosure brochures. Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is a registered investment advisory firm and has been in business since October 29th, 1982. Ladenburg is a wholly owned subsidiary of Osaic Holdings, Inc. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2006 Trust. Osaic Holdings, Inc. owns 100% of both Ladenburg and LTCO, a registered broker-dealer. As explained in the Fees and Compensation section above, LTCO can execute trades on behalf of clients who receive advisory services from Ladenburg. LTCO receives compensation for these brokerage services, which it shares with Ladenburg Financial Advisers who are also registered broker-dealer representatives of LTCO. Ladenburg has the following affiliates, which are wholly owned subsidiaries of Osaic Holdings, Inc. or wholly owned subsidiaries of one of Osaic, Inc.’s affiliates. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. Ladenburg Thalmann & Co. Inc. (LTCO) Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Highland Capital Brokerage Insurance Company 100% owned by Osaic Holdings, Inc. Ladenburg has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. However, these related persons are not wholly owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (BDF) Registered Investment Advisor 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. Philip Blancato and Jaime Desmond function as CEO 15  and COO of Ladenburg respectively. In certain circumstances, BDF recommends Ladenburg’s advisory services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts and no client is under any obligation to engage the services of Ladenburg. Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the related persons, which are wholly owned subsidiaries of Osaic, Inc., which is a wholly owned subsidiary of Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by OIHI 100% owned by Osaic, Inc. Osaic, Inc. Holding Company Vision2020 Wealth Management Corp. Registered Investment Advisor Osaic Institutions Holdings, Inc. (OIHI) Holding Company Osaic Institutions, Inc. Registered Investment Advisor, Broker/Dealer Osaic Services, Inc. Broker/Dealer Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Related Persons. In that case we or our Related Persons can receive compensation when doing so which results in a conflict of interest. Your Financial Adviser, however, does not receive a portion of the compensation paid to us or our Related Persons and therefore does not have a conflict of interest in recommending the use of one of our affiliated companies. As a result of the fact that your Financial Adviser is not compensated for directing you to products or services offered by our Related Persons, we believe that the Firm’s conflict of interest is mitigated. Certain principal executive officers of Ladenburg may be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg because they will not be devoted exclusively to the business of Ladenburg and can have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Ladenburg Financial Advisers can recommend that clients invest in the Ladenburg Funds for which Ladenburg acts as investment adviser, and LTCO acts as distributor. Transactions for the funds are generally executed through LTCO. For more information see the prospectus. These recommendations create a conflict of interest because Ladenburg and LTCO generally receive more compensation in connection with the purchase of these investments than they do in connection with the purchase of other investments. In addition, these funds pay fees in connection with services or distribution, such as 12b-1 fees. These fees are paid to LTCO as broker-dealer. Ladenburg Financial Advisers can recommend Premier Trust to provide trust and administrative services. Premier Trust provides full disclosure with respect to its trust and administrative services and related costs. 16  As explained above, LTCO acts as a dealer with respect to certain securities, and as such, can execute transactions for Ladenburg clients as principal. As a dealer, LTCO can receive a "mark-up," "mark-down," and/or spread in the net price at which principal transactions are executed. This compensation is in addition to other compensation that client pays to Ladenburg and its affiliates. Thus, Ladenburg has a conflict of interest in recommending or deciding to execute trades through LTCO on a principal basis. Ladenburg addresses this conflict of interest in the following ways. After receiving disclosures about a specific principal transaction with LTCO, clients have the opportunity to reject the transaction before it is completed, to the extent required by applicable law. In addition, Ladenburg has policies and procedures in place to assure that clients receive best execution with respect to principal trades, regardless of whether the trade is executed by LTCO or an unaffiliated dealer. Ladenburg can also recommend that clients invest in securities issued in an initial public and/or secondary offerings (“new issues”) for which LTCO acts as a manager, underwriter and/or a member of the selling group. Ladenburg has a conflict of interest in recommending these securities for several reasons. First, LTCO receives all or a portion of the gross spread – the difference between the price that the client pays for the security and the price that LTCO purchases the security for -- in connection with such sales. This gross spread is generally 7% but can be higher or lower in connection with certain offerings. Ladenburg Financial Advisers generally receive a portion of this compensation as broker-dealer representatives of LTCO. In addition, LTCO has a substantial interest—both financially and with respect to its reputation— in assuring that the offering is successful by having a large number of the securities purchased. Finally, in connection with certain offerings, LTCO has an obligation to purchase and resell a certain number of securities. Thus, because of its affiliation with LTCO, Ladenburg has incentives to recommend investments in these offerings for these reasons, rather than based on a client’s needs. To address these conflicts, Ladenburg has policies and procedures in place to make sure that securities in initial public offerings are recommended only to clients for whom they are suitable given the client’s investment objectives and assets. In addition, clients are generally given transaction specific disclosure prior to the client’s decision to invest in such securities. Securities acquired in initial public and secondary offerings may be oversubscribed and Ladenburg has policies and procedures in place for the allocation process. Ladenburg can compensate its Financial Advisers for the costs of marketing, distribution, business and client development and educational enhancement incurred by the Financial Adviser for the promotion of Ladenburg’s services. This compensation may be based on based on assets under management or otherwise advised. Reverence Capital Partners manages the private investment funds that indirectly own a majority of Osaic Holdings, Inc., which in turn owns the Firm, as well as private investment funds that hold a minority investment in Envestnet. In addition, select management and Financial Advisors own less than 0.5%, indirectly through a Reverence Capital Partners-controlled entity, in Envestnet. As a result, Financial Advisors associated with Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp in particular, have an incentive to offer and recommend to you programs that use Envestnet’s services. Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp have procedures designed to mitigate this conflict. Payments from Third Parties In addition to the various types of compensation Ladenburg’s affiliates may earn from clients in connection with effectuating the investment advice Ladenburg renders to clients, these affiliates can also receive payments from third parties in connection with services rendered to Ladenburg’s clients. 17  For example, LTCO and other affiliated broker-dealers can receive distribution or service (“trail”) fees from the sale of certain unaffiliated mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services. These fees are distributed from the fund’s total assets. LTCO can pay a portion of the distribution fees it earns to Ladenburg’s Financial Advisers in their capacity as broker-dealer representatives of LTCO. For certain accounts custodied at NFS, LTCO credits 12b-1 fees received for Ladenburg Financial Advisers back to the client accounts. Because not all of Ladenburg’s affiliated broker-dealers follow the same practice, an account’s receipt of 12b-1 credits can depend on the broker-dealer chosen to effect trades for the account. Ladenburg’s affiliated broker-dealers can also participate in revenue-sharing arrangements based on fees paid by mutual funds to participate in No-Transaction-Fee (“NTF”) platforms made available by custodians. Ladenburg’s affiliates can also receive payments called “revenue sharing payments” and/or “marketing allowances” from certain product sponsors (“Strategic Partners”) including mutual funds, insurance companies, and Non-Traded products such as Real Estate Investment Trusts (“REITS”). These payments are not shared with Ladenburg’s Financial Advisers. For more detailed information about the products in the Strategic Partners program, you may request the complete disclosure document from your Financial Adviser. Qualified custodians are another source of revenue to Ladenburg’s affiliated broker-dealers. Specifically, NFS and Pershing provide significant compensation to our affiliated broker-dealers in their capacity as introducing broker/dealer to offset its general operating expenses based on the number of accounts and/or account assets held by our affiliated broker dealers. The specific terms of this compensation differ between NFS and Pershing. Certain custodian fees can apply to your brokerage accounts. In some instances, the affiliated broker-dealers pays a portion of the fee charged. In other instances, the affiliated broker-dealers apply a markup to these fees. In this regard, Ladenburg’s affiliated broker-dealers can receive revenue based upon client activity, as well as the amount of assets custodied with these firms. The types of revenue include, but are not limited to, margin interest charges, IRA fees, inactivity fees, 12b-1 trails and other fees set forth in the custodian’s Schedule of Client Fees and Charges. Our affiliated broker-dealers exercise no discretion, nor provide any advice or recommendation in the selection of the Custodian for any specific account or client. As a result, any difference in compensation to our affiliated broker-dealers is based solely on the contracts with the Custodians and your Financial Adviser’s election of a Custodian. Secondly, Financial Advisers do not share in any compensation paid by the custodians to our affiliated broker-dealers. As a result, Financial Advisers have no financial conflict of interest in any recommendation of a Custodian to clients. For more information regarding custodial fees and the above forms of compensation, please see the Disclosures section of the respective affiliated broker-dealer at our Parent Company’s website: https://osaic.com/disclosures for the Pershing and NFS Schedule of Client Fees and Charges. Conflicts of Interest The various compensation arrangements discussed in this section of the Brochure present conflicts of interest for Ladenburg, because they incentivize the firm and its Financial Advisers to select or recommend products that provide such payments. To mitigate these conflicts, Ladenburg prohibits its Financial Advisers and other supervised persons from selecting or recommending any product based solely on payments that Ladenburg, its employees or its affiliates receive in connection with the promotion of that product. Instead, Ladenburg requires Financial Advisers and other supervised persons to advise and make recommendations in clients’ best interests, taking into account clients’ needs, investment objectives and risk tolerances. Ladenburg maintains policies and procedures to ensure recommendations are suitable and 18  require that its Financial Adviser always acts in the client’s best interest. Ladenburg also maintains a supervisory structure to monitor the advisory activities of its Financial Advisers to reduce conflicts of interest. Ladenburg offers a number of investment advisory programs that can include the Ladenburg Funds, a series of mutual funds that are managed by Ladenburg. Since Ladenburg receives an internal management fee from the funds, a conflict of interest exists. To mitigate this conflict, Ladenburg has policies and procedures governing the programs that include an allocation to the Ladenburg Funds. Code of Ethics and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. All supervised persons at Ladenburg must acknowledge the terms of the Code of Ethics and personal securities transactions and holdings annually, or as amended. The Code of Ethics sets forth detailed policies and procedures regarding the personal trading of its personnel. The Code of Ethics also contains policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. A copy of the Ladenburg Code of Ethics may be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. Ladenburg personnel are required to conduct their personal investment activities in a manner that is not detrimental to its advisory clients. Ladenburg personnel are not permitted to transact in securities except under circumstances specified in the Code of Ethics. Ladenburg may give advice, take action, or hold or deal in securities for some clients or accounts, including Ladenburg’s own accounts, which differs or can be similar at times from the advice it gives, action it takes, or securities it holds or deals for other clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Ladenburg will: (a) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (b) at all times place the interests of clients first while, at the same time, allowing employees to invest for their own accounts; (c) disclose all actual and potential conflicts; (d) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (e) conduct all personal trading consistent with the Rules and in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility; and (f) not use any material non-public information in securities trading. The Code of Ethics also establishes policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Ladenburg’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. These pre-clearance requirements and the exceptions are defined in the Code of Ethics. Ladenburg and its employees may not enter orders for accounts in which they have a beneficial ownership interest to benefit from their knowledge of clients’ orders in a particular security (“front- running”). Ladenburg defaults to LTCO’s front running and personal trading policies as the affiliate broker dealer. In addition to those requirements, Ladenburg Access Persons will not be approved to trade in securities that are ETFs and/or Mutual Funds that are held in Ladenburg’s discretionary portfolios within 5 days of a rebalance by Ladenburg. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Ladenburg and its clients. 19  Certain clients also can maintain accounts at LTCO for which Ladenburg does not act in an advisory capacity. In providing execution services to these accounts separately and apart from the client’s advisory accounts, LTCO can enter into transactions as principal. These activities are separate and apart from Ladenburg’s advisory services. The Code of Ethics is enforced through compliance monitoring activities and surveillance. In cases where the firm discovers that an employee has violated a firm policy and/or procedure, the firm’s code of business conduct or code of ethics, a state or federal law, regulation of the SEC, or other regulatory agency, the Compliance Department will take appropriate steps to investigate the circumstances and will take action commensurate with the manner of the violation. Such actions could take the form of a written warning to the employee in conjunction with the firm’s Legal Department or be as serious as disciplinary action up to and including termination. Any such investigations will be brought to the appropriate regulator’s attention, if necessary, which can result in a disclosure of the violation on the employee’s U-4 form, if required. Review of Accounts The adviser is primarily responsible for reviewing the investment manager(s) selected by the client on an on-going basis to ensure that it continues to be suitable for the client, taking into account any changes to the information provided by the client. Ladenburg generally reviews ICS Managers and accounts at least quarterly. These reviews are performed by Ladenburg’s Investment Committee and Compliance Officer. Ladenburg or the adviser may provide clients with quarterly performance reviews of ICS accounts. Ladenburg and the adviser may not provide tax advice, and nothing in the performance review should be construed as advice concerning any tax matter. Performance reviews are not a substitute for regular monthly account statements received from the custodian or Form 1099. Performance reviews should not be used to calculate fees or to complete income tax returns. Upon a client's specific request and subject to the relevant firm’s policies and procedures and applicable law, the performance review may include information about assets outside the program. By including any such assets in the performance review, the firm is not undertaking to provide or responsible for providing any services with respect to those assets. Client Referrals and Other Compensation Ladenburg may enter into agreements with third parties that will solicit clients for Ladenburg and receive compensation for solicitation efforts. In such instances, the third-party solicitor will receive either a percentage of, or a set fee from, the fee charged to the client. If a solicitor is used in connection with a client’s account, the structure and arrangement of the solicitation agreement, as well as the compensation paid to the solicitor, will be fully disclosed to the client. This disclosure will be acknowledged in writing by the client when participating in an Ladenburg program. The fee charged to a client is not affected by the use of a third-party solicitor in connection with client accounts, and a client will not be charged any additional fees for the use of such services. Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 20  Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice FACTS What does Ladenburg Thalmann Asset Management Inc. do with your personal information? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 21  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO Yes Yes  If your financial professional terminates his or her relationship with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out, you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic, Holdings Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 22  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. Ladenburg Thalmann Asset Management Inc., is an SEC registered investment adviser. 03/2025 23 

Ladenburg Thalmann Asset Management Inc. Architect Wrap Fee Program Brochure SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 www.ltam.com This wrap fee program brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”). Ladenburg is registered with the Securities and Exchange Commission (“SEC”) as a registered investment adviser. Registration does not imply any level of skill or training. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ladenburg Thalmann Asset Management Inc. is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 03/28/2025 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 28th, 2024. Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604. Material Changes: • Item 6: Portfolio Manager Selection and Evaluation: This section was updated in order for investors to understand the risks associated with each recommendation and investment type available. • Item 9: Additional Information: Other Financial Industry Activities and Affiliations: This section was amended to reflect changes to and renaming of certain related persons and affiliates. 2  Table of Contents Item 2 – Summary of Material Changes ............................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 3 Item 4 – Services, Fees and Compensation .......................................................................................................... 4 Item 5 – Account Requirements and Types of Clients.......................................................................................... 8 Item 6 – Portfolio Manager Selection and Evaluation .......................................................................................... 8 Item 7 – Client Information Provided to Ladenburg .......................................................................................... 11 Item 8 – Client Contact with Ladenburg ............................................................................................................. 11 Item 9 – Additional Information ......................................................................................................................... 11 Ladenburg Thalmann Asset Management - Privacy Notice……………………………………………………………………………18 Item 3 – Table of Contents 3  Item 4 – Services, Fees and Compensation Investment Advisory Services Each client has a Financial Adviser, who is a Financial Adviser of Ladenburg Thalmann Asset Management (“Ladenburg”). The Financial Adviser is generally also a broker-dealer representative of Ladenburg Thalmann & Co. Inc. Clients who wish to participate in the Architect Program (“Architect”) will enter into an Architect agreement with Ladenburg. Clients inform their Financial Advisers of the investment objectives, risk tolerance, and investment time horizon, and any investment policies, guidelines, or reasonable restrictions applicable to the assets they designate for investment through the Architect Program. Based on the information provided, the Financial Adviser recommends securities to the client and assists the client in purchasing, selling, or otherwise trading securities or other investments. Such securities may include, but are not limited to, equities, bonds, options, government securities, exchange-traded funds, and mutual funds. Neither Ladenburg nor its Financial Adviser will have any discretionary authority over the account and will purchase or sell securities only as authorized by the client. Execution of Trades Clients generally authorize and direct Ladenburg to execute trades for the account in Architect through Ladenburg Thalmann & Co. Inc. (“LTCO”), a broker-dealer affiliated with Ladenburg. Assets in the Architect program are also not generally aggregated by Ladenburg. In accordance with applicable law and regulation, broker-dealers can execute principal trades for the account(s). In addition, the broker-dealer has the authority to effect “agency-cross” transactions (i.e., transactions for which a broker-dealer acts as broker for both the client and the counterparty to the transaction) for the account(s) in accordance with applicable law and regulations. In both a principal and agency-cross trade, the affiliate broker-dealer of Ladenburg can receive compensation from the other party for such a transaction and, thus, Ladenburg can have a potentially conflicting division of loyalties and responsibilities. Client may revoke authorization to effect agency cross transactions at any time by written notice to Ladenburg. Ladenburg has policies and procedures to address such conflicts of interest. Custody Ladenburg does not take custody of any client assets. However, certain clients have the option of authorizing Ladenburg to debit advisory fees from their custodial account. All client assets are held by an independent qualified custodian, which may be a broker-dealer, bank or trust company. Clients will receive account statements from the broker-dealer, bank or other qualified custodian holding the clients’ assets at least on a quarterly basis. Clients should carefully review those statements. Clients who also receive account reviews from Ladenburg should compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of clients’ accounts. Any account information provided by Ladenburg is for informational purposes only. Ladenburg may have standing letters of authorization granting it first-party asset movement authority on its clients’ accounts at certain of Ladenburg’s qualified custodians. Ladenburg provides the qualifying Custodian with the client’s authorization in writing. The qualifying Custodian has a record that the client has identified the accounts for which the transfer is being effected as belonging to the client (both sending and receiving accounts). Ladenburg’s authority to transfer client assets between clients’ accounts at the same qualified custodian or between another independent qualified custodian, (which may be a broker-dealer, bank or trust company) in which both have access to the sending and receiving account numbers and client account name(s) are deemed to be first party asset movement and does not constitute custody. 4  Fees and Compensation Each account in Architect will generally be charged an asset-based fee (“Wrap Fee”) on a quarterly basis. The Wrap Fee will be calculated based on the value of the Architect assets in the account. The rate or rates used to calculate the Wrap Fee are subject to negotiation between the Financial Adviser and each client. The actual fee rates paid by the client will be set forth in the client’s Architect agreement. The maximum annual Wrap Fee rates for accounts at National Financial Services (“NFS”) are: Value of Account Assets Maximum Annual Program Fee Rate Up to $100,000 3.00% $100,001 – $250,000 2.75% $250,001 – $500,000 2.50% $500,001 – $1,000,000 2.25% Over $1,000,001 2.00% The Wrap Fee rate can be either a flat annual fee rate (maximum rate of 3.00%) or will be a blended fee using two or more of the rate tiers set forth above. The blended rate is calculated by charging a lower rate on the assets above the designated tiers. The Wrap Fee will generally be charged in advance. However, certain clients may be charged in arrears. Certain clients may also be charged monthly rather than quarterly. Whether the Wrap Fee is charged in advance or in arrears, or quarterly or monthly, is set forth in the client’s Architect agreement. Either party at any time upon written notice can terminate the Architect agreement and a pro rata portion of any Wrap Fee paid by the client in advance will be remitted to the client based on the number of days left in the quarter following receipt of the notice of termination by Ladenburg. When the Wrap Fee in paid in arrears, a pro rata portion of the Wrap Fee will be due by the client based on the number of days elapsed during the quarter prior to receipt of the notice of termination. The Wrap Fee covers the advisory services provided by the Financial Adviser, program administrative services provided by Ladenburg, transaction charges and commissions in connection with execution of transactions through Ladenburg Thalmann & Co. Inc. (“LTCO”), and custodial services (unless otherwise agreed between the custodian and the client). Ladenburg also shares a portion of the Wrap Fee with the Ladenburg Financial Adviser. LTCO will also receive a portion of the Wrap Fee for the execution of transactions and generally pays part of its compensation to the custodian. Architect can cost a client more or less than purchasing such service separately depending on the frequency of trading in the Architect accounts, commissions charged at other broker-dealers for similar products, fees charged for like services by other advisers and broker-dealers and other factors. The Wrap Fee does not cover: • Brokerage commissions or other charges resulting from transactions not effected through LTCO; • "Mark-ups" and "mark-downs" or "dealer spreads" that broker-dealers, including affiliates of Ladenburg, can receive when acting as principal in certain transactions; • Short term redemption fees that can be charged in connection with certain funds (see below); • Any additional custodial services contracted for directly by the client with the custodian; 5  • Certain costs or charges that can be imported by LTCO or the custodian, including costs associated with exchanging foreign currencies, odd-lot differentials, IRA fees, transfer taxes, exchange fees, confirmation, statement, prospectus fees; • wire transfer fees, postage fees, and other fees or taxes required by law. Certain securities, such as over-the-counter stocks, are traded primarily in "dealer" markets. In such markets, securities are directly purchased from, or sold to, a financial institution acting as a dealer, or "principal." Dealers executing principal trades typically include a "mark-up," "mark-down," and/or spread in the net price at which transactions are executed. When LTCO executes a transaction for a security traded in the dealer markets, LTCO either will execute the transaction as agent through a dealer unaffiliated with LTCO, or as principal in accordance with applicable law. Clients in the Program will not pay commissions or separate transaction charges to LTCO in connection with these transactions, however, the client will bear the cost (including any mark-up, mark-down, and/or spread) imposed by the dealer as part of the price of the security. Thus, the dealer will receive compensation in connection with most principal trades. Ladenburg has a conflict of interest in using LTCO to execute principal transactions because LTCO will receive compensation in connection with the trade as dealer, which is in addition to the Program Fee. For more information about how this conflict of interest is addressed, see the Additional Information section below. In addition to the Wrap Fee, each mutual fund or exchange-traded fund (“ETF”) in which a client may invest also bears its own investment advisory fees and other expenses. Mutual funds may be available directly from the funds pursuant to the terms of their prospectuses and without paying the Wrap Fee and ETFs may be available outside of the Program without paying the Wrap Fee, subject to applicable commissions and/or transaction charges. Further, to the extent that cash used for investment through Architect comes from redemptions of the client’s mutual fund or other investments outside of Architect, there can be tax consequences or additional cost from sales charges previously paid and redemption fees incurred. Such redemption fees would be in addition to the Wrap Fee on those assets. LTCO and Ladenburg’s other affiliated broker-dealers receive fees in connection with the client assets participating in the Bank Deposit Sweep Program and the Insured Cash Account Program, which fees are in addition to the management fee that Ladenburg receives in connection with such assets pursuant to the client’s advisory contract. When your Program Account is maintained at one of our affiliated broker-dealer’s clearing firms, Pershing, LLC (“Pershing”) or National Financial Services, Inc. (“NFS”), your free credit balance will be automatically deposited or “swept” to a deposit account at one or more banks whose deposits are insured up to applicable limits by the Federal Deposit Insurance Corporation (“FDIC”) (the “Sweep Program”). Under the Sweep Program, our affiliated broker-dealers, maintain two FDIC-insured deposit programs, the Bank Deposit Sweep Program (“BDSP”) and the Insured Cash Account Program (“ICAP”), that create financial benefits for our affiliated broker-dealers as described below. For certain Program Account types, free credit balances are swept to a money market mutual fund product (the “Money Market Mutual Fund Program”). Please see the Sweep Program Terms and Conditions document, available from your Financial Adviser or from the website listed below, for full details about the Sweep Program. As set forth in the terms of your Customer Agreement with our affiliated broker-dealer, you may remove your Program Account from participating in the Sweep Program by notifying your Financial Adviser. If you remove your Program Account from the Sweep Program, cash balances will be held by the clearing firm as a free credit balance. In addition, there are always alternatives for the short-term investment of cash balances, including non-sweep money market mutual funds, treasury bills, and brokered certificates of deposit, that offer higher returns than the sweep options made available to you. 6  FDIC Insured Deposit Program (BDSP & ICAP) Eligible account types: all accounts except ERISA Title 1 accounts, 403(b)(7), & Keogh plans. Free credit balances swept to a deposit account will earn interest that is compounded daily and credited to your Program Account monthly. Interest begins to accrue on the date of deposit with the banks participating in the program (“Program Banks”), through the business day preceding the date of withdrawal from the deposit account. The daily rate is 1/365 (or 1/366 in a leap year) of the posted interest rate. Bank Deposit Sweep Program-BDSP Our affiliated broker-dealers have established deposit levels or tiers which ordinarily pay different rates of interest depending on deposit balances. Generally, Program Accounts with higher deposit balances receive higher rates of interest than accounts with lower balances. The interest rate payable to you is determined by our affiliated broker-dealers and is based on the amounts paid by the Program Banks to obtain the deposits. The amount our affiliated broker-dealers retain, less a fee paid to the clearing agent and the third- party administrator, will not exceed 600 basis points (6.00%) per year (the “Maximum Program Fee”) on the average daily balances held in the BDSP. Interest paid on the deposit accounts will generally be lower than the rate of return on (i) other investment products that are not FDIC insured, such as money market mutual funds and (ii) on bank deposits offered outside of the BDSP. Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. The income our affiliated broker-dealers earn from Program Banks based on your balances in BDSP will in almost all circumstances be substantially greater than the amount of interest you earn from the same balances. As such, our affiliated broker-dealers receive a substantially higher percentage of the interest generated by deposit balances in the BDSP than the interest credited to your accounts. When evaluating whether to utilize the Sweep Program and the extent to which the fee exceeds the interest rate you receive, you should assume that our affiliated broker-dealers are receiving the Maximum Program Fee as described above. Insured Cash Account Program - ICAP Our affiliated broker-dealers will receive a monthly per-account fee for services it provides in connection with maintaining and administering the Sweep Program for IRAs held in an advisory/ fee-based account (the “Sweep Account Fee”). The Sweep Account Fee that each of our affiliated broker-dealers can earn from Program Accounts participating in ICAP is subject to a maximum monthly per account fee that is between $34.25 and $36.75. Please refer to the applicable Sweep Program Terms and Conditions document, which you can obtain from your Financial Adviser or from the website listed below; refer to “Disclosures,” then to the FDIC Insured Deposit Program used in your account (ICAP), for further details about the maximum monthly per account fee. The Sweep Account Fee does not depend on or vary with (and is not affected by) the actual amounts held in any particular account or your Program Account. Thus, the compensation for Program Accounts that participate in ICAP is composed solely of the Sweep Account Fee. The fee received may differ among each Program Bank. You will have no rights to the amounts paid by the Program Banks, except for interest actually credited to your account. The Sweep Account Fee will reduce the interest you are paid on the amount of assets in your Program Account. The Sweep Account Fee will generally be paid by the Program Banks on your Program Account’s behalf; however, the Fee or any portion thereof can be deducted directly from your Program Account if, for example, the amounts paid by the Program Banks are insufficient to cover the Sweep Account Fee. In the event that we debit all or a portion of the monthly account fee from your account, each such amount will be reflected on your account statement. The amount of fees received by our affiliated broker-dealers, the clearing agent, and any other service provider reduces the interest you receive on your deposit account(s). Ladenburg and your Financial Advisor do not receive any portion of the fees paid by the Program Banks. 7  Because the Sweep Program generates significant payments from third parties (i.e., the Program Banks that participate in BDSP and/or ICAP) to our affiliated broker-dealers, a conflict of interest exists. A conflict of interest also arises because our affiliated broker-dealers earn more compensation from cash balances being swept to or maintained in the Sweep Program than if you purchase other investment funds or securities. The more client deposits held in BDSP, and the longer such deposits are held, the greater the compensation our affiliated broker-dealers, the clearing firms, and the third-party administrator receive. By investing through an advisory account, the compensation our affiliated broker-dealers receive from the BDSP or ICAP, as applicable, is in addition to the advisory fees that you pay. This means that our affiliated broker- dealers earn two layers of fees on the same cash balances in client advisory accounts with them. In addition, a conflict of interest arises as a result of the financial incentive for our affiliated broker-dealers to recommend and offer a Sweep Program over which they have control of certain functions. Our affiliated broker-dealers have the ability to establish and change interest rates paid on Sweep Program balances, to select or change Program Banks that participate in the BDSP and ICAP, and to determine the tier levels (if applicable) at which interest rates are paid, all of which generates additional compensation for our affiliated broker-dealers. Our affiliated broker-dealers maintain policies and procedures to ensure recommendations made to you are in your best interest. For additional information about the Sweep Program for accounts custodied at Pershing and NFS, please visit our website located at https://osaic.com/disclosures/cash-sweep-program. LTCO and/or the custodian will receive payments from certain mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services and are distributed from the fund’s total assets. These fee arrangements will be disclosed upon request of a client and are available in the applicable fund’s prospectus. Other forms of compensation that LTCO, Ladenburg’s Financial Advisers acting in their capacity as LTCO registered representatives, and/or Ladenburg’s other affiliated broker-dealers can earn in connection with the sale of investment products recommended to clients by Ladenburg are described in the Other Financial Industry Activities and Affiliations section below. Item 5 – Account Requirements and Types of Clients The minimum amount of assets required to open an account in the Architect Program is $50,000. Ladenburg may waive these minimums under certain circumstances. Should the market value of an account fall below the stated minimum, Ladenburg will have the right to require that additional monies be deposited to bring the account value up to the required minimum or close the account. The following types of clients may participate in Architect: individuals, including high net worth individuals, including small business owners, pension and profit-sharing plans, trusts, estates and charitable organizations, corporations or other business entities, Taft-Hartley plans, and not for profit entities. Item 6 – Portfolio Manager Selection and Evaluation Ladenburg advisers are the only portfolio managers available through Architect. Individual Needs of Clients and Restrictions Ladenburg advisers tailor their advisory services to the individual needs of the client in the Architect program. Clients inform their adviser of their investment objectives, risk tolerance, and investment time horizon and give their adviser any applicable investment policies, guidelines, or reasonable restrictions. 8  Clients can impose reasonable restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. Any restrictions imposed by a client may cause the adviser to make different recommendations than he or she would in the absence of such restrictions. Thus, the account may not perform as well. Other Types of Accounts Ladenburg provides advice through other programs and services, which include other Wrap Fee programs. These programs and services are described in different disclosure documents which are available upon request. These programs and services generally may not be managed using the same securities, strategies and funds used in Architect. No Performance-based Fees Neither Ladenburg nor any of its supervised persons accepts performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Methods of Analysis, Investment Strategies and Risk Financial Advisers base recommendations that they make in Architect using various types of investment strategies. The main sources of information advisers can use include financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filing with the SEC and company press releases. The investment strategies used to manage accounts can include long-term purchases, short-term purchases, selling securities within 30 days, short sales, margin transactions, and option writing. Ladenburg advisers may have access to third party vendors that provide support services in portfolio design and strategy implementation. Examples of third-party sources used to assist in managing assets are S&P Research, Independent Research, Bloomberg, Morningstar Workstation, various ETF & fund screeners, economic news services, statistical ratings organizations and asset allocation software or proposal systems. Our firm may use these tools along with an investor profile or questionnaires to recommend a portfolio or a selection of securities that will assist a client to achieve their objectives and risk tolerances. Each investment style, strategy, and investment entails varying degrees of risk. There can be no assurance that a particular investment or strategy will be successful or that clients will not suffer losses. Results generated for each account will differ, and the investment advice provided to an individual will differ from client to client. Investment performance is not guaranteed, and the adviser’s past performance with respect to a client’s account or other accounts does not predict future performance. The investment strategies used to manage accounts can include long-term purchases, short-term purchases, selling securities within 30 days, short sales, margin transactions, and option writing. It is important to understand the risks associated with each recommendation and investment type available. The following is a summary of some of the general risks associated with investing. Please note that this list is not all inclusive, and is provided as an indication of some of the factors that can impact the value of your investments: Business Risk: This is the risk that the strength of the company you are buying a piece of ownership in (stock for example) or are loaning money to (a bond, for example) affects your potential returns. Your returns from the stock purchase or bond purchase are influenced by factors like the company going out of business, or going into bankruptcy, or having a viable and strong revenue stream from the products or services it sells that is not over-shadowed by expenses. If a company goes bankrupt and its assets are liquidated, common stockholders are the last in line to share in the proceeds. 9  Credit Risk: This is the risk that the government entity or company that issued the investment will run into financial difficulties and won’t be able to pay the interest or repay the principal at maturity. Credit risk applies to debt investments such as bonds. You can evaluate credit risk by looking at the credit rating of the bond or the issuer. For example, long-term U.S. government bonds currently have a credit rating of AAA, which indicates the lowest possible credit risk. Cybersecurity Risk: The Firm’s information and technology systems may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by its professionals, power outages and catastrophic events such as fires, tornados, floods, hurricanes and earthquakes. Although the Firm has implemented various measures to protect the confidentiality of its internal data and to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, the Firm will likely have to make a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the Firm’s operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information relating to clients. Such a failure could harm the Firm’s reputation or subject it or its affiliates to legal claims and otherwise affect their business and financial performance. The Firm will seek to notify affected clients of any known cybersecurity incident that will likely pose substantial risk of exposing confidential personal data about such clients to unintended parties. Margin risk: Leverage increases a portfolio’s risk as price swings are amplified in a margin account and clients can lose more funds than deposited if the value of securities decline. Financial Risk: This is the risk that the companies you invest in will perform poorly, which affect the price of your investment. You cannot eliminate financial risk; however, you may be able to minimize the impact through diversification. Market Risk: This is the risk that the stock market will decline, decreasing the value of the securities owned. Stock market bubbles and crashes are good examples of heightened market risk. You can’t eliminate market risk; however, you may be able to minimize the impact through diversification. Regulatory Risk: This is the risk that changes in law and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. Options risks: An option holder runs the risk of losing the entire amount paid for the option in a relatively short period of time. This risk reflects the nature of an option as a wasting asset which becomes worthless when it expires. An option holder who neither sells their option in the secondary market nor exercises it prior to its expiration will necessarily lose their entire investment in the option. An option writer may be assigned an exercise at any time during the period the option is exercisable. Starting with the day it is purchased, an American-style option is subject to being exercised by the option holder at any time until the option expires. This means that the option writer is subject to being assigned an exercise at any time after they have written the option, until the option expires or until they have closed out their option position in a closing transaction. By contrast, the writer of a European-style or capped option is subject to assignment only when the option is exercisable or, in the case of a capped option, when the automatic exercise value of the underlying interest hits the cap price. For more information regarding 10  the risks of options, please read the ‘Characteristics and Risks of Standardized Options’ brochure, which can be found at www.optionsclearing.com. Other Risks: The risks associated with investment in funds that invest primarily in private funds entail a significant amount of risk. The types of risk include: loss of all or a substantial portion of the investment due to leveraging, short selling or other speculative practices; lack of liquidity in that there may be no secondary market for the fund or the securities that make-up the fund, and none may develop or expected to develop; volatility of returns; restrictions on transferring interests in the fund; absence of information regarding valuations and pricing; complex tax structures and delays in tax reporting; adviser risk; and less regulation and potentially higher fees than traditional mutual fund strategies. Voting Client Securities With respect to the Architect program, unless Ladenburg and the client otherwise agree in writing, Ladenburg is expressly precluded from taking any action or rendering any advice with respect to the voting of proxies solicited by, or with respect to, the issuers of any securities held in the account. The client expressly retains the authority and responsibility with respect to voting proxies for the account(s) or will delegate discretion with respect to voting such proxies to a third party. If Ladenburg receives any proxy materials that pertain to securities held in the account, Ladenburg will forward the materials to the person designated by the client. Item 7 – Client Information Provided to Ladenburg As described in Services, Fees and Compensation above, clients inform their adviser of their investment objectives, risk tolerance, and investment time horizon and give their adviser any applicable investment policies, guidelines, or reasonable restrictions. Clients can impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. A client also can request that Ladenburg make recommendations for the client's account in accordance with client-specified investment guidelines or policies or otherwise implement a strategy in the client's account in a manner that can differ from that in which Ladenburg would otherwise have recommended. The client must promptly inform their assigned adviser of material changes in their financial circumstances or investment objectives. The adviser will periodically discuss, at least once a year, whether the management of the account continues to reflect the investment objectives and financial requirements of the client. Item 8 – Client Contact with Ladenburg Clients are encouraged to contact their adviser directly. Item 9 – Additional Information Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without 11  having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is an investment advisory firm and has been in business since October 29th, 1982. Ladenburg is a wholly owned subsidiary of Osaic Holdings, Inc. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2006 Trust. Osaic Holdings, Inc. owns 100% of both Ladenburg and LTCO, a registered broker-dealer. As explained in the Fees and Compensation section above, LTCO may execute trades on behalf of clients who receive advisory services from Ladenburg. LTCO receives compensation for these brokerage services, which it shares with Ladenburg Financial Advisers who are also registered broker-dealer representatives of LTCO. Ladenburg has the following affiliates, which are wholly owned by Osaic Holdings, Inc. or wholly owned subsidiaries of one of Osaic, Inc.’s affiliates. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. Ladenburg Thalmann & Co. Inc. (LTCO) Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Highland Capital Brokerage Insurance Company 100% owned by Osaic Holdings, Inc. Ladenburg has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. However, these related persons are not wholly owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (BDF) Registered Investment Advisor 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. Philip Blancato and Jaime Desmond function as CEO and COO of Ladenburg respectively. In certain circumstances, BDF recommends Ladenburg’s advisory services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts and no client is under any obligation to engage the services of Ladenburg. Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the related persons, which are wholly owned subsidiaries of Osaic, Inc. which is a wholly owned subsidiary of Osaic Holdings, Inc. 12  100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by OIHI Osaic, Inc. Holding Company Vision2020 Wealth Management Corp. Registered Investment Advisor Osaic Institutions Holdings, Inc. (OIHI) Osaic Institutions, Inc. Registered Investment Advisor, Broker/Dealer 100% owned by Osaic, Inc. Osaic Services, Inc. Broker/Dealer Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Related Persons. In that case we or our Related Persons can receive compensation when doing so which results in a conflict of interest. Your Financial Adviser, however, does not receive a portion of the compensation paid to us or our Related Persons and therefore does not have a conflict of interest in recommending the use of one of our affiliated companies. As a result of the fact that your Financial Adviser is not compensated for directing you to products or services offered by our Related Persons, we believe that the Firm’s conflict of interest is mitigated. Certain principal executive officers of Ladenburg may be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg because they will not be devoted exclusively to the business of Ladenburg and may have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Ladenburg Financial Advisers may recommend that clients invest in the Ladenburg Funds for which Ladenburg acts as investment adviser, and LTCO acts as distributor. Transactions for the funds are generally executed through LTCO. For more information see the prospectus. These recommendations create a conflict of interest because Ladenburg and LTCO generally receive more compensation in connection with the purchase of these investments than they do in connection with the purchase of other investments. In addition, these funds pay fees in connection with services or distribution, such as 12b-1 fees. These fees are paid to LTCO as broker-dealer. Ladenburg Financial Advisers may recommend Premier Trust to provide trust and administrative services. Premier Trust provides full disclosure with respect to its trust and administrative services and related costs. As explained above, LTCO acts as a dealer with respect to certain securities, and as such, may execute transactions for Ladenburg clients as principal. As a dealer, LTCO may receive a "mark-up," "mark-down," and/or spread in the net price at which principal transactions are executed. This compensation is in addition to other compensation that client pays to Ladenburg and its affiliates. Thus, Ladenburg has a conflict of interest in recommending or deciding to execute trades through LTCO on a principal basis. Ladenburg addresses this conflict of interest in the following ways. After receiving disclosures about a specific principal transaction with LTCO, clients have the opportunity to reject the transaction before it is completed, to the extent required by applicable law. In addition, Ladenburg has policies and procedures in 13  place to assure that clients receive best execution with respect to principal trades, regardless of whether the trade is executed by LTCO or an unaffiliated dealer. Ladenburg may also recommend that clients invest in securities issued in an initial public and/or secondary offerings (“new issues”) for which LTCO acts as a manager, underwriter and/or a member of the selling group. Ladenburg has a conflict of interest in recommending these securities for several reasons. First, LTCO receives all or a portion of the gross spread – the difference between the price that the client pays for the security and the price that LTCO purchases the security for -- in connection with such sales. This gross spread is generally 7% but may be higher or lower in connection with certain offerings. Ladenburg Financial Advisers generally receive a portion of this compensation as broker-dealer representatives of LTCO. In addition, LTCO has a substantial interest—both financially and with respect to its reputation— in assuring that the offering is successful by having a large number of the securities purchased. Finally, in connection with certain offerings, LTCO has an obligation to purchase and resell a certain number of securities. Thus, because of its affiliation with LTCO, Ladenburg has incentives to recommend investments in these offerings for these reasons, rather than based on a client’s needs. To address these conflicts, Ladenburg has policies and procedures in place to make sure that securities in initial public offerings are recommended only to clients for whom they are suitable given the client’s investment objectives and assets. In addition, clients are generally given transaction specific disclosure prior to the client’s decision to invest in such securities. Securities acquired in initial public and secondary offerings may be oversubscribed and Ladenburg has policies and procedures in place for the allocation process. Ladenburg can also compensate its Financial Advisers for the costs of marketing, distribution, business and client development and educational enhancement incurred by the Financial Adviser for the promotion of Ladenburg’s services. This compensation may be based on based on assets under management or otherwise advised. Reverence Capital Partners manages the private investment funds that indirectly own a majority of Osaic Holdings, Inc., which in turn owns the Firm, as well as private investment funds that hold a minority investment in Envestnet. In addition, select management and Financial Advisors own less than 0.5%, indirectly through a Reverence Capital Partners-controlled entity, in Envestnet. As a result, Financial Advisors associated with Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp in particular, have an incentive to offer and recommend to you programs that use Envestnet’s services. Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp have procedures designed to mitigate this conflict. Payments from Third Parties In addition to the various types of compensation Ladenburg’s affiliates may earn from clients in connection with effectuating the investment advice Ladenburg renders to clients, these affiliates may also receive payments from third parties in connection with services rendered to Ladenburg’s clients. For example, LTCO and other affiliated broker-dealers may receive distribution or service (“trail”) fees from the sale of certain unaffiliated mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services. These fees are distributed from the fund’s total assets. LTCO may pay a portion of the distribution fees it earns to Ladenburg’s Financial Advisers in their capacity as broker-dealer representatives of LTCO. For accounts custodied at NFS, LTCO credits 12b-1 fees received for Ladenburg Financial Advisers back to the client accounts. Ladenburg’s affiliated broker-dealers may also participate in revenue-sharing arrangements based on fees paid by mutual funds to participate in No-Transaction-Fee (“NTF”) platforms made available by custodians. 14  Ladenburg’s affiliates may also receive payments called “revenue sharing payments” and/or “marketing allowances” from certain product sponsors (“Strategic Partners”) including mutual funds, insurance companies, and Non-Traded products such as Real Estate Investment Trusts (“REITS”). These payments are not shared with Ladenburg’s Financial Advisers. For more detailed information about the products in the Strategic Partners program, you may request the complete disclosure document from your Financial Adviser. Qualified custodians are another source of revenue to Ladenburg’s affiliated broker-dealers. Specifically, NFS and Pershing provide significant compensation to our affiliated broker-dealers in their capacity as introducing broker/dealer to offset its general operating expenses based on the number of accounts and/or account assets held by our affiliated broker dealers. The specific terms of this compensation differ between NFS and Pershing. Certain custodian fees may apply to your brokerage accounts. In some instances, the affiliated broker- dealers pays a portion of the fee charged. In other instances, the affiliated broker-dealers apply a markup to these fees. In this regard, Ladenburg’s affiliates broker-dealers can receive revenue based upon client activity, as well as the amount of assets custodied with these firms. The types of revenue include, but are not limited to, margin interest charges, IRA fees, inactivity fees, 12b-1 trails and other fees set forth in the custodian’s Schedule of Client Fees and Charges. Our affiliated broker-dealers exercise no discretion, nor provide any advice or recommendation in the selection of the Custodian for any specific account or client. As a result, any difference in compensation to our affiliated broker-dealers is based solely on the contracts with the Custodians and your Financial Adviser’s election of a Custodian. Secondly, Financial Advisers do not share in any compensation paid by the custodians to our affiliated broker-dealers. As a result, Financial Advisers have no financial conflict of interest in any recommendation of a Custodian to clients. For more information regarding custodial fees and the above forms of compensation, please see the Disclosures section of the respective affiliated broker-dealer at our Parent Company’s website: https://osaic.com/disclosures for the Pershing and NFS Schedule of Client Fees and Charges. Conflicts of Interest The various compensation arrangements discussed in this section of the Brochure present conflicts of interest for Ladenburg, because they incentivize the firm and its Financial Advisers to select or recommend products that provide such payments. To mitigate these conflicts, Ladenburg prohibits its Financial Advisers and other supervised persons from selecting or recommending any product based solely on payments that Ladenburg, its employees or its affiliates may receive in connection with the promotion of that product. Instead, Ladenburg requires Financial Advisers and other supervised persons to advise and make recommendations in clients’ best interests, taking into account clients’ needs, investment objectives and risk tolerances. Ladenburg maintains policies and procedures to ensure recommendations are suitable and require that its Financial Advisers always acts in the client’s best interest. Ladenburg also maintains a supervisory structure to monitor the advisory activities of its Financial Advisors to reduce conflicts of interest. Ladenburg offers a number of investment advisory programs that may include the Ladenburg Funds, a series of mutual funds that are managed by Ladenburg. Since Ladenburg receives an internal management fee from the funds, a conflict of interest exists. To mitigate this conflict, Ladenburg has policies and procedures governing the programs that include an allocation to the Ladenburg Funds. 15  Code of Ethics and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. All supervised persons at Ladenburg must acknowledge the terms of the Code of Ethics and personal securities transactions and holdings annually, or as amended. The Code of Ethics sets forth detailed policies and procedures regarding the personal trading of its personnel. The Code of Ethics also contains policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. A copy of the Ladenburg Code of Ethics may be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. Ladenburg personnel are required to conduct their personal investment activities in a manner that is not detrimental to its advisory clients. Ladenburg personnel are not permitted to transact in securities except under circumstances specified in the Code of Ethics. Ladenburg may give advice, take action, or hold or deal in securities for some clients or accounts, including Ladenburg’s own accounts, which differs or may be similar at times from the advice it gives, action it takes, or securities it holds or deals for other clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Ladenburg will: (a) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (b) at all times place the interests of clients first while, at the same time, allowing employees to invest for their own accounts; (c) disclose all actual and potential conflicts; (d) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (e) conduct all personal trading consistent with the Rules and in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility; and (f) not use any material non-public information in securities trading. The Code of Ethics also establishes policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Ladenburg’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. These pre-clearance requirements and the exceptions are defined in the Code of Ethics. Ladenburg and its employees may not enter orders for accounts in which they have a beneficial ownership interest to benefit from their knowledge of clients’ orders in a particular security (”front- running”). Ladenburg defaults to LTCO’s front running and personal trading policies as the affiliate broker dealer. In addition to those requirements, Ladenburg Access Persons will not be approved to trade in securities that are ETFs and/or Mutual Funds that are held in Ladenburg’s discretionary portfolios within 5 days of a rebalance by Ladenburg. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Ladenburg and its clients. Certain clients also may maintain accounts at LTCO for which Ladenburg does not act in an advisory capacity. In providing execution services to these accounts separate and apart from the client’s advisory accounts, LTCO may enter into transactions as principal. These activities are separate and apart from Ladenburg’s advisory services. 16  The Code of Ethics is enforced through compliance monitoring activities and surveillance. In cases where the firm discovers that an employee has violated a firm policy and/or procedure, the firm’s code of business conduct or code of ethics, a state or federal law, regulation of the SEC, or other regulatory agency, the Compliance Department will take appropriate steps to investigate the circumstances and will take action commensurate with the manner of the violation. Such actions could take the form of a written warning to the employee in conjunction with the firm’s Legal Department or be as serious as disciplinary action up to and including termination. Any such investigations will be brought to the appropriate regulator’s attention, if necessary, which can result in a disclosure of the violation on the employee’s U-4 form, if required. Review of Accounts The adviser is primarily responsible for reviewing the accounts on an on-going basis to ensure that the investment strategy continues to be suitable for the client, taking into account any changes to the information provided by the client. Ladenburg generally reviews Architect accounts at least annually. These reviews are performed by Ladenburg’s Chief Compliance Officer and Branch Officer Managers. Ladenburg or the adviser may provide clients with quarterly performance reviews of Architect accounts. Ladenburg and the adviser may not provide tax advice, and nothing in the performance review should be construed as advice concerning any tax matter. Performance reviews are not a substitute for regular monthly account statements received from the custodian or Form 1099. Performance reviews should not be used to calculate fees or to complete income tax returns. Upon a client's specific request and subject to the relevant firm’s policies and procedures and applicable law, the performance review may include information about assets outside the program. By including any such assets in the performance review, the firm is not undertaking to provide or be responsible for providing any services with respect to those assets. Client Referrals and Other Compensation Ladenburg may enter into agreements with third parties that will solicit clients for Ladenburg and receive compensation for solicitation efforts. In such instances, the third-party solicitor will receive either a percentage of, or a set fee from, the fee charged to the client. If a solicitor is used in connection with a client’s account, the structure and arrangement of the solicitation agreement, as well as the compensation paid to the solicitor, will be fully disclosed to the client. This disclosure will be acknowledged in writing by the client when participating in an Ladenburg program. The fee charged to a client is not affected by the use of a third-party solicitor in connection with client accounts, and a client will not be charged any additional fees for the use of such services. Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 17  Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice FACTS What does Ladenburg Thalmann Asset Management Inc. do with your personal information? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 1  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO Yes Yes  If your financial professional terminates his or her relationship with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic Holdings, Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 2  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. Ladenburg Thalmann Asset Management Inc., is an SEC registered investment adviser. 03/2025 © Ladenburg Thalmann Asset Management • 640 5th Avenue, 4th Floor • New York, NY 10019 • 800-995-5267 • ltam.com 3 

Ladenburg Thalmann Asset Management Inc. PLAN SPONSOR & PLAN PARTICIPANT SERVICES BROCHURE SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 www.ltam.com This brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”). Ladenburg is registered with the Securities and Exchange Commission (“SEC”) as a registered investment adviser. Registration does not imply any level of skill or training. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ladenburg Thalmann Asset Management Inc. is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 03/28/2025 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 28th, 2024. Ladenburg may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604. Material Changes: • Item 10: Other Financial Industry Activities and Affiliations: This section was amended to reflect changes to and renaming of certain related persons and affiliates. 2  Table of Contents Item 2 – Summary of Material Changes ............................................................................................. 2 Item 3 – Table of Contents .................................................................................................................. 3 Item 4 - Advisory Business ................................................................................................................. 4 Item 5 - Fees and Compensation ......................................................................................................... 4 Item 6 - Performance-Based Fees and Side-By-Side Management .................................................... 5 Item 7 - Types of Clients ..................................................................................................................... 5 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................. 5 Item 9 - Disciplinary Information ....................................................................................................... 6 Item 10 - Other Financial Industry Activities and Affiliations ........................................................... 6 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 8 Item 12 - Brokerage Practices ............................................................................................................. 9 Item 13 - Review of accounts .............................................................................................................. 9 Item 14 - Client Referrals and Other Compensation ......................................................................... 10 Item 15 - Custody .............................................................................................................................. 10 Item 16 - Investment Discretion ........................................................................................................ 10 Item 17 - Voting Client Securities..................................................................................................... 10 Item 18 - Financial Information ........................................................................................................ 10 Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice ..................................... 11 Item 3 – Table of Contents 3  Item 4 - Advisory Business Ladenburg Advisory Services Ladenburg provides investment consulting services to sponsors of retirement plans (“Plan Sponsors”). These services can include: identifying funds for the Plan Sponsor’s review and final selection based on the selection criteria stated in the Plan’s investment policy statement; selecting funds for inclusion in a participant directed plan on a discretionary basis based on the selection criteria stated in the Plan’s investment policy statement; assisting in enrollment and communication meetings for plan participants; and assisting the Plan Sponsor in reviewing quarterly fund performance reports. Ladenburg will enter into an agreement with the Plan Sponsor describing the services provided. As set forth in the Plan Sponsor agreement (or in a separate agreement), a third-party adviser (“RIA”) may provide certain services to the Plan Sponsor in addition to, or instead of Ladenburg. The RIA may be affiliated with Ladenburg, and the adviser of the RIA affiliate may also be a broker-dealer representative of Ladenburg Thalmann & Co Inc. (“LTCO”) or Osaic Wealth, Inc., all of which are affiliates of Ladenburg. Information about the RIA is set forth in the RIA’s disclosure brochure, which is available from the RIA. Plan participants may separately engage Ladenburg to manage their Plan assets on a discretionary basis through the Ladenburg Thalmann Discretionary – Professionally Managed program. Ladenburg will buy and sell funds available through the Plan on a discretionary basis in accordance with the investment strategy selected by the Participant and any limitations set by the Plan Sponsor. Ladenburg will not have discretion to select a different investment strategy without the client's written authorization. Ladenburg 3(38) Investment Manager Program: Ladenburg will also act as an “investment manager” as defined by section 3(38) of ERISA, to provide 3(38) Manager Program Services in agreement with either a Plan Fiduciary and/or a Sponsor. Ladenburg offers the Qui(k) program (Qui(k)), a fully-bundled 401(k) plan offering that incorporates a broad selection of investment products that are selected and monitored by Ladenburg, which serves as the ERISA Section 3(38) investment fiduciary for the plans associated with the platform. Through Qui(k), Ladenburg has entered into an agreement to provide 3(38) investment fiduciary services to American Trust Retirement Services, LLC (ATR). ATR is the Pooled Plan Provider (PPP) for the Qui(k) platform, ATR’s Pooled Employer Plan (PEP). Ladenburg, as well as the other Qui(k) platform service providers, are engaged by ATR in their capacity as the PPP named fiduciary and PEP plan sponsor. Employers who participate in Qui(k) will sign a separate agreement engaging ATR as the PPP. The specific manner in which fees are charged is established for a client in the client’s written investment advisory agreement. Ladenburg’s fee for the “3(38) Manager” Program Services is equal to a maximum of 0.10 % per annum of Plan assets. Ladenburg provides various other types of advisory services in addition to and separate from the plan sponsor and participant services described in this brochure. These services are described in other Ladenburg brochures. More information about these services is available upon request. Item 5 - Fees and Compensation Ladenburg is compensated for the plan sponsor and plan participant advisory services as set forth below. All fees are subject to negotiation. The specific manner in which fees are charged by Ladenburg is established for a client in the client’s written investment advisory agreement with Ladenburg. In exchange for the services provided to Plan Sponsors, Ladenburg will charge an annual fee of up to 1.15% based on the value of the Plan assets. The fee can be charged as a single fee with a portion of the fee retained by Ladenburg and the remainder is paid to the Ladenburg Financial Adviser or to the RIA (if applicable). The fee can be charged as two separate fees, one fee for services provided by Ladenburg and the other fee for services provided by the RIA. If charged as two separate fees, Ladenburg’s fee will not exceed 0.15% and the RIA’s fee will not exceed 1.00%. 4  The fee will generally be charged in arrears and can be charged monthly, bi-quarterly, or quarterly. However, certain clients can be charged in advance and can be charged monthly, bi-quarterly or quarterly. Plan Sponsors can terminate their agreements at any time upon thirty days’ written notice. If the Plan Sponsor services are terminated during any period except on the last business day of a quarterly period, the fee will be assessed pro rata based on the number of days that services were provided. If the fee is to be paid out of Plan assets, the Plan Sponsor generally authorizes the Plan record keeper to calculate and instruct the custodian to deduct the fee from the Plan assets and pay it to Ladenburg; otherwise Ladenburg will send the Plan Sponsor an invoice and payment of which is generally due in full within ten business days. Ladenburg will charge participants who elect to enroll in the Ladenburg Thalmann Discretionary – Professionally Managed program an additional annual fee of up to 0.15% based on the value of the Plan assets in their accounts. The fee is paid bi-quarterly or at the end of each quarter in arrears. Clients generally authorize the Plan’s record keeper to calculate and instruct the custodian to debit the fee directly from the client’s account. Participants can terminate their Ladenburg Thalmann Discretionary – Professionally Managed agreements at any time upon written or online notice and a pro rata portion of the fee will be assessed based on the number of days that services were provided. Notwithstanding the above, Plan Sponsor and participants can terminate their Agreement without penalty within five (5) business days after the Agreement has been signed by the client and accepted by Ladenburg. The fees paid for plan sponsor and participant services described above cover only the services provided by Ladenburg (and the RIA if applicable) under the agreement(s) with the Plan Sponsor or participants, as applicable. Ladenburg can share a portion of the fees that it receives with an affiliated entity, as permitted by applicable law. Plan Sponsor and/or participants will also pay separate fees for custody, third party administrative services, and for trustee or other third-party services. In addition, each mutual fund or exchange-traded fund (“ETF”) in which a client can invest also bears its own investment advisory fees and other expenses. Fund transactions can also be subject to applicable commissions and/or transactions charged by the platform chosen by the Plan Sponsors. The value of the assets will be based on information provided by the third-party administrator of the plan or the plan’s custodian. Ladenburg does not independently verify this information nor does Ladenburg guarantee the accuracy or validity of such information. The third-party administrator or record-keeper will generally calculate the fee owed to Ladenburg and debit the applicable plan accounts. Item 6 - Performance-Based Fees and Side-By-Side Management Neither Ladenburg nor any of its supervised persons receives performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 - Types of Clients Ladenburg may provide plan sponsor and participant advisory services to corporations or other business entities as plan sponsors of 401(k) programs and to participants in those plans. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Ladenburg does not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Ladenburg cannot offer any guarantees or promises that any client’s financial goals and objectives will be met. Past performance is in no way an indication of future performance. Ladenburg employs a regimen of quantitative and qualitative investment criteria which allows us to arrive at a universe of funds for the plan sponsors. Below are some of the criteria utilized: • Top quartile of performance within its peer group • Positive alpha, which indicates a funds relative performance to the risk being taken by the portfolio 5  manager • Perform well in bear markets • Lead portfolio manager has a minimum of 5 years as head portfolio manager of fund • Have a portfolio composition that is consistent with its corresponding asset class For the Ladenburg Thalmann Discretionary – Professionally Managed program, Ladenburg uses several strategies for each Plan utilizing approximately 25 mutual funds and/or exchange-traded funds that are available through the platform selected by the Plan Sponsor. Each strategy will consist of a targeted, strategic allocation. Ladenburg selects funds for each asset class in each strategy. The fund selection is based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and selects those with the above average ratings for inclusion in the strategies. Ladenburg periodically reviews each strategy and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the applicable strategy. At its discretion, Ladenburg may also add additional asset classes and funds to each strategy as well as buy and sell funds for each account to correspond to any changes made to the applicable strategy. Ladenburg also rebalances accounts periodically if the accounts’ asset allocations move beyond acceptable variance levels set for each strategy due to market movements. Investing in securities involves the risk of loss of principal that the client should be prepared to bear. Item 9 - Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. Item 10 - Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is an investment advisory firm and has been in business since October 29th, 1982. Ladenburg is a wholly owned subsidiary of Osaic Holdings, Inc. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2006 Trust. Osaic Holdings, Inc. owns 100% of both Ladenburg and LTCO, a registered broker-dealer. As such, LTCO can execute trades on behalf of clients who receive advisory services from Ladenburg. However, LTCO does not act as broker-dealer with respect to any Plans whose Plan Sponsors receive advisory services from Ladenburg. In addition, LTCO does not act as broker-dealer for any participant accounts participating in the Ladenburg Thalmann Discretionary – Professionally Managed program. 6  Other Industry Affiliates Ladenburg has the following affiliates, which are wholly owned by Osaic Holdings, Inc. or wholly owned subsidiaries of one of Osaic, Inc.’s affiliates. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by SAFC Ladenburg Thalmann & Co. Inc. (LTCO) Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Securities America, Inc. Broker/Dealer Highland Capital Brokerage Insurance Company 100% owned by Osaic Holdings, Inc. Ladenburg has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. However, these related persons are not wholly owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (BDF) Registered Investment Advisor 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. Philip Blancato and Jaime Desmond function as CEO and COO of Ladenburg respectively. In certain circumstances, BDF recommends Ladenburg’s advisory services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts and no client is under any obligation to engage the services of Ladenburg. Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the related persons, which are wholly owned subsidiaries of Osaic, Inc., which is a wholly owned subsidiary of Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by OIHI Osaic, Inc. Holding Company Vision2020 Wealth Management Corp. Registered Investment Advisor, Broker/Dealer Osaic Institutions Holdings, Inc. (OIHI) Holding Company Osaic Institutions, Inc. Registered Investment Advisor, Broker/Dealer 100% owned by Osaic, Inc. Osaic Services, Inc. Broker/Dealer Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Related Persons. In that case we or our Related Persons can receive compensation when doing so which results in a conflict of interest. Your Financial Adviser, however, does not receive a portion of the compensation paid to us or our 7  Related Persons and therefore does not have a conflict of interest in recommending the use of one of our affiliated companies. As a result of the fact that your Financial Adviser is not compensated for directing you to products or services offered by our Related Persons, we believe that the Firm’s conflict of interest is mitigated. Certain principal executive officers of Ladenburg may be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg because they will not be devoted exclusively to the business of Ladenburg and can have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Ladenburg or affiliated RIA Financial Advisers recommend services and products offered through Ladenburg affiliates to Plan Sponsor or Plan Participants that are separate from the advisory services described in this brochure. For example, they can recommend Premier Trust to provide trust and administrative services. Premier Trust provides full disclosure with respect to its trust and administrative services and related costs. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. All supervised persons at Ladenburg must acknowledge the terms of the Code of Ethics and personal securities transactions and holdings annually, or as amended. The Code of Ethics sets forth detailed policies and procedures regarding the personal trading of its personnel. The Code of Ethics also contains policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. A copy of the Ladenburg Code of Ethics may be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. Ladenburg personnel are required to conduct their personal investment activities in a manner that is not detrimental to its advisory clients. Ladenburg personnel are not permitted to transact in securities except under circumstances specified in the Code of Ethics. Ladenburg may give advice, take action, or hold or deal in securities for some clients or accounts, including Ladenburg’s own accounts, which differs or may be similar at times from the advice it gives, action it takes, or securities it holds or deals for other clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Ladenburg will: (a) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (b) at all times place the interests of clients first while, at the same time, allowing employees to invest for their own accounts; (c) disclose all actual and potential conflicts; (d) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (e) conduct all personal trading consistent with the Rules and in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility; and (f) not use any material non-public information in securities trading. The Code of Ethics also establishes policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Ladenburg’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. These pre-clearance requirements and the exceptions are defined in the Code of Ethics. Ladenburg and its employees may not enter orders for accounts in which they have a beneficial ownership 8  interest to benefit from their knowledge of clients’ orders in a particular security (“front-running’’). Ladenburg defaults to LTCO’s front running and personal trading policies as the affiliate broker dealer. In addition to those requirements, Ladenburg Access Persons will not be approved to trade in securities that are ETFs and/or Mutual Funds that are held in Ladenburg’s discretionary portfolios within 5 days of a rebalance by Ladenburg. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Ladenburg and its clients. Certain clients also may maintain accounts at LTCO for which Ladenburg does not act in an advisory capacity. In providing execution services to these accounts separate and apart from the client’s advisory accounts, LTCO may enter into transactions as principal. These activities are separate and apart from Ladenburg’s advisory services. The Code of Ethics is enforced through compliance monitoring activities and surveillance. In cases where the firm discovers that an employee has violated a firm policy and/or procedure, the firm’s code of business conduct or code of ethics, a state or federal law, regulation of the SEC, or other regulatory agency, the Compliance Department will take appropriate steps to investigate the circumstances and will take action commensurate with the manner of the violation. Such actions could take the form of a written warning to the employee in conjunction with the firm’s Legal Department or be as serious as disciplinary action up to and including termination. Any such investigations will be brought to the appropriate regulator’s attention, if necessary, which can result in a disclosure of the violation on the employee’s U-4 form, if required. Item 12 - Brokerage Practices With respect to plan participant accounts in the Ladenburg Thalmann Discretionary – Professionally Managed program, Ladenburg generally does not aggregate orders for accounts in the program that are being managed in accordance with the same investment strategy. Ladenburg also does not aggregate orders for this program with accounts it manages outside of this program. Ladenburg will allocate securities so purchased or sold, as well as any applicable expense incurred in the transaction, in a manner that it considers to be equitable and consistent with its fiduciary obligations to its clients. Ladenburg or the broker-dealer for aggregate orders assigns the average price resulting from any such aggregated trades to each applicable account. LTCO does not act as broker-dealer with respect to any Plans whose Plan Sponsors receive advisory services from Ladenburg. In addition, LTCO does not act as broker-dealer for any participant accounts participating in the Ladenburg Thalmann Discretionary – Professionally Managed program. Ladenburg does not generally receive research or other products or services other than execution from any non-affiliated broker-dealer of third party in connection with client securities transactions, otherwise known as “soft dollars.” Item 13 - Review of accounts Ladenburg generally reviews the advice it gives to Plan Sponsors each quarter. These reviews consist of qualitative and quantitative review of each plan sponsor’s investment offerings. These reviews are performed by Ladenburg’s analysts and Portfolio Management Team. Similarly, Ladenburg reviews the plan participant accounts in the Ladenburg Thalmann Discretionary – Professionally Management program each quarter. These investment reviews are part of the ongoing Ladenburg investment review process which includes peer analysis, performance ranking, risk analysis, investment manager conference calls, and model rebalancing. Ladenburg does not independently verify information provided by a custodian, client or other third party, nor does Ladenburg guarantee the accuracy or validity of such information. Ladenburg is not liable in connection with its use of any information provided by a client, a custodian, or other third-party in the quarterly performance reviews. 9  Certain Ladenburg Financial Advisers may provide written reports to their clients. Item 14 - Client Referrals and Other Compensation Ladenburg does not enter into agreements with third parties that will solicit clients for Ladenburg Plan Sponsor and Plan Participant services. Item 15 - Custody Ladenburg does not take custody of any client assets. However, certain clients have the option of authorizing Ladenburg to debit advisory fees from their custodial account. All client assets are held by an independent qualified custodian, which may be a broker-dealer, bank or trust company. Clients will receive account statements from the broker-dealer, bank or other qualified custodian holding the clients’ assets at least on a quarterly basis. Clients should carefully review those statements. Clients who also receive account reviews from Ladenburg should compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of clients’ accounts. Any account information provided by Ladenburg is for informational purposes only. Ladenburg may have standing letters of authorization granting it first-party asset movement authority on its clients’ accounts at certain of Ladenburg’s qualified custodians. Ladenburg provides the qualifying Custodian with the client’s authorization in writing. The qualifying Custodian has a record that the client has identified the accounts for which the transfer is being effected as belonging to the client (both sending and receiving accounts). Ladenburg’s authority to transfer client assets between clients’ accounts at the same qualified custodian or between another independent qualified custodian, (which may be a broker-dealer, bank or trust company) in which both have access to the sending and receiving account numbers and client account name(s) are deemed to be first party asset movement and does not constitute custody. Item 16 - Investment Discretion As described in “Advisory Business” above, Ladenburg may have discretionary authority to determine which funds are included in a participant directed plan. In addition, certain Plan participants may engage Ladenburg to manage their Plan assets on a discretionary basis through the Ladenburg Thalmann Discretionary – Professionally Managed program. Before Ladenburg assumes discretionary authority over any participant’s account, the participant must sign an investment management agreement with Ladenburg. As set forth in the participant agreement, Ladenburg will buy and sell funds available through the Plan on a discretionary basis in accordance with the investment strategy selected by the Participant and any limitations set by the Plan Sponsor. Ladenburg will not have the discretion to select a different investment strategy without the client's written authorization. Item 17 - Voting Client Securities With respect to Plan Sponsor Services and the Plan Participant accounts in the Ladenburg Thalmann Discretionary-Professionally managed program, unless Ladenburg and client otherwise agree in writing, Ladenburg is expressly precluded from taking any action or rendering any advice with respect to the voting of proxies solicited by, or with respect to, the issuers of any securities. The client expressly retains the authority and responsibility with respect to voting proxies for the account(s) or will delegate discretion with respect to voting such proxies to a third party. If Ladenburg receives any proxy materials that pertain to securities held in the Account, Ladenburg will forward the materials to the person designated by the client. Item 18 - Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 10  What does Ladenburg Thalmann Asset Management Inc. do with your personal information? FACTS Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 11  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO  If your financial professional terminates his or her relationship Yes Yes with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic Holdings, Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 12  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. Ladenburg Thalmann Asset Management Inc., is an SEC registered investment adviser. 03.2025 13 

Ladenburg Thalmann Asset Management Inc. Ladenburg Asset Management Program (LAMP) Wrap Fee Program Brochure SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 www.ltam.com This wrap fee program brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”). Ladenburg is registered with the Securities and Exchange Commission (“SEC”) as a registered investment adviser. Registration does not imply any level of skill or training. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Ladenburg is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 03/28/2025 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 28th, 2024. Ladenburg may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604. Material Changes: • Item 6 – Portfolio Manager Selection and Evaluation: Methods of Analysis, Investment Strategies and Risk was updated to include to include language on a new model added under the investment strategy “Specialty Strategies”. • Item 9: Other Financial Industry Activities and Affiliations: This section was amended to reflect changes to and renaming of certain related persons and affiliates. 2  Table of Contents Item 2 – Summary of Material Changes ....................................................................................................... 2 Item 3 –Table of Contents............................................................................................................................. 4 Item 4 – Services, Fees and Compensation .................................................................................................. 4 Consulting Services ............................................................................................................................... 4 Portfolio Management .......................................................................................................................... 4 Execution of Trades ............................................................................................................................... 4 Other Assets .......................................................................................................................................... 5 Custody ................................................................................................................................................. 5 Fees and Compensation ........................................................................................................................ 5 Item 5 – Account Requirements and Types of Clients .................................................................................. 9 Item 6 – Portfolio Manager Selection and Evaluation ................................................................................ 10 Individual Needs of Clients and Restrictions ....................................................................................... 10 Other Types of Accounts ..................................................................................................................... 10 No Performance-based Fees ............................................................................................................... 10 Methods of Analysis, Investment Strategies and Risk ........................................................................ 10 Voting Client Securities ....................................................................................................................... 12 Item 7 – Client Information Provided to Ladenburg ................................................................................... 13 Item 8 – Client Contact with Ladenburg ..................................................................................................... 13 Item 9 – Additional Information ................................................................................................................. 13 Disciplinary Information ...................................................................................................................... 13 Other Financial Industry Activities and Affiliations ............................................................................. 14 Payments from Third Parties .............................................................................................................. 16 Conflicts of Interest ............................................................................................................................. 17 Code of Ethics and Personal Trading .................................................................................................. 18 Review of Accounts ............................................................................................................................. 19 Client Referrals and Other Compensation .......................................................................................... 19 Financial Information .......................................................................................................................... 19 Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice ................................................ 20 3  Ite 3 Item 4 – Services, Fees and Compensation Consulting Services Each client has a Financial Adviser, who may be a Financial Adviser of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”), Osaic Wealth, Inc. or Osaic Advisory Services, LLC, all of which are affiliates of Ladenburg, as described in “Other Financial Industry Activities and Affiliations” below. The Financial Adviser may also be registered as, or a Financial Adviser of, an investment adviser that is not affiliated with Ladenburg. The Financial Adviser may be a broker-dealer representative of Ladenburg Thalmann & Co Inc., (“LTCO”), or Osaic Wealth, Inc. Clients who wish to participate in the Ladenburg Asset Management Program (“LAMP”) will enter into a LAMP agreement. The LAMP agreement will set forth which investment advisory entity is providing consulting services in connection with the client’s account. Clients inform their Financial Advisers of the investment objectives, risk tolerance, investment time horizon, and any investment policies, guidelines, or reasonable restrictions applicable to the assets they designate for investment through the LAMP Program. Based on the information provided, the Financial Adviser assists the client in determining if there is an appropriate LAMP solution for their investment needs and helps select an investment strategy for the client’s account from those available through LAMP. Portfolio Management A team of investment managers employed by Ladenburg (“LAMP Managers”) manage the accounts in LAMP on a discretionary basis in accordance with the investment strategy that the client selects, and information provided by the client. Any restrictions on the management of an account imposed by a client can cause the LAMP Managers to deviate from the investment decisions they would otherwise make in managing the account. Ladenburg will not have the discretion to select a different investment strategy without the client’s written authorization. in the LAMP program. You can find information about Ladenburg offers a number of other investment advisory products and services that are not described in this brochure. You can find information about these other products and services at www.ltam.com. Ladenburg also manages a series of mutual funds, known as the Ladenburg Funds, which utilize the same five strategies the Ladenburg Funds at used www.ladenburgfunds.com. Execution of Trades A broker-dealer affiliated with Ladenburg, and the Financial Adviser typically executes trades for accounts in LAMP. The specific broker-dealer will be named in the LAMP agreement. If a Ladenburg Financial Adviser is providing consulting services, the broker-dealer will generally be LTCO. If an Osaic Wealth Financial Adviser is providing consulting services, Osaic Wealth, Inc. will generally also act as broker- dealer. If a registered broker-dealer representative is registered separately as an investment adviser and providing consulting services, that broker-dealer will generally act as broker-dealer. In certain cases, the Financial Adviser may recommend/require that clients establish brokerage accounts to maintain custody of clients’ assets and to effect trades for their accounts with a broker-dealer that is not affiliated with the Financial Adviser or Ladenburg (“Unaffiliated Broker”). The Unaffiliated Broker will be named in the LAMP agreement. The final decision to select an Unaffiliated Broker is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA account holder. The Unaffiliated Broker may provide the Financial Adviser or Ladenburg with access to its institutional trading and customer services, which may not be available to retail investors. These services are generally available to independent advisers on an unsolicited basis; however, certain Unaffiliated Brokers only provide the services at no charge as long as a 4  designated amount of the adviser’s clients’ assets are maintained in accounts with the Unaffiliated Broker. For example, the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”) provides certain services at no charge to advisers as long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab. This creates a conflict of interest as the Financial Adviser will have an incentive to recommend Schwab or another Unaffiliated Broker over other broker-dealers. The services that may be provided by the Unaffiliated Brokers include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analysis and reports, and access to mutual funds and other investments that may be otherwise generally available only to institutional investors or would require a significantly higher minimum investment. Unaffiliated Brokers may make available other products and services that benefit the Financial Adviser or Ladenburg but may not benefit the clients’ accounts. These benefits may include national, regional or Ladenburg investment adviser specific educational events organized or sponsored by the Unaffiliated Broker. Other potential benefits may include occasional business entertainment, software, research, support functions, and or professional services provided by the Unaffiliated Broker. Thus, a Financial Adviser’s recommendation/requirement that clients maintain their assets in accounts at a particular Unaffiliated Broker can be based in part on the benefit the investment adviser of the availability of certain products and services provided by the Unaffiliated Broker and not solely on the nature, cost or quality of custody and brokerage services provided by the Unaffiliated Broker, which creates a potential conflict of interest. Other Assets In certain limited circumstances, the broker-dealer may permit assets that are not being managed under LAMP to be held in the same brokerage account as the LAMP assets. These assets are referred to as “non- LAMP assets.” Ladenburg will not provide discretionary management of the non-LAMP assets, and the assets will not be taken into account when Ladenburg manages the LAMP assets. Client will typically receive consulting services in connection with the non-LAMP assets from their Financial Adviser and pay fees to their Financial Adviser based on the value of the non-LAMP assets. Custody Ladenburg does not take custody of any client assets. However, certain clients have the option of authorizing Ladenburg to debit advisory fees from their custodial account. All client assets are held by an independent qualified custodian, which may be a broker-dealer, bank or trust company. Clients will receive account statements from the broker-dealer, bank or other qualified custodian holding the clients’ assets at least on a quarterly basis. Clients should carefully review those statements. Clients who also receive account reviews from Ladenburg should compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of clients’ accounts. Any account information provided by Ladenburg is for informational purposes only. Ladenburg may have standing letters of authorization granting it first-party asset movement authority on its clients’ accounts at certain of Ladenburg’s qualified custodians. Ladenburg provides the qualifying Custodian with the client’s authorization in writing. The qualifying Custodian has a record that the client has identified the accounts for which the transfer is being effected as belonging to the client (both sending and receiving accounts). Ladenburg’s authority to transfer client assets between clients’ accounts at the same qualified custodian or between another independent qualified custodian, (which may be a broker- dealer, bank or trust company) in which both have access to the sending and receiving account numbers and client account name(s) are deemed to be first party asset movement and does not constitute custody. Fees and Compensation Each account in LAMP will generally be charged an asset-based fee (“Wrap Fee”) on a quarterly basis. The Wrap Fee will be calculated based on the value of the LAMP assets in the account. The rate or rates used to calculate the Wrap Fee are subject to negotiation between the Financial Adviser and each client. 5  The actual fee rates paid by the client will be set forth in the client’s LAMP agreement. The maximum annual Wrap Fee rates are: Asset Level Tiers Account Size Range $150,000 $150,001 – $250,000 $250,001 – $500,000 $500,001 - $1,000,000 $1,000,000 – and Up Up to Next $100,000 Next $250,000 Next $500,000 Assets Over Maximum Wrap Fee Rate 2.25% 2.15% 2.05% 1.95% 1.85% The Wrap Fee rate may be either a flat annual fee rate (maximum rate of 2.25%) or will be a blended fee using two or more of the rate tiers set forth above. The blended rate is calculated by charging a lower rate on the assets above the designated tiers. The Wrap Fee will generally be charged in advance. However, certain clients may be charged in arrears. Certain clients may also be charged monthly rather than quarterly. Whether the Wrap Fee is charged in advance or in arrears, or quarterly or monthly, is set forth in the client’s LAMP agreement. Either party at any time upon written notice may terminate the LAMP agreement and a pro rata portion of any Wrap Fee paid by the client in advance will be remitted to the client based on the number of days left in the quarter following receipt of the notice of termination by Ladenburg. When the Wrap Fee is paid in arrears, a pro rata portion of the Wrap Fee will be due by the client based on the number of days elapsed in the quarter prior to receipt of the notice of termination. The Wrap Fee covers the consulting services provided by the Financial Adviser, the portfolio management services provided by Ladenburg, program administrative services, execution of transactions through the broker-dealer named in the agreement and custodial services (unless otherwise agreed between the custodian and the client). Ladenburg‘s portion of the Wrap Fee for portfolio management ranges from 0.00% to 0.45%. If there are any non-LAMP assets in the account, Ladenburg will generally not receive a portion of the Wrap Fee for portfolio management services with respect to those assets. Ladenburg can receive a portion of the fee for administrative services and the Financial Adviser will receive a portion for consulting services. The Wrap Fee charged on non-LAMP assets can be less than the Wrap Fee charges on LAMP assets, as set forth in the client’s LAMP agreement. Osaic Advisory Services, LLC can receive a portion of the fee for supervision and administrative services, if one of its Financial Advisers is providing consulting services. If the broker-dealer for the account is LTCO, the broker-dealer will also receive a portion of the Wrap Fee for the execution of transactions and generally pays part of its compensation to the custodian. If the Financial Adviser is independently registered as an investment adviser, the broker-dealer with whom the Financial Adviser is associated can receive a portion of the Wrap Fee for certain administrative services provided. If the client directs Ladenburg to execute transactions through an Unaffiliated Broker, the client may pay a Wrap Fee. If the client pays a Wrap Fee, Ladenburg or the Financial Adviser (or the Financial Adviser’s investment adviser) will generally pay the Unaffiliated Broker a transaction charge for each trade in the account. The cost of these trades is covered by the Wrap Fee. Thus, the Financial Adviser (or the Financial Adviser’s investment adviser) will earn more compensation if fewer transactions are executed for the accounts. In addition, this creates a potential disincentive to trade securities. This conflict of interest is mitigated because the Financial Adviser who pays the cost of the transactions is not managing the account, and the Ladenburg Managers generally manage these accounts in the same way that they manage accounts that execute through LTCO or another affiliated broker-dealer (see Methods of Analysis, Investment Strategies and Risk below). 6  Certain clients who direct Ladenburg to execute transactions through an Unaffiliated Broker will not pay a Wrap Fee. These clients will pay one fee (“Program Fee”) that covers all of the services covered by the Wrap Fee except for execution of transactions and custodial services, which the client will pay for separately. The client can be charged a separate asset-based fee for execution of transactions through the broker-dealer named in the agreement and for custodial services or the client can pay separate transaction charges and custodial fees. The fee structure will be set forth in the LAMP agreement or in other documents provided to the client. LAMP can cost a client more or less than purchasing such service separately depending on the frequency of trading in the LAMP accounts, commissions charged at other broker-dealers for similar products, fees charged for like services by other advisers and broker-dealers, the fee structure, and other factors. LAMP can also cost a client more or less than purchasing the Ladenburg Funds which offer the same investment strategies through a series of mutual funds. The Wrap Fee does not cover: • Brokerage commissions or other charges resulting from transactions not effected through the broker- dealer named in the client’s LAMP agreement; • Short term redemption fees that may be charged in connection with certain funds (see below) • Any additional custodial services contracted for directly by the client with the custodian; • Certain costs or charges that may be imported by the broker-dealer or custodian named in the client’s LAMP agreement or third parties, including costs associated with exchanging foreign currencies, odd- lot differentials, IRA fees, transfer taxes, exchange fees, wire transfer fees, postage fees, confirmation, statement, prospectus fees and other fees or taxes as required by law. In addition to the Wrap Fee, each mutual fund or exchange-traded fund (ETF) in which a client may invest also bears its own investment advisory fees and other expenses. The mutual funds available through the LAMP Program may be available directly from the funds pursuant to the terms of their prospectuses and without paying the Wrap Fee and exchange-traded funds are available outside of the Program without paying the Wrap Fee, subject to applicable commissions and/or transaction charges. Further, to the extent that cash used for investment through LAMP comes from redemptions of client’s mutual fund or other investments outside of LAMP, there can be tax consequences or additional cost from sales charges previously paid and redemption fees incurred. Such redemption fees would be in addition to the Wrap Fee on those assets. The broker-dealer and/or custodian will receive payments from certain mutual funds (including money market) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services and are distributed from the fund’s total assets. These fee arrangements will be disclosed upon request of a client and are available in the applicable fund’s prospectus. LTCO and Ladenburg’s other affiliated broker-dealers receive fees in connection with the client assets participating in the Bank Deposit Sweep Program and the Insured Cash Account Program, which fees are in addition to the management fee that Ladenburg receives in connection with such assets pursuant to the client’s advisory contract. When your Program Account is maintained at one of our affiliated broker-dealer’s clearing firms, Pershing, LLC (“Pershing”) or National Financial Services, Inc. (“NFS”), your free credit balance will be automatically deposited or “swept” to a deposit account at one or more banks whose deposits are insured up to applicable limits by the Federal Deposit Insurance Corporation (“FDIC”) (the “Sweep Program”). Under the Sweep Program, our affiliated broker-dealers, maintain two FDIC-insured deposit programs, the Bank Deposit Sweep Program (“BDSP”) and the Insured Cash Account Program (“ICAP”), that create financial benefits for our affiliated broker-dealers as described below. For certain Program Account types, free credit balances are swept to a money market mutual fund product (the “Money Market Mutual Fund 7  Program”). Please see the Sweep Program Terms and Conditions document, available from your Financial Adviser or from the website listed below, for full details about the Sweep Program. As set forth in the terms of your Customer Agreement with our affiliated broker-dealer, you may remove your Program Account from participating in the Sweep Program by notifying your Financial Adviser. If you remove your Program Account from the Sweep Program, cash balances will be held by the clearing firm as a free credit balance. In addition, there are always alternatives for the short-term investment of cash balances, including non-sweep money market mutual funds, treasury bills, and brokered certificates of deposit, that offer higher returns than the sweep options made available to you. FDIC Insured Deposit Program (BDSP & ICAP) Eligible account types: all accounts except ERISA Title 1 accounts, 403(b)(7), & Keogh plans. Free credit balances swept to a deposit account will earn interest that is compounded daily and credited to your Program Account monthly. Interest begins to accrue on the date of deposit with the banks participating in the program (“Program Banks”), through the business day preceding the date of withdrawal from the deposit account. The daily rate is 1/365 (or 1/366 in a leap year) of the posted interest rate. Bank Deposit Sweep Program-BDSP Our affiliated broker-dealers have established deposit levels or tiers which ordinarily pay different rates of interest depending on deposit balances. Generally, Program Accounts with higher deposit balances receive higher rates of interest than accounts with lower balances. The interest rate payable to you is determined by our affiliated broker-dealers and is based on the amounts paid by the Program Banks to obtain the deposits. The amount our affiliated broker-dealers retain, less a fee paid to the clearing agent and the third- party administrator, will not exceed 600 basis points (6.00%) per year (the “Maximum Program Fee”) on the average daily balances held in the BDSP. Interest paid on the deposit accounts will generally be lower than the rate of return on (i) other investment products that are not FDIC insured, such as money market mutual funds and (ii) on bank deposits offered outside of the BDSP. Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. The income our affiliated broker-dealers earn from Program Banks based on your balances in BDSP will in almost all circumstances be substantially greater than the amount of interest you earn from the same balances. As such, our affiliated broker-dealers receive a substantially higher percentage of the interest generated by deposit balances in the BDSP than the interest credited to your accounts. When evaluating whether to utilize the Sweep Program and the extent to which the fee exceeds the interest rate you receive, you should assume that our affiliated broker-dealers are receiving the Maximum Program Fee as described above. Insured Cash Account Program - ICAP Our affiliated broker-dealers will receive a monthly per-account fee for services it provides in connection with maintaining and administering the Sweep Program for IRAs held in an advisory/ fee-based account (the “Sweep Account Fee”). The Sweep Account Fee that each of our affiliated broker-dealers can earn from Program Accounts participating in ICAP is subject to a maximum monthly per account fee that is between $34.25 and $36.75. Please refer to the applicable Sweep Program Terms and Conditions document, which you can obtain from your Financial Adviser or from the website listed below; refer to “Disclosures,” then to the FDIC Insured Deposit Program used in your account (ICAP), for further details about the maximum monthly per account fee. The Sweep Account Fee does not depend on or vary with (and is not affected by) the actual amounts held in any particular account or your Program Account. Thus, the compensation for Program Accounts that participate in ICAP is composed solely of the Sweep Account Fee. The fee received may differ among each Program Bank. You will have no rights to the amounts paid by the Program Banks, except for interest actually credited to your account. The Sweep Account Fee will reduce the interest you are paid on the amount of assets in your Program Account. 8  The Sweep Account Fee will generally be paid by the Program Banks on your Program Account’s behalf; however, the Fee or any portion thereof can be deducted directly from your Program Account if, for example, the amounts paid by the Program Banks are insufficient to cover the Sweep Account Fee. In the event that we debit all or a portion of the monthly account fee from your account, each such amount will be reflected on your account statement. The amount of fees received by our affiliated broker-dealers, the clearing agent, and any other service provider reduces the interest you receive on your deposit account(s). Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. Because the Sweep Program generates significant payments from third parties (i.e., the Program Banks that participate in BDSP and/or ICAP) to our affiliated broker-dealers, a conflict of interest exists. A conflict of interest also arises because our affiliated broker-dealers earn more compensation from cash balances being swept to or maintained in the Sweep Program than if you purchase other investment funds or securities. The more client deposits held in BDSP, and the longer such deposits are held, the greater the compensation our affiliated broker-dealers, the clearing firms, and the third-party administrator receive. By investing through an advisory account, the compensation our affiliated broker-dealers receive from the BDSP or ICAP, as applicable, is in addition to the advisory fees that you pay. This means that our affiliated broker- dealers earn two layers of fees on the same cash balances in client advisory accounts with them. In addition, a conflict of interest arises as a result of the financial incentive for our affiliated broker-dealers to recommend and offer a Sweep Program over which they have control of certain functions. Our affiliated broker-dealers have the ability to establish and change interest rates paid on Sweep Program balances, to select or change Program Banks that participate in the BDSP and ICAP, and to determine the tier levels (if applicable) at which interest rates are paid, all of which generates additional compensation for our affiliated broker-dealers. Our affiliated broker-dealers maintain policies and procedures to ensure recommendations made to you are in your best interest. For additional information about the Sweep Program for accounts custodied at Pershing and NFS, please visit our website located at https://osaic.com/disclosures/cash- sweep-program Other forms of compensation that LTCO, Ladenburg’s Financial Advisers acting in their capacity as LTCO registered representatives, and/or Ladenburg’s other affiliated broker-dealers can earn in connection with the sale of investment products recommended to clients by Ladenburg are described in the “Other Financial Industry Activities and Affiliations” section below. Item 5 – Account Requirements and Types of Clients The minimum amount of assets required to open an account in LAMP will vary depending on the investment strategy selected as follows: Investment Strategy Minimum Assets Managed Mutual Fund Strategies $5,500 Ladenburg American Funds® Core Strategies $5,500 Ladenburg Franklin Templeton Strategies $5,500 Managed ETF Strategies $5,500 Buffered ETF Strategy $5,500 Socially Responsible Strategies $25,000 Tax Sensitive Strategies $25,000 Specialty Strategies $25,000 9  Ladenburg may waive these minimums under certain circumstances. Should the market value of an account fall below the stated minimum, Ladenburg will have the right to require that additional monies be deposited to bring the account value up to the required minimum or close the account. The following types of clients may participate in LAMP: individuals, including high net worth individuals, including small business owners, pension and profit-sharing plans, including the plan participants, trusts, estates and charitable organizations, corporations or other business entities, Taft-Hartley plans, and not for profit entities. Item 6 – Portfolio Manager Selection and Evaluation Ladenburg is the only portfolio manager available through LAMP. Individual Needs of Clients and Restrictions As described in “Services, Fees and Compensation” above, clients inform their Financial Adviser of their investment objectives, risk tolerance, and investment time horizon and give their Financial Adviser any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, the Financial Adviser assists the client in selecting an investment strategy. Clients may impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. The Financial Adviser will communicate any restrictions imposed by the client to Ladenburg. Ladenburg may reject the restriction or the account if Ladenburg deems the restriction to be unreasonable. A client also may request that Ladenburg manage the client's account in accordance with client-specified investment guidelines or policies or otherwise implement a strategy in the client's account in a manner that may differ from that in which Ladenburg would otherwise implement the strategy in the account. The Financial Adviser will communicate any such instruction to Ladenburg. Ladenburg may either reject these changes or reject the account. In the absence of client-specified investment restrictions, guidelines or policies and/or other modifications to the implementation of a strategy that have been accepted by Ladenburg, Ladenburg will generally manage accounts in a manner very similar to that of other clients who have selected the same strategy. Other Types of Accounts Ladenburg provides advice through other programs and services, which include other Wrap Fee programs. These programs and services are described in different disclosure documents which are available upon request. These programs and services generally are not managed using the same strategies and funds used in LAMP, except that Ladenburg utilizes the same strategies and funds in managing the Ladenburg Funds and except that Ladenburg offers portfolio management services to participants of certain 401(k) plans that are similar to the management provided through LAMP. Other than due to operational issues specific to each 401(k) plan, Ladenburg does not manage these accounts differently than accounts in LAMP. No Performance-based Fees Neither Ladenburg nor any of its supervised persons accepts performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Methods of Analysis, Investment Strategies and Risk Ladenburg manages accounts in LAMP using the following types of investment strategies: 1. Managed Mutual Fund Strategies. Clients may select one of five managed mutual fund strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there may be multiple investment 10  styles. Each Account in these strategies can consist of approximately 15 mutual funds primarily, Exchange-Traded Funds (“ETFs”) and Exchange-Traded Notes (“ETNs”) secondarily, which encompass the asset classes targeted for that strategy’s asset allocation. The mutual funds, ETFs and ETNs are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings for inclusion in the managed mutual fund strategies. Ladenburg periodically reviews each strategy and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the strategies. 2. Ladenburg American Funds® Core Portfolios. Clients may select one of five mutual fund strategies: These five strategies are aggressive growth, growth, growth & income, income & growth, and income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Accounts utilizing these strategies will have a target allocation of 63% American Funds mutual funds, 35% Ladenburg mutual funds and 2% in cash. Ladenburg will evaluate the portfolios for rebalancing back to the target allocation at least annually or based on extreme market conditions. The mutual funds that are selected for these strategies are within the universe of American Funds mutual funds and based on due diligence conducted by Ladenburg on a variety of performance measures. Ladenburg periodically reviews each strategy to remove or replace those mutual funds that no longer meet the qualifications necessary for inclusion in the strategies. For more information about how we handle affiliated investments (see Conflicts of Interest below). 3. Managed ETF Strategies. Clients may select one of five managed ETF strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there may be multiple investment styles. Each Account in these strategies can consist of approximately 15 ETFs primarily and mutual funds, or ETNs secondarily (if an appropriate ETF is not available), which encompass the asset classes targeted for that strategy’s asset allocation. The ETFs, mutual funds and ETNs are selected for these strategies based on due diligence conducted by Ladenburg. This due diligence includes an analysis of the underlying market index on which each ETF or ETN is based, as well as the expense ratio, longevity, liquidity and size of the ETF or ETN. Based on this evaluation, Ladenburg recommends those ETFs and/or ETNs with the best ratings for inclusion in the managed ETF strategies. Ladenburg periodically meets to review each strategy and remove or replace those ETFs and/or ETNs that no longer meet the qualifications necessary for inclusion in the strategies. 4. Tax Sensitive Strategies. Clients may select one of five managed tax sensitive strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there may be multiple investment styles. Each Account in these strategies can consist of approximately 15 mutual funds, ETFs or ETNs, which encompass the asset classes targeted for that strategy’s asset allocation. The mutual funds or ETFs and/or ETNs are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings and most tax sensitive investment strategies for inclusion in the managed tax sensitive strategies. Ladenburg periodically reviews each strategy and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the strategies. 5. Specialty Strategies. Clients may select one of the specifically focused strategies: Conservative Income, Enhanced Income, Ultra Income and Buffered ETF. Clients may select a specialty strategy which is designed with a combination of investment objectives, time horizon, and risk tolerance targeted to achieve a certain investment goal. Each Account in these strategies will consist of either a combination or solely comprised of mutual funds and ETFs, which encompass the asset classes 11  targeted for that strategy’s asset allocation. The funds are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings for inclusion in the specialty strategies. Ladenburg periodically reviews each strategy and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the strategies. 6. Ladenburg Franklin Templeton Strategies. Clients may select one of five mutual fund strategies: These five strategies are aggressive growth, growth, growth & income, income & growth, and income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Accounts utilizing these strategies will have a target allocation of 63% Franklin Templeton funds, 35% Ladenburg mutual funds and 2% in cash. Ladenburg will evaluate the portfolios for rebalancing back to the target allocation at least annually or based on extreme market conditions. The funds that are selected for these strategies are within the universe of Franklin Templeton funds and based on due diligence conducted by Ladenburg on a variety of performance measures. Ladenburg periodically reviews each strategy to remove or replace those funds that no longer meet the qualifications necessary for inclusion in the strategies. For more information about how we manage affiliated investments (see Conflicts of Interest below). 7. Socially Responsible Strategies. Clients may select one of five managed socially responsible strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there may be multiple investment styles. Each model in these strategies will consist of a combination of ETFs and Mutual Funds which are “socially conscious” per Morningstar Direct. The ETFs and mutual funds are selected for these strategies based on due diligence conducted by Ladenburg. The due diligence on ETFs includes an analysis of the underlying market index on which each ETF is based, as well as the expense ratio, longevity, liquidity and size of the ETF. The due diligence on mutual funds includes a variety of performance measures and recommends those with the best ratings for inclusion in SRI strategies. Ladenburg periodically reviews each strategy and removes or replaces those ETFs or mutual funds that no longer meet the qualifications necessary for inclusion in the strategies. Ladenburg employs a regimen of quantitative and qualitative investment criteria which allows LAMP to analyze potential funds and select funds for inclusion in the strategies available through LAMP. Below are some of the criteria utilized in selecting funds for the inclusion in the strategies: • Top quartile of performance within its peer group • Positive alpha, which indicates a funds relative performance to the risk being taken by the portfolio manager • Perform well in bear markets • Lead portfolio manager has a minimum of 5 years as head portfolio manager of fund • Have a portfolio composition that is consistent with its corresponding asset class Each investment strategy and fund entail varying degrees of risk. There can be no assurance that a particular investment strategy will be successful or that clients will not suffer losses. Results generated for each account will differ, and the investment advice provided to an individual will differ from client to client. Investment performance is not guaranteed, and Ladenburg’s past performance with respect to a client’s account or other accounts does not predict future performance. Voting Client Securities The designation for voting of proxies for securities will be defined in the respective Ladenburg -Lamp client agreement, under the section “Proxies”. If Ladenburg is delegated to vote proxies for securities in the 12  accounts, (as per the respective Ladenburg client agreement) it will do so, in accordance with Ladenburg’s policies and procedures regarding proxy voting. This delegation to Ladenburg may be revoked at any time by written notice to Ladenburg. These proxy voting policies and procedures contain guidelines that Ladenburg follows in order to minimize conflicts of interest and to ensure that it votes proxies in a manner consistent with the best interests of its clients. A copy of these policies and procedures is available upon request. Further, clients may obtain information from Ladenburg on how their proxies were voted by submitting a written request to Ladenburg. Item 7 – Client Information Provided to Ladenburg As described in Services, Fees and Compensation above, clients inform their Financial Adviser of their investment objectives, risk tolerance, and investment time horizon and give their Financial Adviser any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, the Financial Adviser assists the client in selecting an investment strategy. The Financial Adviser informs Ladenburg which strategy the client has selected in the account opening paperwork. The Financial Adviser also provides Ladenburg with information about the client. The Financial Adviser is responsible for communicating any changes to the investment strategy selected or client information to Ladenburg. Clients may impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. The Financial Adviser will communicate any restrictions imposed by the client, or any changes to these restrictions that the client makes, to Ladenburg. Ladenburg may reject the restriction or the account if Ladenburg deems the restriction to be unreasonable. A client also may request that Ladenburg manage the client's account in accordance with client-specified investment guidelines or policies or otherwise implement a strategy in the client's account in a manner that may differ from that in which Ladenburg would otherwise implement the strategy in the account. The Financial Adviser will communicate any such instruction, or changes made by the client to such instruction, to Ladenburg. Ladenburg may either reject these changes or reject the account. Item 8 – Client Contact with Ladenburg Clients are encouraged to contact their Financial Adviser to arrange for a consultation with the Ladenburg Managers. Clients are also free to contact Ladenburg Managers directly. Item 9 – Additional Information Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. For information about any disciplinary events that are material to an evaluation of Osaic Wealth, Inc., Osaic Advisory Services, LLC, or separately registered investment advisers, please see their disclosure brochures. 13  Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is an investment advisory firm and has been in business since October 29th, 1982. Ladenburg is a wholly-owned subsidiary of Osaic Holdings, Inc. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2006 Trust. Osaic Holdings, Inc. owns 100% of both Ladenburg and LTCO, a registered broker-dealer. As explained in the Fees and Compensation section above, LTCO can execute trades on behalf of clients who receive advisory services from Ladenburg. LTCO receives compensation for these brokerage services, which it shares with Ladenburg Financial Advisers who are also registered broker-dealer representatives of LTCO. Ladenburg has the following affiliates, which are wholly-owned subsidiaries of Osaic Holdings, Inc. or wholly-owned subsidiaries of one of Osaic, Inc.’s affiliates. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. Ladenburg Thalmann & Co. Inc. (LTCO) Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Highland Capital Brokerage Insurance Company 100% owned by Osaic Holdings, Inc. Ladenburg has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. However, these related persons are not wholly-owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (BDF) Registered Investment Adviser 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. Philip Blancato and Jaime Desmond function as CEO and COO of Ladenburg respectively. In certain circumstances, BDF recommends Ladenburg’s advisory services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts, and no client is under any obligation to engage the services of Ladenburg. Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the Related Persons, which are wholly-owned subsidiaries of Osaic, Inc., which is a wholly-owned subsidiary of Osaic Holdings, Inc. 14  100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by OIHI 100% owned by Osaic, Inc. Osaic, Inc. Holding Company Vision2020 Wealth Management Corp. Registered Investment Advisor Osaic Institutions Holdings, Inc. (OIHI) Holding Company Osaic Institutions, Inc. Registered Investment Advisor, Broker/Dealer Osaic Services, Inc. Broker/Dealer Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Related Persons. In that case we or our Related Persons can receive compensation when doing so which results in a conflict of interest. Your Financial Adviser, however, does not receive a portion of the compensation paid to us or our Related Persons and therefore does not have a conflict of interest in recommending the use of one of our affiliated companies. As a result of the fact that your Financial Adviser is not compensated for directing you to products or services offered by our Related Persons, we believe that the Firm’s conflict of interest is mitigated. Certain principal executive officers of Ladenburg may be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg because they will not be devoted exclusively to the business of Ladenburg and can have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Ladenburg Financial Advisers can recommend that clients invest in the Ladenburg Funds for which Ladenburg acts as investment adviser, and LTCO acts as distributor. Transactions for the funds are generally executed through LTCO. For more information see the prospectus. These recommendations create a conflict of interest because Ladenburg and LTCO generally receive more compensation in connection with the purchase of these investments than they do in connection with the purchase of other investments. In addition, these funds pay fees in connection with services or distribution, such as 12b-1 fees. These fees are paid to LTCO as broker-dealer. Ladenburg Financial Advisers can recommend Premier Trust to provide trust and administrative services. Premier Trust provides full disclosure with respect to its trust and administrative services and related costs. As explained above, LTCO acts as a dealer with respect to certain securities, and as such, can execute transactions for Ladenburg clients as principal. As a dealer, LTCO can receive a "mark-up," "mark-down," and/or spread in the net price at which principal transactions are executed. This compensation is in addition to other compensation that client pays to Ladenburg and its affiliates. Thus, Ladenburg has a conflict of interest in recommending or deciding to execute trades through LTCO on a principal basis. Ladenburg addresses this conflict of interest in the following ways. After receiving disclosures about a specific principal transaction with LTCO, clients have the opportunity to reject the transaction before it is completed, to the extent required by applicable law. In addition, Ladenburg has policies and procedures in place to assure that clients receive best execution with respect to principal trades, regardless of whether the trade is executed by LTCO or an unaffiliated dealer. 15  Ladenburg can also recommend that clients invest in securities issued in an initial public and/or secondary offerings (“new issues”) for which LTCO acts as a manager, underwriter and/or a member of the selling group. Ladenburg has a conflict of interest in recommending these securities for several reasons. First, LTCO receives all or a portion of the gross spread – the difference between the price that the client pays for the security and the price that LTCO purchases the security for -- in connection with such sales. This gross spread is generally 7% but can be higher or lower in connection with certain offerings. Ladenburg Financial Advisers generally receive a portion of this compensation as broker-dealer representatives of LTCO. In addition, LTCO has a substantial interest—both financially and with respect to its reputation— in assuring that the offering is successful by having a large number of the securities purchased. Finally, in connection with certain offerings, LTCO has an obligation to purchase and resell a certain number of securities. Thus, because of its affiliation with LTCO, Ladenburg has incentives to recommend investments in these offerings for these reasons, rather than based on a client’s needs. To address these conflicts, Ladenburg has policies and procedures in place to make sure that securities in initial public offerings are recommended only to clients for whom they are suitable given the client’s investment objectives and assets. In addition, clients are generally given transaction specific disclosure prior to the client’s decision to invest in such securities. Securities acquired in initial public and secondary offerings may be oversubscribed and Ladenburg has policies and procedures in place for the allocation process. Ladenburg can also compensate its Financial Advisers for the costs of marketing, distribution, business and client development and educational enhancement incurred by the Financial Adviser for the promotion of Ladenburg’s services. This compensation may be based on assets under management or otherwise advised. Reverence Capital Partners manages the private investment funds that indirectly own a majority of Osaic Holdings, Inc., which in turn owns the Firm, as well as private investment funds that hold a minority investment in Envestnet. In addition, select management and Financial Advisors own less than 0.5%, indirectly through a Reverence Capital Partners-controlled entity, in Envestnet. As a result, Financial Advisors associated with Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp in particular, have an incentive to offer and recommend to you programs that use Envestnet’s services. Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp have procedures designed to mitigate this conflict. Payments from Third Parties In addition to the various types of compensation Ladenburg’s affiliates may earn from clients in connection with effectuating the investment advice Ladenburg renders to clients, these affiliates can also receive payments from third parties in connection with services rendered to Ladenburg’s clients. For example, LTCO and other affiliated broker-dealers can receive distribution or service (“trail”) fees from the sale of certain unaffiliated mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services. These fees are distributed from the fund’s total assets. LTCO can pay a portion of the distribution fees it earns to Ladenburg’s Financial Advisers in their capacity as broker-dealer representatives of LTCO. For certain accounts custodied at NFS, LTCO credits 12b-1 fees received for Ladenburg Financial Advisers back to the client accounts. Ladenburg’s affiliated broker-dealers can also participate in revenue-sharing arrangements based on fees paid by mutual funds to participate in No-Transaction-Fee (NTF) platforms made available by custodians. Ladenburg’s affiliates can also receive payments called “revenue sharing payments” and/or “marketing allowances” from certain product sponsors (“Strategic Partners”) including mutual funds, insurance companies, and Non-Traded products such as Real Estate Investment Trusts (“REITS”). These payments 16  are not shared with Ladenburg’s Financial Advisers. For more detailed information about the products in the Strategic Partners program, you may request the complete disclosure document from your Financial Adviser. Qualified custodians are another source of revenue to Ladenburg’s affiliated broker-dealers. Specifically, NFS and Pershing provide significant compensation to our affiliated broker-dealers in their capacity as introducing broker/dealer to offset its general operating expenses based on the number of accounts and/or account assets held by our affiliated broker dealers. The specific terms of this compensation differ between NFS and Pershing. Certain custodian fees can apply to your brokerage accounts. In some instances, the affiliated broker-dealers pays a portion of the fee charged. In other instances, the affiliated broker-dealers apply a markup to these fees. In this regard, Ladenburg’s affiliates broker-dealers can receive revenue based upon client activity, as well as the amount of assets custodied with these firms. The types of revenue include, but are not limited to, margin interest charges, IRA fees, inactivity fees, 12b-1 trails and other fees set forth in the custodian’s Schedule of Client Fees and Charges. Our affiliated broker-dealers exercise no discretion, nor provide any advice or recommendation in the selection of the Custodian for any specific account or client. As a result, any difference in compensation to our affiliated broker-dealers is based solely on the contracts with the Custodians and your Financial Adviser’s election of a Custodian. Secondly, Financial Advisers do not share in any compensation paid by the custodians to our affiliated broker-dealers. As a result, Financial Advisers have no financial conflict of interest in any recommendation of a Custodian to clients. For more information regarding custodial fees and the above forms of compensation, please see the Disclosures section of the respective affiliated broker-dealer at our Parent Company’s website: https://osaic.com/disclosures for the Pershing and NFS Schedule of Client Fees and Charges. Conflicts of Interest The various compensation arrangements discussed in this section of the Brochure present conflicts of interest for Ladenburg, because they incentivize the firm and its Financial Advisers to select or recommend products that provide such payments. To mitigate these conflicts, Ladenburg prohibits its Financial Advisers and other supervised persons from selecting or recommending any product based solely on payments that Ladenburg, its employees or its affiliates receive in connection with the promotion of that product. Instead, Ladenburg requires Financial Advisers and other supervised persons to advise and make recommendations in clients’ best interests, taking into account clients’ needs, investment objectives and risk tolerances. Ladenburg maintains policies and procedures to ensure recommendations are suitable and require that its Financial Adviser always acts in the client’s best interest. Ladenburg also maintains a supervisory structure to monitor the advisory activities of its Financial Advisors to reduce conflicts of interest. The Ladenburg American Funds® Core Portfolios have a target allocation of 35% to affiliated mutual funds for tactical asset allocation purposes. Ladenburg, the manager of the Ladenburg Funds, does not receive any portion of the Wrap Fee. However, Ladenburg receives an internal management fee from the funds. Ladenburg is not affiliated with American Funds. The Ladenburg Franklin Templeton Strategies have a target allocation of 35% to affiliated mutual funds for tactical asset allocation purposes. Ladenburg, the manager of the Ladenburg Funds, does not receive any portion of the Wrap Fee. However, Ladenburg receives an internal management fee from the funds. Ladenburg is not affiliated with Franklin Templeton. 17  Code of Ethics and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. All supervised persons at Ladenburg must acknowledge the terms of the Code of Ethics and personal securities transactions and holdings annually, or as amended. The Code of Ethics sets forth detailed policies and procedures regarding the personal trading of its personnel. The Code of Ethics also contains policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. A copy of the Ladenburg Code of Ethics may be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. Ladenburg personnel are required to conduct their personal investment activities in a manner that is not detrimental to its advisory clients. Ladenburg personnel are not permitted to transact in securities except under circumstances specified in the Code of Ethics. Ladenburg may give advice, take action, or hold or deal in securities for some clients or accounts, including Ladenburg’s own accounts, which differs or may be similar at times from the advice it gives, action it takes, or securities it holds or deals for other clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Ladenburg will: (a) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (b) at all times place the interests of clients first while, at the same time, allowing employees to invest for their own accounts; (c) disclose all actual and potential conflicts; (d) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (e) conduct all personal trading consistent with the Rules and in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility; and (f) not use any material non-public information in securities trading. The Code of Ethics also establishes policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Ladenburg’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. These pre-clearance requirements and the exceptions are defined in the Code of Ethics. Ladenburg and its employees may not enter orders for accounts in which they have a beneficial ownership interest to benefit from their knowledge of clients’ orders in a particular security (“front- running”). Ladenburg defaults to LTCO’s front running and personal trading policies as the affiliate broker dealer. In addition to those requirements, Ladenburg Access Persons will not be approved to trade in securities that are ETFs and/or Mutual Funds that are held in Ladenburg’s discretionary portfolios within 5 days of a rebalance by Ladenburg. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Ladenburg and its clients. Certain clients also may maintain accounts at LTCO for which Ladenburg does not act in an advisory capacity. In providing execution services to these accounts separate and apart from the client’s advisory accounts, LTCO may enter into transactions as principal. These activities are separate and apart from Ladenburg’s advisory services. The Code of Ethics is enforced through compliance monitoring activities and surveillance. In cases where the firm discovers that an employee has violated a firm policy and/or procedure, the firm’s code of business 18  conduct or code of ethics, a state or federal law, regulation of the SEC, or other regulatory agency, the Compliance Department will take appropriate steps to investigate the circumstances and will take action commensurate with the manner of the violation. Such actions could take the form of a written warning to the employee in conjunction with the firm’s Legal Department or be as serious as disciplinary action up to and including termination. Any such investigations will be brought to the appropriate regulator’s attention, if necessary, which can result in a disclosure of the violation on the employee’s U-4 form, if required. Review of Accounts The Financial Adviser is primarily responsible for reviewing the investment strategy selected by the client on an on-going basis to ensure that it continues to be suitable for the client, taking into account any changes to the information provided by the client. Ladenburg generally reviews LAMP accounts at least quarterly. These reviews are performed by Ladenburg’s Investment Committee and Chief Compliance Officer. Ladenburg or Financial Adviser may provide clients with quarterly performance reviews of LAMP accounts. Ladenburg and Financial Adviser may not provide tax advice, and nothing in the performance review should be construed as advice concerning any tax matter. Performance reviews are not a substitute for regular monthly account statements received from the custodian or Form 1099. Performance reviews should not be used to calculate fees or to complete income tax returns. Upon a client's specific request and subject to the relevant firm’s policies and procedures and applicable law, the performance review may include information about assets outside the program. By including any such assets in the performance review, the firm is not undertaking to provide or responsible for providing any services with respect to those assets. Client Referrals and Other Compensation Ladenburg may enter into agreements with third parties that will solicit clients for Ladenburg and receive compensation for solicitation efforts. In such instances, the third-party solicitor will receive either a percentage of, or a set fee from, the fee charged to the client. If a solicitor is used in connection with a client’s account, the structure and arrangement of the solicitation agreement, as well as the compensation paid to the solicitor, will be fully disclosed to the client. This disclosure will be acknowledged in writing by the client when participating in a Ladenburg program. The fee charged to a client is not affected by the use of a third-party solicitor in connection with client accounts, and a client will not be charged any additional fees for the use of such services. Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 19  Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice FACTS What does Ladenburg Thalmann Asset Management Inc. do with your personal information? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 20  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO Yes Yes  If your financial professional terminates his or her relationship with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic Holdings, Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 21  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. Ladenburg Thalmann Asset Management Inc., is an SEC registered investment adviser. 03/2025 22 

Ladenburg Thalmann Asset Management Inc. $ymbil® SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 http://www.ltam.com This disclosure brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”), as it relates to the Ladenburg Symbil service. Ladenburg is registered with the Securities and Exchange Commission (“SEC”) as a registered investment adviser. Registration does not imply any level of skill or training. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ladenburg Thalmann Asset Management Inc. is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 03/28/2025 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 28th, 2024. Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604. Material Changes: • Item 10: Other Financial Industry Activities and Affiliations: This section was amended to reflect changes to and renaming of certain related persons and affiliates. 2  ITEM 2 – SUMMARY OF MATERIAL CHANGES .................................................................................. 2 Table of Contents ITEM 4 - ADVISORY BUSINESS .............................................................................................................. 4 ITEM 5 - FEES AND COMPENSATION ................................................................................................... 4 ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................. 4 ITEM 7 - TYPES OF CLIENTS ................................................................................................................... 4 ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............... 5 ITEM 9 - DISCIPLINARY INFORMATION .............................................................................................. 5 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................... 5 ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..................................................................................................................... 7 ITEM 12 - BROKERAGE PRACTICES ...................................................................................................... 8 ITEM 13 - REVIEW OF ACCOUNTS ........................................................................................................ 8 ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ...................................................... 8 ITEM 15 - CUSTODY .................................................................................................................................. 8 ITEM 16 - INVESTMENT DISCRETION .................................................................................................. 8 ITEM 17 - VOTING CLIENT SECURITIES .............................................................................................. 8 ITEM 18 - FINANCIAL INFORMATION .................................................................................................. 8 ..................... 9 LADENBURG THALMANN ASSET MANAGEMENT (“LADENBURG”) - PRIVACY NOTICE 3  Item 4 - Advisory Business Symbil Service Symbil is an online interactive tool designed to assist clients in selecting among five mutual funds that Ladenburg manages. The service is accessed through the Symbil website at www.Symbil.com. Symbil uses a client questionnaire to gauge the client’s time horizon, risk tolerance and investment objectives and creates the client’s investment profile. The Symbil tool then suggests one of five Ladenburg Sponsored Funds whose investment guidelines and asset allocation most closely matches this profile. The five Funds are Ladenburg Income, Ladenburg Income and Growth, Ladenburg Growth and Income, Ladenburg Growth, or Ladenburg Aggressive Growth. (These are referred to as the “Funds” below.) These five Funds are the only investments Ladenburg recommends through the Symbil tool. The Symbil service features goal-based interactive software which helps clients better understand how their risk tolerance, time horizon, and investment goals can affect the expected performance of certain investments. Any projections regarding the likelihood of investment outcomes are hypothetical in nature and are provided for educational purposes. Symbil does not provide comprehensive investment advice, retirement planning services, or consider other assets held by clients. Symbil recommendations do not constitute tax or legal advice. Ladenburg does not exercise any form of discretion over a Symbil client’s investments. Clients have no obligation to accept any suggestions provided by Symbil or to invest in any of the Ladenburg Funds. If a client chooses to invest in the Fund Symbil recommends, the client will pass from the Symbil website into the website for the Funds’ transfer agent, where the client will be guided through the purchasing process. The client also will be responsible for monitoring and adjusting his or her Fund investment as necessary, based on any significant changes in personal situation, time horizons, risk tolerance, and investment objectives. Clients should periodically reevaluate whether their time horizon, investment goals or risk tolerance have changed. The client may utilize the Symbil tool again for this purpose. Ladenburg offers a number of other investment advisory products and services that are not described in this brochure, including a wrap-fee program that utilizes the same five strategies that are used by the Funds. You can find information about Ladenburg’s other products and services at www.ltam.com. Item 5 - Fees and Compensation There is no charge for the Symbil service. However, Ladenburg receives fees for managing the five Funds that are recommended through Symbil. In addition to the advisory fees payable to Ladenburg, each Fund incurs administrative, and custodial fees, as well as other fees and expenses, such as brokerage commissions in connection with buying and selling securities for the Fund’s portfolio. These costs make up each Fund’s expense ratio and are paid out of each Fund’s own assets. Thus, these costs are ultimately paid by the shareholders of each Fund. Symbil clients purchase the Funds directly through the transfer agent’s website without paying any load, sales charge or redemption fee. A client may also purchase the Funds through other channels, and fees and costs can be higher or lower than those charged to Symbil clients who purchase through the transfer agent’s website. Before choosing to invest in the Funds, please read each Fund’s prospectus for further information about the Fund’s expense ratio and other charges. Prospectuses are available at www.ladenburgfunds.com or by contacting the fund administrator toll-free at 1-877-803-6583. Item 6 - Performance-Based Fees and Side-By-Side Management Neither Ladenburg nor any of its supervised persons receive performance-based fees, that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 - Types of Clients Symbil is available to all types of clients but is primarily designed for individuals and families who plan to keep their account invested for at least one year. Clients must have a bank account to maintain a Symbil 4  account. The minimum initial investment in each of the Funds is $500. Subsequent investments must be at least $50. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Through the Symbil service, Ladenburg applies an algorithm to a client’s answers to a set of questions regarding risk tolerance, time horizon and investment goals and objectives in order to identify which of the Funds most closely matches the client’s investment profile. The investment objectives of the Funds are aggressive growth, growth, growth & income, income & growth, or income. Each Fund is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Each Fund’s underlying portfolio will primarily consist of Exchange Traded Funds (ETFs), Exchange Traded Notes (ETNs), and mutual funds targeted for that Fund’s underlying asset allocation. Clients cannot choose to exclude any of the underlying holdings of a Fund. Symbil recommendations are based on the information that the client provides through an investment questionnaire. Inaccurate information can impact the validity of Symbil recommendations. In addition to managing the Funds, Ladenburg also manages separate accounts in a wrap fee program using the same strategies and types of investments. See the discussion below in the Code of Ethics, Participation or Interest in Client Transactions and Personal Trading section for information on the potential conflicts presented by this situation and the steps Ladenburg takes to address those conflicts. Ladenburg, as manager to each Fund employs a regimen of quantitative and qualitative investment criteria which allows Ladenburg to analyze potential funds and select funds for inclusion in the underlying holdings of the Fund. Each Fund entails varying degrees of risk. There can be no assurance that a particular Fund will be successful or that clients will not suffer losses. Results generated for each Fund can differ from the results achieved by separately managed accounts using the same strategies, and Fund performance is not guaranteed. Diversification does not ensure a profit or protect against loss in a declining market. There is no assurance that you will achieve positive investment results from investing in the Funds or using Symbil. Ladenburg cannot guarantee the future performance of its recommendation or the investment in the Funds and cannot guarantee that its recommendation will meet a client’s needs or provide a given level of income. Please read each Fund’s prospectus carefully for further information about a specific Fund's investment objectives, underlying portfolios, and risk. Mutual fund investing involves risk, including the possible loss of principal. Prospectuses are available at www.ladenburgfunds.com or by contacting the fund administrator toll-free at 1-877-803-6583. Item 9 - Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. Item 10 - Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is an investment advisory firm and has been in business since October 29th, 1982. Ladenburg is a wholly owned subsidiary of Osaic Holdings, Inc. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP 5  Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2016 Trust. Osaic Holdings, Inc. owns 100% of both Ladenburg and Ladenburg Thalmann & Co. Inc. (“LTCO”). LTCO is a registered broker-dealer and is the distributor of the Funds. Other Industry Affiliates Ladenburg has the following affiliates, which are wholly owned by Osaic Holdings, Inc. or wholly-owned subsidiaries of one of Osaic, Inc.’s affiliates. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. Ladenburg Thalmann & Co. Inc. Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Highland Capital Brokerage Insurance Company 100% owned by Osaic Holdings, Inc. Ladenburg has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. However, these related persons are not wholly owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (“BDF”) Registered Investment Advisor 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. Philip Blancato and Jaime Desmond function as CEO and COO of Ladenburg respectively. In certain circumstances, BDF recommends Ladenburg’s advisory services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts, and no client is under any obligation to engage the services of Ladenburg. Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the Related Persons, which are wholly-owned subsidiaries of Osaic, Inc. which is a wholly-owned subsidiary of Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by OIHI 100% owned by Osaic, Inc. Osaic, Inc. Holding Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Vision2020 Wealth Management Corp. Registered Investment Advisor Osaic Institutions Holdings, Inc. (“OIHI”) Holding Company Osaic Institutions Investments, Inc. Registered Investment Advisor, Broker/Dealer Osaic Services, Inc. Broker/Dealer 6  Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Related Persons. In that case we or our Related Persons can receive compensation when doing so which results in a conflict of interest. Your Financial Adviser, however, does not receive a portion of the compensation paid to us or our Related Persons and therefore does not have a conflict of interest in recommending the use of one of our affiliated companies. As a result of the fact your Financial Adviser is not compensated for directing you to products or services offered by our Related Persons, we believe that the Firm’s conflict of interest is mitigated. Certain principal executive officers of Ladenburg may be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg will not be devoted exclusively to the business of Ladenburg and may have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Affiliated brokers can receive commissions or other selling compensation for effecting portfolio trades for the Funds. As explained below in Client Referrals and Other Compensation, affiliates and their associated persons can also receive fees for referring certain clients to Symbil. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. The Code of Ethics also sets forth detailed policies and procedures regarding the personal trading of its personnel, as well as policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. In addition, the Code of Ethics establishes policies regarding other matters, such as outside employment and the giving or receiving of gifts and entertainment. All supervised persons at Ladenburg must acknowledge the terms of the Code of Ethics annually, as amended. A copy of the Ladenburg Code of Ethics may be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. As described above, through Symbil, Ladenburg recommends that clients invest in one or more mutual funds that Ladenburg manages. Because Ladenburg is compensated for managing these Funds, Ladenburg does not charge a separate fee for the Symbil service. Furthermore, Ladenburg’s recommendations regarding the Funds are non-discretionary; clients can choose to follow or not follow the Symbil recommendation. Ladenburg can recommend the Funds to Symbil clients at or about the same time that Ladenburg or its affiliates buy the Funds for their own accounts or recommend the Funds to, or buy the Funds for, other clients. Given the automated and non-discretionary nature of the Symbil service, Ladenburg does not believe this poses a conflict of interest. Ladenburg’s Code of Ethics and internal policies and procedures are designed to reasonably ensure that Ladenburg acts at all times in the best interests of its clients. As explained above, in addition to managing the Funds, Ladenburg manages separate accounts through a wrap fee program utilizing the same strategies and types of investments Ladenburg uses in managing the Funds. Ladenburg has a strict policy of not favoring one type of client account over another and has implemented procedures reasonably designed to ensure that all clients are treated fairly. Ladenburg employs a trade rotation policy for trading its managed accounts and the Funds. 7  Item 12 - Brokerage Practices Through Symbil, Ladenburg neither places securities trades with brokers on clients’ behalf, nor recommends brokers to clients. As explained above, Symbil clients are given the opportunity to purchase Funds directly through the Fund’s transfer agent. The brokerage practices of the Funds themselves are described in the Fund prospectuses. Item 13 - Review of Accounts Symbil does not provide ongoing advice or monitoring or reviews of accounts. Item 14 - Client Referrals and Other Compensation In exchange for referring clients to the Symbil service, Ladenburg can pay a fee of 20bps annually to persons who are associated with one of Ladenburg’s affiliated broker-dealers. The recipient of a referral fee can also be a Ladenburg-affiliated investment adviser or an independent investment adviser or a person associated with an affiliate. Such fees, which are payable only when a referred client chooses to invest in one of the recommended Funds, are a portion of the fee Ladenburg receives for managing the chosen Fund. The referral fee is paid through the solicitor’s registered broker-dealer or registered investment adviser. The referral fee arrangement between Ladenburg and the affiliated solicitor will be disclosed to the client upon entering the Symbil website. Item 15 - Custody Ladenburg does not have custody of Symbil client funds or securities. An unaffiliated entity acts as custodian for the Funds and clients receive statements on a monthly or quarterly basis from the custodian. Item 16 - Investment Discretion Ladenburg does not exercise investment discretion on behalf of Symbil clients. Clients have no obligation to accept any suggestions provided by Symbil or invest in any of the Funds. Item 17 - Voting Client Securities Under Symbil, Ladenburg will not vote or exercise similar rights for client securities. The exercise of all voting rights associated with any Fund is the responsibility of the client. Ladenburg will not advise or act for the client in any legal proceedings, including bankruptcies or class actions, involving securities held by the clients. Proxies of the Funds will be delivered to the client by the issuer of the security, the custodian, or its agent. Item 18 - Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 8  What does Ladenburg Thalmann Asset Management Inc. do with your personal information? FACTS Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 9  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO  If your financial professional terminates his or her relationship Yes Yes with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out, you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic Holdings, Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 10  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. Ladenburg Thalmann Asset Management Inc., is an SEC registered investment adviser. 03/2025 11 

Ladenburg Thalmann Asset Management Inc. Private Investment Management Services (PIM) Wrap Fee Program Brochure SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 www.ltam.com This wrap fee program brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”). Ladenburg is registered with the Securities and Exchange Commission (“SEC”) as a registered investment adviser. Registration does not imply any level of skill or training. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ladenburg Thalmann Asset Management Inc. is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 03/28/2025 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 28th, 2024. Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604 Material Changes: • Item 6: Portfolio Manager Selection and Evaluation: This section was updated in order for investors to understand the risks associated with each recommendation and investment type available. • Item 9: Additional Information: Other Financial Industry Activities and Affiliations: This section was amended to reflect changes to and renaming of certain related persons and affiliates. 2  Table of Contents Item 2 – Summary of Material Changes ....................................................................................................... 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Services, Fees and Compensation .................................................................................................. 4 Item 5 – Account Requirements and Types of Clients .................................................................................. 8 Item 6 – Portfolio Manager Selection and Evaluation .................................................................................. 8 Item 7 – Client Information Provided to Ladenburg ................................................................................... 11 Item 8 – Client Contact with Ladenburg ..................................................................................................... 11 Item 9 – Additional Information ................................................................................................................. 11 Ladenburg Thalmann Asset Management - Privacy Notice………………………………………………………………......18 Item 3 – Table of Contents 3  Item 4 – Services, Fees and Compensation Investment Advisory Services Each client has a Financial Adviser, who is a Financial Adviser of Ladenburg Thalmann Asset Management (“Ladenburg”). The Financial Adviser is generally also a broker-dealer representative of Ladenburg Thalmann & Co. Inc. Clients who wish to participate in the Private Investment Management Services Program (“PIM”) will enter into a PIM agreement with Ladenburg. Clients grant Ladenburg discretionary authority over accounts in the PIM program. This means that Ladenburg will invest and reinvest the assets in the account, including, but not limited to, the purchase and sale of securities at such time and in such manner as Ladenburg in its discretion shall determine, and will act on the client’s behalf in all other matters necessary or incidental to the handling of the account, without discussing these transactions or actions with the client in advance, except with respect to principal trades and certain investments in products sponsored by Ladenburg or its affiliates, as discussed in detail below. Such securities may include, but are not limited to, equities, bonds, options, government securities, exchange-traded funds, and mutual funds. Clients inform their Financial Advisers of the investment objectives, risk tolerance, and investment time horizon, and any investment policies, guidelines, or reasonable restrictions applicable to the assets they designate for investment through the PIM Program. Ladenburg will manage PIM accounts in accordance with the investment objectives that the client selects and information provided by the client. Any restrictions on the management of an account imposed by a client may cause Ladenburg to deviate from the investment decisions or recommendations it would otherwise make in managing the account. Financial Advisers must be pre-approved by the Ladenburg management team in order to offer the PIM program to their clients. Individuals and teams must illustrate an investment theory and strategy to be approved. Execution of Trades Clients generally authorize and direct Ladenburg to execute trades through Ladenburg Thalmann & Co. Inc.(“LTCO”), a broker-dealer affiliated with Ladenburg. Assets in the PIM program are also not generally aggregated by Ladenburg. In accordance with applicable law and regulation, broker-dealers can execute principal trades for the account(s). In addition, the broker-dealer has the authority to effect “agency-cross” transactions (i.e. transactions for which a broker-dealer acts as broker for both the client and the counterparty to the transaction) for the account(s) in accordance with applicable law and regulations. In both a principal and agency-cross trade, the affiliate broker-dealer of Ladenburg can receive compensation from the other party for such a transaction and, thus, Ladenburg can have a potentially conflicting division of loyalties and responsibilities. Client can revoke authorization to effect agency cross transactions at any time by written notice to Ladenburg. Ladenburg has policies and procedures to address such conflicts of interest. Custody Ladenburg does not take custody of any client assets. However, certain clients have the option of authorizing Ladenburg to debit advisory fees from their custodial account. All client assets are held by an independent qualified custodian, which may be a broker-dealer, bank or trust company. Clients will receive account statements from the broker-dealer, bank or other qualified custodian holding the clients’ assets at least on a quarterly basis. Clients should carefully review those statements. Clients who also receive account reviews from Ladenburg should compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of clients’ accounts. Any account information provided by Ladenburg is for informational purposes only. Ladenburg may have standing letters of authorization granting it first-party asset movement authority on its clients’ accounts at certain of Ladenburg’s qualified custodians. Ladenburg provides the qualifying Custodian with the client’s authorization in writing. The qualifying Custodian has a record that the client has identified the accounts for which the transfer is being effected as belonging to the client (both sending 4  and receiving accounts). Ladenburg’s authority to transfer client assets between clients’ accounts at the same qualified custodian or between another independent qualified custodian, (which may be a broker- dealer, bank or trust company) in which both have access to the sending and receiving account numbers and client account name(s) are deemed to be first party asset movement and does not constitute custody. Fees and Compensation Each account in PIM will generally be charged an asset-based fee (“Wrap Fee”) on a quarterly basis. The Wrap Fee will be calculated based on the value of the PIM assets in the account. The rate or rates used to calculate the Wrap Fee are subject to negotiation between the Financial Adviser and each client. The actual fee rates paid by the client will be set forth in the client’s PIM agreement. The maximum annual Wrap Fee rates for accounts at National Financial Services (“NFS”) are: Value of Account Assets Maximum Annual Program Fee Rate Up to– $500,000 3.00% $500,001 – $1.000,000 2.50% $500,001 – $2,000,000 2.25% Over $2,000,001 2.00% The Wrap Fee rate can be either a flat annual fee rate (maximum rate of 3.00%) or will be a blended fee using two or more of the rate tiers set forth above. The blended rate is calculated by charging a lower rate on the assets above the designated tiers. The Wrap Fee will generally be charged in advance. However, certain clients may be charged in arrears. Certain clients may also be charged monthly rather than quarterly. Whether the Wrap Fee is charged in advance or in arrears, or quarterly or monthly, is set forth in the client’s PIM agreement. Either party at any time upon written notice can terminate the PIM agreement and a pro rata portion of any Wrap Fee paid by the client in advance will be remitted to the client based on the number of days left in the quarter following receipt of the notice of termination by Ladenburg. When the Wrap Fee is paid in arrears, a pro rata portion of the Wrap Fee will be due by the client based on the number of days elapsed during in the quarter prior to receipt of the notice of termination. The Wrap Fee covers the advisory services provided by the Financial Adviser, program administrative services provided by Ladenburg, transaction charges and commissions in connection with execution of transactions through Ladenburg Thalmann & Co. Inc. (“LTCO”), and custodial services (unless otherwise agreed between the custodian and the client). Ladenburg also shares a portion of the Wrap Fee with the Ladenburg Financial Adviser. LTCO will also receive a portion of the Wrap Fee for the execution of transactions and generally pays part of its compensation to the custodian. PIM can cost a client more or less than purchasing such service separately depending on the frequency of trading in the PIM accounts, commissions charged at other broker-dealers for similar products, fees charged for like services by other advisers and broker-dealers and other factors. The Wrap Fee does not cover: • Brokerage commissions or other charges resulting from transactions not effected through LTCO; • "Mark-ups" and "mark-downs" or "dealer spreads" that broker-dealers, including affiliates of Ladenburg, can receive when acting as principal in certain transactions; • Short term redemption fees that can be charged in connection with certain funds (see below): • Any additional custodial services contracted for directly by the client with the custodian; 5  • Certain costs or charges that can be imported by LTCO or the custodian, including costs associated with exchanging foreign currencies, odd-lot differentials, IRA fees, transfer taxes, exchange fees, wire transfer fees, postage fees, confirmation, statement, prospectus fees and other fees or taxes as required by law. Certain securities, such as over-the-counter stocks, are traded primarily in "dealer" markets. In such markets, securities are directly purchased from, or sold to, a financial institution acting as a dealer, or "principal." Dealers executing principal trades typically include a "mark-up," "mark-down," and/or spread in the net price at which transactions are executed. When LTCO executes a transaction for a security traded in the dealer markets, LTCO either will execute the transaction as agent through a dealer unaffiliated with LTCO, or as principal in accordance with applicable law. Clients in the Program will not pay commissions or separate transaction charges to LTCO in connection with these transactions, however, the client will bear the cost (including any mark-up, mark-down, and/or spread) imposed by the dealer as part of the price of the security. Thus, the dealer will receive compensation in connection with most principal trades. LTAM has a conflict of interest in using LTCO to execute principal transactions because LTCO will receive compensation in connection with the trade as dealer, which is in addition to the Program Fee. For more information about how this conflict of interest is addressed, see the Additional Information section below. In addition to the Wrap Fee, each mutual fund or Exchange-Traded Fund (“ETF”) in which a client may invest also bears its own investment advisory fees and other expenses. Mutual funds may be available directly from the funds pursuant to the terms of their prospectuses and without paying the Wrap Fee and ETFs may be available outside of the Program without paying the Wrap Fee, subject to applicable commissions and/or transaction charges. Further, to the extent that cash used for investment through PIM comes from redemptions of the client’s mutual fund or other investments outside of PIM, there can be tax consequences or additional cost from sales charges previously paid and redemption fees incurred. Such redemption fees would be in addition to the Wrap Fee on those assets. LTCO and LTAM’s other affiliated broker-dealers receive fees in connection with the client assets participating in the Bank Deposit Sweep Program and the Insured Cash Account Program, which fees are in addition to the management fee that LTAM receives in connection with such assets pursuant to the client’s advisory contract. When your Program Account is maintained at one of our affiliated broker-dealer’s clearing firms, Pershing, LLC (“Pershing”) or National Financial Services, Inc. (“NFS”), your free credit balance will be automatically deposited or “swept” to a deposit account at one or more banks whose deposits are insured up to applicable limits by the Federal Deposit Insurance Corporation (“FDIC”) (the “Sweep Program”). Under the Sweep Program, our affiliated broker-dealers, maintain two FDIC-insured deposit programs, the Bank Deposit Sweep Program (“BDSP”) and the Insured Cash Account Program (“ICAP”), that create financial benefits for our affiliated broker-dealers as described below. For certain Program Account types, free credit balances are swept to a money market mutual fund product (the “Money Market Mutual Fund Program”). Please see the Sweep Program Terms and Conditions document, available from your Financial Adviser or from the website listed below, for full details about the Sweep Program. As set forth in the terms of your Customer Agreement with our affiliated broker-dealer, you may remove your Program Account from participating in the Sweep Program by notifying your Financial Adviser. If you remove your Program Account from the Sweep Program, cash balances will be held by the clearing firm as a free credit balance. In addition, there are always alternatives for the short-term investment of cash balances, including non-sweep money market mutual funds, treasury bills, and brokered certificates of deposit, that offer higher returns than the sweep options made available to you. FDIC Insured Deposit Program (BDSP & ICAP) Eligible account types: all accounts except ERISA Title 1 accounts, 403(b)(7), & Keogh plans. 6  Free credit balances swept to a deposit account will earn interest that is compounded daily and credited to your Program Account monthly. Interest begins to accrue on the date of deposit with the banks participating in the program (“Program Banks”), through the business day preceding the date of withdrawal from the deposit account. The daily rate is 1/365 (or 1/366 in a leap year) of the posted interest rate. Bank Deposit Sweep Program-BDSP Our affiliated broker-dealers have established deposit levels or tiers which ordinarily pay different rates of interest depending on deposit balances. Generally, Program Accounts with higher deposit balances receive higher rates of interest than accounts with lower balances. The interest rate payable to you is determined by our affiliated broker-dealers and is based on the amounts paid by the Program Banks to obtain the deposits. The amount our affiliated broker-dealers retain, less a fee paid to the clearing agent and the third- party administrator, will not exceed 600 basis points (6.00%) per year (the “Maximum Program Fee”) on the average daily balances held in the BDSP. Interest paid on the deposit accounts will generally be lower than the rate of return on (i) other investment products that are not FDIC insured, such as money market mutual funds and (ii) on bank deposits offered outside of the BDSP. LTAM and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. The income our affiliated broker-dealers earn from Program Banks based on your balances in BDSP will in almost all circumstances be substantially greater than the amount of interest you earn from the same balances. As such, our affiliated broker-dealers receive a substantially higher percentage of the interest generated by deposit balances in the BDSP than the interest credited to your accounts. When evaluating whether to utilize the Sweep Program and the extent to which the fee exceeds the interest rate you receive, you should assume that our affiliated broker-dealers are receiving the Maximum Program Fee as described above. Insured Cash Account Program - ICAP Our affiliated broker-dealers will receive a monthly per-account fee for services it provides in connection with maintaining and administering the Sweep Program for IRAs held in an advisory/ fee-based account (the “Sweep Account Fee”). The Sweep Account Fee that each of our affiliated broker-dealers can earn from Program Accounts participating in ICAP is subject to a maximum monthly per account fee that is between $34.25 and $36.75. Please refer to the applicable Sweep Program Terms and Conditions document, which you can obtain from your Financial Adviser or from the website listed below; refer to “Disclosures,” then to the FDIC Insured Deposit Program used in your account (ICAP), for further details about the maximum monthly per account fee. The Sweep Account Fee does not depend on or vary with (and is not affected by) the actual amounts held in any particular account or your Program Account. Thus, the compensation for Program Accounts that participate in ICAP is composed solely of the Sweep Account Fee. The fee received may differ among each Program Bank. You will have no rights to the amounts paid by the Program Banks, except for interest actually credited to your account. The Sweep Account Fee will reduce the interest you are paid on the amount of assets in your Program Account. The Sweep Account Fee will generally be paid by the Program Banks on your Program Account’s behalf; however, the Fee or any portion thereof can be deducted directly from your Program Account if, for example, the amounts paid by the Program Banks are insufficient to cover the Sweep Account Fee. In the event that we debit all or a portion of the monthly account fee from your account, each such amount will be reflected on your account statement. The amount of fees received by our affiliated broker-dealers, the clearing agent, and any other service provider reduces the interest you receive on your deposit account(s). LTAM and your Financial Advisor do not receive any portion of the fees paid by the Program Banks. Because the Sweep Program generates significant payments from third parties (i.e., the Program Banks that participate in BDSP and/or ICAP) to our affiliated broker-dealers, a conflict of interest exists. A conflict of interest also arises because our affiliated broker-dealers earn more compensation from cash balances being swept to or maintained in the Sweep Program than if you purchase other investment funds or securities. The more client deposits held in BDSP, and the longer such deposits are held, the greater the compensation 7  our affiliated broker-dealers, the clearing firms, and the third-party administrator receive. By investing through an advisory account, the compensation our affiliated broker-dealers receive from the BDSP or ICAP, as applicable, is in addition to the advisory fees that you pay. This means that our affiliated broker- dealers earn two layers of fees on the same cash balances in client advisory accounts with them. In addition, a conflict of interest arises as a result of the financial incentive for our affiliated broker-dealers to recommend and offer a Sweep Program over which they have control of certain functions. Our affiliated broker-dealers have the ability to establish and change interest rates paid on Sweep Program balances, to select or change Program Banks that participate in the BDSP and ICAP, and to determine the tier levels (if applicable) at which interest rates are paid, all of which generates additional compensation for our affiliated broker-dealers. Our affiliated broker-dealers maintain policies and procedures to ensure recommendations made to you are in your best interest. For additional information about the Sweep Program for accounts custodied at Pershing and NFS, please visit our website located at https://osaic.com/disclosures/cash-sweep-program. LTCO and/or the custodian will receive payments from certain mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services and are distributed from the fund’s total assets. These fee arrangements will be disclosed upon request of a client and are available in the applicable fund’s prospectus. Other forms of compensation that LTCO, LTAM’s Financial Advisers acting in their capacity as LTCO registered representatives, and/or LTAM’s other affiliated broker-dealers can earn in connection with the sale of investment products recommended to clients by LTAM are described in the Other Financial Industry Activities and Affiliations section below. Item 5 – Account Requirements and Types of Clients The minimum amount of assets required to open an account in the PIM Program is $50,000. Ladenburg may waive these minimums under certain circumstances. Should the market value of an account fall below the stated minimum, Ladenburg will have the right to require that additional monies be deposited to bring the account value up to the required minimum or close the account. The following types of clients may participate in PIM: individuals, including high net worth individuals, including small business owners, pension and profit-sharing plans, trusts, estates and charitable organizations, corporations or other business entities, Taft-Hartley plans, and not for profit entities. Item 6 – Portfolio Manager Selection and Evaluation Ladenburg Financial Advisers are the only portfolio managers available through PIM. Individual Needs of Clients and Restrictions Ladenburg Financial Advisers tailor their advisory services to the individual needs of the client in the PIM program. Clients inform their Financial Adviser of their investment objectives, risk tolerance, and investment time horizon and give their Financial Adviser any applicable investment policies, guidelines, or reasonable restrictions. Clients can impose reasonable restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. Any restrictions imposed by a client may cause the Financial Adviser to manage the account differently than he or she would in the absence of such restrictions. Thus, the account may not perform as well. A client also may request that Ladenburg manage the client's account in accordance with client-specified investment guidelines or policies or otherwise implement a strategy in the client's account in a manner that may differ from that in which Ladenburg would otherwise implement the strategy in the account. The advisor representative will communicate any such instruction to Ladenburg. Ladenburg may either reject these changes or reject the account. 8  Other Types of Accounts Ladenburg provides advice through other programs and services, which include other Wrap Fee programs. These programs and services are described in different disclosure documents which are available upon request. These programs and services generally may not be managed using the same securities, strategies and funds used in PIM. No Performance-based Fees Neither Ladenburg nor any of its supervised persons accepts performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Methods of Analysis, Investment Strategies and Risk Financial Advisers manage accounts in PIM using various types of investment strategies. The main sources of information advisers can use include financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filing with the SEC and company press releases. The investment strategies used to manage accounts can include long-term purchases, short-term purchases, selling securities within 30 days, short sales, margin transactions, and option writing. Ladenburg Financial Advisers may have access to third party vendors that provide support services in portfolio design and strategy implementation. Examples of third-party sources used to assist in managing assets are S&P Research, Independent Research, Bloomberg, Morningstar Workstation, various ETF & fund screeners, economic news services, statistical ratings organizations and asset allocation software or proposal systems. Our firm can use these tools along with an investor profile or questionnaires to recommend a portfolio or a selection of securities that will assist a client to achieve their objectives and risk tolerances. Each investment style, strategy, and investment entails varying degrees of risk. There can be no assurance that a particular investment or strategy will be successful or that clients will not suffer losses. Results generated for each account will differ, and the investment advice provided to an individual will differ from client to client. Investment performance is not guaranteed, and the Financial Adviser’s past performance with respect to a client’s account or other accounts does not predict future performance. The investment strategies used to manage accounts can include long-term purchases, short-term purchases, selling securities within 30 days, short sales, margin transactions, and option writing. It is important to understand the risks associated with each recommendation and investment type available. The following is a summary of some of the general risks associated with investing. Please note that this list is not all inclusive, and is provided as an indication of some of the factors that can impact the value of your investments: Business Risk: This is the risk that the strength of the company you are buying a piece of ownership in (stock for example) or are loaning money to (a bond, for example) affects your potential returns. Your returns from the stock purchase or bond purchase are influenced by factors like the company going out of business, or going into bankruptcy, or having a viable and strong revenue stream from the products or services it sells that is not over-shadowed by expenses. If a company goes bankrupt and its assets are liquidated, common stockholders are the last in line to share in the proceeds. Credit Risk: This is the risk that the government entity or company that issued the investment will run into financial difficulties and won’t be able to pay the interest or repay the principal at maturity. Credit risk applies to debt investments such as bonds. You can evaluate credit risk by looking at the credit rating of the bond or the issuer. For example, long-term U.S. government bonds currently have a credit rating of AAA, which indicates the lowest possible credit risk. Cybersecurity Risk: The Firm’s information and technology systems may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by its professionals, power outages and catastrophic events such as fires, tornados, floods, hurricanes and earthquakes. Although the Firm has 9  implemented various measures to protect the confidentiality of its internal data and to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, the Firm will likely have to make a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the Firm’s operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information relating to clients. Such a failure could harm the Firm’s reputation or subject it or its affiliates to legal claims and otherwise affect their business and financial performance. The Firm will seek to notify affected clients of any known cybersecurity incident that will likely pose substantial risk of exposing confidential personal data about such clients to unintended parties. Margin risk: Leverage increases a portfolio’s risk as price swings are amplified in a margin account and clients can lose more funds than deposited if the value of securities decline. Financial Risk: This is the risk that the companies you invest in will perform poorly, which affect the price of your investment. You cannot eliminate financial risk; however, you may be able to minimize the impact through diversification. Market Risk: This is the risk that the stock market will decline, decreasing the value of the securities owned. Stock market bubbles and crashes are good examples of heightened market risk. You can’t eliminate market risk; however, you may be able to minimize the impact through diversification. Regulatory Risk: This is the risk that changes in law and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. Options risks: An option holder runs the risk of losing the entire amount paid for the option in a relatively short period of time. This risk reflects the nature of an option as a wasting asset which becomes worthless when it expires. An option holder who neither sells their option in the secondary market nor exercises it prior to its expiration will necessarily lose their entire investment in the option. An option writer may be assigned an exercise at any time during the period the option is exercisable. Starting with the day it is purchased, an American-style option is subject to being exercised by the option holder at any time until the option expires. This means that the option writer is subject to being assigned an exercise at any time after they have written the option, until the option expires or until they have closed out their option position in a closing transaction. By contrast, the writer of a European-style or capped option is subject to assignment only when the option is exercisable or, in the case of a capped option, when the automatic exercise value of the underlying interest hits the cap price. For more information regarding the risks of options, please read the ‘Characteristics and Risks of Standardized Options’ brochure, which can be found at www.optionsclearing.com. Other Risks: The risks associated with investment in funds that invest primarily in private funds entail a significant amount of risk. The types of risk include: loss of all or a substantial portion of the investment due to leveraging, short selling or other speculative practices; lack of liquidity in that there may be no secondary market for the fund or the securities that make-up the fund, and none may develop or expected to develop; volatility of returns; restrictions on transferring interests in the fund; absence of information regarding valuations and pricing; complex tax structures and delays in tax reporting; adviser risk; and less regulation and potentially higher fees than traditional mutual fund strategies. Voting Client Securities With respect to the PIM program, unless Ladenburg and the client otherwise agree in writing, Ladenburg is expressly precluded from taking any action or rendering any advice with respect to the voting of proxies solicited by, or with respect to, the issuers of any securities held in the account. The client expressly retains the authority and responsibility with respect to voting proxies for the account(s) or will delegate discretion 10  with respect to voting such proxies to a third party. If Ladenburg receives any proxy materials that pertain to securities held in the account, Ladenburg will forward the materials to the person designated by the client. Item 7 – Client Information Provided to Ladenburg As described in Services, Fees and Compensation above, clients inform their Financial Adviser of their investment objectives, risk tolerance, and investment time horizon and give their Financial Adviser any applicable investment policies, guidelines, or reasonable restrictions. Clients can impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. A client also can request that Ladenburg manage the client's account in accordance with client-specified investment guidelines or policies or otherwise implement a strategy in the client's account in a manner that can differ from that in which Ladenburg would otherwise have recommended. The client must promptly inform their assigned Financial Adviser of material changes in their financial circumstances or investment objectives. The Financial Adviser will periodically discuss, at least once a year, whether the management of the account continues to reflect the investment objectives and financial requirements of the client. Item 8 – Client Contact with Ladenburg Clients are encouraged to contact their Financial Adviser directly. Item 9 – Additional Information Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is an investment advisory firm and has been in business since October 29th, 1982. Ladenburg is a wholly owned subsidiary of Osaic Holdings, Inc. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2006 Trust. Osaic Holdings, Inc. owns 100% of both Ladenburg and LTCO, a registered broker-dealer. As explained in the Fees and Compensation section above, LTCO may execute trades on behalf of clients who receive advisory services from Ladenburg. LTCO receives compensation for these brokerage services, which it shares with Ladenburg Financial Advisers who are also registered broker-dealer representatives of LTCO. Ladenburg has the following affiliates, which are wholly owned by Osaic Holdings, Inc. or wholly owned subsidiaries of one of Osaic, Inc.’s affiliates. 11  100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. Ladenburg Thalmann & Co. Inc. (LTCO) Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Highland Capital Brokerage Insurance Company 100% owned by Osaic Holdings, Inc. Ladenburg has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. However, these related persons are not wholly owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (BDF) Registered Investment Advisor 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. Philip Blancato and Jaime Desmond function as CEO and COO of Ladenburg respectively. In certain circumstances, BDF recommends Ladenburg’s advisory services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts and no client is under any obligation to engage the services of Ladenburg. Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the related persons, which are wholly owned subsidiaries of Osaic, Inc., which is a wholly owned subsidiary of Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by OIHI 100% owned by Osaic Holdings, Inc. 100% owned by APHI 100% owned by APHI 100% owned by Osaic, Inc. Osaic, Inc. Holding Company Vision2020 Wealth Management Corp. Registered Investment Advisor Osaic Institutions Holdings, Inc. (OIHI) Osaic Institutions, Inc. Registered Investment Advisor, Broker/Dealer American Portfolios Holdings, Inc. (APHI) Holding Company American Portfolios Advisory, Inc. Registered Investment Advisor American Portfolios Financial Services, Inc. Broker/Dealer Osaic Services, Inc. Broker/Dealer Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Related Persons. In that case we or our Related Persons can receive compensation when doing so which results in a conflict of interest. Your Financial Adviser, however, does not receive a portion of the compensation paid to us or our Related Persons and therefore does not have a conflict of interest in recommending the use of one of our affiliated companies. As a result of the fact that your Financial Adviser is not compensated for directing 12  you to products or services offered by our Related Persons, we believe that the Firm’s conflict of interest is mitigated. Certain principal executive officers of Ladenburg may be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg because they will not be devoted exclusively to the business of Ladenburg and may have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Ladenburg Financial Advisers may recommend that clients invest in the Ladenburg Funds for which Ladenburg acts as investment adviser, and LTCO acts as distributor. Transactions for the funds are generally executed through LTCO. For more information see the prospectus. These recommendations create a conflict of interest because Ladenburg and LTCO generally receive more compensation in connection with the purchase of these investments than they do in connection with the purchase of other investments. In addition, these funds pay fees in connection with services or distribution, such as 12b-1 fees. These fees are paid to LTCO as broker-dealer. Ladenburg Financial Advisers may recommend Premier Trust to provide trust and administrative services. Premier Trust provides full disclosure with respect to its trust and administrative services and related costs. As explained above, LTCO acts as a dealer with respect to certain securities, and as such, may execute transactions for Ladenburg clients as principal. As a dealer, LTCO may receive a "mark-up," "mark-down," and/or spread in the net price at which principal transactions are executed. This compensation is in addition to other compensation that client pays to Ladenburg and its affiliates. Thus, Ladenburg has a conflict of interest in recommending or deciding to execute trades through LTCO on a principal basis. Ladenburg addresses this conflict of interest in the following ways. After receiving disclosures about a specific principal transaction with LTCO, clients have the opportunity to reject the transaction before it is completed, to the extent required by applicable law. In addition, Ladenburg has policies and procedures in place to assure that clients receive best execution with respect to principal trades, regardless of whether the trade is executed by LTCO or an unaffiliated dealer. Ladenburg may also recommend that clients invest in securities issued in an initial public and/or secondary offerings (“new issues”) for which LTCO acts as a manager, underwriter and/or a member of the selling group. Ladenburg has a conflict of interest in recommending these securities for several reasons. First, LTCO receives all or a portion of the gross spread – the difference between the price that the client pays for the security and the price that LTCO purchases the security for -- in connection with such sales. This gross spread is generally 7% but may be higher or lower in connection with certain offerings. Ladenburg Financial Advisers generally receive a portion of this compensation as broker-dealer representatives of LTCO. In addition, LTCO has a substantial interest—both financially and with respect to its reputation— in assuring that the offering is successful by having a large number of the securities purchased. Finally, in connection with certain offerings, LTCO has an obligation to purchase and resell a certain number of securities. Thus, because of its affiliation with LTCO, Ladenburg has incentives to recommend investments in these offerings for these reasons, rather than based on a client’s needs. To address these conflicts, Ladenburg has policies and procedures in place to make sure that securities in initial public offerings are recommended only to clients for whom they are suitable given the client’s investment objectives and assets. 13  In addition, clients are generally given transaction specific disclosure prior to the client’s decision to invest in such securities. Securities acquired in initial public and secondary offerings may be oversubscribed and Ladenburg has policies and procedures in place for the allocation process. Ladenburg can also compensate its Financial Advisers for the costs of marketing, distribution, business and client development and educational enhancement incurred by the Financial Adviser for the promotion of Ladenburg’s services. This compensation may be based on based on assets under management or otherwise advised. Reverence Capital Partners manages the private investment funds that indirectly own a majority of Osaic Holdings, Inc., which in turn owns the Firm, as well as private investment funds that hold a minority investment in Envestnet. In addition, select management and Financial Advisors own less than 0.5%, indirectly through a Reverence Capital Partners-controlled entity, in Envestnet. As a result, Financial Advisors associated with Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp in particular, have an incentive to offer and recommend to you programs that use Envestnet’s services. Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp have procedures designed to mitigate this conflict. Payments from Third Parties In addition to the various types of compensation Ladenburg’s affiliates may earn from clients in connection with effectuating the investment advice Ladenburg renders to clients, these affiliates may also receive payments from third parties in connection with services rendered to Ladenburg’s clients. For example, LTCO and other affiliated broker-dealers may receive distribution or service (“trail”) fees from the sale of certain unaffiliated mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services. These fees are distributed from the fund’s total assets. LTCO may pay a portion of the distribution fees it earns to Ladenburg’s Financial Advisers in their capacity as broker-dealer representatives of LTCO. For certain accounts custodied at NFS, LTCO credits 12b-1 fees received for Ladenburg Financial Advisers back to the client accounts. Ladenburg’s affiliated broker-dealers may also participate in revenue-sharing arrangements based on fees paid by mutual funds to participate in No-Transaction-Fee (“NTF”) platforms made available by custodians. Ladenburg’s affiliates may also receive payments called “revenue sharing payments” and/or “marketing allowances” from certain product sponsors (“Strategic Partners”) including mutual funds, insurance companies, and Non-Traded products such as Real Estate Investment Trusts (“REITS”). These payments are not shared with Ladenburg’s Financial Advisers. For more detailed information about the products in the Strategic Partners program, you may request the complete disclosure document from your Financial Adviser. Qualified custodians are another source of revenue to Ladenburg’s affiliated broker-dealers. Specifically, NFS and Pershing provide significant compensation to our affiliated broker-dealers in their capacity as introducing broker/dealer to offset its general operating expenses based on the number of accounts and/or account assets held by our affiliated broker dealers. The specific terms of this compensation differ between NFS and Pershing. Certain custodian fees may apply to your brokerage accounts. In some instances, the affiliated broker- dealers pays a portion of the fee charged. In other instances, the affiliated broker-dealers apply a markup to these fees. In this regard, Ladenburg’s affiliates broker-dealers can receive revenue based upon client activity, as well as the amount of assets custodied with these firms. The types of revenue include, but are 14  not limited to, margin interest charges, IRA fees, inactivity fees, 12b-1 trails and other fees set forth in the custodian’s Schedule of Client Fees and Charges. Our affiliated broker-dealers exercise no discretion, nor provide any advice or recommendation in the selection of the Custodian for any specific account or client. As a result, any difference in compensation to our affiliated broker-dealers is based solely on the contracts with the Custodians and your Financial Adviser’s election of a Custodian. Secondly, Financial Advisers do not share in any compensation paid by the custodians to our affiliated broker-dealers. As a result, Financial Advisers have no financial conflict of interest in any recommendation of a Custodian to clients. For more information regarding custodial fees and the above forms of compensation, please see the Disclosures section of the respective affiliated broker-dealer at our Parent Company’s website: https://osaic.com/disclosures for the Pershing and NFS Schedule of Client Fees and Charges. Conflicts of Interest The various compensation arrangements discussed in this section of the Brochure present conflicts of interest for Ladenburg, because they incentivize the firm and its Financial Advisers to select or recommend products that provide such payments. To mitigate these conflicts, Ladenburg prohibits its Financial Advisers and other supervised persons from selecting or recommending any product based solely on payments that Ladenburg, its employees or its affiliates may receive in connection with the promotion of that product. Instead, Ladenburg requires Financial Advisers and other supervised persons to advise and make recommendations in clients’ best interests, taking into account clients’ needs, investment objectives and risk tolerances. . Ladenburg maintains policies and procedures to ensure recommendations are suitable and require that its Financial Advisers always acts in the client’s best interest. Ladenburg also maintains a supervisory structure to monitor the advisory activities of its Financial Advisors to reduce conflicts of interest. Ladenburg offers a number of investment advisory programs that may include the Ladenburg Funds, a series of mutual funds that are managed by Ladenburg. Since Ladenburg receives an internal management fee from the funds, a conflict of interest exists. To mitigate this conflict, Ladenburg has policies and procedures governing the programs that include an allocation to the Ladenburg Funds. Code of Ethics and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. All supervised persons at Ladenburg must acknowledge the terms of the Code of Ethics and personal securities transactions and holdings annually, or as amended. The Code of Ethics sets forth detailed policies and procedures regarding the personal trading of its personnel. The Code of Ethics also contains policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. A copy of the Ladenburg Code of Ethics may be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. Ladenburg personnel are required to conduct their personal investment activities in a manner that is not detrimental to its advisory clients. Ladenburg personnel are not permitted to transact in securities except under circumstances specified in the Code of Ethics. Ladenburg may give advice, take action, or hold or deal in securities for some clients or accounts, including Ladenburg’s own accounts, which differs or may be similar at times from the advice it gives, action it takes, or securities it holds or deals for other clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Ladenburg will: (a) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the 15  performance of their duties; (b) at all times place the interests of clients first while, at the same time, allowing employees to invest for their own accounts; (c) disclose all actual and potential conflicts; (d) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (e) conduct all personal trading consistent with the Rules and in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility; and (f) not use any material non-public information in securities trading. The Code of Ethics also establishes policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Ladenburg’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. These pre-clearance requirements and the exceptions are defined in the Code of Ethics. Ladenburg and its employees may not enter orders for accounts in which they have a beneficial ownership interest to benefit from their knowledge of clients’ orders in a particular security (“front-running”). Ladenburg defaults to LTCO’s front running and personal trading policies as the affiliate broker dealer. In addition to those requirements, Ladenburg Access Persons will not be approved to trade in securities that are ETFs and/or Mutual Funds that are held in Ladenburg’s discretionary portfolios within 5 days of a rebalance by Ladenburg. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Ladenburg and its clients. Certain clients also may maintain accounts at LTCO for which Ladenburg does not act in an advisory capacity. In providing execution services to these accounts separate and apart from the client’s advisory accounts, LTCO may enter into transactions as principal. These activities are separate and apart from Ladenburg’s advisory services. The Code of Ethics is enforced through compliance monitoring activities and surveillance. In cases where the firm discovers that an employee has violated a firm policy and/or procedure, the firm’s code of business conduct or code of ethics, a state or federal law, regulation of the SEC, or other regulatory agency, the Compliance Department will take appropriate steps to investigate the circumstances and will take action commensurate with the manner of the violation. Such actions could take the form of a written warning to the employee in conjunction with the firm’s Legal Department or be as serious as disciplinary action up to and including termination. Any such investigations will be brought to the appropriate regulator’s attention, if necessary, which can result in a disclosure of the violation on the employee’s U-4 form, if required. Review of Accounts The Financial Adviser is primarily responsible for reviewing the accounts on an on-going basis to ensure that the investment strategy continues to be suitable for the client, taking into account any changes to the information provided by the client. Ladenburg generally reviews PIM accounts at least annually. These reviews are performed by Ladenburg’s Chief Compliance Officer and Branch Officer Managers. Ladenburg or the Financial Adviser may provide clients with quarterly performance reviews of PIM accounts. Ladenburg and the Financial Adviser may not provide tax advice, and nothing in the performance review should be construed as advice concerning any tax matter. Performance reviews are not a substitute for regular monthly account statements received from the custodian or Form 1099. Performance reviews should not be used to calculate fees or to complete income tax returns. Upon a client's specific request and subject to the relevant firm’s policies and procedures and applicable law, the performance review may 16  include information about assets outside the program. By including any such assets in the performance review, the firm is not undertaking to provide or be responsible for providing any services with respect to those assets. Client Referrals and Other Compensation Ladenburg may enter into agreements with third parties that will solicit clients for Ladenburg and receive compensation for solicitation efforts. In such instances, the third-party solicitor will receive either a percentage of, or a set fee from, the fee charged to the client. If a solicitor is used in connection with a client’s account, the structure and arrangement of the solicitation agreement, as well as the compensation paid to the solicitor, will be fully disclosed to the client. This disclosure will be acknowledged in writing by the client when participating in an Ladenburg program. The fee charged to a client is not affected by the use of a third-party solicitor in connection with client accounts, and a client will not be charged any additional fees for the use of such services. Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 17  Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice FACTS What does Ladenburg Thalmann Asset Management Inc. do with your personal information? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 1  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO Yes Yes  If your financial professional terminates his or her relationship with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic Holdings, Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 2  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. Ladenburg Thalmann Asset Management Inc., is an SEC registered investment adviser. 03/2025 © Ladenburg Thalmann Asset Management • 640 5th Avenue, 4th Floor • New York, NY 10019 • 800-995-5267 • ltam.com 3 

Ladenburg Thalmann Asset Management Inc. SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 www.ltam.com Form ADV Part 2A - Firm Brochure This brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”). Ladenburg is registered with the Securities and Exchange Commission (“SEC”) as a registered investment adviser. Registration does not imply any level of skill or training. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Ladenburg is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 03/28/2025 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 28th, 2024. Ladenburg may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604. Material Changes: • Item 4: Advisory Business: Discretionary and non-discretionary assets managed were updated as of 12/31/2024. • Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss section was updated in order for investors to understand the risks associated with each recommendation and investment type available. • Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss: Separately Managed Accounts and Allocation Consulting Services was updated to include language on a new model added under the investment strategy “Specialty Strategies”. • Item 10: Other Financial Industry Activities and Affiliations: This section was amended to reflect changes to and renaming of certain related persons and affiliates. 2  Table of Contents Item 2 – Summary of Material Changes ....................................................................................................... 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 4 Item 5 – Fees and Compensation ................................................................................................................. 6 Item 6 - Performance-Based Fees and Side-By-Side Management ............................................................ 11 Item 7 - Types of Clients .............................................................................................................................. 11 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss ...................................................... 11 Item 9 - Disciplinary Information ................................................................................................................ 16 Item 10 - Other Financial Industry Activities and Affiliations ..................................................................... 16 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 20 Item 12 - Brokerage Practices ..................................................................................................................... 21 Item 13 – Review of Accounts..................................................................................................................... 22 Item 14 - Client Referrals and Other Compensation .................................................................................. 23 Item 15 - Custody ........................................................................................................................................ 23 Item 16 – Investment Discretion ................................................................................................................ 24 Item 17 – Voting Client Securities ............................................................................................................... 24 Item 18 – Financial Information .................................................................................................................. 24 Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice ................................................ 25 Item 3 – Table of Contents 3  Item 4 – Advisory Business Ladenburg Thalmann Asset Management (“Ladenburg”) is an SEC Registered Investment Advisory firm, established in 1982, and has over $5.0 billion in assets under management. Ladenburg is a wholly owned subsidiary of Osaic Holdings, Inc. which provides investment banking, equity research, institutional sales and trading, independent brokerage and advisory and asset management services through its subsidiaries. Osaic Holdings, Inc. is also the holding company of Ladenburg Thalmann & Co. Inc. (“LTCO”), a registered broker-dealer, which was established in 1876. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P. and The Berliniski Family 2006 Trust. Ladenburg is led by CEO Philip Blancato and COO Jaime Desmond. Ladenburg has 15 full-time employees supporting the organization in the areas of market research and analysis, manager and fund due diligence, trading and operations activity, consulting services and business development. Additional information can be found at www.ltam.com Types of Ladenburg Advisory Services Consulting Services Ladenburg provides personal consultations to clients that are intended to address the client’s individual questions, financial needs, and personal circumstances. The consulting services may encompass a wide variety of issues and topics, including investment recommendations. The consulting services may include the preparation of and/or updates to a written financial plan. The client has sole responsibility for determining whether to implement any recommendations made during any personal consultation or in a financial plan. The client may, but is not required to, implement any of the recommendations through Ladenburg as investment adviser or through any of its affiliates. If the client chooses to use Ladenburg or an affiliate to implement any recommendations, those activities are separate and distinct from the financial consulting services provided by Ladenburg under a consulting services agreement. Ladenburg Funds Ladenburg is the investment adviser to five funds collectively called the Ladenburg Funds. The five Ladenburg Funds are Ladenburg Income Fund, Ladenburg Income & Growth Fund, Ladenburg Growth & Income Fund, Ladenburg Growth Fund, and the Ladenburg Aggressive Growth Fund. Each of the Ladenburg Funds is an open-end fund of funds that primarily invests in a combination of equity, fixed income and alternative strategy exchange traded funds ("ETFs"), exchange traded notes (“ETNs”) and mutual funds (together, “Underlying Funds”). The Funds employ the same investment strategies and features as the ones Ladenburg employs in managing separate client accounts in in the Ladenburg Asset Management Program (“LAMP”), which is described below under Ladenburg Sponsored Programs. Each Fund will have substantially the same investment objective, policies and strategies as its corresponding separate account strategy. Funds’ fees can be more or less than the fees and expenses associated with the separate accounts managed by Ladenburg in LAMP. The Fund’s results will differ from that of the separate accounts in LAMP managed in a similar strategy because of differences in future behavior of the various investment markets, brokerage commissions, account expenses, the size of positions taken in relation to account size and diversification of securities, and the timing of purchases and sales, among other things. The Ladenburg Funds offer A, C, and I share classes in each fund. LTCO is the distributor of the Funds and can also receive commissions when executing trades on behalf of the Funds. There is a conflict of interest when Ladenburg or its affiliates recommend any of the Ladenburg Funds. For more information, please see the Conflicts of Interest section below. Information about the Ladenburg Funds and the services Ladenburg provides to them can be found in Funds’ prospectus. Prospectuses are available at www.ladenburgfunds.com or by contacting the fund administrator toll-free at 1-877-803-6583. 4  The Ladenburg Total Portfolio Series (Collective Investment Trusts) Ladenburg is the investment adviser to The Ladenburg Thalmann Total Portfolio Series which is a series of Collective Investment Trusts (“CITs”). The CITs are a series of 5 portfolios established for qualified retirement plans, such as 401(k) plans and Profit-Sharing Plans. The portfolios are generally comprised of Exchange Traded Funds (“ETF”) which closely mimic Ladenburg’s traditional LAMP ETF models. The CITs are maintained by a bank trust, and are offered in 2 share classes, Advisory or Investor. Ladenburg 3(38) Investment Manager Program Ladenburg will also act as an “investment manager” as defined by section 3(38) of ERISA, to provide 3(38) Manager Program Services in agreement with either a Plan Fiduciary and/or a Sponsor. Ladenburg offers the Qui(k) program (Qui(k)), a fully-bundled 401(k) plan offering that incorporates a broad selection of investment products that are selected and monitored by Ladenburg, which serves as the ERISA Section 3(38) investment fiduciary for the plans associated with the platform. Through Qui(k), Ladenburg has entered into an agreement to provide 3(38) investment fiduciary services to American Trust Retirement Services, LLC (“ATR”). ATR is the Pooled Plan Provider (PPP) for the Qui(k) platform, ATR’s Pooled Employer Plan (PEP). Ladenburg, as well as the other Qui(k) platform service providers, are engaged by ATR in their capacity as the PPP named fiduciary and PEP plan sponsor. Employers who participate in Qui(k) will sign a separate agreement engaging ATR as the PPP. The specific manner in which fees are charged is established for a client in the client’s written investment advisory agreement. Ladenburg Sponsored Programs Ladenburg also provides advisory services through several Ladenburg-sponsored programs, including: Ladenburg Architect, Ladenburg Asset Management Program (“LAMP”); the Private Investment Management (“PIM”) Program; and the Investment Consulting Services (“ICS”) Program and Plan Sponsor and Plan Participant Services. Under these programs, clients generally pay a single fee that covers both advisory services provided by Ladenburg and brokerage services provided by its affiliated broker-dealers. These broker-dealers, LTCO and Osaic Wealth, Inc., as applicable, receive a portion of the wrap fee, as does the Financial Adviser servicing the account. In certain cases, Ladenburg or another investment adviser may recommend/require that clients establish brokerage accounts to maintain custody of clients’ LAMP or ICS assets and to effect trades for their accounts with a broker-dealer that is not affiliated with the investment adviser or Ladenburg (“Unaffiliated Broker”). For more information see “Brokerage Practices” below. Additional information about the Ladenburg sponsored programs and descriptions of the applicable fee schedules are set forth in separate program brochures that are available upon request. Separately Managed Accounts Ladenburg manages separate accounts in wrap and non-wrap programs that are sponsored by third party investment advisers. Ladenburg also manages separate accounts for clients that are referred by third party investment advisers outside of a sponsored program. Investment management provided to these clients is substantially the same as that provided to clients in the wrap fee programs sponsored by Ladenburg. However, the different structures of various programs or other arrangements can result in differences in how accounts are managed inside and outside of Ladenburg sponsored programs. $ymbil® Ladenburg operates Symbil, an online, interactive tool designed to assist clients in selecting among the five Ladenburg Funds. The service is accessed through the Symbil website at www.Symbil.com. Symbil uses a client questionnaire to gauge the client’s time horizon, risk tolerance and investment objectives and creates the client’s investment profile. The Symbil tool suggests the Ladenburg Fund whose investment guidelines and asset allocation most closely matches this profile. Ladenburg does not exercise any form of discretion over a Symbil client’s investments. Clients have no obligation to accept any suggestions provided by Symbil or to invest in any of the Ladenburg Funds. Symbil does not provide comprehensive investment advice or consider other assets held by clients. Additional information about Symbil set forth 5  in a separate program brochure that is available upon request or at symbil.com/docs/Symbil-Program- Brochure.pdf. Allocation Consulting Services Ladenburg provides model allocations and updates to those models to other registered investment advisers for a service fee. These other advisers utilize the models to provide advice to their clients. Ladenburg generally does not provide investment advice directly to these clients. The other registered investment adviser, not Ladenburg, has the authority to conduct trading activity as necessary to change or rebalance their clients’ portfolios, in accordance with any changes to the model allocations provided. Currently Ladenburg provides this service to advisers, including Envestnet Asset Management, Inc. (“Envestnet”), CreativeOne Wealth, LLC (“CreativeOne”), and Orion Portfolio Solutions, LLC (“Orion”). None of these companies are affiliated with Ladenburg. Ladenburg does not provide any individualized advice with respect to CreativeOne, or Orion clients but may provide advice to Envestnet with respect to specific trades for its client accounts. For more information regarding Envestnet, CreativeOne, and Orion please visit www.adviserinfo.sec.gov and refer to their respective registered investment adviser’s Form ADV Part 2A. Individual Client Needs and Restrictions For consulting services, clients inform their Ladenburg Financial Adviser of their investment objectives, risk tolerance, and investment time horizon and give their Financial Adviser any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, Ladenburg tailors its advisory services to the individual needs of the client. These clients can impose reasonable restrictions on investments in certain securities or types of securities. With respect to fund management, Ladenburg tailors its advice to the fund itself, not to the individual investors in the fund. With respect to Ladenburg wrap fee programs and separately managed accounts, clients inform their Financial Adviser, who may be a representative of Ladenburg or another investment adviser, of their investment objectives, risk tolerance, and investment time horizon and give their Financial Adviser any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, the Financial Adviser assists the client in selecting an investment strategy. Clients can impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. The Financial Adviser will communicate any restrictions imposed by the client to Ladenburg. Ladenburg may reject the restriction or the account if Ladenburg deems the restriction to be unreasonable. In the absence of client-specified investment restrictions, guidelines or policies and/or other modifications to the implementation of a strategy that have been accepted by Ladenburg, Ladenburg will generally manage accounts in a manner very similar to that of other clients who have selected the same strategy. With respect to asset allocations services, Ladenburg generally provides advice to another registered investment adviser, who is responsible for tailoring that advice to the individual needs of their clients. Upon request, Ladenburg may provide the investment adviser with advice specific to one or more clients. In all cases, the other adviser is responsible for decisions regarding client-imposed restrictions on investment in certain securities or types of securities. Assets Managed Ladenburg managed $1,606,976,694 of assets on a discretionary basis and $4,004,102,065 of assets on a non-discretionary basis as of 12/31/2024. Item 5 – Fees and Compensation Ladenburg is compensated for its advisory services as set forth below. All fees are subject to negotiation. The specific manner in which fees are charged by Ladenburg is established for a client in the client’s written investment advisory agreement with Ladenburg. 6  Consulting Services Ladenburg generally charges either a one-time flat consulting fee, a periodic flat fee, an hourly fee, or a periodic asset-based fee for consulting services in advance. The fee type and amount or rates are subject to negotiation between Ladenburg and each client. The actual fee rates paid by the client will be set forth in the client’s agreement with Ladenburg. The maximum asset-based consulting fee is an annual fee rate of 0.75%. The fee is based on the value of the assets in designated accounts and will be pro-rated for any partial quarters. The value of the assets will be based on information provided by the custodian of the assets, the client or other third party, as applicable. Ladenburg is entitled to rely on the financial and other information that the client, any custodian, or any other third party provides to Ladenburg. Ladenburg does not independently verify this information, nor does Ladenburg guarantee the accuracy or validity of such information. Ladenburg will generally send the client an invoice for the Fee, which will be due within thirty days of the client’s receipt of the invoice, unless the client instructs custodian to take instructions from Ladenburg to debit the fee from one of client’s accounts. The Fee covers only the consulting services provided by Ladenburg under the consulting services agreement. In addition to the consulting fee that clients pay to Ladenburg, clients who chose to implement the recommendations will incur certain fees and charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers. The fees and charges can include, but not limited to: brokerage commissions, mark-up or mark-downs on principal transactions, transaction fees, exchange fees, SEC fees, custodial fees, deferred sales charges, transfer taxes, confirmation, statement, prospectus fees, IRA fees, wire transfer and electronic fund processing fees. Each mutual fund, exchange-traded fund (“ETF”) or private fund in which a client may invest also bears its own investment advisory fees and other expenses. Fund transactions are also subject to applicable commissions, transaction charges or other fees. If the client chooses to implement any portion of the recommendations through Ladenburg or an affiliate, Ladenburg and its affiliates will receive additional compensation. For example, if the client decides to implement a portion of the recommendations through a Ladenburg advisory program, the client will pay program fees to Ladenburg in connection with the program as part of the total advisory fee that is negotiated with the Ladenburg Financial Adviser who will generally receive a portion of advisory fees for services rendered under the Ladenburg program. Similarly, if the client decides to implement a portion of the recommendations through a brokerage account at LTCO or at another broker-dealer affiliate of Ladenburg’s, the client will pay commissions and fees to LTCO or the other affiliated broker-dealer. The fee that a client pays to Ladenburg for consulting services will not be reduced if fees are paid to Ladenburg, LTCO, or its affiliates for other services. Clients can purchase securities through broker-dealers in initial public offerings, and/or secondary offerings (“new issues”). If LTCO acts as an underwriter or manager or as a member of the selling group for such offerings, it will receive compensation equal to either all or a portion of “gross spread” (the difference between the price the client pays for the security and the price at which LTCO purchased the securities). The advisory fee is not reduced to offset this new issue securities compensation. The amount of the gross spread is described in the relevant prospectus, offering circular or official statement. Certain securities, such as over-the-counter stocks, are traded primarily in "dealer" markets. In such markets, securities are directly purchased from, or sold to, a financial institution acting as a dealer, or "principal." Dealers executing principal trades typically include a "mark-up," "mark-down," and/or spread in the net price at which transactions are executed. When LTCO executes a transaction for a security traded in the dealer markets, LTCO either will execute the transaction as agent through a dealer unaffiliated with LTCO, or as principal in accordance with applicable law. In addition to any applicable commission or transaction fee, the client will bear the cost (including any mark-up, mark-down, and/or spread) imposed 7  by the dealer as part of the price of the security. Thus, the dealer will receive compensation in connection with most principal trades. Ladenburg has a conflict of interest in using LTCO to execute principal transactions because LTCO will receive compensation in connection with the trade as dealer. LTCO can receive distribution or service (“trail”) fees from the sale of certain mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services and are distributed from the fund’s total assets. The fees received by LTCO create a conflict of interest. These fee arrangements will be disclosed upon client’s request and are described in the applicable fund’s prospectus. All Ladenburg Financial Advisers are also registered broker-dealer representatives of LTCO. LTCO can share a portion of payments received from a mutual fund, CIT, or in connection with an initial public offering, a secondary offering, and/or a private placement with these Ladenburg Financial Advisers. These Financial Advisers can also receive compensation, such as 12(b)-1 or services fees, in connection with the sale of funds or investments, including the Ladenburg Funds, and the Ladenburg Total Portfolio Series CITs. Therefore, the Ladenburg Financial Adviser has an incentive to recommend implementing the recommendations made through the consulting services through LTCO. This conflict of interest is heightened when the Ladenburg Financial Adviser recommends securities where LTCO acts as underwriter because the Financial Adviser typically receives more compensation in connection with these securities than in connection with other types of securities. The Ladenburg Financial Adviser will also have a heightened conflict of interest when recommending funds, CITs and other products that pay compensation. Other forms of compensation that LTCO, Ladenburg’s Financial Advisers acting in their capacity as LTCO registered representatives, and/or Ladenburg’s other affiliated broker-dealers can earn in connection with the sale of investment products recommended to clients by Ladenburg are described in the Other Financial Industry Activities and Affiliations section below. Clients have the option to purchase investment products that Ladenburg recommends through other brokers or agents that are not affiliated with Ladenburg. In addition, Ladenburg has policies and procedures in place to monitor whether any Ladenburg program in which client investments or any security (or other investment purchased through LTCO) is in the best interests of the client. Sweep Program LTCO and Ladenburg’s other affiliated broker-dealers receive fees in connection with the client assets participating in the Bank Deposit Sweep Program and the Insured Cash Account Program. These fees are in addition to the management fee that Ladenburg receives in connection with such assets pursuant to the client’s advisory contract. When your Program Account is maintained at one of our affiliated broker-dealer’s clearing firms, Pershing, LLC (“Pershing”) or National Financial Services, Inc. (“NFS”), your free credit balance will be automatically deposited or “swept” to a deposit account at one or more banks whose deposits are insured up to applicable limits by the Federal Deposit Insurance Corporation (“FDIC”) (the “Sweep Program”). Under the Sweep Program, our affiliated broker-dealers, maintain two FDIC-insured deposit programs, the Bank Deposit Sweep Program (“BDSP”) and the Insured Cash Account Program (“ICAP”), that create financial benefits for our affiliated broker-dealers as described below. For certain Program Account types, free credit balances are swept to a money market mutual fund product (the “Money Market Mutual Fund Program”). Please see the Sweep Program Terms and Conditions document, available from your Financial Adviser or from the website listed below, for full details about the Sweep Program. As set forth in the terms of your Customer Agreement with our affiliated broker-dealer, you may remove your Program Account from participating in the Sweep Program by notifying your Financial Adviser. If you remove your Program Account from the Sweep Program, cash balances will be held by the clearing firm as a free credit balance. In addition, there are always alternatives for the short-term investment of cash balances, including non-sweep money market mutual funds, treasury bills, and brokered certificates of deposit, that offer higher returns than the sweep options made available to you. 8  FDIC Insured Deposit Program (BDSP & ICAP) Eligible account types: all accounts except ERISA Title 1 accounts, 403(b)(7), & Keogh plans. Free credit balances swept to a deposit account will earn interest that is compounded daily and credited to your Program Account monthly. Interest begins to accrue on the date of deposit with the banks participating in the program (“Program Banks”), through the business day preceding the date of withdrawal from the deposit account. The daily rate is 1/365 (or 1/366 in a leap year) of the posted interest rate. Bank Deposit Sweep Program-BDSP Our affiliated broker-dealers have established deposit levels or tiers which ordinarily pay different rates of interest depending on deposit balances. Generally, Program Accounts with higher deposit balances receive higher rates of interest than accounts with lower balances. The interest rate payable to you is determined by our affiliated broker-dealers and is based on the amounts paid by the Program Banks to obtain the deposits. The amount our affiliated broker-dealers retain, less a fee paid to the clearing agent and the third- party administrator, will not exceed 600 basis points (6.00%) per year (the “Maximum Program Fee”) on the average daily balances held in the BDSP. Interest paid on the deposit accounts will generally be lower than the rate of return on (i) other investment products that are not FDIC insured, such as money market mutual funds and (ii) on bank deposits offered outside of the BDSP. Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. The income our affiliated broker-dealers earn from Program Banks based on your balances in BDSP will in almost all circumstances be substantially greater than the amount of interest you earn from the same balances. As such, our affiliated broker-dealers receive a substantially higher percentage of the interest generated by deposit balances in the BDSP than the interest credited to your accounts. When evaluating whether to utilize the Sweep Program and the extent to which the fee exceeds the interest rate you receive, you should assume that our affiliated broker-dealers are receiving the Maximum Program Fee as described above. Insured Cash Account Program - ICAP Our affiliated broker-dealers will receive a monthly per-account fee for services it provides in connection with maintaining and administering the Sweep Program for IRAs held in an advisory/ fee-based account (the “Sweep Account Fee”). The Sweep Account Fee that each of our affiliated broker-dealers can earn from Program Accounts participating in ICAP is subject to a maximum monthly per account fee that is between $34.25 and $36.75. Please refer to the applicable Sweep Program Terms and Conditions document, which you can obtain from your Financial Adviser or from the website listed below; refer to “Disclosures,” then to the FDIC Insured Deposit Program used in your account (ICAP), for further details about the maximum monthly per account fee. The Sweep Account Fee does not depend on or vary with (and is not affected by) the actual amounts held in any particular account or your Program Account. Thus, the compensation for Program Accounts that participate in ICAP is composed solely of the Sweep Account Fee. The fee received may differ among each Program Bank. You will have no rights to the amounts paid by the Program Banks, except for interest actually credited to your account. The Sweep Account Fee will reduce the interest you are paid on the amount of assets in your Program Account. The Sweep Account Fee will generally be paid by the Program Banks on your Program Account’s behalf; however, the Fee or any portion thereof can be deducted directly from your Program Account if, for example, the amounts paid by the Program Banks are insufficient to cover the Sweep Account Fee. In the event that we debit all or a portion of the monthly account fee from your account, each such amount will be reflected on your account statement. The amount of fees received by our affiliated broker-dealers, the clearing agent, and any other service provider reduces the interest you receive on your deposit account(s). Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. Because the Sweep Program generates significant payments from third parties (i.e., the Program Banks that participate in BDSP and/or ICAP) to our affiliated broker-dealers, a conflict of interest exists. A conflict of interest also arises because our affiliated broker-dealers earn more compensation from cash balances being 9  swept to or maintained in the Sweep Program than if you purchase other investment funds or securities. The more client deposits held in BDSP, and the longer such deposits are held, the greater the compensation our affiliated broker-dealers, the clearing firms, and the third-party administrator receive. By investing through an advisory account, the compensation our affiliated broker-dealers receive from the BDSP or ICAP, as applicable, is in addition to the advisory fees that you pay. This means that our affiliated broker- dealers earn two layers of fees on the same cash balances in client advisory accounts with them. In addition, a conflict of interest arises as a result of the financial incentive for our affiliated broker-dealers to recommend and offer a Sweep Program over which they have control of certain functions. Our affiliated broker-dealers have the ability to establish and change interest rates paid on Sweep Program balances, to select or change Program Banks that participate in the BDSP and ICAP, and to determine the tier levels (if applicable) at which interest rates are paid, all of which generates additional compensation for our affiliated broker-dealers. Our affiliated broker-dealers maintain policies and procedures to ensure recommendations made to you are in your best interest. For additional information about the Sweep Program for accounts custodied at Pershing and NFS, please visit our website located at https://osaic.com/disclosures/cash-sweep-program. Fund Management The Ladenburg Funds pay Ladenburg a management fee monthly in arrears which are equal to a maximum of 0.50% per annum of the assets in the fund. For more information, see the fund’s prospectus. CIT Management The Ladenburg Total Portfolio Series pays Ladenburg an investment management fee monthly in arrears which is equal to a maximum of 0.10% per annum of the assets in the CITs. Ladenburg 3(38) Investment Manager Program Ladenburg’s fee for the “3(38) Manager” Program Services is equal to a maximum of 0.10% per annum of Plan assets. Ladenburg Sponsored Programs Details and fee schedule regarding the fees for programs sponsored by Ladenburg Thalmann Asset Management can be found within their respective Program brochure, which is available upon request or visit adviserinfo.sec.gov/firm/brochure/108604. Separately Managed Accounts With respect to some clients, Ladenburg may have a separate agreement with the client under which it charges an advisory fee for management services. The advisory fee will generally be charged quarterly in advance. However, certain clients may be charged in arrears and/or monthly. Whether the advisory fee is charged in advance or in arrears, or quarterly or monthly, is set forth in the client’s Ladenburg agreement. Either party at any time upon written notice can terminate the Ladenburg agreement and a pro rata portion of any advisory paid to Ladenburg by the client in advance will be remitted to the client based on the number of days left in the quarter following receipt of the notice of termination by Ladenburg. When the advisory fee is paid in arrears, a pro rata portion of the fee will be due by the client based on the number of days elapsed during the quarter prior to receipt of the notice of termination. The Ladenburg advisory fee covers the portfolio management services provided by Ladenburg and the services of any model manager utilized by Ladenburg to manage the account. The client will pay separately for all other expenses, such as the consulting investment adviser’s fee and execution of transactions. With respect to other clients, another registered investment adviser is responsible for paying Ladenburg’s fee as set forth in Ladenburg’s agreement with that adviser. For more information, see the other advisory’s disclosure or wrap fee brochure. 10  Ladenburg can share a portion of the fees that it receives with an affiliated entity, as permitted by applicable law. Allocation Consulting Services For our allocation consulting services, Ladenburg’s fee is a maximum of .50% annually based on the value of the assets managed in accordance with the applicable models. Another registered investment adviser is responsible for paying Ladenburg’s fee as set forth in Ladenburg’s agreement with that adviser. For more information, see the other registered investment adviser’s disclosure brochure. Item 6 - Performance-Based Fees and Side-By-Side Management Neither Ladenburg nor any of its supervised persons receives performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 - Types of Clients Ladenburg may provide consulting services to: Individuals, including high net worth individuals, including small business owners, pension and profit-sharing plans, including the plan participants, trusts, estates and charitable organizations, corporations or other business entities, investment companies, pooled investment vehicles and other investment advisers. Ladenburg also provides advisory services to registered investment companies and other registered investment advisers. Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Ladenburg does not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Ladenburg cannot offer any guarantees or promises that any client’s financial goals and objectives will be met. Past performance is in no way an indication of future performance. Certain advisory strategies may consist of portfolios being either fully or primarily invested in money market funds and/or short-term bond funds, depending on the client’s unique financial planning needs and/or our economic market outlook. There can be a conflict of interest if Ladenburg and its affiliates invest in different parts of the capital structure of the same issuer and if that company is involved in a bankruptcy proceeding, each client’s ability to recoup their initial investment can vary significantly. Ladenburg has policies and procedures to address such conflicts of interest. If there is a trade error in an account, Ladenburg has policies and procedures to correct the error in favor of the client. Ladenburg will provide other registered investment advisers with model allocations. Ladenburg will evaluate the model allocations it provides and factors to be considered in monitoring performance which include comparing model portfolio performance relative to certain market indices. The main sources of information that Ladenburg may use include financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the SEC and company press releases. Consulting Services The Financial Adviser will assist client in the selection of other money managers or asset allocation programs. The Financial Adviser will assist in determining the client’s investment objectives, selecting managers, funds or portfolios, setting restrictions or limitations on the management of the account, explaining portfolio strategies and transactions, and answering questions. The Financial Adviser will also evaluate the overall investment strategy and performance of any third-party money manager or asset allocation program. Factors to be considered in monitoring performance include comparing client portfolio performance relative to certain market indices and other money managers. 11  General Investment Risks It is important to understand the risks associated with each recommendation and investment type available. The following is a summary of some of the general risks associated with investing. Please note that this list is not all inclusive, and is provided as an indication of some of the factors that can impact the value of your investments: Business Risk: This is the risk that the strength of the company you are buying a piece of ownership in (stock for example) or are loaning money to (a bond, for example) affects your potential returns. Your returns from the stock purchase or bond purchase are influenced by factors like the company going out of business, or going into bankruptcy, or having a viable and strong revenue stream from the products or services it sells that is not over-shadowed by expenses. If a company goes bankrupt and its assets are liquidated, common stockholders are the last in line to share in the proceeds. Credit Risk: This is the risk that the government entity or company that issued the investment will run into financial difficulties and won’t be able to pay the interest or repay the principal at maturity. Credit risk applies to debt investments such as bonds. You can evaluate credit risk by looking at the credit rating of the bond or the issuer. For example, long-term U.S. government bonds currently have a credit rating of AAA, which indicates the lowest possible credit risk. Cybersecurity Risk: The Firm’s information and technology systems may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by its professionals, power outages and catastrophic events such as fires, tornados, floods, hurricanes and earthquakes. Although the Firm has implemented various measures to protect the confidentiality of its internal data and to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, the Firm will likely have to make a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the Firm’s operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information relating to clients. Such a failure could harm the Firm’s reputation or subject it or its affiliates to legal claims and otherwise affect their business and financial performance. The Firm will seek to notify affected clients of any known cybersecurity incident that will likely pose substantial risk of exposing confidential personal data about such clients to unintended parties. Financial Risk: This is the risk that the companies you invest in will perform poorly, which affect the price of your investment. You cannot eliminate financial risk; however, you may be able to minimize the impact through diversification. Market Risk: This is the risk that the stock market will decline, decreasing the value of the securities owned. Stock market bubbles and crashes are good examples of heightened market risk. You can’t eliminate market risk; however, you may be able to minimize the impact through diversification. Margin Risk: Leverage increases a portfolio’s risk as price swings are amplified in a margin account and clients can lose more funds than deposited if the value of securities decline. Material Risks from Investment Strategies: Investing involves risk of loss that clients should be prepared to bear. Many factors affect performance, and past performance does not guarantee futures results. Account values are expected to fluctuate, and clients could lose money by investing. There is no assurance that Ladenburg will achieve the client’s investment objective, and Ladenburg’s investment strategy will not necessarily produce the intended results. Options Risk: The investment strategies used to manage accounts include long-term purchases, short-term purchases, selling securities within 30 days, short sales, margin transactions, and option writing. An option holder runs the risk of losing the entire amount paid for the option in a relatively short period of time. This risk reflects the nature of an option as a wasting asset which becomes worthless when it expires. An option holder who neither sells their option in the secondary market nor exercises it prior to its 12  expiration will necessarily lose their entire investment in the option. An option writer may be assigned an exercise at any time during the period the option is exercisable. Starting with the day it is purchased, an American-style option is subject to being exercised by the option holder at any time until the option expires. This means that the option writer is subject to being assigned an exercise at any time after they have written the option until the option expires or until they have closed out their option position in a closing transaction. By contrast, the writer of a European-style or capped option is subject to assignment only when the option is exercisable or, in the case of a capped option, when the automatic exercise value of the underlying interest hits the cap price. For more information regarding the risks of options, please read the ‘Characteristics and Risks of Standardized Options’ brochure, which can be found at www.optionsclearing.com. Regulatory Risk: This is the risk that changes in law and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. Risks of Investing with Third-Party Money Managers: Some managers utilize leveraged mutual funds or ETFs and leveraged inverse mutual funds or ETFs (hereafter referred to as “leveraged funds”) as part of their investment strategy. Leveraged funds are investment vehicles that use debt and derivatives in order to magnify the returns of an underlying index on a daily basis. Trading in leveraged funds is designed to be a market timing or active trading strategy, are not as tax efficient as traditional ETFs/mutual funds and are not suitable as a long-term investment. Some managers invest assets in funds that primarily invest in futures. Investing in futures involves additional risk due to the use of derivatives which are often more volatile than other investments and can magnify the fund’s gains and losses. Investors considering these types of investment should have a long-term investment horizon as funds trading futures can experience immediate and substantial loss or gain due to relatively small movements in the price of a futures contract. These techniques may expose a client to potentially dramatic changes (losses) in the value of its allocation to the manager and/or investment fund. Possibility of Fraud and Other Misconduct – When client assets are allocated to a manager or investment funds, the Firm does not have custody of the assets. Therefore, there is the risk that the manager or investment fund or its custodian could divert or abscond with those assets, fail to follow agreed upon investment strategies, provide false reports of operations, or engage in other misconduct. Moreover, there can be no assurances that all managers and investment funds will be operated in accordance with all applicable laws and that assets entrusted to manager or investment funds will be protected. Other Risks: The risks associated with investment in funds that invest primarily in private funds entail a significant amount of risk. The types of risk include: loss of all or a substantial portion of the investment due to leveraging, short selling or other speculative practices; lack of liquidity in that there may be no secondary market for the fund or the securities that make-up the fund, and none may develop or expected to develop; volatility of returns; restrictions on transferring interests in the fund; absence of information regarding valuations and pricing; complex tax structures and delays in tax reporting; adviser risk; and less regulation and potentially higher fees than traditional mutual fund strategies. Real Estate Investment Trusts (“REITs”) involve additional risk due to potential adverse developments affecting the real estate industry and real property, such as economic recession, changes in interest rates, oversupply, competition from other management companies, property acquisition risks, development overruns, project completion delays, rising borrowing costs and tightening of available capital, defaults and insolvencies of major tenants, property damage, security threats, natural disasters, environmental clean-ups and liability lawsuits. When you are deciding whether to invest in a specific investment, make sure you obtain, review and discuss with your Financial Adviser the documentation related to the investment which outlines the details of the investment (i.e., prospectuses, annual reports and offering memorandums that discuss the structure of the investment, fees/costs, management, portfolio, restrictions, contributions, distributions, risks, etc.). The 13  documentation should be provided by your Financial Adviser or can be obtained directly from the investment sponsor. Ladenburg Sponsored Programs and Symbil See the applicable program or Symbil brochure, each of which is available at: adviserinfo.sec.gov/firm/summary/108604 Fund Management Each fund within the Ladenburg Funds is generally managed in the same manner as the traditional Ladenburg’s Managed ETF Strategies described below under Separately Managed Accounts and Allocation Consulting Services. For more information about the methods of analysis, investment strategies and risk of loss for the five funds that collectively make up the Ladenburg Funds please see the Funds’ prospectus. Prospectuses are available at www.ladenburgfunds.com or by contacting the fund administrator toll-free at 1-877-803-6583. The prospectus should be read carefully before investing. Ladenburg Total Portfolio Series (CIT) The five strategies in this series are generally managed in the same manner as the traditional Ladenburg’s Managed ETF Strategies described below under Separately Managed Accounts and Allocation Consulting Services. Separately Managed Accounts and Allocation Consulting Services Ladenburg generally manages separate accounts and constructs its models using the following types of investment strategies: 1. Managed Mutual Fund Strategies: Clients may select one of five managed mutual fund strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there can be multiple investment styles. Each model in these strategies can consist of approximately 15 mutual funds primarily, exchange-traded funds (“ETFs”) and exchange-traded notes (“ETNs”) secondarily, which encompass the asset classes targeted for that strategy’s asset allocation. The mutual funds, ETFs and ETNs are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings for inclusion in the managed mutual fund strategies. Ladenburg periodically reviews each model and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the model. 2. Managed ETF Strategies: Clients may select one of five managed ETF strategies. These strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there can be multiple investment styles. Each model in these strategies can consist of approximately 15 ETFs primarily and mutual funds, or ETNs secondarily (if an appropriate ETF is not available), which encompass the asset classes targeted for that strategy’s asset allocation. The ETFs, mutual funds and ETNs are selected for these strategies based on due diligence conducted by Ladenburg. This due diligence includes an analysis of the underlying market index on which each ETF or ETN is based, as well as the expense ratio, longevity, liquidity and size of the ETF or ETN. Based on this evaluation, Ladenburg will recommend those ETFs and/or ETNs with the best ratings for inclusion in the managed ETF strategies. Ladenburg periodically reviews each model and removes or replaces those ETFs and/or ETNs that no longer meet the qualifications necessary for inclusion in the model. 3. Tax Sensitive Strategies: Clients may select one of five managed tax sensitive strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there can be multiple investment styles. Each Account in these strategies can consist of approximately 15 mutual funds, ETFs or ETNs, which 14  encompass the asset classes targeted for that strategy’s asset allocation. The mutual funds or ETFs and/or ETNs are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings and most tax sensitive investment strategy for inclusion in the managed tax sensitive strategies. Ladenburg periodically reviews each strategy and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the models. 4. Specialty Strategies: Clients may select one of the specifically focused strategies: Conservative Income, Enhanced Income, Ultra Income and Buffered ETF. Clients can select a specialty strategy which is designed with a combination of investment objectives, time horizon, and risk tolerance targeted to achieve a certain investment goal. Each account in these strategies will consist of either a combination or solely comprised of mutual funds and ETFs, which encompass the asset classes targeted for that strategy’s asset allocation. The funds are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings for inclusion in the specialty strategies. Ladenburg periodically reviews each model and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the model. 5. Model Manager Strategies: The client may also select Ladenburg to manage an account pursuant to a model portfolio provided by a third-party manager. For these strategies, Ladenburg enters into a contract with the third-party money manager under which the manager agrees to provide the model portfolio to Ladenburg and to provide updates to that model portfolio to Ladenburg on a regular basis. In these cases, the third-party manager has no responsibility to manage any client accounts and does not act as investment adviser to any specific clients. Ladenburg is responsible for managing the account in accordance with the model portfolio. These strategies have varying degrees of risk that depend on the specific model portfolio involved. Clients will be provided with additional information about the risk involved in a particular model portfolio if the client is interested in, and is eligible to select, that particular strategy. 6. Ladenburg American Funds® Core Portfolios: Clients may select one of five mutual fund strategies: These five strategies are aggressive growth, growth, growth & income, income & growth, and income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Accounts utilizing these strategies will have a target allocation of 63% American Funds mutual funds, 35% Ladenburg mutual funds and 2% in cash. Ladenburg will evaluate the portfolios for rebalancing back to the target allocation at least annually or based on extreme market conditions. The mutual funds that are selected for these strategies are within the universe of American Funds mutual funds and based on due diligence conducted by Ladenburg on a variety of performance measures. Ladenburg periodically reviews each strategy to remove or replace those mutual funds that no longer meet the qualifications necessary for inclusion in the strategies. 7. Ladenburg Franklin Templeton Strategies: Clients may select one of five mutual fund strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, and income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Accounts utilizing these strategies will have a target allocation of 63% Franklin Templeton funds, 35% Ladenburg mutual funds and 2% in cash. Ladenburg will evaluate the portfolios for rebalancing back to the target allocation at least annually or based on extreme market conditions. The funds that are selected for these strategies are within the universe of Franklin Templeton funds and based on due diligence conducted by Ladenburg on a variety of performance measures. Ladenburg periodically reviews each strategy to remove or replace those funds that no longer meet the qualifications necessary for inclusion in the strategies. 8. Socially Responsible Strategies: Clients may select one of five managed socially responsible strategies. These five strategies are aggressive growth, growth, growth & income, income & 15  growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there can be multiple investment styles. Each model in these strategies will consist of a combination of ETFs and Mutual Funds which are “socially conscious” per Morningstar Direct. The ETFs and mutual funds are selected for these strategies based on due diligence conducted by Ladenburg. The due diligence on ETFs includes an analysis of the underlying market index on which each ETF is based, as well as the expense ratio, longevity, liquidity and size of the ETF. The due diligence on mutual funds includes a variety of performance measures and recommends those with the best ratings for inclusion in the SRI strategies. Ladenburg periodically reviews each strategy and removes or replaces those ETFs or mutual funds that no longer meet the qualifications necessary for inclusion in the strategies. For more information about how we manage affiliated investments (see Conflicts of Interest below). Ladenburg employs a regimen of quantitative and qualitative investment criteria which allows it to analyze potential funds and select funds for inclusion in the strategies. Below are some of the criteria utilized in selecting funds for the inclusion in the strategies: • Top quartile of performance within its peer group • Positive alpha, which indicates a funds relative performance to the risk being taken by the portfolio manager • Perform well in bear markets • Lead portfolio manager has a minimum of 5 years as head portfolio manager of fund • Have a portfolio composition that is consistent with its corresponding asset class The third-party investment adviser sponsoring the program can require that Ladenburg select funds for accounts from a specified universe of funds. For example, some sponsors request that Ladenburg select funds with a class of shares that can be purchased with no transaction fee charged by the broker-dealer or custodian (“NTF fund shares”). Item 9 - Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. For more information about any disciplinary events that are material to an evaluation of our affiliates listed in item 10, or a separately registered adviser, please see their disclosure brochure. Item 10 - Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is an investment advisory firm and has been in business since October 29th, 1982, Ladenburg is a wholly owned subsidiary of Osaic Holdings, Inc. Osaic Holdings, Inc. is owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. The consortium of investors includes RCP Genpar Holdco LLC, RCP Genpar L.P., RCP Opp Fund II GP, L.P., and The Berliniski Family 2006 Trust. 16  Osaic Holdings, Inc. owns 100% of both Ladenburg and LTCO, a registered broker-dealer. As explained in the Fees and Compensation section above, LTCO can execute trades on behalf of clients who receive advisory services from Ladenburg. LTCO receives compensation for these brokerage services, which it shares with Ladenburg Financial Advisers who are also registered broker-dealer representatives of LTCO. Other Industry Affiliates Ladenburg has the following affiliates, which are wholly owned subsidiaries of Osaic Holdings, Inc. or wholly owned subsidiaries of one of Osaic, Inc.’s affiliates. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. Ladenburg Thalmann & Co. Inc. (LTCO) Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Highland Capital Brokerage Insurance Company 100% owned by Osaic Holdings, Inc. Ladenburg has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. However, these related persons are not wholly owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (BDF) Registered Investment Advisor 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. In certain circumstances, BDF recommends Ladenburg’s advisory services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts, and no client is under any obligation to engage the services of Ladenburg. Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the Related Persons, which are wholly owned subsidiaries of Osaic, Inc., which is a wholly owned subsidiary of Osaic Holdings, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by Osaic, Inc. 100% owned by Osaic Holdings, Inc. 100% owned by OIHI 100% owned by Osaic, Inc. Osaic, Inc. Holding Company Vision2020 Wealth Management Corp. Registered Investment Advisor Osaic Institutions Holdings, Inc. (OIHI) Holding Company Osaic Institutions, Inc. Registered Investment Advisor, Broker/Dealer Osaic Services, Inc. Broker/Dealer 17  Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Related Persons. In that case we or our Related Persons can receive compensation when doing so which results in a conflict of interest. Your Financial Adviser, however, does not receive a portion of the compensation paid to us or our Related Persons and therefore does not have a conflict of interest in recommending the use of one of our affiliated companies. As a result of the fact that your Financial Adviser is not compensated for directing you to products or services offered by our Related Persons, we believe that the Firm’s conflict of interest is mitigated. Certain principal executive officers of Ladenburg can be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg because they will not be devoted exclusively to the business of Ladenburg and can have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Certain Ladenburg programs are also available to clients of Osaic Advisory Services, LLC, Osaic Wealth, Inc. or Premier Trust. Ladenburg performs investment management, due diligence, sales support and/or other operational services for a portion of the fees paid by the client. Ladenburg Financial Advisers can recommend Premier Trust to provide trust and administrative services. Premier Trust provides full disclosure with respect to its trust and administrative services and related costs. Ladenburg Financial Advisers can recommend that clients invest in the Ladenburg Funds for which Ladenburg acts as investment adviser, and LTCO acts as distributor. Transactions for the funds are generally executed through LTCO. For more information see the prospectus. These recommendations create a conflict of interest because Ladenburg and LTCO generally receive more compensation in connection with the purchase of these investments than they do in connection with the purchase of other investments. In addition, these funds pay fees in connection with services or distribution, such as 12b-1 fees. These fees are paid to LTCO as broker-dealer. As explained above, LTCO acts as a dealer with respect to certain securities, and as such, can execute transactions for Ladenburg clients as principal. As a dealer, LTCO can receive a "mark-up," "mark-down," and/or spread in the net price at which principal transactions are executed. This compensation is in addition to other compensation that client pays to Ladenburg and its affiliates. Thus, Ladenburg has a conflict of interest in recommending or deciding to execute trades through LTCO on a principal basis. Ladenburg addresses this conflict of interest in the following ways. After receiving disclosures about a specific principal transaction with LTCO, clients have the opportunity to reject the transaction before it is completed, to the extent required by applicable law. In addition, Ladenburg has policies and procedures in place to assure that clients receive best execution with respect to principal trades, regardless of whether the trade is executed by LTCO or an unaffiliated dealer. Ladenburg can also recommend that clients invest in securities issued in an initial public and/or secondary offerings (“new issues”) for which LTCO acts as a manager, underwriter and/or a member of the selling group. Ladenburg has a conflict of interest in recommending these securities for several reasons. First, LTCO receives all or a portion of the gross spread – the difference between the price that the client pays for the security and the price that LTCO purchases the security for -- in connection with such sales. This gross spread is generally 7% but can be higher or lower in connection with certain offerings. Ladenburg Financial Advisers generally receive a portion of this compensation as broker-dealer representatives of LTCO. In addition, LTCO has a substantial interest—both financially and with respect to its reputation— in assuring that the offering is successful by having a large number of the securities purchased. Finally, in connection with certain offerings, LTCO has an obligation to purchase and resell a certain number of 18  securities. Thus, because of its affiliation with LTCO, Ladenburg has incentives to recommend investments in these offerings for these reasons, rather than based on a client’s needs. To address these conflicts, Ladenburg has policies and procedures in place to make sure that securities in initial public offerings are recommended only to clients for whom they are suitable given the client’s investment objectives and assets. In addition, clients are generally given transaction specific disclosure prior to the client’s decision to invest in such securities. Securities acquired in initial public and secondary offerings may be oversubscribed and Ladenburg has policies and procedures in place for the allocation process. Ladenburg can also compensate its Financial Advisers for the costs of marketing, distribution, business and client development and educational enhancement incurred by the Financial Adviser for the promotion of Ladenburg’s services. This compensation may be based on assets under management or otherwise advised. Reverence Capital Partners manages the private investment funds that indirectly own a majority of Osaic Holdings, Inc., which in turn owns the Firm, as well as private investment funds that hold a minority investment in Envestnet. In addition, select management and Financial Advisors own less than 0.5%, indirectly through a Reverence Capital Partners-controlled entity, in Envestnet. As a result, Financial Advisors associated with Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp in particular, have an incentive to offer and recommend to you programs that use Envestnet’s services. Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp have procedures designed to mitigate this conflict. Payments from Third Parties In addition to the various types of compensation Ladenburg’s affiliates may earn from clients in connection with effectuating the investment advice Ladenburg renders to clients, these affiliates can also receive payments from third parties in connection with services rendered to Ladenburg’s clients. For example, LTCO and other affiliated broker-dealers can receive distribution or service (“trail”) fees from the sale of certain unaffiliated mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services. These fees are distributed from the fund’s total assets. LTCO can pay a portion of the distribution fees it earns to Ladenburg’s Financial Advisers in their capacity as broker-dealer representatives of LTCO. For certain accounts custodied at NFS, LTCO credits 12b-1 fees received for Ladenburg Financial Advisers back to the client accounts. Ladenburg’s affiliated broker-dealers can also participate in revenue-sharing arrangements based on fees paid by mutual funds to participate in No-Transaction-Fee (“NTF”) platforms made available by custodians. Ladenburg’s affiliates can also receive payments called “revenue sharing payments” and/or “marketing allowances” from certain product sponsors (“Strategic Partners”) including mutual funds, insurance companies, and Non-Traded products such as Real Estate Investment Trusts (“REITs”). These payments are not shared with Ladenburg’s Financial Advisers. For more detailed information about the products in the Strategic Partners program, you may request the complete disclosure document from your Financial Adviser. Qualified custodians are another source of revenue to Ladenburg’s affiliated broker-dealers. Specifically, NFS and Pershing provide significant compensation to our affiliated broker-dealers in their capacity as introducing broker/dealer to offset its general operating expenses based on the number of accounts and/or account assets held by our affiliated broker dealers. The specific terms of this compensation differ between NFS and Pershing. Certain custodian fees may apply to your brokerage accounts. In some instances, the affiliated broker- dealers pays a portion of the fee charged. In other instances, the affiliated broker-dealers apply a markup to these fees. In this regard, Ladenburg’s affiliates broker-dealers can receive revenue based upon client activity, as well as the amount of assets custodied with these firms. The types of revenue include, but are not limited to, margin interest charges, IRA fees, inactivity fees, 12b-1 trails and other fees set forth in the custodian’s Schedule of Client Fees and Charges. 19  Our affiliated broker-dealers exercise no discretion, nor provide any advice or recommendation in the selection of the Custodian for any specific account or client. As a result, any difference in compensation to our affiliated broker-dealers is based solely on the contracts with the Custodians and your Financial Adviser’s election of a Custodian. Secondly, Financial Advisers do not share in any compensation paid by the custodians to our affiliated broker-dealers. As a result, Financial Advisers have no financial conflict of interest in any recommendation of a Custodian to clients. For more information regarding custodial fees and the above forms of compensation, please see the Disclosures section of the respective affiliated broker-dealer at our Parent Company’s website: https://osaic.com/disclosures for the Pershing and NFS Schedule of Client Fees and Charges. Conflicts of Interest The various compensation arrangements discussed in this section of the Brochure present conflicts of interest for Ladenburg, because they incentivize the firm and its Financial Advisers to select or recommend products that provide such payments. To mitigate these conflicts, Ladenburg prohibits its Financial Advisers and other supervised persons from selecting or recommending any product based solely on payments that Ladenburg, its employees or its affiliates can receive in connection with the promotion of that product. Instead, Ladenburg requires Financial Advisers and other supervised persons to advise and make recommendations in clients’ best interests, taking into account clients’ needs, investment objectives and risk tolerances. Ladenburg maintains policies and procedures to ensure recommendations are suitable and require that its Financial Advisers always acts in the client’s best interest. Ladenburg also maintains a supervisory structure to monitor the advisory activities of its Financial Advisors to reduce conflicts of interest. Ladenburg offers a number of investment advisory programs that may include the Ladenburg Funds, a series of mutual funds that are managed by Ladenburg. Since Ladenburg receives an internal management fee from the funds, a conflict of interest exists. To mitigate this conflict, Ladenburg has policies and procedures governing the programs that include an allocation to the Ladenburg Funds. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. All supervised persons at Ladenburg must acknowledge the terms of the Code of Ethics and personal securities transactions and holdings annually, or as amended. The Code of Ethics sets forth detailed policies and procedures regarding the personal trading of its personnel. The Code of Ethics also contains policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. A copy of Ladenburg’s Code of Ethics can be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. Ladenburg personnel are required to conduct their personal investment activities in a manner that is not detrimental to its advisory clients. Ladenburg personnel are not permitted to transact in securities except under circumstances specified in the Code of Ethics. Ladenburg may give advice, take action, or hold or deal in securities for some clients or accounts, including Ladenburg’s own accounts, which differs or may be similar at times from the advice it gives, action it takes, or securities it holds or deals for other clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Ladenburg will: (a) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (b) at all times place the interests of clients first while, at the same time, allowing employees to invest for their own accounts; (c) disclose all actual and potential conflicts; (d) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (e) conduct all personal trading consistent with the Rules and in such a manner as to avoid any actual or potential conflict 20  of interest or any abuse of their position of trust and responsibility; and (f) not use any material non-public information in securities trading. The Code of Ethics also establishes policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Ladenburg’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. These pre-clearance requirements and the exceptions are defined in the Code of Ethics. Ladenburg and its employees cannot enter orders for accounts in which they have a beneficial ownership interest to benefit from their knowledge of clients’ orders in a particular security (“front- running”). Ladenburg defaults to LTCO’s front running and personal trading policies as the affiliate broker dealer. In addition to those requirements, Ladenburg Access Persons will not be approved to trade in securities that are ETFs and/or Mutual Funds that are held in Ladenburg’s discretionary portfolios within 5 days of a rebalance by Ladenburg. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Ladenburg and its clients. Certain clients also can maintain accounts at LTCO for which Ladenburg does not act in an advisory capacity. In providing execution services to these accounts separately and apart from the client’s advisory accounts, LTCO can enter into transactions as principal. These activities are separate and apart from Ladenburg’s advisory services. The Code of Ethics is enforced through compliance monitoring activities and surveillance. In cases where the firm discovers that an employee has violated a firm policy and/or procedure, the firm’s code of business conduct or code of ethics, a state or federal law, regulation of the SEC, or other regulatory agency, the Compliance Department will take appropriate steps to investigate the circumstances and will take action commensurate with the manner of the violation. Such actions could take the form of a written warning to the employee in conjunction with the firm’s Legal Department or be as serious as disciplinary action up to and including termination. Any such investigations will be brought to the appropriate regulator’s attention, if necessary, which can result in a disclosure of the violation on the employee’s U-4 form, if required. Item 12 - Brokerage Practices Consulting Services As described in “Fees and Compensation” above, Ladenburg can recommend that clients receiving consulting services execute transactions through LTCO as broker-dealer. If the client elects to execute transactions through LTCO, the compensation paid by the client is negotiated separately with LTCO as part of a separate brokerage relationship between the client and LTCO. Ladenburg does not receive research or other products or services other than execution from LTCO as broker-dealer. Ladenburg does not generally receive research or other products or services other than execution from any non-affiliated broker-dealer or third party in connection with client securities transactions, otherwise known as “soft dollars benefits.” Assets on which Ladenburg provides consulting services are generally not aggregated by Ladenburg in connection with these services. Fund Management With respect to the funds it manages, Ladenburg generally aggregates orders for accounts in the program that are being managed in accordance with the same investment strategy. Ladenburg employs a trade rotation policy for trading its managed accounts and the Ladenburg Funds. Ladenburg also does not aggregate fund management orders because orders are typically single orders or block trades. 21  Separately Managed Accounts and Asset Allocation For separately managed accounts, Ladenburg will execute transactions as directed by the client or third- party investment adviser. For asset allocation services, Ladenburg has no role in the execution of transitions. Because Ladenburg permits clients and investment advisers to direct brokerage, Ladenburg may be unable to achieve the most favorable execution of client transactions. Directing brokerage may cost clients more money than if Ladenburg had selected the broker-dealer. Ladenburg may not be able to aggregate orders with other clients to reduce transaction costs or the client may receive less favorable prices. Ladenburg Sponsored Programs In certain cases, Ladenburg or another investment adviser providing consulting services in connection with the LAMP or ICS program can recommend/require that clients establish brokerage accounts to maintain custody of clients’ assets and to effect trades for their accounts with a brokers-dealer that is not affiliated with the Financial Adviser or Ladenburg (“Unaffiliated Broker”). The Unaffiliated Broker will be named in the program agreement. The final decision to select an Unaffiliated Broker is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA account holder. The Unaffiliated Broker may provide the investment adviser or Ladenburg with access to its institutional trading and customer services, which may not be available to retail investors. These services are generally available to independent advisers on an unsolicited basis; however, certain Unaffiliated Brokers only provide the services at no charge as long as a designated amount of the adviser’s clients’ assets are maintained in accounts with the Unaffiliated Broker. For example, the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”) provides certain services at no charge to advisers as long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab. This can create a conflict of interest as the investment adviser may have an incentive to recommend Schwab or another Unaffiliated Broker over other broker-dealers. The services that may be provided by the Unaffiliated Brokers include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analysis and reports, and access to mutual funds and other investments that may be otherwise generally available only to institutional investors or would require a significantly higher minimum investment. Unaffiliated Brokers can make available other products and services that benefit the investment adviser but may not benefit the clients’ accounts. These benefits can include national, regional or Ladenburg investment adviser specific educational events organized or sponsored by the Unaffiliated Broker. Other potential benefits can include occasional business entertainment, software, research, support functions, and/or professional services provided by the Unaffiliated Broker. Thus, an investment adviser’s recommendation/requirement that clients maintain their assets in accounts at a particular Unaffiliated Broker can be based in part on the benefit the investment adviser and of the availability of certain products and services provided by the Unaffiliated Broker and not solely on the nature, cost or quality of custody and brokerage services provided by the Unaffiliated Broker, which can create a potential conflict of interest. Item 13 – Review of Accounts Ladenburg reviews the consulting services as warranted based on the services provided. This review is performed by the Ladenburg Financial Adviser and/or a supervisor. Ladenburg may provide clients receiving consulting services with a quarterly performance review of the client’s assets identified in the consulting services agreement. Clients who receive these reports direct the custodian(s) of the assets to provide Ladenburg with any information necessary to provide these performance reviews. Clients may also provide information to Ladenburg themselves or direct other third parties to give information to Ladenburg. Ladenburg does not include information in a review if it does not receive it on a timely basis. If Ladenburg does not receive information about the original cost of a security, the market value of the security on a date set by Ladenburg can be used in lieu of the original cost in certain circumstances. Ladenburg does not independently verify information provided by a custodian, client or other third party, nor does Ladenburg guarantee the accuracy or validity of such information. Ladenburg 22  is not liable in connection with its use of any information provided by a client, a custodian, or other third- party in the quarterly performance reviews. Ladenburg generally reviews allocation models at least quarterly. These reviews are generally performed by Ladenburg’s Investment Committee. Ladenburg generally reviews the fund management services daily, weekly, monthly, quarterly and annually. Portfolio monitoring is performed by Ladenburg’s analysts and Portfolio Management Team of the Ladenburg Funds. We use performance and risk analysis data to evaluate each holding and the portfolio composite as a whole. In addition, monthly compliance monitoring is performed by the fund administrator and Ladenburg’s Compliance Officer. Quarterly and annually, there are certifications to the Funds’ independent Board of Directors. The Financial Adviser recommending Ladenburg separate account management services is primarily responsible for reviewing the investment strategy selected by the client on an on-going basis to ensure that it continues to be suitable for the client, taking into account any changes to the information provided by the client. Ladenburg generally reviews separately managed accounts at least quarterly. These reviews are performed by Ladenburg’s Investment Committee and the Chief Compliance Officer. Ladenburg or the investment adviser may provide clients with quarterly performance reviews of LAMP accounts. Nothing in the performance review should be construed as advice concerning any tax matter. Performance reviews are not a substitute for regular monthly account statements received from the custodian or Form 1099. Performance reviews should not be used to calculate fees or to complete income tax returns. Item 14 - Client Referrals and Other Compensation Ladenburg may enter into agreements with third parties that will solicit clients for Ladenburg and receive compensation for solicitation efforts. In such instances, the third-party solicitor will receive either a percentage of, or a set fee from, the fee charged to the client. If a solicitor is used in connection with a client’s account, the structure and arrangement of the solicitation agreement, as well as the compensation paid to the solicitor, will be disclosed to the client. This disclosure will be acknowledged by the client when participating in a Ladenburg program. The fee charged to a client is not affected by the use of a third-party solicitor in connection with client accounts, and a client will not be charged any additional fees for the use of such services. Item 15 - Custody Ladenburg does not take custody of any client assets. However, as set forth in Item 5 of this brochure, certain clients have the option of authorizing Ladenburg to debit advisory fees from their custodial account. All client assets are held by an independent qualified custodian, which can be a broker-dealer, bank or trust company. Clients will receive account statements from the broker-dealer, bank or other qualified custodian holding the clients’ assets at least on a quarterly basis. Clients should carefully review those statements. Clients who also receive account reviews from Ladenburg should compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of clients’ accounts. Any account information provided by Ladenburg is for informational purposes only. Ladenburg may have standing letters of authorization granting it first-party asset movement authority on its clients’ accounts at certain of Ladenburg’s qualified custodians. Ladenburg provides the qualifying Custodian with the client’s authorization in writing. The qualifying Custodian has a record that the client has identified the accounts for which the transfer is being effected as belonging to the client (both sending and receiving accounts). Ladenburg’s authority to transfer client assets between clients’ accounts at the same qualified custodian or between another independent qualified custodian, (which may be a broker-dealer, bank or trust company) in which both have access to the sending and receiving account numbers and client account name(s) are deemed to be first party asset movement and does not constitute custody. 23  Item 16 – Investment Discretion Ladenburg has discretionary authority to manage the Ladenburg Funds. Ladenburg does not have discretionary authority under the consulting services or allocation consulting services described in this brochure. Ladenburg has discretionary authority to manage separately managed accounts. Client grants Ladenburg this authority in the Ladenburg agreement or in the agreement that the client signs to participate in a program sponsored by a third-party adviser in which Ladenburg acts as a portfolio manager. Ladenburg can also have discretion in certain Ladenburg sponsored programs, as described in the applicable program brochure and client agreement. Additionally, for 3(38) clients and for purposes of carrying out services, as described in the 3(38) Manager Program Client Agreement, Ladenburg shall have discretionary power, authority and responsibility to select, add, remove or replace investment options. Item 17 – Voting Client Securities With respect to the Ladenburg Funds, Ladenburg will vote proxies for securities in the accounts in accordance with Ladenburg’s policies and procedures regarding proxy voting. These proxy voting policies and procedures contain guidelines that Ladenburg follows in order to minimize conflicts of interest and to ensure that it votes proxies in a manner consistent with the best interests of its clients. A copy of these policies and procedures is available upon request. Further, investors in the fund can obtain information from Ladenburg on how their proxies were voted by submitting a written request to Ladenburg. With respect to Ladenburg separately managed accounts, the designation for voting of proxies for securities will be defined in the respective Ladenburg client agreement, under the section “Proxies”. If Ladenburg is delegated to vote proxies for securities in the accounts, (as per the respective Ladenburg client agreement) it will do so, in accordance with Ladenburg’s policies and procedures regarding proxy voting. This delegation to Ladenburg can be revoked at any time by written notice to Ladenburg. The proxy voting policies and procedures contain guidelines that Ladenburg follows in order to minimize conflicts of interest and to ensure that it votes proxies in a manner consistent with the best interests of its clients. A copy of these policies and procedures is available upon request. Further, clients can obtain information from Ladenburg on how their proxies were voted by submitting a written request to Ladenburg. Item 18 – Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 24  Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice FACTS What does Ladenburg Thalmann Asset Management Inc. do with your personal information? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 25  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO Yes Yes  If your financial professional terminates his or her relationship with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic Holdings, Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 26  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. Ladenburg Thalmann Asset Management Inc. is an SEC registered investment adviser. 03/2025 27