Overview

Assets Under Management: $6.2 billion
Headquarters: COLUMBUS, GA
High-Net-Worth Clients: 1,383
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection, Educational Seminars

Fee Structure

Primary Fee Schedule (CREATIVE FINANCIAL GROUP ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $250,000 1.50%
$250,001 $500,000 1.25%
$500,001 $1,000,000 1.00%
$1,000,001 and above 0.75%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $11,875 1.19%
$5 million $41,875 0.84%
$10 million $79,375 0.79%
$50 million $379,375 0.76%
$100 million $754,375 0.75%

Additional Fee Schedule (SYNOVUS SECURITIES, INC. ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $500,000 2.40%
$500,001 $1,000,000 2.30%
$1,000,001 $2,000,000 2.20%
$2,000,001 and above 2.10%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $23,500 2.35%
$5 million $108,500 2.17%
$10 million $213,500 2.14%
$50 million $1,053,500 2.11%
$100 million $2,103,500 2.10%

Clients

Number of High-Net-Worth Clients: 1,383
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 52.48
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 12,037
Discretionary Accounts: 7,606
Non-Discretionary Accounts: 4,431

Regulatory Filings

CRD Number: 14023
Last Filing Date: 2024-12-12 00:00:00
Website: HTTP://WWW.CFGLTD.COM

Form ADV Documents

Primary Brochure: CREATIVE FINANCIAL GROUP ADV PART 2A (2025-03-31)

View Document Text
Item 1 – Cover Page A division of Synovus Securities, Inc. Creative Financial Group 3400 Overton Park Drive SE, Suite 600 Atlanta, GA 30339 (770) 913‐9704 www.cfgltd.com March 31, 2025 This Brochure provides information about the qualifications and business practices of Creative Financial Group (“CFG”), a division of Synovus Securities, Inc. If you have any questions about the contents of this Brochure, please contact Gene Gunderson, Chief Compliance Officer at (706) 644‐ 0298 or by email at genegunderson@synovus.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. Creative Financial Group is a division of Synovus Securities, Inc. (“SSI”), a registered investment adviser and registered broker‐dealer with the U.S. Securities and Exchange Commission (“SEC”). Registration as an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. This disclosure Brochure describes the business practices of CFG. Advisory services are also offered directly through other divisions of Synovus Securities, Inc. SSI’s business practices are described in a separate Brochure, which is available upon request. Additional information about Creative Financial Group and Synovus Securities, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. i Item 2 – Material Changes This Brochure dated March 31, 2025, is a revised document prepared according to the SEC's requirements and rules. This Item will discuss only specific material changes that are made to the Brochure and provide clients with a summary of such changes. Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business' fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. This Brochure does not contain any material changes but has been updated since the previous version filed with the Securities and Exchange Commission dated March 28, 2024, to include refreshed totals for assets under management. Our Brochure may be requested by contacting Gene Gunderson, Chief Compliance Officer at (706) 644‐ 0298 or genegunderson@synovus.com. It is also available on our web site www.cfgltd.com free of charge. Clients have the option to electronically receive copies of this Brochure, along with any subsequent updates. Please contact your Creative Financial Group representative for more information about electing electronic delivery for future brochures. ii Item 3 ‐Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 – Material Changes ........................................................................................................................... ii Item 3 ‐ Table of Contents .......................................................................................................................... iii Item 4 – Advisory Business............................................................................................................................ 4 Item 5 – Fees and Compensation ..................................................................................................................6 Item 6 – Performance‐Based Fees and Side‐By‐Side Management ............................................................. 9 Item 7 – Types of Clients............................................................................................................................. 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10 Item 9 – Disciplinary Information................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations..................................................................... 11 Item 11 – Code of Ethics..............................................................................................................................13 Item 12 – Brokerage Practices..................................................................................................................... 13 Item 13 – Review of Accounts....................................................................................................................... 15 Item 14 – Client Referrals and Other Compensation.................................................................................... 15 Item 15 – Custody........................................................................................................................................ 15 Item 16 – Investment Discretion................................................................................................................. 16 Item 17 – Voting Client Securities… ............................................................................................................. 16 Item 18 – Financial Information…............................................................................................................... 16 Appendix A – Risk Definitions..................................................................................................................... 17 CFG Asset Management Transaction & Miscellaneous Fee and Expenses Brochure Supplement(s) iii Item 4 – Advisory Business Creative Financial Group was founded in 1988 as an independent registered investment advisor. In February of 2001, Creative Financial Group (“CFG”) became a subsidiary of Synovus Financial Corporation, a publicly traded company (NYSE: SNV). As of January 1, 2011, CFG was merged into the corporate structure of its affiliate, Synovus Securities, Inc. (“SSI”) a dually registered broker‐dealer and investment adviser. CFG operates as a separate division of SSI, maintains its own office space and personnel, and offers a different scope of advisory services than SSI’s other divisions. As of January 1, 2025, CFG’s assets under management were $2,183,564,830 on a discretionary basis, and $82,610,046 on a non‐discretionary basis. A. Financial Planning: CFG offers a comprehensive package of wealth management services to its Clients, or provides individual service components, such as broad‐based financial planning, investment and asset management, tax related services, risk management services, or administrative services. A broad‐based financial planning relationship with emphasis upon the six steps listed below as the Financial Planning Process. The primary objective of the Financial Planning services is to construct a comprehensive financial plan that provides sufficient cash flow to meet the Client’s standard of living throughout their lifetime. Other objectives include retirement planning, risk management, tax planning, estate planning, investments, education and special needs planning. The fee CFG charges for preparing a written financial plan and other financial planning services is based on the complexity involved and skill required to complete the plan. The Financial Planning Process includes: 1. Establishing and defining the client‐planner relationship; 2. Gathering extensive personal and financial client data, including the exploration of Client’s goals and objectives; 3. Analyzing and evaluate the Client’s financial status and formulate action recommendations and plans for Client to progress towards goals and objectives; 4. Developing and present recommendations to Client in a consultative and interactive manner towards formal financial plan; 5. Implementing the financial planning recommendations, including any action plans and investment plans; 6. Monitoring the financial planning recommendations, per agreement. The advice and monitoring arrangement is continuous if the Client elects to engage CFG for regular review of the plan. B. Investment and Asset Management: Typically, a broad‐based written financial plan would include advice on income tax planning, life and disability insurance planning, estate planning, retirement planning, children’s education planning, cash flow and investment planning. All these things might not necessarily involve securities. Broad‐based financial planning comprises the bulk of services provided by CFG. Page 4 CFG provides individualized discretionary and non‐ discretionary investment advisory services, including but not limited to utilizing the following kinds of assets: mutual funds, stocks, bonds, exchange traded funds, index products, and on a more limited basis, options, private placements, hedge funds, as well as separate accounts, with services provided internally or through third‐parties. Clients can impose reasonable restrictions on the management of their account, such as limiting the amount of certain securities or types of securities in their portfolio. For discretionary accounts, CFG has full Creative Financial Group Disclosure Brochure March 31, 2025 ACFG14023V23 discretion to supervise, manage and direct the assets in the Client account; however, CFG attempts to secure Client approval prior to execution of any transactions. CFG serves as an overall wealth manager for its Clients. CFG’s Financial Planning services revolve around setting investment goals and objectives, formulating a comprehensive asset allocation strategy, selecting investment managers or funds, reporting and meeting periodically, and making change recommendations as necessary. Many of the actual processes and advisory services are integrated with the Financial Planning services: 1. Planning: Set investment scope, goals and objectives, and formalize an appropriate asset allocation strategy. 2. Implementation: Select investment products appropriate for each Client’s investment goals. Products and services recommended by CFG may be implemented through CFG or through any other broker, agent or representative chosen by the client. Clients are not required to implement the Financial Plan through CFG. 3. Monitoring: Portfolio reports are prepared for Clients, usually quarterly. Account reviews are scheduled, at least annually, to assess asset allocations and discuss any changes to the Client’s financial situation. C. Tax‐Related Services: Unsupervised Assets: Under certain circumstances, a Client may hold securities or other property in their brokerage account for which CFG does not provide investment advisory services (“Unsupervised Assets”). An unsupervised asset is not monitored or reviewed by CFG and is only traded upon instructions from the Client. CFG may request that Clients provide a list of Unsupervised Assets in writing and may also request any trade instructions are in writing. Client account statements normally include the Unsupervised Assets, but these assets are not included in the account fee calculations, do not count towards assets under management, and CFG will have no duty, responsibility or liability with respect to the Unsupervised Assets and will not take the Unsupervised Assets into consideration when managing the portion of the account for which it provides investment advice. Unsupervised assets are not included in current investment performance calculations, nor historical performance calculations, provided that the asset has been designated as unsupervised since the account’s inception. In cases where an asset is part of the managed portfolio and is later designated as unsupervised, the historical performance will include that asset’s returns up to the point at which it was designated as unsupervised. CFG provides individualized tax‐related services with emphasis upon: 1. Identifying tax‐saving opportunities, primarily through the financial planning relationship, including employee benefits, investment planning, gifts and charitable giving, and estate planning concerns. 2. Preparing periodic tax projections. 3. Preparing tax returns, as described in the Client agreement and/or engagement letter. 4. Considering changes in tax laws, investment products, business relationships, employee D. Risk Management Services: benefits plans, and family relationships. CFG provides individual risk management services with emphasis upon identifying financial and non‐financial risk‐related alternatives including: 1. Long‐term care; 2. Life insurance; 3. Employee/employer benefits; Page 5 Creative Financial Group Disclosure Brochure March 31, 2025 4. Disability insurance; ACFG14023V23 5. Business succession planning; and/or 6. Estate planning. E. Administrative Services: CFG, under the broad umbrella of administrative/family office services, provides management and coordination of the following: 1. Cash flow management, including services with budgeting and financial statement preparation; 2. Document and Record Management; 3. Coordination of external advisors, including legal, financial, and risk management; 4. Family objectives development, including philanthropy and trust referrals. Item 5 – Fees and Compensation Financial Planning Services – Fees and Compensation: Fees associated with financial planning services vary in conjunction with the complexity of each individual engagement. Fees for a comprehensive financial plan begin at $2,500/plan. In addition, some engagements may be agreed upon via an hourly rate approach, ranging from $150/hour to $300/hour depending upon the level of complexity and/or experience level of the advisor(s) providing the services. Terms and schedule of payment are agreed upon at time of engagement and can be modified upon agreement between the Client and CFG. For producing a written financial plan and providing other financial planning advice, CFG charges fees according to the degree of complexity involved and the skill required in the formulation of the advice. After initial data gathering, a fee is estimated by CFG and quoted to the Client for the Client’s agreement. One‐half the agreed upon fee is due immediately upon acceptance by the Client. The remaining one‐half of the fee is due at completion and delivery of the written financial plan. The financial planning agreement can be terminated at any time by the Client prior to completion of the plan. There will be a refund to the Client of fees paid for which services have not been rendered. If a Client elects an update of a written financial plan, the fee is negotiated and agreed upon in advance of preparation and delivery of the plan. These fees are payable one‐half upon engagement and one‐half upon delivery of the updated written financial plan. Termination and refund of unearned fees for written financial plan updates are handled in the same manner as for the original written financial plan. If a Client elects a periodic review, the fee is negotiated, agreed upon and paid in advance, and is refundable on a pro‐rata basis if the Client wishes to terminate the agreement. Incidental investment analysis is priced at a fee agreed upon with the Client in advance, but due and payable in arrears. There is Investment and Asset Management Services – Fees and Compensation: no refund policy for fees paid in arrears. Fees for investment and asset management services are billed quarterly in arrears and based upon the market value of assets held in the Client’s accounts on the last business day of each quarter. Unsupervised assets are not included in the fee calculations. The fee will be prorated if the contract is made effective or cancelled within a quarter. Fees are negotiable. While fees to different Clients may vary, all fees are quoted to the Client in advance and the Client is always free to decline the fee and the service. The actual fee schedule paid by the Client is noted in each Client’s advisory agreement. CFG’s basic fee schedule for Investment and Asset Management services is as follows: First $250,000 Next $250,000 Next $500,000 Over $1,000,000 1.50% annual rate 1.25% annual rate 1.00% annual rate 0.75% annual rate Page 6 ‐ ‐ ‐ ‐ Creative Financial Group Disclosure Brochure March 31, 2025 ACFG14023V23 Tax‐Related Services – Fees and Compensation : Fees associated with tax related services vary based on the complexity of each individual engagement and the skill required in providing tax‐ related services. Fees for an individual tax return preparation begin at $500/return. In addition, some engagements may be agreed upon via an hourly rate approach, ranging from $150/hour to $300/hour depending upon level of complexity and/or experience level of the advisor(s) providing the services. Terms and schedule of payment are agreed upon at time of engagement and can be modified upon agreement between the Client and CFG. In conjunction with its tax‐related service offerings to Clients, CFG utilizes the services of NDTS Books & Taxes 101, a tax preparation company that is owned and operated by an employee of CFG. CFG provides Risk Management Services – Fees and Compensation payment to the tax preparation company for services rendered. : Risk management or insurance services are often imbedded with the comprehensive financial planning services and are not billed separately. In special circumstances, special engagements may be agreed upon via an hourly rate approach, ranging from $150/hour to $300/hour depending upon level of complexity and/or experience level of the advisor(s) providing the services. Terms and schedule of payment are agreed upon at the time of engagement and can be modified upon agreement between the Client and CFG. Insurance products recommended as part of risk management services may incur additional costs, such Administrative Services – Fees and Compensation as commissions, transaction fees, account fees or other expenses. : Fees associated with administrative services vary in conjunction with the determination and complexity of each individual relationship. Administrative services will be coordinated, if applicable, with other services provided by CFG into a comprehensive wealth management approach. Terms and schedule of payment are agreed upon at time of engagement and can be modified upon agreement between the Client and CFG. These services are offered individually and in combination. Additional fees may be incurred from products, transaction fees, account fees, or services provided by other affiliated or unaffiliated third General Information Regarding Fees and Compensation: parties. While it is the policy of CFG to charge investment management fees to its Clients in accordance with the fee schedules in effect at the time of executing the investment management agreement, fees are subject to negotiation and may vary from the aforementioned schedule to reflect circumstances that may apply to a specific client relationship or account. Examples of exceptions to standard CFG fee schedule include: 1. 2. 3. 4. 5. 6. 7. Fee schedules for accounts of employees, family members, or associates of CFG; Affiliates of CFG, accounts of employees of broker‐dealer or advisory firms with whom CFG maintains a relationship or agreement; Long‐standing client relationships; Anticipated additions to Client’s assets; Size and scope of the assets under management; The nature of the financial planning relationship, including potential credits applied for fees; and, Aggregation of all accounts of one family or household. Fees are calculated based upon valuations from CFG’s portfolio management system. These valuations may vary from the custodian statements due to timely recognition of accruals, dividends, minor pricing differences, corporate actions, other transactions in process, etc. In accordance with CFG’s account house‐ holding policy and upon request from the Client, accounts may be aggregated for purposes of the fee calculation, with the blended fees applied to the individual accounts pro‐rata. Page 7 When a third party manager is selected to provide investment advice to the Client, the actual fee schedule may be higher than what is listed herein. From these fees, CFG at its sole discretion may pay a portion of Creative Financial Group Disclosure Brochure the management fee to the third party manager for their services. March 31, 2025 ACFG14023V23 All fees paid to CFG for investment and asset management services are separate and distinct from the internal fees and expenses charged by open‐end mutual funds, closed‐end mutual funds, exchange‐traded funds, unit investment trusts or other investment company securities. Unless otherwise noted, the standard fees described herein do not include items such as transaction charges, postage and handling fees for statements and/or trade confirmations, transfer fees, exchange fees, electronic fund and wire transfer fees, product expense or purchase/sales fees, brokerage account maintenance fees/charges, or any other charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with the Client. Clients directing CFG to use another broker‐dealer/custodian will incur fees, transaction costs and expenses established by the firm selected by the Client and to whom CFG has been directed to use. Neither CFG nor its affiliates has control over the pricing of the specified broker‐dealer/custodian's fees, transaction costs, or other expenses related to the account established at said firm. Some of these fees may be paid to CFG. In addition, any out‐of‐pocket expenses, such as travel expenses, may be invoiced separately. Please refer to Item 12 for more information about CFG’s brokerage practices. Many mutual funds are offered with more than one type of fee structure, commonly called “share classes”. There are several factors to consider when selecting a mutual fund share class. For example it is important to evaluate whether a share class involves payment of a commission at the time of purchase (commonly referred to as “front end loads”), at the time of liquidation (“back end loads”), incrementally while the investor owns the share class (“level loads”) or no commission at all (“no‐loads”). Share classes also differ in terms of what fees and expenses are deducted from the mutual fund’s pooled investment assets, since these fees and expenses are often not billed separately to a mutual fund shareholder. While there a variety of fees investors may encounter when purchasing a mutual fund, common fees/expenses include management fees paid to the fund’s investment manager, operating expenses used to pay for the day‐to‐day costs incurred to operate the mutual fund, and distribution fees (known as “12b‐1” fees) used to promote, advertise, or compensate financial professionals for aiding in sales of a mutual fund. Though not all mutual fund shares classes include each of the fees/expenses presented here, what remains consistent is that a mutual fund’s share class with a lower total annual expense as compared to another share class of the same fund can result in a significant difference in investment returns over time. It is common for mutual funds to set certain eligibility requirements, such as minimum investment amounts, for an investor to qualify for purchasing a lower cost share class. Investors can learn more about a specific mutual fund’s available share classes and the fees, loads, expenses, and eligibility requirements by reading the fund’s investment prospectus. In addition, we encourage Clients to ask their representative about the fees and expenses associated with mutual funds currently owned by the Clients or those presented to them. The programs described in this brochure do not offer, or may not qualify for, all share classes offered by a fund company. Therefore, it is possible you could invest in a lower costing share class of the same fund if purchased outside the programs outlined in this brochure, though without the benefit of the advice and related services we offer through our programs. Despite our reasonable efforts to utilize cost‐ effective share classes, there is no guarantee that a client will always be in the most cost advantageous share class. Ask your representative about shares classes available to you. Page 8 With respect to funds that pay 12b‐1 fees, SSI's intent (including that of the CFG division), is to limit the use of such funds by opting to use a share class of the same fund which does not include 12b‐1 fee payments wherever possible. However, in cases where we receive 12b‐1 payments from a fund, the Firm generally will seek to credit the entire 12b‐1 payment to the advisory Client's(s') account holding the asset which generated the payment from the fund. These credits are intended to but may not guarantee the same effect as investing into a non‐12b‐1 class. Credits to client accounts generally occur monthly and represent the total 12b‐1 fee payments credited during the preceding month. Additionally, the Firm will generally seek to issue a check to the most recent address of record of closed client accounts representing 12b‐1 payments the Firm received as a result of funds owned during the quarter in which the account was closed. Creative Financial Group Disclosure Brochure SSI’s clearing firm, Fidelity Clearing and Custody Solutions ("FCCS"), sponsors a “No Transaction Fee” March 31, 2025 ACFG14023V23 program (the “NTF Program”) whereby FCCS does not charge SSI a transaction fee for purchase or sell orders SSI submits on a Client’s behalf for mutual funds participating in the NTF Program. SSI benefits from this cost savings, therefore creating a conflict in that SSI may be incented to recommend or use the mutual funds participating in the NTF Program for advisory client accounts over those mutual funds which do not participate. However, SSI does not give preference itself, nor does the Firm influence, recommend, promote, advise or otherwise direct any third party investment adviser, to select mutual funds participating in the NTF Program over those funds which do not participate. Advisory Clients may also maintain non‐advisory brokerage accounts. Representatives of CFG are compensated through commissions assessed on the transactions executed in these accounts or through some other manner, such as 12b‐1 fees. This creates an incentive for the representative to recommend investment products based on the compensation received rather than on the Client’s needs. However, all brokerage services are performed on a non‐discretionary basis; therefore, transactions are approved by the Client in advance. In addition, advisory fees are not charged on brokerage accounts. To the extent that a Client invests in new issues of equity or fixed‐income security, SSI will receive a selling concession or other similar type of compensation, as described in the prospectus or offering document of the security. This compensation is in addition to the fees paid in conjunction with Investment and Asset Management services. Clients are not required to implement any investment recommendation through CFG, SSI or its affiliates. Investment products may be purchased through brokers or representatives that are not affiliated with CFG. On a limited basis, Clients may direct CFG to utilize a specified Custodian for custody purposes and for all securities transactions for a specified account. By directing use of a specific broker‐dealer and/or custodian, a Client may not receive best execution on transactions for such account. SSI has partnered with Synovus Bank, an SSI affiliate and Federal Deposit Insurance Corporation (“FDIC”) member bank, to offer certain advisory clients the option of sweeping free credit balances within the investment account to a Synovus Bank deposit account chosen as those clients’ core investment vehicle (the “Bank Sweep Program). SSI receives an annual fee from Synovus Bank of $25 to $50 for each account participating in the Bank Sweep Program. Items 10 and 12 of this Brochure contain additional information and important disclosures about the Bank Sweep Program. The CFG Division of SSI charges a transaction fee of $10 for each mutual fund and equity order of 5000 shares or less ($10 plus $0.0125 per share for equity trades of over 5000 shares), up to $50 for options orders and $15 dollars for fixed income trades. These transaction fees are in addition to asset management fees assessed to accounts, and thus may create a financial incentive to trade more frequently within advisory accounts. However, CFG does not recommend or place transactions with the intent of increasing fee revenue. Rather, transactions within portfolios are recommended and placed with the Client’s best interest in mind and in accordance with the Client’s expressed investment purpose, needs, risk appetite, and other factors important to the Client. Further information regarding transaction fees and other miscellaneous service costs are detailed in CFG’s Asset Management Transaction Fee Schedule, a copy of which is available free of charge at any time upon request or via CFG’s website Fee Debiting Authority www.cfgltd.com. : Clients may, but are not required to, grant CFG the authority to debit fees directly from the Clients’ accounts held through FCCS, SSI’s clearing firm. If the Client authorizes CFG to CFG urges clients to review debit fees, CFG is deemed to have custody of the Client’s funds. Clients will receive a statement, usually the information on the statement for accuracy and compare the information to any reports monthly but no less than quarterly, directly from their account custodian. received directly from CFG/SSI. Please refer to Item 15 of this document for additional disclosures relating to Custody. Item 6 – Performance‐Based Fees and Side‐By‐Side Management Page 9 Creative Financial Group does not charge any Clients a performance‐based fee. Creative Financial Group Disclosure Brochure March 31, 2025 ACFG14023V23 Item 7 – Types of Clients Creative Financial Group provides financial planning and asset management services to individuals, high net worth individuals, estates, corporate pension and profit‐sharing plans, charitable institutions, foundations, endowments, trust programs, and other corporations or business entities. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Creative Financial Group offers advice on the following types of securities: 1. Equity securities, including exchange‐listed securities, securities traded over‐the‐counter, and foreign issues; 2. Warrants; 3. Corporate debt securities; 4. Commercial paper; 5. Certificates of deposit (CDs); 6. Municipal securities; 7. Investment company securities, including, variable life insurance, variable annuities, and mutual fund shares; 8. United States government securities; 9. Options contracts on securities; and Interests in partnerships investing in real estate, oil and gas interests. In the event that it is an appropriate investment for the Client, CFG may recommend partnership interests, such as real estate, commodities, agriculture, citrus crops, cattle, equipment leasing and/or entertainment investments. CFG may also recommend alternative investments such as hedge funds, private placements, and tangible assets, such as precious metals, coins, precious stones or stamps. Recommendations of these asset types are typically associated with very high investment risk and very high volatility. CFG purchases information from open sources and from industry sources such as Morningstar, Value Line, and by publications such as Standard & Poor’s Corporation Stock Guide, Barron’s, Wall Street Journal, or other such publications. In addition, CFG depends upon its contacts and qualified third parties, including its affiliates, in the investment community with certain technical experts who offer advice on market timing, cyclical analysis, etc. CFG utilizes many third‐party resources for investment knowledge, perspective, forecasting, etc., in personalized investment strategies. CFG may use third party managers for investment guidance and asset allocation recommendations. If the Client elects to use the services of a third party manager, CFG may pay a portion of its management fee to the third party manager for their services. Investing in securities involves risk of loss that Clients should be prepared to bear. CFG uses its best judgment and good faith efforts in providing advisory services to Clients. CFG cannot warrant or Not every investment decision or recommendation made by CFG will be profitable. The Client guarantee any particular level of account performance, or that an account will be profitable over time. should understand that investments in securities are subject to various market, currency, inflation, economic, political and business risks. We attempt to minimize these risks by recommending diversified portfolios constructed to meet the specific goals and objectives of Clients. In such instances, Clients are exposed to unique risks not otherwise inherent to their advisory From time to time, Clients may pledge assets held in their advisory accounts as collateral for a loan. Creative Financial Group Disclosure Brochure Page 10 March 31, 2025 ACFG14023V23 accounts and this strategy is not suitable for everyone . Before a Client decides to pledge their • advisory assets as collateral for a loan, care must be given to consider the following: • Changes in market conditions could impact your account at any time and affect the value of the securities in your account pledged as collateral. Should the value of your assets fall below the amount of your loan, you may be unable to draw upon your account, pledged securities may need to be sold for less than the original price you paid, and/or other appropriate steps may need to be taken to ensure you can still meet your loan obligation to Synovus. • If you are required to sell some of the pledged securities, any long‐term investment strategies and goals may be impacted. Therefore, it is important you discuss with your advisory representative your investment goals, objectives, risk tolerance, strategies and time horizon concerning any advisory account you pledge as collateral. • Should loan repayment terms not be met, the lender may instruct us to sell some or all pledged securities as payment against the loan. In this instance, you are not able to choose which securities are liquidated. You would also be responsible for any shortfall in the loan after such sale. It is essential that you carefully review the provisions outlined in your loan agreement and the corresponding collateral control agreement, as it contains details such as who has trading authority, amongst other important information. • The CFG division of SSI provides certain tax services to a limited number of Clients with whom the extent of tax services provided is determined on a case‐by‐case basis. Pledging advisory account assets as collateral can have tax implications and we encouraged you to discuss those with your tax professional. CFG does not provide tax advice concerning assets pledged as collateral unless the Client has specifically engaged CFG to tax advice regarding such matters. • SSI is an affiliate of Synovus Bank (the “Bank”), and both are subsidiaries of Synovus Financial Corp. By establishing an investment advisory account used to collateralize a loan, you will be responsible for paying to SSI any advisory/management fees, and any other fees as outlined in Item 5 of this Brochure, in addition to paying to the Bank any interest, fees, or other agreed upon expenses. Your SSI advisory representative may also be a dual employee of the Bank, and your Bank loan officer may also be an advisory representative of SSI. SSI advisory representatives and/or the Bank’s loan officers may receive incentive compensation relating to loans and advisory accounts used as collateral. There is no guarantee that returns of any advisory account will meet or exceed your loan costs. Carefully consider the interest rate and repayment terms of the loan before making a final decision. We have included in Appendix A of this brochure a list of common risks and their definitions. The list is not meant to be inclusive of all possible risks but rather to help our Clients better understand that each investment management program involves certain risks. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of CFG or the integrity of CFG’s management. The Firm does not have any disciplinary disclosure information. Item 10 – Other Financial Industry Activities and Affiliations Page 11 CFG is a division of Synovus Securities, Inc. (“SSI”). SSI is also a broker‐dealer registered with the Securities and Exchange Commission, FINRA and various state regulatory agencies. In this capacity, SSI is involved in the sale of various types of securities, such as stock, bonds, and mutual funds. Employees Creative Financial Group Disclosure Brochure providing investment advisory services to Clients are also registered representatives and are able to March 31, 2025 ACFG14023V23 affect securities transactions on behalf of Clients. Clients may maintain brokerage accounts that are not advisory accounts. In these accounts, CFG and its representatives are compensated based on commissions and/or other fees paid by the Client as a result of the purchase or sale of an investment product. This may represent a conflict of interest when determining recommendations for the Client, as there is an incentive to recommend investment products based on the compensation received rather than on the Client’s needs. Consequently, brokerage services are offered to Clients on a non‐discretionary basis. Brokerage transactions and sales of any investment products are approved by Clients in advance. Representatives of CFG do not receive separate commissions on advisory accounts. Likewise, advisory fees are not charged on non‐advisory brokerage accounts. CFG recognizes that a potential conflict exists when it offers both brokerage services and investment advisory services to its Clients. CFG requires its representatives, when offering both types of services, to explain the different services and identify the capacity in which they are acting when making recommendations. SSI is a licensed insurance company in all five of the Firm’s footprint states including Georgia, Florida, Alabama, South Carolina, Tennessee, and various other states outside the company’s brick and mortar locations in the aforementioned footprint states. Additionally, SSI has affiliations with other insurance companies in those states. Individuals of SSI may also be licensed insurance agents. To the extent that a representative of SSI recommends insurance products and services, SSI and/or the representative will receive commissions on the sale of those products. In some instances, SSI representatives receive a higher percentage of insurance commissions generated than the percentage they receive from brokerage or advisory business. These commissions are paid directly from the insurance company underwriting the insurance policy and are not paid separately by the Client. CFG is a division of Synovus Securities, Inc. SSI is a wholly owned subsidiary of Synovus Financial Corp., a publicly traded multi‐billion dollar bank holding company based in Columbus, GA. Synovus Financial Corp. provides integrated financial services including banking, financial management, insurance, mortgage, and leasing service. CFG is under common control with the following entities that have material business arrangements with CFG and/or other divisions of SSI. Certain employees, directors and members of CFG’s executive management may also serve as employees, directors and/or executive Synovus Trust Company, N.A. (a National Trust Company) management of these entities: 33 West 14th Street Columbus, Georgia 31901 Synovus Bank (a Georgia state chartered bank) 33 West 14th Street Columbus, Georgia 31901 SSI utilizes its affiliate, Synovus Bank, to provide a bank sweep deposit option (“Bank Sweep Program”) as the core account investment vehicle for free credit balances in brokerage accounts. This includes accounts opened as part of CFG’s investment advisory offerings (see Item 5 for a description of the offerings) with limited exceptions. Specifically, the Bank Sweep Program is not available to ERISA plan accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase Plans, etc.) or to individual retirement accounts (e.g. Traditional IRA, Roth IRA, SIMPLE, etc.) managed as part of an investment advisory program. The arrangement between SSI and Synovus Bank to deliver a Bank Sweep Program creates certain conflicts in that both SSI and its affiliates financially benefit from having free credit balances swept from brokerage accounts to deposit accounts held at Synovus Bank. More details about the Bank Sweep Program, related conflicts of interest, and compensation derived from it are found under Item 12‐Brokerage Practices. Page 12 Robert W. “Buzz” Law, President of the CFG division of Synovus Securities, Inc., is a licensed real estate Creative Financial Group Disclosure Brochure broker in the State of Georgia through Austral Realty, an unaffiliated entity. March 31, 2025 ACFG14023V23 In conjunction with its tax‐related service offerings to Clients, CFG utilizes the services of NDTS Books & Taxes 101, a tax preparation company that is owned and operated by an employee of CFG. CFG provides payment to the tax preparation company for services rendered. Item 11 – Code of Ethics Code of Ethics & Personal Trading CFG’s Code of Ethics (the “Code”) sets forth a professional business standard to guide CFG and its employees to place the Clients’ interests before its own. No CFG employee shall prefer his or her own interest to that of the advisory Client. CFG requires its employees to act in accordance with applicable federal, state and regulatory agency regulations governing investment advisory practices. The standards of conduct outline our fiduciary responsibilities and the Code includes our policies related to insider trading, personal securities transactions, privacy of Client information and reporting requirements. CFG employees may purchase and sell securities for their own accounts that have also been recommended to Clients. The Code is designed to prevent personal securities transactions and interests of CFG employees from interfering with making decisions in the best interest of Clients. Nonetheless, because the Code permits employees to invest in the same securities as Clients, there is a possibility that employees might benefit from market activity by a Client. Certain security types, such as Initial Public Offerings and Private Placements, may be prohibited or subject to a pre‐ clearance requirement. CFG’s associated persons are required to provide a quarterly report to the Firm’s Compliance Department showing investment transactions in their personal accounts, as well as disclosing annually all securities held on their behalf. Governing regulations provide that certain securities are exempt from this reporting requirement based upon the determination such securities would not pose any material conflicts. These reports are monitored regularly in an effort to reasonably prevent conflicts of interest between SSI and its Clients. Clients or prospective Clients may request a copy of the firm's Code of Ethics by contacting SSI’s Participation or Interest in Client Transactions Chief Compliance Officer, Gene Gunderson, at 706‐644‐0298. CFG or its associated persons may engage in principal transactions and/or agency cross transactions, subject to Section 206(3) of the Investment Advisers Act of 1940. In accordance with the regulation, SSI will disclose the capacity in which it acted and will obtain client consent from both parties involved in the transaction prior to the trade settlement date. These disclosures and consents are required to make all necessary facts known and to alert Clients to SSI’s potential conflicts of interest in a principal, riskless principal, or agency cross transaction. Item 12 – Brokerage Practices CFG does not receive any proprietary or third party research in connection with any soft dollar arrangements. All research is paid for with hard dollars. CFG does not receive client referrals from unaffiliated broker‐dealers. Page 13 Many employees of CFG are registered representatives of SSI. SSI is a registered investment adviser, registered broker‐dealer, and member of FINRA/SIPC. Fidelity Clearing and Custody Solutions (“FCCS”) was selected by SSI to provide custody, clearing and trade execution for SSI Clients. Services provided by FCCS in this capacity are provided pursuant to a separate agreement between SSI and FCCS. In its capacity as SSI’s clearing firm, FCCS provides discounted execution costs upon SSI reaching certain transaction volumes. In addition, SSI receives benefits, not related to execution of transactions, to offset the costs of certain workstation expenses. SSI is otherwise unaffiliated with FCCS. SSI may also receive additional compensation directly from FCCS on behalf of the advisory accounts for which they serve as custodian. FCCS may pay SSI a percentage of the uninvested cash and/or the balance maintained in a money market Creative Financial Group Disclosure Brochure sweep vehicle. March 31, 2025 ACFG14023V23 CFG requires all client accounts (with very limited exceptions) to be held in custody at FCCS and all transactions to be executed by FCCS through SSI. This creates a conflict of interest, as SSI is in effect acting as both broker and adviser on behalf of the client. Not all investment advisers require clients to use a specific broker‐dealer. This requirement may represent a conflict of interest, as CFG is limited in its ability to seek out brokers with different pricing structures or broader services, or to receive more favorable pricing on securities transactions. Therefore, by directing brokerage, Clients may not receive best execution on transactions though it is SSI’s aim to provide the most cost effective executions based upon prevailing conditions at the time of trade. On a limited basis, Clients may direct CFG to use a particular broker‐dealer and/or custodian other than FCCS to execute client transactions and custody client funds and securities. Clients that choose to designate a particular broker should consider that such designation may result in certain additional costs or disadvantages to the Client, either because the Client may pay higher commissions on transactions that might otherwise be attainable, or the Client may receive less favorable executions. SSI is dependent upon FCCS, as its clearing firm, for having agreements in place with mutual fund sponsors in order for SSI’s investment advisory customers to have access to mutual funds. While FCCS has agreements in place with a large variety of mutual fund sponsors, not all mutual funds are available through FCCS. Moreover, many mutual funds offer different share classes, often for the same fund, representing different fee and expense structures paid by shareholders of a fund. Certain classes of shares may not be available through FCCS and consequently SSI Clients may not have access to a lower costing share class otherwise available to investors directly from the fund, a different clearing firm, or other financial intermediary. This limitation could result in SSI Clients purchasing and/or holding a more expensive share class of a mutual fund thereby reducing the investment returns. In coordination with FCCS, SSI also offers to CFG brokerage and investment advisory customers' participation in the Bank Sweep Program as their core investment vehicle, subject to the exclusions noted under Item 10 of this Brochure. Participants in the program have free credit balances within their brokerage/investment advisory account automatically swept to an interest bearing bank deposit account at Synovus Bank, a Federal Deposit Insurance Corporation (“FDIC”) member bank that is affiliated with SSI. Client balances swept into a deposit account at Synovus Bank are eligible for FDIC insurance coverage up to $250,000 per depositor in each insurable capacity. Examples of separate insurable capacities include the following non‐exhaustive list: individual accounts, joint accounts, certain trust arrangements, etc. However, a Client’s cash balance in the Bank Sweep Program is subject to aggregation with other deposit assets the Client has at Synovus Bank outside of the Bank Sweep Program. Neither SSI (inclusive of the CFG division) nor Synovus Bank will monitor the aggregate amount of deposits a Client has with Synovus Bank either directly or through participation in the Bank Sweep Program to determine the extent of deposit insurance coverage available at any time for program participants. Therefore, each Client participating in Bank Sweep Program is responsible for monitoring the aggregate total of deposited assets and determining the extent of deposit insurance applicable to the Client’s deposits. Page 14 Through the Bank Sweep Program arrangement, SSI and its affiliates benefit financially. Synovus Bank earns net income from the difference in interest paid to Bank Sweep Program participants for balances held in their core investment accounts and income received from new lending or investment activity derived from the program deposits (referred to as “spread”). As with any depository institution, Synovus Bank’s income increases when the spread between interest paid, and income received widens. Synovus Bank has no obligation to base its interest payments to Bank Sweep Program participants on the profitability of the income generated from the spread. In addition, SSI receives from Synovus Bank an annual fee ranging from $25 to $50 for each account participating in the Bank Sweep Program. Together, these financial benefits to SSI and its affiliates create a conflict of interest as accounts participating in the program may be more profitable to Synovus than those who do not participate. To address this conflict, Clients may decline participation in the Bank Sweep Program and SSI offers alternative choices for core investment vehicles for free credit balances. In addition, SSI excludes eligibility from the Bank Sweep Creative Financial Group Disclosure Brochure Program any ERISA plan accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase March 31, 2025 ACFG14023V23 Plans, etc.) or to individual retirement accounts (e.g. Traditional IRA, Roth IRA, SIMPLE, etc. opened under an investment advisory program. Lastly, at the time of account opening, or election into the program, Clients seeking participation in the Bank Sweep Program are provided with important disclosure documents and agreements containing further details. These documents may be obtained at any time free of charge upon the request of current or prospective Clients. Accounts are managed on an individual basis. Therefore, with the exception of fixed income transactions, it is not a customary practice for CFG to aggregate client trades. If CFG finds that aggregating trades is in the Client’s best interest, CFG will allocate these trades in a manner that is fair and equitable to each account participating in the trade. To the extent that a Client uses a third party portfolio manager, the third party portfolio manager may aggregate trades in accordance with their own policies and procedures which may differ from CFG’s policies and procedures. Item 13 – Review of Accounts As described in Item 1, many facets of a Client’s financial situation are reviewed as part of the Financial Planning services offered to Clients. Thereafter, Clients may request periodic updates to their financial plan or consultations to discuss changes to their financial situation. The financial planning agreement may also provide for regular reviews and updates to the plan at regular intervals. Clients receive account statements and transaction confirmations directly from the account custodian usually monthly, but not less than quarterly. Quarterly or other periodic reports are sent out to each investment and asset management Client, unless suppressed at a client’s direction. CFG representatives meet with Clients periodically (at the Client’s preference) to review investment accounts and ensure accounts continue to be managed in accordance with the Client’s goals and objectives. Item 14 – Client Referrals and Other Compensation CFG and its representatives do not receive any economic benefits from any third parties with respect to the advisory services offered to Clients. Product sponsors, mutual fund companies or other third parties may offer CFG representatives invitations to training sessions, due diligence visits or other meeting or events at the expense of the third party. These invitations are not offered directly as a result of any amount of business placed with the third party, but the volume of business placed with a particular sponsor may be indirectly related. CFG does not compensate, either directly or indirectly, any unaffiliated party for client referrals or solicitations. Item 15 – Custody SSI is dually registered as an investment adviser and broker‐dealer. As broker‐dealer SSI has a minimum net capital requirement of $250,000 and can accept checks made payable to SSI for deposit into Client accounts. However, all checks and securities are promptly forwarded to our clearing firm, Fidelity Clearing and Custody Solutions. Because SSI and CFG accept checks in this manner, under SEC rule 206(4)‐2, they are deemed to have custody of investment advisory accounts. CFG also has custody because investment advisory fees are directly debited from certain Client accounts. CFG Debiting of fees is done pursuant to authorization provided by each Client. FCCS, as the account custodian, urges Clients to carefully review their statements for accuracy and compare those records to any furnishes account statements usually monthly, but no less than quarterly, directly to the Clients. report received directly from CFG/SSI. Reports prepared by SSI may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. CFG urges Clients to carefully review their statements for In very limited situations, Clients may direct CFG to manage assets held with custodians other than FCCS accuracy and compare those records to any report received directly from CFG/SSI. and with whom CFG is not affiliated. Page 15 Reports Creative Financial Group Disclosure Brochure prepared by CFG/SSI may vary from custodial statements based on accounting procedures, reporting March 31, 2025 ACFG14023V23 dates, or valuation methodologies of certain securities. Except in limited circumstances, CFG officers and employees are restricted from serving as account trustees or in similar capacities unless a pre‐existing, personal relationship exists, or with prior consent of the Chief Compliance Officer. If the relationship is not based on a personal or familial relationship, CFG and/or its affiliates will engage an independent public accountant to conduct a surprise audit each year. CFG will ensure that these accounts are maintained with a qualified custodian that will send statements at least quarterly to the Client (or independent representative of the Client.) In order to comply with the custody rules, SSI engages an independent public accountant to perform an internal controls audit on the operations of SSI, its divisions, and certain affiliates and also to conduct a surprise examination of any accounts over which it is deemed to have custody. Audits are done annually and a copy of CFG/SSI's most recent Accountant Surprise Examination Report can be obtained free of charge via www.adviserinfo.sec.gov. Item 16 – Investment Discretion CFG manages client portfolios on both a discretionary and non‐discretionary basis. Clients grant CFG discretion over their account by providing authorization in the investment advisory agreement. This discretionary authority authorizes CFG to determine the securities to be bought or sold and the amount of securities to be bought or sold. Selections of investments follow the parameters determined for the Client as well as any specific instructions, investment objectives and risk profile associated with each Client. Item 17 – Voting Client Securities CFG does not take any action or render any advice on voting proxies. Furthermore, CFG will not advise or act on a Client’s behalf in any legal proceedings, including bankruptcies or class action lawsuits. Clients will receive proxies, and any other issuer communication, directly from their account custodian. Clients may contact CFG with questions relating to the proxy voting process, but CFG does not provide any recommendations on how to vote any particular issue. Item 18 – Financial Information Creative Financial Group is required to provide you with certain financial information or disclosures about its financial condition. CFG has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding. (space intentionally blank) Page 16 Creative Financial Group Disclosure Brochure March 31, 2025 ACFG14023V23 Appendix A – Risk Definitions All investments offer a balance between risk and potential return. Generally speaking, a typical investor will take on more investment risk in exchange for the opportunity for greater return. The risk definitions below are intended to assist our clients in understanding the common risks associated in investing. The terms listed below are not comprehensive to all potential investment risks and may not be applicable for all investment strategies. Business Cycle Risk Call Risk The risk that cyclical business cycles, with periods of peak performance followed by a downturn, then a trough of low activity, affect the returns of an investment, an asset class or an individual company’s profits. See reinvestment risk. Some corporate, municipal and agency bonds have a “call provision” entitling their issuers to redeem them at a specified price on a date prior to maturity. Declining interest rates may accelerate the redemption of a callable bond, causing an investor’s principal to be returned sooner than expected. In that scenario, investors have to reinvest the principal at the lower interest rates than they may have had prior. Collateral Account Risk Commodity Price Risk A client may enter into a separate agreement with a creditor, bank, broker/dealer or other financial institution (together, “creditor”) to pledge securities or assets against a loan or collateral amount. This agreement grants the creditor a security interest to transfer, sell, redeem, close, open, trade or otherwise liquidate any assets in the account (including instructions to transfer assets directly) in the pledged assets or collateral account. Adverse market conditions can impact the value of the value of the pledged securities causing the portfolio value to decline. This may result in the client to pledge additional assets, pay down the line of credit or the creditor may instruct the adviser and/or custodian to sell pledged assets, which depending on market conditions may result in receiving less for the securities than the original purchase price. Declining market conditions may also limit client’s ability to draw upon their account. Long‐term investment strategies and goals may be adversely impacted by the creditor’s actions, as they may instruct the adviser to sell some or all of the pledged assets as payment against the loan. In this instance, since the creditor agreement may provide certain rights, the client may not be able to choose which securities are liquidated and the client would also be responsible for any loan shortfall after such sale. There is no guarantee that investment account returns will meet or exceed loan costs. The possibility that fluctuations in the price, shortage or overabundance of material inputs, such as fuel, energy, raw materials, metals, manpower, etc. will materially impact operating a company, production of goods/services or reduce the attractiveness or price of an investment. Composition Risk Page 17 The possibility that changes in an index, resulting from security membership, market capitalization and weighting, and investment guide changes may increase the relative dispersion for a strategy and result in unexpected performance variance. Security membership, being added, reduced or weight changed, in an index may result in security prices Creative Financial Group Disclosure Brochure changes. March 31, 2025 ACFG14023V23 Consumers Risk The risk when clients are exposed to unsuitable investments that they do not fully understand. Correlation Risk See Diversification Risk ‐ When portfolio holdings are too highly correlated with each other, meaning that the move up and down in value together, there may be insufficient diversification to counter market or security risks. Counterparty Risk Also called default risk. Counterparty risk occurs when one or more parties to an agreement, such as a bond, defaults and does not fulfill their contractual obligation, such as payments or principal. For example, a bond issuer with a lower quality rating may have a higher default risk and its bonds will need to pay a higher yield than an issuer with a higher rating. Credit Rating / Issuer Quality Risk Credit rating agencies provide analysis and comparative opinions on the bond issuer's ability and willingness to meet its financial obligations. For bond holders, risk occurs when the opinion changes, resulting in a lower rating, which may decrease the current holding value and may make it more expensive, in the form of higher interest rates, for the issuer to raise new debt to meet future obligations. Credit ratings are not indications of investment merit, but are a significant factor in the investment decision. Generally, the higher the credit rating, the higher the bond price relative to the yield rate. Currency / Foreign Exchange Risk Also called foreign exchange risk and implies international investing: the possibility that the relative change in currency value from one country to another will reduce the investment value when converted back from one currency to the other. Dispersion Risk The uncertainty risk associated when an investment strategy is not in accordance with its model, resulting in performance or risk that is less or greater than expected. Diversification Risk Diversification means to reduce risk by investing in a variety of assets, and generally in assets that do not move up or down in value together (correlate). There are two forms of diversification risk: A portfolio that is relatively undiversified, such as having a single security or positively correlated holdings may be more volatile and value sensitive to the security’s market actions. A portfolio that is too diversified may result in a proxy for an index, and not provide acceptable returns relative to the fees or expenses incurred with a managed account. Economic Risk The risk that economic conditions, such as government regulations, tax policies, political or social instability, workforce, or exchange rates will negatively affect investments, usually one in a foreign country. Economic risk is one of the reasons why international investing, especially in emerging countries, carries more risk than domestic investing. Expenses and Fees Risk Page 18 Exchange traded funds, like mutual funds, generally incur operating expenses for management, record‐keeping, custodial services, taxes, legal, accounting and audit fees, which are taken from the fund's assets Creative Financial Group Disclosure Brochure March 31, 2025 ACFG14023V23 and lower investor return. Different funds may have different expenses and fees ratios, relative to the fund assets. Therefore, selection of a fund with higher expenses and fees may have lower performance than a comparable fund with a lower expense ratio. Industry Risk The possibility of investment losses related to a specific industry or market sector stemming from economic or regulatory change, instability, volatility or market shift from a particular industry. These losses may increase in relation to overall portfolio weighting towards that industry. Inflation Risk Inflation causes tomorrow’s dollar to be worth less than today’s. Inflation reduces the purchasing power of a bond investor’s future interest payments and principal, collectively known as “cash flows.” Inflation also leads to higher interest rates, which in turn leads to lower bond prices. Interest Rate Risk The possibility that the value of a security, especially a bond, will reduce as a resulting from a rise in interest rates. Inverse Market ETF Risk Inverse ETFs are designed to replicate the opposite direction of the matching or indicated index. These ETFs often use a combination of futures, swaps, short sales, and other derivatives to achieve these inverse objectives. As complex products, inverse ETFs may not track the underlying or contra benchmark as expected and are often designed to achieve their results on a daily basis only. That means over periods longer than a trading day, the value of these ETFs can and usually do deviate from the reciprocal performance of the associated index to which they correlate. Over longer periods of time or in situations of high volatility, these deviations can be substantial. Legal Risk The risk that a legal contract or financial transaction won't be fulfilled because it breaks a law or there is a regulatory conflict. In addition, companies involved in legal actions may have to increase cash reserves for settlement, which may restrict their growth ability, lower their relative profit or income potential, and be more volatile. Liquidity Risk The risk that investors may have difficulty finding a buyer when they want to sell a security and may be forced to sell at a significant discount to its expected market value. Liquidity risk is greater for thinly traded securities. Market Capitalization Risk Page 19 Creative Financial Group Disclosure Brochure March 31, 2025 A company's market capitalization, one measure of potential growth, is the value calculated from the company's shares outstanding multiplied by the price per share. The basic market cap categories are large‐cap, mid‐cap and small‐cap. Large‐cap stocks, representing companies over $10 billion in size, are generally researched and followed more by analysts or investors. Many large‐cap companies are called “Blue Chips”. Large‐caps historically experience comparatively slower growth, with less risk, than smaller‐sized companies. Smaller‐sized companies typically are not as financially strong but are expected to grow at a faster rate with greater investment return potential. Smaller‐sized companies and funds may experience greater up/down price and value volatility. ACFG14023V23 Within investment guidelines, many strategies, ETFs or mutual funds focus their funds in investing in specific market cap sized companies. Market capitalization risk exists when comparative‐sized companies, such as large, mid‐ or small‐caps as a whole and the ETFs and funds targeted to the cap, would decline, bringing the associated values down regardless of the fundamental characteristics or investment potential. Strategy allocations that over‐ or under‐weight asset classes, including market caps, may have greater volatility missed return potential, or relative loss. Market Risk Also called systematic or undiversifiable risk: The risk that the stock or bond market as a whole would decline, bringing the value of individual securities down with it regardless of their fundamental characteristics or investment potential. Model Risk The possibility that the analysis, investment or allocation decisions for a strategy model may be unreliable or provide incorrect signals in volatile market conditions. Pandemic Risk Large‐scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. Regulatory Risk The risk that changes in laws and regulations will impact a security, business, sector or market. A change in laws or regulations made by the government or a regulatory body can increase the costs of operating a business, reduce the attractiveness of investment, and/or change the competitive landscape. Reinvestment Risk Also see inflation risk. Risk occurs, especially in a declining interest rate environment, when an income producing bond or security is sold or called and the reinvested funds may yield a lower rate than the original security. The reinvested assets may provide a lower cash flow than expected or required to meet the investor’s investment objectives. Security Selection Risk The risk that an investor chooses a security that underperforms the market for reasons that cannot be anticipated. The possibility of investment losses related to a specific company or security stemming from economic or regulatory change, business climate, earnings surprise or legal action relative to a specific company. These losses may increase in relation to the security's overall portfolio weighting. Sociopolitical Risk Tax Risk The danger that political or cultural changes or instability in a location or a country could turn against an investment. For taxable accounts, the possibility that the security holdings, interest, dividends and timing of the buys/sell transactions will increase one's tax liability. Tax risk may also occur when investing just prior to dividend or capital gain activities for ETFs or mutual funds. Page 20 Creative Financial Group Disclosure Brochure March 31, 2025 ACFG14023V23 Time Horizon Risk Investment time horizon generally reflects the total length of time the investor expects to invest before the assets are used for their financial goal (e.g., retirement income). Because different security types, such as equities, bonds and cash have different reward and risk characteristics, a client's time horizon is important in influencing the investment and strategy decisions. Generally, the shorter the client's time horizon, the less time available to the client to recover from any incurred losses. Timing Risk The risk that an investment performs poorly after its purchase or better after its sale. This risk may reflect security selection made either too soon or too late, relative to historical review, and thereby missing profit opportunities or increasing loss potential. Tracking Error Risk Also called active risk. The possibility that a security, such as ETF or mutual fund, deviates from and does not accurately track its defined index or benchmark. The fund does not work as effectively as intended, resulting in unexpected asset allocation and price behavior for the holding. Trading Volume Risk Trading volume occurs as a direct result of supply and demand. Generally, the greater the trading volume, the more liquid it is and the spread between buy/sell transactions is smaller. A lightly‐traded security may have more volatile pricing, be less liquid and have higher transaction costs due the buy/sell spreads. Turnover Rate Risk Turnover rate or ratio reflects the frequency that managers buy or sells securities within a portfolio. There is no turnover rate that is correct for all accounts – the rate will vary upon the strategy type, securities held, or investment conditions. In effect, a high turnover rate may reflect excessive trading, resulting in potentially higher costs or transaction expenses, increased capital gains tax liability of the portfolio, and reduced relative performance. A low turnover rate, again not conclusive, may reflect low account management activity or decreased available investment opportunities. Valuation Risk Difficulty in pricing/fairly valuing securities that are thinly or infrequently traded, not readily accessible, illiquid, or of varying quality. In the absence of accurate security valuation, buy or sell transactions may be higher or lower than anticipated. Securities that increase or decrease in price may result in overweight or underweight conditions relative to a model or benchmark, increasing diversification risk. Yield Curve Risk Page 21 The yield curve represents the relationship between rate of return or interest rates and time to maturity. For bond holders, risk occurs when bond values decrease, impacting portfolio value, when interest rates go up or when needed fixed income or cash flow decrease when bond prices go up The yield curve will slope, up/down and widen or narrow, in relationship between short term bond yields and long term bond yields and varying maturities. To compensate for the liquidity risk of tying up one's money for long periods of time, a typical investor expects a higher rate of return for a longer time to maturity. Creative Financial Group Disclosure Brochure March 31, 2025 ACFG14023V23

Additional Brochure: SYNOVUS SECURITIES, INC. ADV PART 2A (2025-03-31)

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Item 1 – Cover Page Synovus Securities, Inc. 33 West 14th Street, 3rd Floor Columbus, GA 31901 (706) 649-2327 March 31, 2025 This Brochure provides information about the qualifications and business practices of Synovus Securities, Inc. (“SSI”). If you have any questions about the contents of this Brochure, please contact Gene Gunderson, Chief Compliance Officer at (706) 644-0298 or by email at genegunderson@synovus.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. Synovus Securities, Inc. is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Inc. and Creative Financial Group is also available on This disclosure Brochure describes the business practices of Synovus Securities, Inc. SSI also offers advisory services under a separate division, known as Creative Financial Group (CFG). CFG’s business practices are described in a separate Brochure, which is available upon request. Additional information about Synovus Securities, the SEC’s website at www.adviserinfo.sec.gov. Page 1 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Item 2 – Material Changes This Brochure dated March 31, 2025, is a revised document prepared according to the Securities and Exchange Commission's (“SEC) requirements and rules. This Item will discuss only specific material changes that are made to the Brochure and provide clients with a summary of such changes. Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business' fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. • We have updated the following sections of this Brochure: • Item 5 contains additional information regarding how SSI Financial Advisors are compensated and we further explain conflicts of interest this may create and how the Firm addresses those conflicts. Another change impacting this section is the termination of a revenue sharing arrangement SSI had with Envestnet, an unaffiliated third party with whom the Firm partners to deliver advisory services. Item 5 reflects reductions in platform fees paid to Envestnet for offerings included in the Synovus Investment Strategies Program. Please review these updates, and all sections of this Brochure, carefully before making investment decisions. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Copies of this Brochure may be requested by contacting Gene Gunderson, Chief Compliance Officer at (706) 644-0298 or genegunderson@synovus.com. It is also available free of charge via our website at https://www.synovus.com/about-us/our-companies. Clients have the option to electronically receive copies of this Brochure, along with any subsequent updates. Please contact your Financial Advisor for more information about electing electronic delivery for future brochures. Page 2 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Item 3 - Table of Contents Item 1 – Cover Page ...................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................ 2 Item 3 - Table of Contents ............................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................... 4 Item 5 – Fees and Compensation .................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management .......................................... 14 Item 7 – Types of Clients ............................................................................................................. 14 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................... 15 Item 9 – Disciplinary Information ............................................................................................... 16 Item 10 – Other Financial Industry Activities and Affiliations .................................................. 17 Item 11 – Code of Ethics ............................................................................................................. 18 Item 12 – Brokerage Practices .................................................................................................... 18 Item 13 – Review of Accounts .................................................................................................... 20 Item 14 – Client Referrals and Other Compensation ................................................................. 21 Item 15 – Custody ....................................................................................................................... 21 Item 16 – Investment Discretion ................................................................................................ 22 Item 17 – Voting Client Securities .............................................................................................. 22 Item 18 – Financial Information .................................................................................................. 22 Brochure Supplement(s) Page 3 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Item 4 – Advisory Business Synovus Securities, Inc., (“SSI”) is a full-service brokerage and investment advisory firm headquartered in Columbus, Georgia, with offices across Georgia, Alabama, Florida, South Carolina, and Tennessee. SSI is owned by Synovus Financial Corp. (NYSE: SNV), a multi-billion dollar publicly traded bank holding company also based in Columbus. SSI is a registered broker-dealer and registered investment adviser with the Securities and Exchange Commission, as well as a member of FINRA and various state regulatory agencies. As of January 1, 2025, Synovus Securities, Inc.’s assets under management were $4,128,937,417 on a discretionary basis, and $2,957,179,318 on a non-discretionary basis. The general investment services offered to clients are outlined in the bullet points below. The specific details of each investment program (each a “Program” or collectively “Programs”) available to clients are described later in Item 4 of this Brochure. • • • • • • • • • • Collecting detailed information about the client’s current financial situation; Identifying client’s goals and objectives; Developing an appropriate asset allocation model; Providing asset management services, including individually managed accounts; Offering mutual fund model portfolios; Selecting money managers; Evaluating performance and monitoring services; Periodic rebalancing; Executing securities transactions; and, Providing custody of assets through National Financial Services, LLC. (“NFS”). Where applicable, portfolio managers selected to manage client accounts may buy, sell or otherwise trade securities of SSI’s parent company, Synovus Financial Corp., in client accounts. While this may appear to create a conflict of interest, these decisions are made solely at the discretion of the manager and are not influenced by SSI or any of its affiliates. SSI does not recommend to advisory clients the purchase or sale of any stock issued by Synovus Financial Corp. Each Program may impose account minimums and due to these minimums, adequate diversification may not be achieved. The number of accounts within any given program varies, including some with a limited number of investor accounts. More information about each program is available from your Financial SYNOVUS INVESTMENT STRATEGIES PROGRAM Advisor. Separately Managed Account Program 1 (“SIS Program”) through Envestnet Asset SSI offers the Synovus Investment Strategies Program Management, Inc. (“Envestnet”). Envestnet is a registered investment adviser that operates a technology platform to assist SSI in providing a variety of managed account offerings, recommending asset allocations or specific investment managers and/or investment products to our clients. Envestnet is not affiliated with SSI. A complete description of the SIS Program and the services provided by Envestnet are outlined in Envestnet’s ADV Part 2, which you should read carefully. The following describes SSI’s offerings available through the SIS Program. SSI offers a Separately Managed Account Program through our relationship with Envestnet. This provides our clients with access to more than 1000 investment strategies available from over 100 portfolio managers selected by Envestnet through their due diligence and portfolio manager 1 Synovus Managed Accounts Solution Platform (“MAS”) prior to October 3, 2016 Page 4 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 evaluation processes. The Separately Managed Account Program is designed to provide our clients the ability to tailor an investment portfolio to their specific financial needs such as diversification or tax-conscious investing, along with affording clients further customization of their portfolio by placing reasonable investment restrictions on the types of assets allowed within the account. Portfolio managers are recommended based on the client’s investment objectives as determined from the Client Risk Tolerance Questionnaire. Manager changes would be recommended if SSI’s or Envestnet’s due diligence reviews indicate the portfolio manager is no longer suitable for a particular investment strategy or if a client’s investment objectives change. The minimum account value for the Separately Managed Account Program varies based upon the subadviser(s) chosen. Mutual Fund & ETF Asset Allocation Wrap Strategies Program (“Strategist Program”) SSI offers mutual fund and ETF asset allocation portfolios (“fund portfolios”) via the Envestnet platform. The Firm offers fund portfolios created by unaffiliated investment advisers who directly manage the assets or use one or more model portfolios created by one or more independent investment advisers (collectively “Strategists”). The Strategists available through SSI are first screened by Envestnet for inclusion on the Envestnet platform. From that pool, SSI then reviews and approves certain Strategists the Firm then makes available to our customers. A number of no load/load-waived mutual funds or exchange-traded funds from various fund families are available within the portfolios. An asset allocation model is selected based on each client’s risk score as determined by the Client Risk Tolerance Questionnaire (the “RTQ”). The client may modify the RTQ at any time by completing the requisite documentation with their adviser representative. After initial fund portfolio selection, the Strategists will make portfolio changes on a discretionary basis for their respective models as deemed necessary or appropriate to maintain the agreed upon investment approach. Advisor Directed Program SSI, through its licensed advisory representatives, provides asset management services to clients. The Advisor Directed Accounts are managed on an individualized basis. Clients have the option to assign investment discretion to SSI and select SSI investment advisory representatives (individually referred to as “Advisory Representative” and collectively “Advisory Representatives”) whom the firm has approved to offer discretionary services. Alternatively, clients can elect to have their account managed on a non- discretionary basis whereby the SSI Advisory Representative provides recommendations to the client, who has ultimate decision-making authority in determining whether to proceed with any recommendation. For clients electing to open a discretionary account, SSI, through selected Advisory Representatives, has full discretion to supervise, manage and direct the assets in the client’s account within the mandates of the client’s stated investment objectives, tolerance for risk, time horizon for investing the assets, and other suitability factors (collectively referred to as the “Client Investment Profile”) provided to SSI by the client during the account opening and/or review process. Clients participating in either the discretionary or non-discretionary offering are free to change or update their Client Investment Profiles at any time by contacting the Advisory Representative assigned to the account and should do so whenever the information previously provided to SSI is no longer current or accurate. By providing written notice to the Firm, clients may elect to revoke the discretion granted to SSI and/or the Advisory Representative and opt to have their Advisor Directed accounts managed a non-discretionary basis. In such cases, the account will remain non-discretionary unless or until a client elects to grant discretion in writing to SSI and/or its Advisory Representative. Page 5 SSI may use professional services of other third parties, including its affiliates, in servicing either discretionary or non-discretionary Advisor Directed Accounts. Clients working with SSI’s Advisory Representatives selected to offer discretionary Advisor Directed Accounts are limited to using only those investments approved by SSI’s Investment Policy Committee based upon research and Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 recommendations made by SSI’s Investment Advisory Group. Investments and any strategy used are determined based upon the client’s responses and completion of the RTQ. Though not an exhaustive list, SSI primarily utilizes mutual funds, stocks, bonds, exchange-traded funds, cash or cash equivalents. On a limited basis, clients participating in the non-discretionary Advisor Directed Program may also utilize options within their portfolios, subject to additional suitability and investor experience criteria specific to investing in options. Finally, clients in either discretionary or non-discretionary offerings have the option to provide specific guidelines or impose reasonable restrictions on the management of the portfolio. For this reason, each portfolio’s investment results will differ, including those with similar investment objectives, and clients should not expect the performance of their portfolios will be identical with another client of SSI. The minimum account Unified Managed Account Program value for the Advisor Directed Account Program is $100,000. Through our relationship with Envestnet, SSI offers the Unified Managed Account (“UMA”) Program, which allows clients access to multiple investment strategies by using Separate Account Managers, mutual funds and/or ETFs, Strategists, model providers, and/or models provided by SSI to facilitate diversification within an individually managed account. The UMA program includes a Synovus- branded offering called Synovus Choice, offering access to a broad array of asset classes through use of mutual funds, ETFs, and/or Separate Account Managers. The fees associated with Synovus Choice are the same as SSI’s other UMA offerings and, importantly, SSI representatives do not receive any extra financial compensation for recommending the Synovus Choice UMA over any other UMA program offered by SSI. The SSI Representative will structure the account based upon the client’s stated goals and objectives as articulated through the RTQ. The minimum account value for the UMA Program is $100,000. The SIS Program includes unregistered securities offerings of alternative investments such as private equity, private debt, and hedge funds. To invest in these offerings, you must meet the definition of an Accredited Investor or a Qualified Purchaser, depending on the specific offering. An investment in alternative assets entails a high degree of risk (including the possible loss of a substantial part, or even the entire amount, of an investment) and no assurance can be given that any alternative investment will achieve its objectives or that investors will receive a return of their capital. Further, such investments may not be subject to the same levels of regulatory scrutiny as publicly listed investments, and as a result, investors may have access to significantly less information than they can access with respect to publicly listed investments. Prospective investors should also note that investments in the products described typically involve long lockups and do not provide investors with liquidity. This Brochure is not intended to provide you with a full description of risks and considerations related to alternative investments offered through the SIS Program; rather, each alternative investment has its own offering memorandum which contains these and other important details. Reviewing the offering memorandum is essential before making an investment decision and you are SSI INDIVIDUALLY MANAGED ACCOUNT PROGRAM strongly encouraged to discuss its contents with your Financial Advisor. Page 6 SSI provides asset management services to clients and manages each client’s account on an individualized basis. Accounts may be managed on a discretionary or non-discretionary basis, depending on the needs of the client. SSI may use professional services of other third parties, including its affiliates, in managing accounts. Investments are determined based upon the client’s investment objectives, risk tolerance, net worth, net income and various other suitability factors. Clients may provide specific guidelines or impose reasonable restrictions on the management of the portfolio. For this reason, performance of portfolios, including those within the same investment objective, is likely to differ and clients should not expect that the performance of their portfolios will be identical with another client of SSI. SSI only accepts accounts that have a minimum asset value of $100,000. However, accounts with a lesser value may be accepted at SSI’s discretion. Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 OUTSIDE MONEY MANAGER PROGRAM Synovus Securities, Inc. may refer customers to other investment advisers or portfolio managers outside of the various Programs listed above. SSI recommends the money management services of non-affiliated companies (“Managers”). Managers are recommended based upon the investment objectives of the client, but the ultimate decision to hire an outside manager is made by each client. SSI regularly monitors and reviews the services provided by the Manager and will recommend changes if the Manager is no longer suitable for a particular investment strategy or if a client’s investment objectives change. Clients participating in the Outside Money Manager Program complete customer investment profile information and/or questionnaires designed to identify their investment objectives and risk appetite. In addition to recommending an outside money manager, SSI representatives can provide ongoing investment advice on assets held directly through insurance carriers’ variable contracts such as variable annuities. SSI’s representatives provide advice concerning the allocation of the contract values across sub-account choices, information pertaining to any contract riders, and guidance on distribution options. Each Manager imposes account minimums varying from $25,000 to $5,000,000. SSI will recommend managers for whom the client meets the minimum investment amount. SSI has no ability to waive the VARIABLE INSURANCE CONTRACT PROGRAM minimum account size imposed by any particular manager. SSI charges an annual fee of 1.50% for advice related to variable insurance contracts. The firm may agree to charge less than 1.50% but has set a minimum annual fee of $500. Fees are billed monthly in advance based upon the prior month’s ending contract value, as calculated by the issuer of the contract. The minimum contract value for this service is $50,000. While this program intends to use variable insurance contracts issued without a commission or 12b-1 fees, certain additional contract fees still apply such as mortality and expense charges, rider fees, contract administration charges, and subaccount investment management fees. These fees and charges are disclosed in the variable contract’s prospectus, which you FINANCIAL PLANNING should read carefully before investing. In addition to the above Programs, Synovus Securities, Inc., provides comprehensive, integrated Financial Planning services intended to address a variety of needs customized for each client situation. The offerings  include:           Asset Allocation Analysis, Investment Planning, Retirement and Cash Flow Planning, Estate and Gift Tax Planning, Wealth Transfer Planning, Charitable Gift Planning, Education Funding, Income Tax Planning, Risk Management Analysis, Personal Insurance Planning, and Closely Held Business Succession Planning The fee Synovus Securities, Inc., charges for preparing a written financial plan and other financial planning services is based on the complexity involved and skill required to complete the plan. The Financial Planning Process includes:    Page 7 Establishing and defining the client-planner relationship and the scope of the services to be provide Gathering extensive personal and financial client data, including the exploration of client’s goals and objectives; Analyzing and evaluating the client’s current financial status and identifying deficiencies and opportunities to move the client closer to achieving goals; Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35    Developing and presenting recommendations and alternatives to the client in a consultative and interactive manner, revising as appropriate, to arrive at actionable recommendations; Assisting the client, to the extent necessary and agreed upon, with the implementation of the recommendations, including coordinating as needed with the client’s other advisers; Monitoring the financial planning recommendations, per agreement. Unless otherwise provided in the engagement agreement, it is the client’s responsibility to contact their Synovus Securities, Inc. advisor to obtain a determination as to whether it is appropriate or necessary to review the plan or to enter into a new engagement. Typically, a comprehensive written financial plan includes recommendations regarding cash flow and debt management, income tax planning, personal (life, disability and long-term care) insurance planning, estate planning, charitable gift planning, retirement planning, children’s education funding, cash flow and investment planning. Not all these areas will necessarily involve securities. Financial planning information is obtained through personal interview with each client concerning the client’s current financial status, future goals, and attitudes toward risk. Documents and information supplied by the client are carefully reviewed. Once the review is complete, a written financial plan is provided to the client. Alternatively, financial planning clients can elect to participate in the Synovus Asset Navigator program, a data aggregation services, whereby clients authorize automated access to investment and financial information for which the client has preauthorized the sharing. The client is under no obligation to act upon SSI’s recommendations. If the client elects to act on any of the recommendations, the EDUCATIONAL OFFERINGS client is under no obligation to affect the transactions through SSI or any registered person of SSI. SSI provides general financial and investment educational services to certain ERISA plans. Examples of the offerings provided include conducting one-on-one or small group educational sessions where the advisory representative discusses the benefits of participating in company sponsored plans, explaining general investment concepts such as historical differences in rates of return between various asset classes, and providing information on assessing one’s own risk tolerance. Services rendered are generic in nature and do not include specific investment recommendations or advice, nor do they involve SSI taking investment discretion over plan assets or individual participants’ accounts. Rather, investment decisions and plan investment options remain the responsibility of the plan participants and/or the plan fiduciary. Clients receiving educational offerings and services of SSI are under no obligation to open accounts through SSI nor are they required to implement any action as a result of the information provided or service rendered. Item 5 – Fees and Compensation Clients in each Program pay a program fee (“Program Fee”) that includes the fees associated with management, custodial and brokerage-related expenses for the client’s account, subject to certain exceptions. Details of these fees are provided by Program in Item 5 of this brochure. Additional costs not part of the Program Fee include, but are not limited to, transactions executed away from SSI, dealer mark- ups, electronic fund and wire transfers, market maker spreads, exchange fees, redemption fees, short-term trading fees imposed by mutual funds or account maintenance fees. In some accounts under SSI’s Outside Money Manager Program described in Item 4, neither SSI nor the Manager are directed to execute trades through SSI; consequently, transactions are expected to be executed primarily away from SSI and accordingly will likely incur additional costs such that the account will not operate as a traditional “wrap” account. Clients grant SSI the authority to debit Program Fees directly from clients’ accounts. Clients receive SSI urges clients to review the information on the statement for accuracy account statements, usually monthly but no less than quarterly, showing the account holdings and and compare the information to any reports received directly from their SSI representative. transactions in their account. Please Page 8 refer to Item 15 of this document for additional disclosures relating to Custody. Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 If the client does not have a sufficient cash/cash equivalent balance to cover the fee, SSI may liquidate assets to generate sufficient funds for the fee to be paid. Conversely, a portion of accounts may be maintained in (and assessed advisory fees on) cash or other cash equivalents. Advisory agreements may be terminated by either party, without penalty, immediately upon receipt of written notice by the other party. Any such termination will not affect a party’s status, obligations or liabilities. If an account is terminated and all assets are withdrawn from the Program prior to the end of a billing period, the client will receive a refund of the Program Fee prorated based on the number of calendar days left in the billing period. At the time of termination, any unpaid fees will be due. Clients may receive comparable services from other broker-dealers or investment advisers and pay fees that are higher or lower than those charged under these Programs. The fees for the various Programs may be more or less than the client would have paid if the services (account management, custody and brokerage transactions) were purchased separately outside of the Programs. Therefore, SSI representatives recommending the Programs may have a financial incentive to recommend these Programs over other services offered by SSI. Not all Program fees are the same and the fees Synovus receives vary by Program. This creates a financial incentive for SSI to recommend the advisory Programs for which it receives the most compensation. However, this conflict is mitigated by working with current and prospective clients to clearly identify each person’s goals, objectives, financial needs, risk appetite, investment preferences, and other facts unique to the investor. This fact-finding process is designed to identify the Program (or Programs) we recommend based upon the investor’s best interest. We further mitigate this conflict by providing transparent fee pricing for each Program offered, including fees clients pay to Synovus, those paid to third party managers (if any), and to Envestnet, with whom we have partnered to deliver the technology platform used in managing clients’ accounts. We encourage you to review the various Program offerings described in this brochure and to compare the fees found in Item 5 of this brochure associated with each Program. Page 9 Many mutual funds are offered with more than one type of fee structure, commonly called “share classes”. There are several factors to consider when selecting a mutual fund share class. For example it is important to evaluate whether a share class involves payment of a commission at the time of purchase (commonly referred to as “front end loads”), at the time of liquidation (“back end loads”), incrementally while the investor owns the share class (“level loads”) or no commission at all (“no-loads”). Share classes also differ in terms of what fees and expenses are deducted from the mutual fund’s pooled investment assets, since these fees and expenses are often not billed separately to a mutual fund shareholder. While there a variety of fees investors may encounter when purchasing a mutual fund, common fees/expenses include management fees paid to the fund’s investment manager, operating expenses used to pay for the day-to-day costs incurred to operate the mutual fund, and distribution fees (known as “12b-1” fees) used to promote, advertise, or compensate financial professionals for aiding in sales of a mutual fund. Though not all mutual fund shares classes include each of the fees/expenses presented here, what remains consistent is that a mutual fund’s share class with a lower total annual expense as compared to another share class of the same fund can result in a significant difference in investment returns over time. It is common for mutual funds to set eligibility requirements, such as minimum investment amounts, for an investor to qualify for purchasing a lower cost share class. Investors can learn more about a specific mutual fund’s available share classes, their fees, loads, expenses, and eligibility requirements by reading the fund’s investment prospectus. In addition, we encourage clients to ask their representative about the fees and expenses associated with mutual funds currently owned by the clients or those presented to them. The programs described in this brochure do not offer, or may not qualify for, all share classes offered by a fund company. Therefore, it is possible you could invest in a lower costing share class of the same fund if purchased outside the programs outlined in this brochure, though without the benefit of the advice and related services we offer through our programs. Despite SSI’s reasonable efforts to utilize cost-effective share classes, there is no guarantee that a client will always be in the most cost advantageous share class. Ask your representative about shares classes available With respect to funds that pay 12b-1 fees, SSI’s intent is to limit the use of such funds by opting to to you. use a share class of the same fund which does not include 12b-1 fee payments wherever possible. However, in cases where SSI receives 12b-1 payments from a fund, the Firm generally will seek to credit the entire 12b-1 payment to the advisory client(s) account holding the asset which generated the payment from the fund. These credits are intended to but may not guarantee the same effect as investing into a non-12b-1 Synovus Securities, Inc. Disclosure Brochure class. Credits to client accounts generally occur monthly and represent the total 12b-1 fee payments credited March 31, 2025 • A14023V35 during the preceding month. Additionally, SSI will generally seek to issue a check to the most recent address of record of closed client accounts representing 12b-1 payments the Firm received as a result of funds owned during the quarter in which the account was closed. SSI’s clearing firm, NFS, sponsors a “No Transaction Fee” program (the “NTF Program”) whereby NFS does not charge SSI a transaction fee for purchase or sell orders SSI submits on a client’s behalf for mutual funds participating in the NTF Program. SSI benefits from this cost savings, therefore creating a conflict in that SSI may be incented to recommend or use the mutual funds participating in the NTF Program for advisory client accounts over those mutual funds which do not participate. Those funds that do not participate in the NTF Program may include lower cost share classes. Upon a client’s request, SSI will provide at no cost a list of any NTF eligible mutual funds held within the account and will make a representative available to the client to answer any questions related to the share class selected along with any other share classes available from the same fund. Information for contacting SSI is provided on the first page of this Brochure. In conjunction with offering the Synovus Choice UMA, SSI receives access to Envestnet Fiduciary Solutions Program (“EFS”) free of charge. The EFS Program provides SSI additional access to research, watch lists, alerts, Large Case Support, Overlay Services and other Envestnet investment-related intellectual capital. Without offering the Synovus Choice UMA, SSI would have to pay Envestnet for access to the EFS Program. This creates the potential for a conflict of interest because without offering the Synovus Choice UMA, SSI would incur extra cost for the research content available from the EFS Program. To mitigate potential conflicts, SSI’s cost-free access to the EFS Program is not contingent upon any minimum asset values in the Synovus Choice UMA program, nor are there any requirements to offer certain Separate Account Managers, mutual funds, ETFs, or any other products—including those proprietary to Envestnet or its affiliates. Furthermore, clients in the Synovus Choice UMA do not pay additional fees as compared to any other of SSI’s UMA offerings, nor do SSI representatives receive more compensation for asset within the Synovus Choice UMA over assets in SSI’s other UMA offerings. SSI’s access to the EFS Program content is intended to benefit the Firm’s customers by providing SSI associated persons additional research and investment information used in the management of client assets. To the extent that a client of the SIS Advisor Directed or the SSI Individually Managed Account Program invests in new issues of an equity or fixed-income security purchased in their account, SSI will receive a selling concession, or other similar type of compensation, as described in the prospectus or offering document of the security. SSI receives this compensation in addition to the Program Fee received for investment advisory services. You have the option to restrict the purchase of new issues in your account or to revoke at any time previous authorization granted to purchase them. SSI’s advisory clients may also maintain non-advisory SSI brokerage accounts. Representatives of SSI are compensated through commissions assessed on the transactions executed in these accounts or through some other manner, such as 12b-1 fees. This creates an incentive for the representative to recommend investment products based on the compensation received rather than on the client’s needs. However, SSI’s brokerage services are generally performed on a non-discretionary basis; therefore, except in rare instances whereby a customer has granted an SSI representative written discretionary authority, transactions are approved by the client in advance and clients receive trade confirmations inclusive of the commissions charged. Moreover, clients are provided a copy of SSI’s brokerage account commissions schedule at the time of account opening. Additional copies of the brokerage commissions schedule are available free of charge upon request by contacting your account representative or the SSI home office by calling 706-649-2327. In addition, advisory fees are not charged on such brokerage accounts. To address this conflict, an SSI Designated Principal reviews each new brokerage and advisory account for appropriateness based upon the expressed needs of the client. Page 10 While it is the policy of SSI to charge investment management fees to its clients in accordance with the fee schedules in effect at the time of executing the investment management agreement, fees are subject to negotiation and reflect circumstances that may apply to a specific client relationship or account. Thus, fees paid by clients do Synovus Securities, Inc. Disclosure Brochure vary from the program schedules described later in this section, and it is possible clients with similar asset levels March 31, 2025 • A14023V35 to have differing fee schedules and pay different fees, even within the same program. The fees specific to each client account are detailed in that account’s advisory contract. If a client and the firm agree to a flat fee arrangement instead of the tiered program schedules described later in this Brochure, the client may pay more fees than if the relevant program’s tiered fee schedule had been used. This scenario is more likely to occur when the client’s account asset value crosses one or more of the program schedule’s fee discount tiers. The potential for a flat fee arrangement causing a client to pay more in fees versus the program’s standard tiered schedule creates a conflict whereby the firm and/or its representatives could be incented to recommend a flat fee schedule in order to receive more compensation. To mitigate this conflict, SSI and its representatives are bound to act solely in the client’s best interest including when advising on fee arrangements. Moreover, SSI has implemented procedures at account opening and throughout the account’s lifecycle to assess (and remediate as deemed prudent) the impact a negotiated flat fee schedule will have, or has had, on a client’s fees. Clients can qualify for SSI advisory fee discounts by combining household balances of related accounts within Synovus’s investment advisory offerings. This is accomplished by notifying your Financial Advisor of any accounts sharing the same residential address for which you want to link for fee billing purposes (“household discounts”). Accounts qualifying for household discounts can be added to, or removed from, the linked group at your direction. SSI has determined to offer employees, associated persons and their immediate family fee discounts resulting in lower fees than those published in this brochure. SSI reserves the right to amend or terminate this program at its discretion. SSI has partnered with Synovus Bank, an SSI affiliate and Federal Deposit Insurance Corporation (“FDIC”) member bank, to offer certain advisory clients the option of sweeping free credit balances within the investment account to a Synovus Bank deposit account chosen as those clients’ core investment vehicle (the “Bank Sweep Program). SSI receives an annual fee from Synovus Bank of $25 to $50 for each account participating in the Bank Sweep Program. Items 10 and 12 beginning on pages 17 and 19, respectively, of this Brochure contain additional information and important disclosures about the Bank Sweep Program. Standard Program Fee Schedules SSI SYNOVUS INVESTMENT STRATEGIES Clients’ payments for advisory services contain three general components: (a) fees paid to SSI for investment advice and related services; (b) fees paid to the subadviser(s) managing the portfolio; (c) fees paid to Envestnet for use of their technology platform and administration of client accounts. The total cost to a client is the combination of these fee components and the following shows the maximum costs associated with each program offered. Separately Managed Account (SMA) Program SYNOVUS INVESTMENT STRATEGIES SMA PROGRAM Synovus Investment Strategies SMA program fees are billed monthly in advance based on the prior month’s ending market value. The annual rates are shown in the table that follows:  Amount paid to SSI Amount paid to subadviser(s)* Amount paid to Envestnet Varies by subadviser chosen 1.40% 1.30% 1.20% 1.10% 0.13% to 1.02% 0.13% to 1.02% 0.13% to 1.02% 0.13% to 1.02% 0.17% 0.17% 0.17% 0.17% Asset Range first $500,000 next $500,000 next $1,000,000 Account Minimum† Amount over $2,000,000 *The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment. Page 11 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 SSI has compensation arrangements in place that provide more compensation to the Advisor than the amount paid to SSI listed above. The additional compensation will be paid by SSI. These compensation arrangements will not increase the amount paid by the client to SSI. † The minimums may be waived at the sole discretion of SSI and/or the program’s money manager Advisor Directed Program & Mutual Fund/ETF Asset Allocation Wrap Strategies Program (“Strategist”) SYNOVUS INVESTMENT STRATEGIES-STRATEGIC ALLOCATION PROGRAM Synovus Investment Strategies Strategist program fees are billed monthly in advance based on the prior month’s ending market value. The annual rates are shown in the table that follows:  Amount paid to SSI Amount paid to subadviser(s)* Amount paid to Envestnet Asset Range First $500,000 Next $500,000 Next $1,000,000 Account Minimum† Amount over $2,000,000 1.26% 1.16% 1.06% 0.96% 0.00% to 0.18% 0.00% to 0.18% 0.00% to 0.18% $50,000 0.00% to 0.18% 0.13% 0.13% 0.13% 0.13% SYNOVUS INVESTMENT STRATEGIES-TACTICAL ALLOCATION PROGRAM  $50,000 Asset Range First $500,000 Next $500,000 Next $1,000,000 Account Minimum† Amount over $2,000,000 Amount paid to SSI 1.30% 1.20% 1.10% 1.00% Amount paid to subadviser(s)* 0.25% to 0.35% 0.23% to 0.30% 0.20% to 0.25% 0.15% to 0.25% Amount paid to Envestnet 0.13% 0.13% 0.13% 0.13% SYNOVUS INVESTMENT STRATEGIES-FOUNDATIONS  Asset Range First $500,000 Next $1,500,000 Account Minimum† Amount over $2,000,000 Amount paid to subadviser 0.10% 0.10% $15,000 0.10% Amount paid to Envestnet 0.10% 0.10% 0.10% Amount paid to SSI 1.15% 1.05% 0.95% SYNOVUS INVESTMENT STRATEGIES-ADVISOR DIRECTED PROGRAM ‡ Amount paid to SSI Amount paid to Envestnet 1.46% 1.36% 1.26% $100,000 1.16% 0.08% 0.08% 0.08% 0.08% Asset Range first $500,000 next $500,000 next $1,000,000 Account Minimum† Amount over $2,000,000 *The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment. In addition to the amount paid to SSI for advisory services, clients also pay to SSI the portfolio construction fee which is reflected in the column titled Amount paid to SSI. This fee is like the amount paid by clients utilizing subadvisers to construct and manage portfolios. As a result, the portion of a ‡ client’s total fee paid to, and retained by SSI, is more than other Strategist programs since SSI does not have to pay a portion of the client fees to another subadviser. This presents a potential conflict of interest whereby the Advisor Directed Program is recommended over the other Wrap Strategist Allocation Programs. However, clients using the Advisor Directed Program may find their overall cost to be less than other Strategist programs depending on the management fee charged by the subadviser. Moreover, SSI does not receive additional compensation (e.g., revenue sharing) from the fund companies utilized within the Advisory Directed Program models. † The minimums may be waived at the sole discretion of SSI and/or the program’s money manager. Page 12 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Unified Managed Account Program SYNOVUS INVESTMENT STRATEGIES-UMA PROGRAM Synovus Investment Strategies UMA program fees are billed monthly in advance based on the prior month’s ending market value. The annual rates are shown in the table that follows:  Amount paid to SSI 1.40% 1.30% 1.20% 1.10% Amount paid to subadviser(s)* 0.15% to 0.67% 0.15% to 0.67% 0.15% to 0.67% $100,000 0.15% to 0.67% Amount paid to Envestnet 0.12% 0.12% 0.12% 0.12% Asset Range First $500,000 Next $500,000 Next $1,000,000 Account Minimum† Amount above $2,000,000 *The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment. SSI has compensation arrangements in place that provide more compensation to the Advisor than the amount paid to SSI listed above. The additional compensation will be paid by SSI. These compensation arrangements will not increase the amount paid by the client to SSI. † The minimums may be waived at the sole discretion of SSI and/or the program’s money manager SSI INDIVIDUALLY MANAGED ACCOUNT AND OUTSIDE MONEY MANAGER PROGRAMS Depending on the money manager, fees are either billed monthly or quarterly in advance based on the prior INDIVIDUALLY MANAGED ACCOUNTS AND OUTSIDE MONEY MANAGER month's/quarter’s ending market value. The annual rates are shown in the table that follows: PROGRAM Asset Range Amount paid to SSI Amount paid to subadviser(s)* Varies by subadviser chosen 1.40% 1.30% 1.20% 1.10% 0.30% to 1.00% 0.30% to 1.00% 0.30% to 1.00% 0.30% to 1.00% Amount paid for technology platform None None None None first $500,000 next $500,000 next $1,000,000 Account Minimum† Amount over $2,000,000 *The subadvisers used in the Separately Managed Account Program charge varying fees as represented above. The fees’ variance is impacted by a variety of factors such as, but not limited to, portfolio objective, securities used within the portfolio, and sectors or geographic region represented in the portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total amount a client will pay for their investment advisory account, inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment. †The minimums may be waived at the sole discretion of SSI and/or the money manager. FINANCIAL PLANNING SERVICES Fees associated with financial planning services vary in conjunction with the complexity of each individual engagement. Standard fees for a comprehensive financial plan begin at $1,500 per plan. In addition, some engagements are based upon an hourly rate, ranging from $150 per hour to $300 per hour depending upon the level of complexity and/or experience level of the advisor(s) providing the services. Terms and schedule of payment are agreed upon at time of engagement, and can be modified upon agreement between the client and Synovus Securities, Inc. Page 13 For producing a written financial plan and providing other financial planning advice, Synovus Securities, Inc., charges fees according to the degree of complexity involved and the skill required in the formulation of the advice. After initial data gathering, a fee is estimated by Synovus Securities, Inc., and quoted to the client for the client’s agreement. One-half the agreed upon fee (or, in the case of an hourly rate engagement, one- half of the estimated project fee) is due upon acceptance by the client. The remaining fee is due at completion and delivery of the written financial plan. The financial planning agreement can be terminated Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 in writing at any time by the client prior to completion of the plan. There will be a refund to the client of fees paid for which services have not been rendered. Alternatively, SSI and/or its representatives may elect to provide a financial plan at no cost. If a client elects an update of a written financial plan, the fee, if any, is negotiated and agreed upon in advance of preparation and delivery of the plan. One-half of the agreed upon engagement fees are due at inception and one-half upon delivery of the updated written financial plan. Termination and refund of unearned fees for written financial plan updates are handled in the same manner as for the original written financial plan. If a client elects a periodic review, any fee is negotiated, agreed upon and paid in advance, and is refundable on a pro-rata basis if the client wishes to terminate the agreement. Incidental investment analysis is priced at a fee agreed upon with the client in advance, but due and payable in arrears. There is no refund policy for fees paid in arrears. Financial planning fees are subject to negotiation and vary from the pricing above to reflect circumstances that apply to a specific client relationship. Examples of exceptions to the standard Synovus Securities, Inc., fee schedule include: a) Accounts of employees, family members, or associates of Synovus Securities, Inc., or its affiliated companies; b) Long-standing client relationships; c) Size and scope of investment advisory or brokerage relationships; d) Anticipated additions to client’s investment advisory accounts; e) Aggregation of family or household accounts. Insurance or investment products implemented as part of a financial planning process may incur additional costs, such as commissions. Additionally, SSI may receive additional compensation from one or more of its insurance partners upon meeting a pre-determined level of commissions. However, financial planning clients are under no obligation to purchase insurance or investment products, or otherwise implement the recommendations provided as a result of a completed plan. Synovus Securities, Inc. does not provide accounting or legal advice. Fees paid by the client to accountants, attorneys or other advisors for advice or work done in connection with the financial planning or investment advisory process are in addition to financial planning or investment advisory fees. EDUCATIONAL OFFERINGS For rendering general investment and financial educational services to ERISA plans and/or participants, SSI charges a fee that is negotiated on a plan-by-plan basis. Fee options vary but include charging a fee based upon the total assets in a plan, a set fee based upon the number of participants, or a combination of both. Fees charged for such services are agreed upon in writing with the plan sponsor/plan fiduciary in advance of the services commencing. Item 6 – Performance-Based Fees and Side-By-Side Management Synovus Securities, Inc. does not charge any clients a performance-based fee. Item 7 – Types of Clients SSI generally provides services to individuals, high net worth individuals, banks or thrift institutions, pension and profit sharing plans, corporations, and trusts, estates and charitable organizations. Page 14 Each investment Program offered by SSI imposes an account minimum in order to be eligible for the Program. SSI, in its sole discretion, may waive the minimum asset size for any of its investment Programs. However, to the extent that the client doesn’t meet the minimums imposed by a portfolio manager or Synovus Securities, Inc. Disclosure Brochure program sponsor, SSI may not have the ability to waive those requirements. March 31, 2025 • A14023V35 SSI provides offerings to investors seeking to roll over balances held in employer-sponsored retirement plans (often referred to as a “rollover”). Individuals with investments in a former employer’s retirement plan generally have five options for those assets: (1) Leave the investments in that plan, (2) roll the assets into his/her new employer’s plan, (3) rollover the money to an Individual Retirement Account, (4) liquidate the investments and cash out the money, or (5) some combination of the previous four options. Each option presents different considerations—including tax implications— and no one solution is right for every investor. We encourage you to talk with your adviser about these options and to consult with a tax professional regarding the potential impacts each of the options may have to your specific situation. SSI has an economic incentive to recommend a rollover because assets rolled into one of our advisory programs will generate investment management fees. In discussing and evaluating your options, it is important you know you are under no obligation to rollover assets to us. Information about minimum account size requirements for each Program can be found in Item 4 of this Brochure. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss SSI offers advisory services through the Programs described in Item 4 of this Brochure. The Programs involve the selection of investment models or separate account managers based on the assessment of each client’s investment goals and objectives. SSI has implemented a due diligence process to review various facets of the manager’s business, such as investment style, performance, portfolio management, trading and operations, and compliance. With respect to the Synovus Investment Solutions Program (“SIS”), SSI employs use of both internal and external resources as part of the due diligence process. Envestnet, as part of the services they perform for SSI, conduct reviews of prospective and current money managers approved for inclusion on the SIS platform. SSI leverages the research and assessment Envestnet performs of third-party money managers for the following offerings available through the SIS platform: (1) Separately Managed Accounts, (2) Mutual Fund Wrap Strategies, and (3) Unified Managed Accounts. Details concerning these program offerings are found under Item 4 of this brochure. SSI’s Investment Advisory Group researches and evaluates prospective and current money managers and/or investment model providers utilized via the SIS program, primarily in connection with the Advisor Directed Model offering, as described in Section 4 of this brochure. Information, reviews and recommendations prepared by SSI’s Investment Advisory Group are supplied to SSI’s Due Diligence Committee, who has final authority to add or remove a money manager or investment model provider from the Firm’s offerings. The composition and asset allocation of each client portfolio may differ depending on a variety of factors, including client specific investment goals, risk tolerance, and overall economic and market conditions. While not the primary focus of the SSI Investment Advisory Group, team personnel may from time to time also perform due diligence reviews of other SIS platform money managers previously reviewed by Envestnet to gain additional perspective and information in support of SSI’s general oversight efforts of the Firm’s selected advisory partners. To the extent SSI representatives are selecting securities for investments in client portfolios, SSI uses an asset allocation strategy, or another strategy based upon specific goals and objectives identified and agreed to by the client to guide investment decisions. Page 15 Investing in securities involves risk of loss that clients should be prepared to bear. SSI uses its best judgment and good faith efforts in providing advisory services to clients. SSI cannot warrant or guarantee any particular level of account performance, or that an account will be profitable over time. Not every investment decision or recommendation made by SSI, or a Program manager will be profitable. Investments in securities are subject to various market, currency, inflation, economic, political and business risks. We attempt to minimize these risks by recommending diversified portfolios constructed to meet the specific goals and objectives of clients. We have included with this brochure and Appendix describing risks inherent Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 with investing; please note while the list covers many of the common risks an investor may encounter it is not meant to be exhaustive. In such instances, clients are exposed to unique risks not otherwise inherent From time to time, clients may elect to use margin lending or pledge assets held in their advisory accounts this strategy is not suitable for everyone to their advisory accounts and as collateral for a loan. . Before a client decides to use margin lending or pledge their advisory assets as collateral for a loan, care must be given to consider the • following: • Changes in market conditions could impact your account at any time and affect the value of the securities in your account to establish and maintain margin or pledged as collateral. Should the value of your assets fall below the amount of your loan or margin maintenance requirement, you may be unable to draw upon your account, pledged securities may need to be sold for less than the original price you paid, and/or other appropriate steps may need to be taken to ensure you can still meet your obligation to your margin lender (NFS) or Synovus. • If you are required to sell some of the margined or pledged securities, any long-term investment strategies and goals may be impacted. Therefore, it is important you discuss with your advisory representative your investment goals, objectives, risk tolerance, strategies and time horizon concerning any advisory account in which you employ margin or pledge as collateral. . • Should loan repayment terms not be met, the lender may instruct us to sell some or all margined or pledged securities as payment against the loan. In this instance, you are not able to choose which securities are liquidated. You would also be responsible for any shortfall in the loan after such sale. It is essential that you carefully review the provisions outlined in your loan agreement and the corresponding collateral control agreement, as it contains details such as who has trading authority, amongst other important information • SSI is not a tax advisor. We encouraged you to discuss with your tax professionals the implications of using margin or pledging securities as collateral. • SSI is an affiliate of Synovus Bank (the “Bank”), and both are subsidiaries of Synovus Financial Corp. By establishing an investment advisory account used to collateralize a loan, you will be responsible for paying to SSI any advisory/management fees, and any other fees as outlined in Item 5 of this Brochure, in addition to paying to the Bank any interest, fees, or other agreed upon expenses. Your SSI advisory representative may also be a dual employee of the Bank, and your Bank loan officer may also be an advisory representative of SSI. SSI advisory representatives and/or the Bank’s loan officers may receive incentive compensation relating to loans and advisory accounts used as collateral. There is no guarantee that returns of any advisory account will meet or exceed your loan costs. Carefully consider the interest rate and repayment terms of the loan before making a final decision. We have included in Appendix A of this brochure a list of common risks and their definitions. The list is not meant to be exhaustive of all risks but rather to help our clients better understand each investment management program involves certain risks. Additional information specific to the risks associated with each program can be found by reading the investment manager’s ADV Part 2a. For example, risks specific to clients in the SIS program should refer to the Envestnet ADV Part 2a. Item 9 – Disciplinary Information Page 16 Synovus Securities, Inc. is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of SSI or the integrity of SSI’s management. SSI does not have any events to disclose. Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Item 10 – Other Financial Industry Activities and Affiliations SSI is also a broker-dealer registered with the Securities and Exchange Commission, FINRA and various state regulatory agencies. In this capacity, SSI is involved in the sale of various types of securities, such as stock, bonds, and mutual funds. Employees providing investment advisory services to clients are also registered representatives and are able to affect securities transactions on behalf of clients. Clients may maintain SSI brokerage accounts that are not advisory accounts. In these accounts, SSI representatives are compensated based on commissions or other fees paid by the client as a result of the purchase or sale of an investment product. This may represent a conflict of interest when determining recommendations for the client, as there is an incentive to recommend investment products based on the compensation received rather than on the client’s needs. Consequently, brokerage services are generally offered to clients on a non-discretionary basis. Except in rare instances whereby a customer has granted an SSI representative written discretionary authority, Brokerage transactions and sales of any investment products are approved by clients in advance. Representatives of SSI do not receive separate commissions on advisory accounts. Likewise, advisory fees are not charged on non-advisory brokerage accounts. SSI recognizes that a potential conflict exists when SSI offers both brokerage services and investment advisory services to its clients. SSI requires its representatives, when offering both types of services, to explain the different services and identify the capacity in which they are acting when making recommendations. SSI is a licensed insurance company in all five of the Firm’s footprint states including Georgia, Florida, Alabama, South Carolina, Tennessee and various other states outside the company’s brick and mortar locations in the aforementioned footprint states. Additionally, SSI has affiliations with other insurance companies in those states. Individuals of SSI may also be licensed insurance agents. To the extent that a representative of SSI recommends insurance products and services, SSI and/or the representative will receive commissions on the sale of those products. These commissions are paid directly from the insurance company underwriting the insurance policy and are not paid separately by the client. In addition, SSI may receive additional compensation from one or more of its insurance partners upon meeting a pre-determined level of business production with the carrier(s). SSI also offers investment advisory services under a separate division, known as Creative Financial Group (“CFG”). Advisory services offered through CFG are substantially different from the services offered through SSI’s Retail advisory program. CFG’s business practices are described in a separate Brochure, which is available upon request. SSI is a wholly owned subsidiary of Synovus Financial Corp. a publicly traded financial services company and a registered bank holding company headquartered in Columbus, Georgia. Synovus provides integrated financial services including commercial and retail banking, financial management, insurance and mortgage services to its customers through Synovus Bank. SSI is under common control with the following entities that have material business arrangements with SSI. Certain employees, directors and members of SSI’s executive management may also serve as employees, directors and/or executive management of these entities: Synovus Trust Company, N.A. (a National Trust Company) 33 West 14th Street Columbus, Georgia 31901 Synovus Bank (a Georgia state-chartered bank) 33 West 14th Street Columbus, Georgia 31901 Page 17 In limited circumstances, advisory clients may utilize the custody services of Synovus Trust Company. These Synovus Securities, Inc. Disclosure Brochure arrangements are usually initiated by the trust company. As a general practice, SSI does not refer advisory March 31, 2025 • A14023V35 clients to Synovus Trust Company for custody services. In the normal course of its business, SSI representatives may refer clients that are in need of Trust services to Synovus Trust Company. SSI is compensated for such referrals and such compensation is shared with the representative. Neither SSI nor its representatives provide additional advisory services to the client. SSI utilizes its affiliate, Synovus Bank, to provide a bank sweep deposit option (“Bank Sweep Program”) as the core account investment vehicle for free credit balances in brokerage accounts. This includes accounts opened as part of SSI’s investment advisory wrap programs (see Item 5 for a description SSI’s wrap programs) with limited exceptions. Specifically, the Bank Sweep Program is not available to ERISA plan accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase Plans, etc.) or foreign domiciled accounts. The arrangement between SSI and Synovus Bank to deliver a Bank Sweep Program creates certain conflicts in that both SSI and its affiliates financially benefit from having free credit balances swept from brokerage accounts to deposit accounts held at Synovus Bank. More details about the Bank Sweep Program, related conflicts of interest, and compensation derived from it are found under Item 12- Brokerage Practices. Item 11 – Code of Ethics Code of Ethics SSI’s Code of Ethics (the “Code”) sets forth a professional business standard to guide SSI and its employees to place our clients’ interests before our own. No SSI associated person shall prefer his or her own interest to that of the advisory client. SSI requires its associated persons to act in accordance with applicable federal, state and regulatory agency regulations governing investment advisory practices. The standards of conduct outline our fiduciary responsibilities and the Code includes our policies related to insider trading, personal securities transactions, privacy of client information and reporting requirements. SSI’s employees may purchase and sell securities for their own accounts that have also been recommended to clients. The Code is designed to prevent personal securities transactions and interests of SSI employees from interfering with making decisions in the best interest of clients. Nonetheless, because the Code permits employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client. Certain security types, such as Initial Public Offerings and Private Placements, may be prohibited or subject to a pre-clearance requirement. SSI’s associated persons are required to provide a quarterly report to the Firm’s Compliance Department showing investment transactions in their personal accounts, as well as disclosing annually all securities held on their behalf. Governing regulations provide that certain securities are exempt from this reporting requirement based upon the determination such securities would not pose any material conflicts. These reports are monitored regularly in an effort to reasonably prevent conflicts of interest between SSI and its clients. Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting SSI’s Chief Compliance Officer, Gene Gunderson, at 706-644-0298. Participation or Interest in Client Transactions SSI or its associated persons may engage in principal transactions and/or agency cross transactions, subject to Section 206(3) of the Investment Advisers Act of 1940. In accordance with the regulation, SSI will disclose the capacity in which it acted and will obtain client consent from both parties involved in the transaction prior to the trade settlement date. These disclosures and consents are required to make all necessary facts known and to alert clients to SSI’s potential conflicts of interest in a principal, riskless principal, or agency cross transaction. Item 12 – Brokerage Practices Page 18 SSI does not receive any proprietary or third-party research in connection with any soft dollar Synovus Securities, Inc. Disclosure Brochure arrangements. All research is paid for with hard dollars. However, to the extent a client selects a third-party March 31, 2025 • A14023V35 manager to manage their account, the third party manager may use client commission to purchase research or brokerage products and services in accordance with that third party manager’s own policies and procedures. Employees providing investment advisory services to clients are registered representatives and are able to affect securities transactions as instructed by clients. National Financial Services, LLC. (“NFS”), member FINRA and SIPC, was selected by SSI to provide custody, clearing and trade execution for SSI clients. Services provided by NFS in this capacity are rendered pursuant to a separate agreement between SSI and NFS. In its capacity as SSI’s clearing firm, NFS provides discounted execution costs upon SSI reaching certain transaction volumes. Execution discounts received, if any, are retained by SSI. In addition, SSI receives benefits, not related to execution of transactions, to offset the costs of certain workstation expenses. SSI is otherwise unaffiliated with NFS. SSI requires all client accounts, with very limited exceptions, to be custodied at NFS and all transactions to be executed by NFS through SSI. This creates a conflict of interest, as SSI is in effect acting as both broker and adviser on behalf of the client. Not all investment advisers require clients to use a specific broker-dealer. This direction to itself may represent a conflict of interest, as SSI is limited in its ability to seek out brokers with different pricing structures or broader services, or to receive more favorable pricing on securities transactions. Therefore, by directing brokerage, clients may not receive best execution on transactions though it is SSI’s aim to provide the most cost effective executions based upon prevailing conditions at the time of trade. In some accounts under SSI’s Outside Money Manager Program, neither SSI nor the manager is directed to execute transactions through SSI/NFS. Consequently, transactions are expected to be executed primarily away from SSI and accordingly are likely to incur additional costs such that the account will not operate as traditional “wrap” account. In such case, the third-party manager is responsible for obtaining best execution under their current policies and procedures. SSI is dependent upon NFS, as its clearing firm, for having agreements in place with mutual fund sponsors in order for SSI’s investment advisory customers to have access to mutual funds. While NFS has agreements in place with a large number of mutual fund sponsors, not all mutual funds are available through NFS. Moreover, many mutual funds offer different share classes, often for the same fund, representing different fee and expense structures paid by shareholders of a fund. Certain classes of shares may not be available through NFS. Consequently, SSI clients may not have access to a lower costing share class that may be otherwise available to investors directly from the fund, a different clearing firm, or other financial intermediaries. This limitation could result in SSI clients purchasing and/or holding a more expensive share class of a mutual fund thereby reducing the investment returns. SSI may also receive additional compensation directly from NFS on behalf of the advisory accounts for which they serve as custodian. NFS may pay SSI a percentage of the uninvested cash and/or the balance maintained in a money market sweep vehicle. As part of its relationship with NFS, SSI’s clients have access to margin lending financed through NFS. Clients must apply and qualify for this additional service. Use of margin introduces additional risks and it not a strategy suitable for everyone. These special risks are covered in more detail under Item 8 of this brochure. Moreover, clients electing the use of margin will be subject to interest charges on any amount borrowed. The interest paid by the investor is in addition to the asset management fees paid. SSI receives from NFS a portion of the margin interest paid by investors. This creates a conflict of interest whereby SSI receives an economic benefit from both margin interest and the asset management fees charged. SSI mitigates this conflict by limiting the use of margin within advisory accounts to only a select number of overlay programs that employ the use of option securities and further limits the availability of such programs to investors meeting eligibility requirements such as a high liquid net worth and investible assets. Margin borrowing is not allowed in advisory accounts outside of these select overlay programs. Page 19 In coordination with NFS, SSI also offers to brokerage and investment advisory customers the participation in the Bank Sweep Program as their core investment vehicle, subject to the exclusions noted under Item 10 Synovus Securities, Inc. Disclosure Brochure of this Brochure. Participants in the program have free credit balances within their brokerage/investment March 31, 2025 • A14023V35 advisory account automatically swept to an interest bearing bank deposit account at Synovus Bank, a Federal Deposit Insurance Corporation (“FDIC”) member bank and SSI affiliate. Client balances swept into a deposit account at Synovus Bank are eligible for FDIC insurance coverage up to $250,000 per depositor in each insurable capacity. Examples of separate insurable capacities include the following non-exhaustive list: individual accounts, joint accounts, certain trust arrangements, etc. However, a client’s cash balance in the Bank Sweep Program is subject to aggregation with other deposit assets the client has at Synovus Bank outside of the Bank Sweep Program. Neither SSI nor Synovus Bank will monitor the aggregate amount of deposits a client has with Synovus Bank either directly or through participation in the Bank Sweep Program to determine the extent of deposit insurance coverage available at any time for program participants. Therefore, each client participating in the Bank Sweep Program is responsible for monitoring the aggregate total of deposited assets and determining the extent of deposit insurance applicable to the client’s deposits. Through the Bank Sweep Program arrangement, SSI and its affiliates benefit financially. Synovus Bank earns net income from the difference in interest paid to the Bank Sweep Program participants for balances held in their core investment accounts and income received from new lending or investment activity derived from the program deposits (referred to as “spread”). As with any depository institution, Synovus Bank’s income increases when the spread between interest paid, and income received widens. Synovus Bank has no obligation to base its interest payments to the Bank Sweep Program participants on the profitability of the income generated from the spread. In addition, SSI receives from Synovus Bank an annual fee ranging from $25 to $50 for each account participating in the Bank Sweep Program. Together, these financial benefits to SSI and its affiliates create a conflict of interest as accounts participating in the program may be more profitable to Synovus than those who do not participate. To address this conflict, clients may decline participation in the Bank Sweep Program and SSI offers alternative choices for core investment vehicles for free credit balances. In addition, SSI excludes eligibility from the Bank Sweep Program any ERISA plan accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase Plans, etc.) and any foreign domiciled account. Lastly, at the time of account opening, or election into the program, clients eligible for participation in the Bank Sweep Program are provided with important disclosure documents and agreements containing further details. These documents may be obtained at any time free of charge upon the request of current or prospective clients. With very limited exemptions, third party managers are instructed to execute SSI client trades with NFS, subject to their fiduciary duty to seek best execution for client trades. Managers have the authority to execute transactions with another broker or dealer if the manager believes it is in the best interests of the client to do so. SSI does not typically aggregate trades for multiple clients, unless trading for clients invested in the same investment strategy. However, SSI and third-party managers are permitted to aggregate trades according to their trading policies and procedures. SSI believes aggregating trades will allow the managers to achieve more favorable pricing and/or better execution at the time of the trade, as well as supporting equitable prices allocations across client accounts. Item 13 – Review of Accounts New accounts are reviewed by an SSI Designated Principal to ensure all information is in order and documentation is complete. SSI representatives provide a regular review of client accounts, the frequency of which is determined based upon the client’s preferences and expectations. Nonetheless, SSI representatives are expected to initiate contact with clients at least annually in order to confirm the accuracy of information regarding the client’s financial situation and the investment objective(s) of an account. Page 20 Clients receive account statements and transaction confirmations directly from the account custodian usually monthly, but not less than quarterly. Clients may request quarterly reports from SSI providing such information as asset allocation and account performance data. Depending on the Program selected, Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 performance information is prepared by the individual managers and may not be calculated on a uniform and consistent basis. Item 14 – Client Referrals and Other Compensation SSI and its representatives do not receive any economic benefits from any third party with respect to the advisory services offered to clients other than the fees described in this Brochure. Product sponsors, mutual fund companies or other third parties may offer SSI representatives invitations to training sessions, due diligence visits or other meetings or events at the expense of the third party. These invitations are not offered directly as a result of any amount of business placed with the third party, but the volume of business placed with a particular sponsor may be indirectly related. SSI entered into a promotional agreement (the “agreement”) with GLOBALT, an unaffiliated investment adviser, on a limited basis. Pursuant to this agreement, representatives of SSI can refer clients directly to GLOBALT and receive a referral fee. The fee paid to SSI by GLOBALT is a percentage of the advisory fee GLOBALT collects from the referred client. The client does not pay a higher fee as a result of the referral; rather, GLOBALT shares with SSI a percentage of the fee they receive from the client. The client enters into an investment advisory agreement directly with GLOBALT. SSI or its representative provides no additional advisory services to the client. SSI has entered into promotional agreements with various unaffiliated third-party professionals such as attorneys, certified public accountants, or investment advisers (collectively “promotors”). The promotors can refer clients to SSI and receive a referral fee. SSI pays a percentage of its fees collected from advisory clients to the promotor who originated the client referral. The client does not pay a higher fee as a result of the referral, however. The client enters into an investment advisory agreement directly with SSI. Any other financial services provided by these promotors to clients are separate from their promotional arrangement with SSI, and neither SSI nor its representatives make any claim or warranty regarding such services. The promotors have a financial incentive to promote the advisory services provided by SSI, creating a conflict of interest whereby the advisory services SSI provides are recommended over those offered by other investment advisers. Investors should independently evaluate the advisory offerings of competing firms before engaging SSI as a result of a promotor’s recommendation. Synovus Bank makes investment products available to its customers, including the advisory services offered by SSI and revenues generated and/or expenses occurred may be shared between the affiliated companies. Nevertheless, SSI’s advisory clients do not pay a higher fee as a result of these revenue sharing or expense arrangements. Conversely, SSI representatives may refer clients to Synovus Bank for banking services. Synovus Bank may, at its discretion, pay an incentive to SSI and/or its representatives for referrals made for banking services. Notwithstanding referral incentive programs, if any, sponsored by Synovus Bank, SSI customers are under no obligation to utilize Synovus Bank for any banking services, and the establishment of an advisory relationship with SSI is not contingent upon a client opening or maintaining a banking relationship with Synovus Bank. In the normal course of its business, SSI representatives may refer clients that are in need of Trust services to Synovus Trust Company. SSI is compensated for such referrals and a portion of the compensation is shared with the SSI representative. SSI or its representative provides no additional advisory services to the client. Item 15 – Custody Page 21 SSI is dually registered as an investment adviser and broker-dealer. As broker-dealer SSI has a minimum net capital requirement of $250,000 and can accept checks made payable to SSI for deposit into client accounts. However, all checks and securities are promptly forwarded to our clearing firm, NFS. Because SSI accepts checks in this manner, under SEC rule 206(4)-2, SSI is deemed to have custody of its investment advisory accounts. Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 SSI also has custody because investment advisory fees are directly debited from client accounts. Debiting of fees is done pursuant to authorization provided by each client. NFS, as the account custodian, furnishes account statements, usually monthly but no less than quarterly, directly to the clients. SSI urges clients to carefully review their statements for accuracy and compare those records to any report received directly from SSI. Reports prepared by SSI and/or its sub-advisors may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. In very limited situations, clients may hold advisory accounts with Synovus Trust Company, an affiliate of SSI. In order to comply with the custody rules, SSI engages an independent public accountant to perform an internal controls audit on the operations of SSI, its divisions, and certain affiliates and also to conduct a surprise examination of any accounts over which it is deemed to have custody. Audits are done annually. Item 16 – Investment Discretion Depending on the investment Program selected, SSI manages client portfolios on both a discretionary and non-discretionary basis. When appropriate, clients grant SSI discretion over their account by providing written authorization. Only certain representatives are permitted to act on a discretionary basis, and an SSI Designated Principal is required to review and approve each discretionary account. Discretionary authority authorizes the Firm, in its sole discretion and at Client’s risk, to determine the securities to be bought or sold and the amount of securities to be bought or sold. Further details concerning SSI’s programs concerning investment discretionary authority are described in Item 4 of this brochure. In some cases, investment discretion is delegated to a third-party manager. Selection of investments follows the parameters determined for the client as well as any specific instructions, investment objectives and risk profile associated with each client. The investment discretion granted to SSI by its clients does not include discretionary authorization over disbursements from a client’s account. Irrespective of a client’s authorization of investment discretion to SSI, clients retain control over disbursements from their accounts; SSI and its associated persons process disbursements from client accounts only after receiving client instructions deemed in good order pursuant to the Firm’s policies and procedures. Item 17 – Voting Client Securities Synovus Securities, Inc. does not take any action or render any advice on voting proxies. Furthermore, SSI will not advise or act on a client’s behalf in any legal proceedings, including bankruptcies or class action lawsuits. Clients will receive proxies, and any other issuer communication, directly from their account custodian. Clients may contact SSI with questions relating to the proxy voting process, but SSI does not provide any recommendations on how to vote any particular issue. If a client uses a third-party manager as described in Item 4, the third-party manager, at its discretion, may accept responsibility for voting proxies on the client’s behalf. Any delegation of voting authority to a third-party manager will be outlined in the investment advisory agreement. Item 18 – Financial Information Synovus Securities, Inc. is required to provide you with certain financial information or disclosures about its financial condition. SSI has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Page 22 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 (space intentionally blank) Page 23 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Appendix A – Risk Definitions All investments offer a balance between risk and potential return. Generally speaking, a typical investor will take on more investment risk in exchange for the opportunity for greater return. The risk definitions below are intended to assist our clients in understanding the common risks associated in investing. The terms listed below are not comprehensive to all potential investment risks and may not be applicable for all investment strategies. Business Cycle Risk Call Risk The risk that cyclical business cycles, with periods of peak performance followed by a downturn, then a trough of low activity, affect the returns of an investment, an asset class or an individual company’s profits. See reinvestment risk. Some corporate, municipal and agency bonds have a “call provision” entitling their issuers to redeem them at a specified price on a date prior to maturity. Declining interest rates may accelerate the redemption of a callable bond, causing an investor’s principal to be returned sooner than expected. In that scenario, investors have to reinvest the principal at the lower interest rates than they may have had prior. Collateral Account Risk A client may enter into a separate agreement with a creditor, bank, broker/dealer or other financial institution (together, “creditor”) to pledge securities or assets against a loan or collateral amount. This agreement grants the creditor a security interest to transfer, sell, redeem, close, open, trade or otherwise liquidate any assets in the account (including instructions to transfer assets directly) in the pledged assets or collateral account. Adverse market conditions can impact the value of the value of the pledged securities causing the portfolio value to decline. This may result in the client to pledge additional assets, pay down the line of credit or the creditor may instruct the adviser and/or custodian to sell pledged assets, which depending on market conditions may result in receiving less for the securities than the original purchase price. Declining market conditions may also limit client’s ability to draw upon their account. Long-term investment strategies and goals may be adversely impacted by the creditor’s actions, as they may instruct the adviser to sell some or all of the pledged assets as payment against the loan. In this instance, since the creditor agreement may provide certain rights, the client may not be able to choose which securities are liquidated and the client would also be responsible for any loan shortfall after such sale. There is no guarantee that investment account returns will meet or exceed loan costs. Commodity Price Risk Composition Risk Consumers Risk The possibility that fluctuations in the price, shortage or overabundance of material inputs, such as fuel, energy, raw materials, metals, manpower, etc. will materially impact operating a company, production of goods/services or reduce the attractiveness or price of an investment. The possibility that changes in an index, resulting from security membership, market capitalization and weighting, and investment guide changes may increase the relative dispersion for a strategy and result in unexpected performance variance. Security membership, being added, reduced or weight changed, in an index may result in security prices changes. The risk when clients are exposed to unsuitable investments that they do not fully understand. Correlation Risk See Diversification Risk - When portfolio holdings are too highly correlated with each other, meaning that the move up and down in value together, there may be insufficient diversification to counter market or security risks. Page 24 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Counterparty Risk Also called default risk. Counterparty risk occurs when one or more parties to an agreement, such as a bond, defaults and does not fulfill their contractual obligation, such as payments or principal. For example, a bond issuer with a lower quality rating may have a higher default risk and its bonds will need to pay a higher yield than an issuer with a higher rating. Credit Rating / Issuer Quality Risk Credit rating agencies provide analysis and comparative opinions on the bond issuer's ability and willingness to meet its financial obligations. For bond holders, risk occurs when the opinion changes, resulting in a lower rating, which may decrease the current holding value and may make it more expensive, in the form of higher interest rates, for the issuer to raise new debt to meet future obligations. Credit ratings are not indications of investment merit but are a significant factor in the investment decision. Generally, the higher the credit rating, the higher the bond price relative to the yield rate. Currency / Foreign Exchange Risk Also called foreign exchange risk and implies international investing: the possibility that the relative change in currency value from one country to another will reduce the investment value when converted back from one currency to the other. Dispersion Risk The uncertainty risk associated when an investment strategy is not in accordance with its model, resulting in performance or risk that is less or greater than expected. Diversification Risk Diversification means to reduce risk by investing in a variety of assets, and generally in assets that do not move up or down in value together (correlate). There are two forms of diversification risk: A portfolio that is relatively undiversified, such as having a single security or positively correlated holdings may be more volatile and value sensitive to the security’s market actions. A portfolio that is too diversified may result in a proxy for an index, and not provide acceptable returns relative to the fees or expenses incurred with a managed account. Economic Risk The risk that economic conditions, such as government regulations, tax policies, political or social instability, workforce, or exchange rates will negatively affect investments, usually one in a foreign country. Economic risk is one of the reasons why international investing, especially in emerging countries, carries more risk than domestic investing. Expenses and Fees Risk Exchange traded funds, like mutual funds, generally incur operating expenses for management, record-keeping, custodial services, taxes, legal, accounting and audit fees, which are taken from the fund's assets and lower investor return. Different funds may have different expenses and fees ratios, relative to the fund assets. Therefore, selection of a fund with higher expenses and fees may have lower performance than a comparable fund with a lower expense ratio. Industry Risk The possibility of investment losses related to a specific industry or market sector stemming from economic or regulatory change, instability, volatility or market shift from a particular industry. These losses may increase in relation to overall portfolio weighting towards that industry. Page 25 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Inflation Risk Inflation causes tomorrow’s dollar to be worth less than today’s. Inflation reduces the purchasing power of a bond investor’s future interest payments and principal, collectively known as “cash flows.” Inflation also leads to higher interest rates, which in turn leads to lower bond prices. Interest Rate Risk The possibility that the value of a security, especially a bond, will reduce as a resulting from a rise in interest rates. Inverse Market ETF Risk Inverse ETFs are designed to replicate the opposite direction of the matching or indicated index. These ETFs often use a combination of futures, swaps, short sales, and other derivatives to achieve these inverse objectives. As complex products, inverse ETFs may not track the underlying or contra benchmark as expected and are often designed to achieve their results on a daily basis only. That means over periods longer than a trading day, the value of these ETFs can and usually do deviate from the reciprocal performance of the associated index to which they correlate. Over longer periods of time or in situations of high volatility, these deviations can be substantial. Legal Risk Liquidity Risk The risk that a legal contract or financial transaction won't be fulfilled because it breaks a law or there is a regulatory conflict. In addition, companies involved in legal actions may have to increase cash reserves for settlement, which may restrict their growth ability, lower their relative profit or income potential, and be more volatile. The risk that investors may have difficulty finding a buyer when they want to sell a security and may be forced to sell at a significant discount to its expected market value. Liquidity risk is greater for thinly traded securities. Market Capitalization Risk A company's market capitalization, one measure of potential growth, is the value calculated from the company's shares outstanding multiplied by the price per share. The basic market cap categories are large-cap, mid-cap and small-cap. Large-cap stocks, representing companies over $10 billion in size, are generally researched and followed more by analysts or investors. Many large-cap companies are called “Blue Chips”. Large-caps historically experience comparatively slower growth, with less risk, than smaller-sized companies. Smaller-sized companies typically are not as financially strong but are expected to grow at a faster rate with greater investment return potential. Smaller-sized companies and funds may experience greater up/down price and value volatility. Within investment guidelines, many strategies, ETFs or mutual funds focus their funds in investing in specific market cap sized companies. Market capitalization risk exists when comparative-sized companies, such as large, mid- or small-caps as a whole and the ETFs and funds targeted to the cap, would decline, bringing the associated values down regardless of the fundamental characteristics or investment potential. Strategy allocations that over- or under-weight asset classes, including market caps, may have greater volatility missed return potential, or relative loss. Market Risk Also called systematic or undiversifiable risk: The risk that the stock or bond market as a whole would decline, bringing the value of individual securities down with it regardless of their fundamental characteristics or investment potential. Page 26 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Model Risk The possibility that the analysis, investment or allocation decisions for a strategy model may be unreliable or provide incorrect signals in volatile market conditions. Pandemic Risk Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. Regulatory Risk The risk that changes in laws and regulations will impact a security, business, sector or market. A change in laws or regulations made by the government or a regulatory body can increase the costs of operating a business, reduce the attractiveness of investment, and/or change the competitive landscape. Reinvestment Risk Also see inflation risk. Risk occurs, especially in a declining interest rate environment, when an income producing bond or security is sold or called and the reinvested funds may yield a lower rate than the original security. The reinvested assets may provide a lower cash flow than expected or required to meet the investor’s investment objectives. Security Selection Risk Sociopolitical Risk The risk that an investor chooses a security that underperforms the market for reasons that cannot be anticipated. The possibility of investment losses related to a specific company or security stemming from economic or regulatory change, business climate, earnings surprise or legal action relative to a specific company. These losses may increase in relation to the security's overall portfolio weighting. Tax Risk The danger that political or cultural changes or instability in a location or a country could turn against an investment. For taxable accounts, the possibility that the security holdings, interest, dividends and timing of the buys/sell transactions will increase one's tax liability. Tax risk may also occur when investing just prior to dividend or capital gain activities for ETFs or mutual funds. Time Horizon Risk Investment time horizon generally reflects the total length of time the investor expects to invest before the assets are used for their financial goal (e.g., retirement income). Because different security types, such as equities, bonds and cash have different reward and risk characteristics, a client's time horizon is important in influencing the investment and strategy decisions. Generally, the shorter the client's time horizon, the less time available to the client to recover from any incurred losses. Timing Risk The risk that an investment performs poorly after its purchase or better after its sale. This risk may reflect security selection made either too soon or too late, relative to historical review, and thereby missing profit opportunities or increasing loss potential. Tracking Error Risk Also called active risk. The possibility that a security, such as ETF or mutual fund, deviates from and does not accurately track its defined index or benchmark. The fund does not work as effectively as intended, resulting in unexpected asset allocation and price behavior for the holding. Page 27 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35 Trading Volume Risk Trading volume occurs as a direct result of supply and demand. Generally, the greater the trading volume, the more liquid it is and the spread between buy/sell transactions is smaller. A lightly-traded security may have more volatile pricing, be less liquid and have higher transaction costs due the buy/sell spreads. Turnover Rate Risk Turnover rate or ratio reflects the frequency that managers buy or sells securities within a portfolio. There is no turnover rate that is correct for all accounts – the rate will vary upon the strategy type, securities held, or investment conditions. In effect, a high turnover rate may reflect excessive trading, resulting in potentially higher costs or transaction expenses, increased capital gains tax liability of the portfolio, and reduced relative performance. A low turnover rate, again not conclusive, may reflect low investment account management activity or decreased available opportunities. Valuation Risk Yield Curve Risk Difficulty in pricing/fairly valuing securities that are thinly or infrequently traded, not readily accessible, illiquid, or of varying quality. In the absence of accurate security valuation, buy or sell transactions may be higher or lower than anticipated. Securities that increase or decrease in price may result in overweight or underweight conditions relative to a model or benchmark, increasing diversification risk. The yield curve represents the relationship between rate of return or interest rates and time to maturity. For bond holders, risk occurs when bond values decrease, impacting portfolio value, when interest rates go up or when needed fixed income or cash flow decrease when bond prices go up The yield curve will slope, up/down and widen or narrow, in relationship between short term bond yields and long term bond yields and varying maturities. To compensate for the liquidity risk of tying up one's money for long periods of time, a typical investor expects a higher rate of return for a longer time to maturity. Page 28 Synovus Securities, Inc. Disclosure Brochure March 31, 2025 • A14023V35

Additional Brochure: SYNOVUS SECURITIES, INC. APPENDIX 1 WRAP BROCHURES (2025-03-31)

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Item 1 – Cover Page Synovus Securities, Inc. 33 West 14th Street, 3rd Floor Columbus, GA 31901 (706) 649-2327 March 31, 2025 This Wrap Fee Program Brochure provides information about the qualifications and business practices of Synovus Securities, Inc. (“SSI”). If you have any questions about the contents of this Brochure, please contact Gene Gunderson, Chief Compliance Officer at (706) 644-0298 or by email at genegunderson@synovus.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. Synovus Securities, Inc. is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information about which you determine to hire or retain an adviser. Additional information about Synovus Securities, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. i Item 2 – Material Changes This Wrap Fee Program Brochure (the "Brochure") dated March 31, 2025, is a revised document prepared according to the Securities and Exchange Commission's requirements and rules. This Item will discuss only specific material changes that are made to the Brochure and provide clients with a summary of such changes. Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business' fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. • We have updated the following sections of this Brochure: • Item 4 contains additional information regarding how SSI Financial Advisors are compensated and we further explain conflicts of interest this may create and how the Firm addresses those conflicts. Another change impacting this section is the termination of a revenue sharing arrangement SSI had with Envestnet, an unaffiliated third party with whom the Firm partners to deliver advisory services. Item 4 reflects reductions in platform fees paid to Envestnet for offerings included in the Synovus Investment Strategies Program. Please review these updates, and all sections of this Brochure, carefully before making investment decisions. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Copies of this Brochure may be requested by contacting Gene Gunderson, Chief Compliance Officer at (706) 644-0298 or genegunderson@synovus.com. It is also available free of charge via our website at https://www.synovus.com/about-us/our-companies. Clients have the option to electronically receive copies of this Brochure, along with any subsequent updates. Please contact your Financial Advisor for more information about electing electronic delivery for future brochures. ii Item 3 - Table of Contents Item 1 – Cover Page ................................................................................................................................... i Item 2 – Material Changes ....................................................................................................................... ii Item 3 - Table of Contents ...................................................................................................................... iii Item 4 – Services, Fees and Compensation ........................................................................................... 1 Item 5 – Account Requirements and Types of Clients ....................................................................... 10 Item 6 – Portfolio Manager Selection and Evaluation ....................................................................... 10 Item 7 – Client Information Provided to Portfolio Managers........................................................... 11 Item 8 – Client Contact with Portfolio Managers .............................................................................. 11 Item 9 – Additional Information ............................................................................................................ 11 iii Item 4 – Services, Fees and Compensation Synovus Securities, Inc., (“SSI”) is a full service brokerage and investment advisory firm headquartered in Columbus, Georgia, with offices across Georgia, Alabama, Florida, South Carolina, and Tennessee. SSI is owned by Synovus Financial Corp., a multi-billion dollar publicly traded bank holding company also based in Columbus. SSI is a registered broker-dealer and registered investment adviser with the Securities and Exchange Commission, as well as a member of FINRA and various state regulatory agencies. As of January 1, 2025, Synovus Securities, Inc.’s assets under management were $4,128,937,417 on a discretionary basis, and $2,957,179,318 on a non-discretionary basis. The general investment services offered to clients are outlined in the bullet points below. The specific details of each investment program (each a “Program” or collectively “Programs”) available to clients follow. • • • • • • • • • • Collecting detailed information about the client’s current financial situation; Identifying client’s goals and objectives; Developing an appropriate asset allocation model; Providing asset management services, including individually managed accounts; Offering mutual fund model portfolios; Selecting of money managers; Evaluating performance and monitoring services; Periodic rebalancing; Executing of securities transactions; and, Providing custody of assets through National Financial Services (“NFS”). Where applicable, portfolio managers selected to manage client accounts may buy, sell or otherwise trade securities of SSI’s parent company, Synovus Financial Corp., in client accounts. While this may appear to create a conflict of interest, these decisions are made solely at the discretion of the manager and are not influenced by SSI or any of its affiliates. SSI does not recommend the purchase or sale of any stock issued by Synovus Financial Corp. to advisory clients. Each Program may impose account minimums and due to these minimums, adequate diversification may not be achieved. The number of accounts within any given program varies, including some with a limited number of investor accounts. More information about each program is available from your Financial Advisor. Clients in each Program pay a program fee (“Program Fee”) that includes all fees associated with management, custodial and brokerage-related expenses for the client’s account, subject to certain exceptions. Additional costs not part of the Program Fee include, but are not limited to, transactions executed away from SSI, dealer mark-ups, electronic fund and wire transfers, market maker spreads, exchange fees, redemption fees and account maintenance fees. SSI pays part of the Program Fee to third party managers managing client assets. Fees vary depending on the manager. Details of these fees are provided by Program in Item 4 of this brochure. Clients grant SSI the authority to debit Program Fees directly from their account. Clients will receive a SSI urges clients to review the information on the statement for accuracy and compare the statement, usually monthly but no less than quarterly, showing all account holdings and transactions in their information to any reports received directly from their SSI Representative. account. If the client does not have a sufficient cash/cash equivalent balance to cover the fee, SSI may liquidate assets to generate sufficient funds for the fee to be paid. Conversely, a portion of accounts may be maintained in (and assessed fees on) cash or other cash equivalents. Page 1 For new Synovus Investment Strategies Program client accounts, the initial fee is calculated the day after assets are placed in the Program, debited the following month, and will be prorated based on the number of calendar days left in the month. If the client deposits or withdraws $10,000 or more to their account during the month, SSI calculates a new fee, or rebate for withdrawals, prorating the additional funds for the remainder Synovus Securities, Inc. Disclosure Brochure – Appendix 1 of the month. March 31, 2025 W14023V34 Advisory agreements may be terminated by either party, without penalty, immediately upon receipt of written notice by the other party. Any such termination will not affect a party’s status, obligations or liabilities. If an account is terminated and all assets are withdrawn from the Program prior to the end of a month, the client will receive a refund of the Program Fee prorated based on the number of calendar days left in the month. At the time of termination, any unpaid fees will be due. Clients may receive comparable services from other broker-dealers or investment advisers and pay fees that are higher or lower than those charged under these Programs. The fees for the various Programs may be more or less than the client would have paid if the services (account management, custody and brokerage transactions) were purchased separately outside of the Program. SSI Representatives recommending the Program are compensated based on the client’s participation in the Program; therefore, they have a financial incentive to recommend these Programs over other services offered by SSI. Not all Program fees are the same and the fees Synovus receives vary by Program. This creates a financial incentive for SSI to recommend the advisory Programs for which it receives the most compensation. However, this conflict is mitigated by working with current and prospective clients to clearly identify each person’s goals, objectives, financial needs, risk appetite, investment preferences, and other facts unique to the investor. This fact-finding process is designed to identify the Program (or Programs) we recommend based upon the investor’s best interest. We further mitigate this conflict by providing transparent fee pricing for each Program offered, including fees clients pay to Synovus, those paid to third party managers (if any), and to Envestnet, with whom we have partnered to deliver the technology platform used in managing clients’ accounts. We encourage you to review the various Program offerings described in this brochure and to compare the fees found in Item 5 of this brochure associated with each Program. SSI requires all client accounts, with very limited exceptions, to be custodied at NFS and all transactions to be executed by NFS through SSI. This creates a conflict of interest, as SSI is in effect acting as both broker and adviser on behalf of the client. Not all investment advisers require clients to use a specific broker-dealer. This direction to itself may represent a conflict of interest, as SSI is limited in its ability to seek out brokers with different pricing structures or broader services, or to receive more favorable pricing on securities transactions. Therefore, by directing brokerage, clients may not receive best execution on transactions though it is SSI’s aim to provide the most cost effective executions based upon prevailing conditions at the time of trade. In some accounts under SSI’s Outside Money Manager Program, neither SSI nor the manager is directed to execute transactions through SSI/NFS. Consequently, transactions are expected to be executed primarily away from SSI and accordingly are likely to incur additional costs such that the account will not operate as traditional “wrap” account. In such case, the third party manager is responsible for obtaining best execution under their current policies and procedures. SSI does not typically aggregate trades for multiple clients, unless trading for clients invested in the same investment strategy. However, SSI and third party managers are permitted to aggregate trades according to their trading policies and procedures. SSI believes aggregating trades will allow the managers to achieve more favorable pricing and/or better execution at the time of the trade, as well as supporting equitable prices allocations across client accounts. SSI is dependent upon NFS, as its clearing firm, for having agreements in place with mutual fund sponsors in order for SSI’s investment advisory customers to have access to mutual funds. While NFS has agreements in place with a large variety of mutual fund sponsors, not all mutual funds are available through NFS. Moreover, many mutual funds offer different share classes, often for the same fund, representing different fee and expense structures paid by shareholders of a fund. Certain classes of shares may not be available through NFS and consequently SSI clients may not have access to a lower costing share class otherwise available to investors directly from the fund, a different clearing firm, or other financial intermediaries. This limitation could result in SSI clients purchasing and/or holding a more expensive share class of a mutual fund thereby reducing the investment returns. Page 2 SSI’s clearing firm, NFS, sponsors a “No Transaction Fee” program (the “NTF Program”) whereby NFS does not charge SSI a transaction fee for purchase or sell orders SSI submits on a client’s behalf for mutual funds Synovus Securities, Inc. Disclosure Brochure – Appendix 1 participating in the NTF Program. SSI benefits from this cost savings, therefore creating a conflict in that SSI March 31, 2025 W14023V34 may be incented to recommend or use the mutual funds participating in the NTF Program for advisory client accounts over those mutual funds which do not participate. However, SSI does not influence, recommend, promote, advise or otherwise direct any third party investment adviser (e.g., Envestnet) to select or give preference to mutual funds participating in the NTF Program over those funds which do not participate. Additionally, upon a client's request, SSI will provide at no cost a list of any NTF eligible mutual funds held within the account and will make a representative available to the client to answer any questions related to the share class selected along with any other share classes available from the same fund. Information for contacting SSI is provided on the first page of this Wrap Brochure. Many mutual funds are offered with more than one type of fee structure, commonly called “share classes”. There are several factors to consider when selecting a mutual fund share class. For example it is important to evaluate whether a share class involves payment of a commission at the time of purchase (commonly referred to as “front end loads”), at the time of liquidation (“back end loads”), incrementally while the investor owns the share class (“level loads”) or no commission at all (“no-loads”). Share classes also differ in terms of what fees and expenses are deducted from the mutual fund’s pooled investment assets, since these fees and expenses are often not billed separately to a mutual fund shareholder. While there a variety of fees investors may encounter when purchasing a mutual fund, common fees/expenses include management fees paid to the fund’s investment manager, operating expenses used to pay for the day-to-day costs incurred to operate the mutual fund, and distribution fees (known as “12b-1” fees) used to promote, advertise, or compensate financial professionals for aiding in sales of a mutual fund. Though not all mutual fund shares classes include each of the fees/expenses presented here, what remains consistent is that a mutual fund’s share class with a lower total annual expense as compared to another share class of the same fund can result in a significant difference in investment returns over time. It is common for mutual funds to set eligibility requirements, such as minimum investment amounts, for an investor to qualify for purchasing a lower cost share class. Investors can learn more about a specific mutual fund’s available share classes, their fees, loads, expenses, and eligibility requirements by reading the fund’s investment prospectus. In addition, we encourage clients to ask their representative about the fees and expenses associated with mutual funds currently owned by the clients or those presented to them. The programs described in this brochure do not offer, or may not qualify for, all share classes offered by a fund company. Therefore, it is possible you could invest in a lower costing share class of the same fund if purchased outside the programs outlined in this brochure, though without the benefit of the advice and related services we offer through our programs. Despite SSI’s reasonable efforts to utilize cost-effective share classes, there is no guarantee that a client will always be in the most cost advantageous share class. Ask your representative about shares classes available to you. With respect to funds that pay 12b-1 fees, SSI’s intent is to limit the use of such funds by opting to use a share class of the same fund which does not include 12b-1 fee payments wherever possible. However, in cases where SSI receives 12b-1 payments from a fund, the Firm generally will seek to credit the entire 12b-1 payment to the advisory client(s) account holding the asset which generated the payment from the fund. These credits are intended to but may not guarantee the same effect as investing into a non-12b-1 class. Credits to client accounts generally occur monthly and represent the total 12b-1 fee payments credited during the preceding month. Additionally, SSI will generally seek to issue a check to the most recent address of record of closed client accounts representing 12b-1 payments the Firm received as a result of funds owned during the quarter in which the account was closed. Page 3 In conjunction with offering the Synovus Choice UMA, SSI receives access to Envestnet Fiduciary Solutions Program (“EFS”) free of charge. The EFS Program provides SSI additional access to research, watch lists, alerts, Large Case Support, Overlay Services and other Envestnet investment-related intellectual capital. Without offering the Synovus Choice UMA, SSI would have to pay Envestnet for access to the EFS Program. This creates the potential for a conflict of interest because without offering the Synovus Choice UMA, SSI would incur extra cost for the research content available from the EFS Program. To mitigate potential conflicts, SSI’s cost-free access to the EFS Program is not contingent upon any minimum asset values in the Synovus Choice UMA program, nor are there any requirements to offer certain Separate Account Managers, mutual funds, ETFs, or any other products—including those proprietary to Envestnet or its affiliates. Furthermore, clients in the Synovus Securities, Inc. Disclosure Brochure – Appendix 1 Synovus Choice UMA do not pay additional fees as compared to any other of SSI’s UMA offerings, nor do SSI March 31, 2025 W14023V34 representatives receive more compensation for asset within the Synovus Choice UMA over assets in SSI’s other UMA offerings. SSI’s access to the EFS Program content is intended to benefit the Firm’s customers by providing SSI associated persons additional research and investment information used in the management of client assets. To the extent that a client of the SIS Advisor Directed or the SSI Individually Managed Account Program invests in new issues of an equity or fixed-income security purchased in their account, SSI will receive a selling concession, or other similar type of compensation, as described in the prospectus or offering document of the security. SSI receives this compensation in addition to the Program Fee received for investment advisory services. You have the option to restrict the purchase of new issues in your account or to revoke at any time previous authorization granted to purchase them. SSI’s advisory clients may also maintain non-advisory SSI brokerage accounts. Representatives of SSI are compensated through commissions assessed on the transactions executed in these accounts or through some other manner, such as 12b-1 fees. This creates an incentive for the representative to recommend investment products based on the compensation received rather than on the client’s needs. However, SSI’s brokerage services are generally performed on a non-discretionary basis; therefore, except in rare instances whereby a customer has granted an SSI representative written discretionary authority, transactions are approved by the client in advance and clients receive trade confirmations inclusive of the commissions charged. Moreover, clients are provided a copy of SSI's brokerage account commissions schedule at the time of account opening. Additional copies of the brokerage commissions schedule are available free of charge upon request by contacting your account representative or the SSI home office by calling 706-649-2327. In addition, advisory fees are not charged on such brokerage accounts. To address this conflict, an SSI Designated Principal reviews each new brokerage and advisory account for appropriateness based upon the expressed needs of the client. While it is the policy of SSI to charge investment management fees to its clients in accordance with the fee schedules in effect at the time of executing the investment management agreement, fees are subject to negotiation and reflect circumstances that may apply to a specific client relationship or account. Thus, fees paid by clients do vary from the program schedules described later in this section, and it is possible clients with similar asset levels to have differing fee schedules and pay different fees, even within the same program. The fees specific to each client account are detailed in that account’s advisory contract. If a client requests and the firm agrees to a flat fee arrangement instead of the tiered program schedules described later in this Brochure, the client may pay more fees than if the relevant program's tiered fee schedule had been used. This scenario is more likely to occur when the client's account asset value crosses one or more of the program schedule's fee discount tiers. The potential for a flat fee arrangement causing a client to pay more in fees versus the program's standard tiered schedule creates a conflict whereby the firm and/or its representatives could be incented to recommend a flat fee schedule in order to receive more compensation. To mitigate this conflict, SSI and its representatives are bound to act solely in the client's best interest including when advising on fee arrangements. Moreover, SSI has implemented procedures at account opening and throughout the account's lifecycle to assess (and remediate as deemed prudent) the impact a negotiated flat fee schedules will have, or has had, on a client's fees. Clients can qualify for SSI advisory fee discounts by combining household balances of related accounts within Synovus’s investment advisory offerings. This is accomplished by notifying your Financial Advisor of any accounts sharing the same residential address for which you want to link for fee billing purposes (“household discounts”). Accounts qualifying for household discounts can be added to, or removed from, the linked group at your direction. SSI has determined to offer employees, associated persons and their immediate family fee discounts resulting in lower fees than those published in this brochure. SSI reserves the right to amend or terminate this program at its discretion. Page 4 SSI has partnered with Synovus Bank, an SSI affiliate and Federal Deposit Insurance Corporation (“FDIC”) member bank, to offer certain advisory clients the option of sweeping free credit balances within the investment account to a Synovus Bank deposit account chosen as those clients’ core investment vehicle (the “Bank Sweep Program”). SSI receives an annual fee from Synovus Bank of $25 to $50 for each account participating in the Bank Sweep Program. Item 9 of this Wrap Program Brochure contains additional Synovus Securities, Inc. Disclosure Brochure – Appendix 1 information and important disclosures about the Bank Sweep Program. March 31, 2025 W14023V34 The SIS Program includes unregistered securities offerings of alternative investments such as private equity, private debt, and hedge funds. To invest in these offerings, you must meet the definition of an Accredited Investor or a Qualified Purchaser, depending on the specific offering. An investment in alternative assets entails a high degree of risk (including the possible loss of a substantial part, or even the entire amount, of an investment) and no assurance can be given that any alternative investment will achieve its objectives or that investors will receive a return of their capital. Further, such investments may not be subject to the same levels of regulatory scrutiny as publicly listed investments, and as a result, investors may have access to significantly less information than they can access with respect to publicly listed investments. Prospective investors should also note that investments in the products described typically involve long lock-ups and do not provide investors with liquidity. This Brochure is not intended to provide you with a full description of risks and considerations related to alternative investments offered through the SIS Program; rather, each alternative investment has its own offering memorandum which contains these and other important details. Reviewing the offering memorandum is essential before making an investment decision and you are strongly encouraged to discuss its contents with your Financial Advisor. SYNOVUS INVESTMENT STRATEGIES PROGRAM Separately Managed Account 1 SSI offers the Synovus Investment Strategies Program (“SIS Program”) through Envestnet Asset Management, Inc. (“Envestnet”). Envestnet is a registered investment adviser that operates a technology platform to assist SSI in providing a variety of managed account offerings, recommending asset allocations or specific investment managers and/or investment products to our clients. Envestnet is not affiliated with SSI. A complete description of the SIS Program and the services provided by Envestnet are outlined in Envestnet’s ADV Part 2, which you should read carefully. The following describes SSI’s offerings available through the SIS Program. SSI offers a Separately Managed Account Program through our relationship with Envestnet. This provides our clients with access to more than 1000 investment strategies available from over 100 portfolio managers selected by Envestnet through their due diligence and portfolio manager evaluation processes. The Separately Managed Account Program is designed to provide our clients the ability to tailor an investment portfolio to their specific financial needs such as diversification or tax-conscious investing, along with affording clients further customization of their portfolio by placing reasonable investment restrictions on the types of assets allowed within the account. Portfolio managers are recommended based on the client’s investment objectives as determined from the Client Risk Tolerance Questionnaire. Manager changes would be recommended if SSI’s or Envestnet’s due diligence reviews indicate the portfolio manager is no longer suitable for a particular investment strategy or if a client’s investment objectives change. The minimum account value for the Separately Managed Account Program varies based Mutual Fund & ETF Asset Allocation Wrap Strategies Program ("Strategist Program") upon the subadviser(s) chosen. SSI offers mutual fund and ETF asset allocation portfolios (“fund portfolios”) via the Envestnet platform. The Firm offers fund portfolios created by affiliated and unaffiliated investment advisers who directly manage the assets on or use one or more model portfolios created by one or more independent investment advisers (collectively “Strategist”). The Strategists available through SSI are first screened by Envestnet for inclusion on the Envestnet platform. From that pool, SSI then reviews and approves certain Strategists the Firm then makes available to our customers. A number of no load/load-waived mutual funds or exchange-traded funds from various fund families are available within the portfolios. An asset allocation model is selected based on each client’s risk score as determined by the Client Risk Tolerance Questionnaire (the “RTQ”). The client may modify the RTQ at any time by completing the requisite documentation with their adviser representative. After initial fund 1 Synovus Managed Account Solutions Platform ("MAS") prior to October 3, 2016 Page 5 Synovus Securities, Inc. Disclosure Brochure – Appendix 1 March 31, 2025 W14023V34 portfolio selection, the Strategists will make portfolio changes on a discretionary basis for their respective Advisor Directed Program models as deemed necessary or appropriate to maintain the agreed upon investment approach. SSI, through its licensed advisory representatives, provides asset management services to clients. The Advisor Directed Accounts are managed on an individualized basis. Clients have the option to assign investment discretion to SSI and select SSI investment advisory representatives (individually referred to as “Advisory Representative” and collectively “Advisory Representatives”) whom the firm has approved to offer discretionary services. Alternatively, clients can elect to have their account managed on a non-discretionary basis whereby the SSI Advisory Representative provides recommendations to the client, who has ultimate decision-making authority in determining whether to proceed with any recommendation. For clients electing to open a discretionary account, SSI, through selected Advisory Representatives, has full discretion to supervise, manage and direct the assets in the client’s account within the mandates of the client’s stated investment objectives, tolerance for risk, time horizon for investing the assets, and other suitability factors (collectively referred to as the “Client Investment Profile”) provided to SSI by the client during the account opening and/or review process. Clients participating in either the discretionary or non-discretionary offering are free to change or update their Client Investment Profiles at any time by contacting the Advisory Representative assigned to the account, and should do so whenever the information previously provided to SSI is no longer current or accurate. By providing written notice to the Firm, clients may elect to revoke the discretion granted to SSI and/or the Advisory Representative and opt to have their Advisor Directed accounts managed a non-discretionary basis. In such cases, the account will remain non-discretionary unless or until a client elects to grant discretion in writing to SSI and/or its Advisory Representative. SSI may use professional services of other third parties, including its affiliates, in servicing either discretionary or non-discretionary Advisor Directed Accounts. Clients working with SSI’s Advisory Representatives selected to offer discretionary Advisor Directed Accounts are limited to using only those investments approved by SSI’s Investment Policy Committee based upon research and recommendations made by SSI’s Investment Advisory Group. Investments and any strategy used are determined based upon the client’s responses and completion of the RTQ. Though not an exhaustive list, SSI primarily utilizes mutual funds, stocks, bonds, exchange-traded funds, cash or cash equivalents. On a limited basis, clients participating in the non-discretionary Advisor Directed Program may also utilize options within their portfolios, subject to additional suitability and investor experience criteria specific to investing in options. Finally, clients in either discretionary or non-discretionary offerings have the option to provide specific guidelines or impose reasonable restrictions on the management of the portfolio. For this reason, each portfolio’s investment results will differ, including those with similar investment objectives, and clients should not expect the performance of their portfolios will be identical with another client of SSI. The Unified Managed Account ("UMA") Program minimum account value for the Advisor Directed Account Program is $100,000. Through our relationship with Envestnet, SSI offers the Unified Managed Account (“UMA”) Program, which allows clients access to multiple investment strategies by using Separate Account Managers, mutual funds and/or ETFs, Strategists, model providers, and/or models provided by SSI to facilitate diversification within an individually managed account. The UMA program includes a Synovus-branded offering called Synovus Choice, offering access to a broad array of asset classes through use of mutual funds, ETFs, and/or Separate Account Managers. The fees associated with Synovus Choice are the same as SSI’s other UMA offerings and, importantly, SSI representatives do not receive any extra financial compensation for recommending the Synovus Choice UMA over any other UMA program offered by SSI. The SSI Representative will structure the account based upon the client’s stated goals and objectives as articulated through the RTQ. The minimum account value for the UMA Program is $100,000. Page 6 In conjunction with offering the Synovus Choice UMA, SSI receives access to Envestnet Fiduciary Solutions Program (“EFS”) free of charge. The EFS Program provides SSI additional access to research, watch lists, Synovus Securities, Inc. Disclosure Brochure – Appendix 1 March 31, 2025 W14023V34 alerts, Large Case Support, Overlay Services and other Envestnet investment-related intellectual capital. Without offering the Synovus Choice UMA, SSI would have to pay Envestnet for access to the EFS Program. This creates the potential for a conflict of interest because without offering the Synovus Choice UMA, SSI would incur extra cost for the research content available from the EFS Program. To mitigate potential conflicts, SSI’s cost-free access to the EFS Program is not contingent upon any minimum asset values in the Synovus Choice UMA program, nor are there any requirements to offer certain Separate Account Managers, mutual funds, ETFs, or any other products—including those proprietary to Envestnet or its affiliates. Furthermore, clients in the Synovus Choice UMA do not pay additional fees as compared to any other of SSI’s UMA offerings, nor do SSI representatives receive more compensation for asset within the Synovus Choice UMA over assets in SSI’s other UMA offerings. SSI’s access to the EFS Program content is intended to benefit the Firm’s customers by providing SSI associated persons additional research and investment information used in the management of client assets. SSI INDIVIDUALLY MANAGED ACCOUNT PROGRAM SSI provides asset management services to clients and manages each client’s account on an individualized basis. Accounts may be managed on a discretionary or non-discretionary basis, depending on the needs of the client. SSI may use professional services of other third parties, including its affiliates, in managing accounts. Investments are determined based upon the client's investment objectives, risk tolerance, net worth, net income and various other suitability factors. Clients may provide specific guidelines or impose reasonable restrictions on the management of the portfolio. For this reason, performance of portfolios, including those within the same investment objective, is likely to differ and clients should not expect that the performance of their portfolios will be identical with another client of SSI. SSI only accepts accounts that have a minimum asset value of $100,000. However, accounts with a lesser value may be accepted at SSI’s discretion. OUTSIDE MONEY MANAGER PROGRAM Synovus Securities, Inc. may refer customers to other investment advisers or portfolio managers outside of the various Programs listed above. SSI recommends the money management services of non-affiliated companies (“Managers”). Managers are recommended based upon the investment objectives of the client, but the ultimate decision to hire an outside manager is made by each client. SSI regularly monitors and reviews the services provided by the Manager and will recommend changes if the Manager is no longer suitable for a particular investment strategy or if a client’s investment objectives change. Clients participating in the Outside Money Manager Program complete customer investment profile information and/or questionnaires designed to identify their investment objectives and risk appetite. Each Manager imposes account minimums varying from $25,000 to $5,000,000. SSI will recommend managers for whom the client meets the minimum investment amount. SSI has no ability to waive the --------------------------------------------------- minimum account size imposed by any particular manager. Standard Program Fee Schedules SSI SYNOVUS INVESTMENT STRATEGIES Clients’ payments for advisory services contain three general components: (a) fees paid to SSI for investment advice and related services; (b) fees paid to the subadviser(s) managing the portfolio; (c) fees paid to Envestnet for use of their technology platform and administration of client accounts. The total cost to a client is the combination of these fee components and the following shows the maximum costs associated with each Separately Managed Account (SMA) Program program offered. Page 7 Synovus Investment Strategies SMA program fees are billed monthly in advance based on the prior month's ending market value. The annual rates are shown in the table that follows: Synovus Securities, Inc. Disclosure Brochure – Appendix 1 March 31, 2025 W14023V34 SYNOVUS INVESTMENT STRATEGIES SMA PROGRAM  Varies by subadviser chosen Amount paid to SSI 1.40% 1.30% 1.20% 1.10% Amount paid to subadviser(s)* 0.13% to 1.02% 0.13% to 1.02% 0.13% to 1.02% 0.13% to 1.02% Amount paid to Envestnet 0.17% 0.17% 0.17% 0.17% Asset Range first $500,000 next $500,000 next $1,000,000 Account Minimum† Amount over $2,000,000 *The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment.  SSI has compensation arrangements in place that provide more compensation to the Advisor than the amount paid to SSI listed above. The additional compensation will be paid by SSI. These compensation arrangements will not increase the amount paid by the client to SSI. † The minimums may be waived at the sole discretion of SSI and/or the program's money manager Advisor Directed Program and Mutual Fund/ETF Asset Allocation Wrap Strategies Program (“Strategist”) SYNOVUS INVESTMENT STRATEGIES-STRATEGIC ALLOCATION PROGRAM Synovus Investment Strategies Strategist program fees are billed monthly in advance based on the prior month's ending market value. The annual rates are shown in the table that follows:  Amount paid to SSI Amount paid to subadviser(s)* Amount paid to Envestnet Asset Range First $500,000 Next $500,000 Next $1,000,000 Account Minimum† Amount over $2,000,000 1.26% 1.16% 1.06% 0.96% 0.00% to 0.18% 0.00% to 0.18% 0.00% to 0.18% $50,000 0.00% to 0.18% 0.13% 0.13% 0.13% 0.13% SYNOVUS INVESTMENT STRATEGIES-TACTICAL ALLOCATION PROGRAM  $50,000 Asset Range First $500,000 Next $500,000 Next $1,000,000 Account Minimum† Amount over $2,000,000 Amount paid to SSI 1.30% 1.20% 1.10% 1.00% Amount paid to subadviser(s)* 0.25% to 0.35% 0.23% to 0.30% 0.20% to 0.25% 0.15% to 0.25% Amount paid to Envestnet 0.13% 0.13% 0.13% 0.13% SYNOVUS INVESTMENT STRATEGIES-FOUNDATIONS  Amount paid to Envestnet Amount paid to SSI Amount paid to subadviser Asset Range First $500,000 Next $1,500,000 Account Minimum† Amount over $2,000,000 0.10% 0.10% $15,000 0.10% 0.10% 0.10% 0.10% 1.15% 1.05% 0.95% SYNOVUS INVESTMENT STRATEGIES-ADVISOR DIRECTED PROGRAM ‡ Amount paid to SSI Amount paid to Envestnet 0.08% 0.08% 0.08% 0.08% Page 8 Asset Range 1.46% first $500,000 1.36% next $500,000 next $1,000,000 1.26% $100,000 Account Minimum† 1.16% Amount over $2,000,000 Synovus Securities, Inc. Disclosure Brochure – Appendix 1 March 31, 2025 W14023V34 *The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment. In addition to the amount paid to SSI for advisory services, clients also pay to SSI the portfolio construction fee which is reflected in the column titled Amount paid to SSI. This fee is like the amount paid by clients utilizing subadvisers to construct and manage portfolios. As a result, the portion of a ‡ client’s total fee paid to, and retained by SSI, is more than other Strategist programs since SSI does not have to pay a portion of the client fees to another subadviser. This presents a potential conflict of interest whereby the Advisor Directed Program is recommended over the other Wrap Strategist Allocation Programs. However, clients using the Advisor Directed Program may find their overall cost to be less than other Strategist programs depending on the management fee charged by the subadviser. Moreover, SSI does not receive additional compensation (e.g., revenue sharing) from the fund companies utilized within the Advisory Directed Program models. † The minimums may be waived at the sole discretion of SSI and/or the program's money manager. Unified Managed Account Program SYNOVUS INVESTMENT STRATEGIES-UMA PROGRAM Synovus Investment Strategies UMA program fees are billed monthly in advance based on the prior month's ending market value. The annual rates are shown in the table that follows:  Amount paid to SSI Amount paid to subadviser(s)* Amount paid to Envestnet Asset Range 1.40% 1.30% 1.20% 1.10% 0.15% to 0.67% 0.15% to 0.67% 0.15% to 0.67% $100,000 0.15% to 0.67% 0.12% 0.12% 0.12% 0.12% First $500,000 Next $500,000 Next $1,000,000 Account Minimum† Amount above $2,000,000 *The subadvisers used in these Programs charge varying fees as represented above. The fees’ variance is impacted by various factors such as, but not limited to, portfolio objective, securities used within the portfolio, sectors and/or geographic regions represented in the portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total percentage of fees a client will pay for their investment advisory account, inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment. SSI has compensation arrangements in place that provide more compensation to the Advisor than the amount paid to SSI listed above. The additional compensation will be paid by SSI. These compensation arrangements will not increase the amount paid by the client to SSI.† The minimums may be waived at the sole discretion of SSI and/or the program's money manager SSI INDIVIDUALLY MANAGED ACCOUNT AND OUTSIDE MONEY MANAGER PROGRAMS Depending on the money manager, fees are either billed monthly or quarterly in advance based on the prior month's/quarter’s ending market value. The annual rates are shown in the table that follows: INDIVIDUALLY MANAGED ACCOUNTS AND OUTSIDE MONEY MANAGER PROGRAM Asset Range Amount paid to SSI Amount paid to subadviser(s)* Amount paid for technology platform 1.40% 1.30% 1.20% 1.10% 0.30% to 1.00% 0.30% to 1.00% 0.30% to 1.00% Varies by subadviser chosen 0.30% to 1.00% None None None None first $500,000 next $500,000 next $1,000,000 Account Minimum† Amount over $2,000,000 *The subadvisers used in the Separately Managed Account Program charge varying fees as represented above. The fees’ variance is impacted by a variety of factors such as, but not limited to, portfolio objective, securities used within the portfolio, and sectors or geographic region represented in the portfolios’ holdings. SSI does not set the amount charged by subadvisers. The total amount a client will pay for their investment advisory account, inclusive of the specific subadvisory fees, are provided to clients no later than at the time of each account’s establishment. †The minimums may be waived at the sole discretion of SSI and/or the money manager. Page 9 Synovus Securities, Inc. Disclosure Brochure – Appendix 1 March 31, 2025 W14023V34 Item 5 – Account Requirements and Types of Clients SSI generally provides services to individuals, high net worth individuals, banks or thrift institutions, pension and profit sharing plans, corporations, and trusts, estates and charitable organizations. Each investment Program offered by SSI imposes an account minimum in order to be eligible for the Program. SSI, in its sole discretion, may waive the minimum asset size for any of its investment Programs. However, to the extent that the client does not meet the minimums imposed by a portfolio manager or program sponsor, SSI may not have the ability to waive those requirements. SSI provides offerings to investors seeking to roll over balances held in employer-sponsored retirement plans (often referred to as a “rollover”). Individuals with investments in a former employer’s retirement plan generally have five options for those assets: (1) Leave the investments in that plan, (2) roll the assets into his/her new employer’s plan, (3) rollover the money to an Individual Retirement Account, (4) liquidate the investments and cash out the money, or (5) some combination of the previous four options. Each option presents different considerations—including tax implications— and no one solution is right for every investor. We encourage you to talk with your adviser about these options and to consult with a tax professional regarding the potential impacts each of the options may have to your specific situation. SSI has an economic incentive to recommend a rollover because assets rolled into one of our advisory programs will generate investment management fees. In discussing and evaluating your options, it is important you know you are under no obligation to rollover assets to us. Item 6 – Portfolio Manager Selection and Evaluation Information about minimum account size requirements for each Program can be found in Item 4. Managers are selected for each client based on the specific needs of each client. Clients provide information which is used to determine their risk tolerance, time horizon, asset allocation and overall investment objectives. SSI offers advisory services through the Programs described in Item 4 of this Brochure. The Programs involve the selection of investment models or separate account managers based on the assessment of each client’s investment goals and objectives. SSI has implemented a due diligence process to review various facets of the manager’s business, such as investment style, performance, portfolio management, trading and operations, and compliance. With respect to the SIS Program described earlier in this Brochure, SSI employs use of both internal and external resources as part of the due diligence process. Envestnet, as part of the services they perform for SSI, conduct reviews of prospective and current money managers approved for inclusion on the platform used for the SIS Program. SSI leverages the research and assessment Envestnet performs of third-party money managers for the following SIS offerings: • • • Separately Managed Account Program; Strategist Program; and, Unified Managed Account Program. Details concerning these program offerings are found under Item 4 of this Brochure. Page 10 SSI’s Investment Advisory Group researches and evaluates prospective and current money managers and/or investment model providers utilized via the SIS Program, primarily in connection with the Advisor Directed offering, as described in Item 4 of this brochure. Information, reviews and recommendations prepared by SSI’s Investment Advisory Group are supplied to SSI’s Due Diligence Committee, who has final authority to add or remove a money manager or investment model provider from the Firm’s offerings. The composition and asset allocation of each client portfolio may differ depending on a variety of factors, including client specific investment goals, risk tolerance, and overall economic and market conditions. While not the primary focus of the SSI Investment Advisory Group, team personnel may from time to time also perform due diligence reviews of other SIS Platform money managers previously reviewed by Envestnet to gain additional perspective and Synovus Securities, Inc. Disclosure Brochure – Appendix 1 information in support of SSI’s general oversight efforts of the Firm’s selected advisory partners. March 31, 2025 W14023V34 Depending on the Program selected, performance information may be prepared by the individual managers and may not be calculated on a uniform and consistent basis. Performance calculations have not been Item 7 – Client Information Provided to Portfolio Managers reviewed by any third party to confirm its accuracy. When a client selects a portfolio manager, the client provides information which is used to determine their risk tolerance, time horizon, asset allocation and overall investment objectives. From that data, SSI provides the portfolio manager with relevant personal information about the client (i.e. name, address and other identifying information) as well as certain financial information to provide evidence that the manager’s investment strategy suits the client’s needs. Information is provided to the portfolio manager initially when the manager is selected and updated subsequently when there are any material changes to the client’s Item 8 – Client Contact with Portfolio Managers information. Client relationships are managed by SSI Representatives. Third party managers are not directly accessible to SSI clients. However, at a client’s request, SSI will make an attempt to arrange a conference call with the third party manager. Item 9 – Additional Information Disciplinary Information Synovus Securities, Inc. is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of SSI or the integrity of SSI’s management. SSI does not have any Other Financial Industry Activities and Affiliations disciplinary events to disclose. SSI is also a broker-dealer registered with the Securities and Exchange Commission, FINRA and various state regulatory agencies. In this capacity, SSI is involved in the sale of various types of securities, such as stock, bonds, and mutual funds. Employees providing investment advisory services to clients are also registered representatives and are able to affect securities transactions on behalf of clients. Clients may maintain SSI brokerage accounts that are not advisory accounts. In these accounts, SSI Representatives are compensated based on commissions or other fees paid by the client as a result of the purchase or sale of an investment product. This may represent a conflict of interest when determining recommendations for the client, as there is an incentive to recommend investment products based on the compensation received rather than on the client’s needs. Brokerage services are offered to clients generally on a non-discretionary basis. Except in rare instances whereby a customer has granted an SSI representative written discretionary authority, transactions are approved by the client in advance and clients receive trade confirmations inclusive of the commissions charged. Moreover, representatives of SSI do not receive separate commissions on advisory accounts. Likewise, advisory fees are not charged on non-advisory brokerage accounts. SSI recognizes that a potential conflict exists when SSI offers both brokerage services and investment advisory services to its clients. SSI requires its Representatives, when offering both types of services, to explain the different services and identify the capacity in which they are acting when making recommendations. Page 11 SSI is a licensed insurance company in all five of the Firm’s footprint states including Georgia, Florida, Alabama, South Carolina, Tennessee and various other states outside the company’s brick and mortar locations in the aforementioned footprint states. Additionally, SSI has affiliations with other insurance companies in those states. Individuals of SSI may also be licensed insurance agents. To the extent that a representative of SSI recommends insurance products and services, SSI and/or the representative will receive commissions on the sale of those products. These commissions are paid directly from the insurance company underwriting the insurance policy and are not paid separately by the client. In addition, SSI may receive additional compensation from one or more of its insurance partners upon meeting a pre-determined level of business Synovus Securities, Inc. Disclosure Brochure – Appendix 1 production with the carrier(s). March 31, 2025 W14023V34 SSI also offers investment advisory services under a separate division, known as Creative Financial Group (CFG). Advisory services offered through CFG are substantially different than the services offered through SSI’s wrap programs. CFG’s business practices are described in a separate Brochure (available upon request). SSI is a wholly owned subsidiary of Synovus Financial Corp. a publicly traded financial services company and a registered bank holding company headquartered in Columbus, Georgia. Synovus provides integrated financial services including commercial and retail banking, financial management, insurance and mortgage services to its customers through Synovus Bank. SSI is under common control with the following entities that have material business arrangements with SSI. Certain employees, directors and members of SSI’s executive management may also serve as employees, directors and/or executive management of these entities: Synovus Trust Company, N.A. (a National Trust Company) 33 West 14th Street Columbus, Georgia 31901 Synovus Bank (a Georgia state chartered bank) 33 West 14th Street Columbus, Georgia 31901 In limited circumstances advisory clients may utilize the custody services of Synovus Trust Company. These arrangements are usually initiated by the trust company. As a general practice, SSI does not refer advisory clients to Synovus Trust Company for custody services. In the normal course of its business, SSI Representatives may refer clients that are in need of Trust services to Synovus Trust Company. SSI is compensated for such referrals and such compensation is shared with the Representative. Neither SSI nor its Representatives provide additional advisory services to the client. In coordination with NFS, SSI also offers to brokerage and investment advisory customers the participation in the Bank Sweep Program as their core investment vehicle, subject to the exclusions noted under Item 10 of this Brochure. Participants in the program have free credit balances within their brokerage/investment advisory account automatically swept to an interest bearing bank deposit account at Synovus Bank, a Federal Deposit Insurance Corporation (“FDIC”) member bank and SSI affiliate. Client balances swept into a deposit account at Synovus Bank are eligible for FDIC insurance coverage up to $250,000 per depositor in each insurable capacity. Examples of separate insurable capacities include the following non-exhaustive list: individual accounts, joint accounts, certain trust arrangements, etc. However, a client’s cash balance in the Bank Sweep Program is subject to aggregation with other deposit assets the client has at Synovus Bank outside of the Bank Sweep Program. Neither SSI nor Synovus Bank will monitor the aggregate amount of deposits a client has with Synovus Bank either directly or through participation in the Bank Sweep Program to determine the extent of deposit insurance coverage available at any time for program participants. Therefore, each client participating in the Bank Sweep Program is responsible for monitoring the aggregate total of deposited assets and determining the extent of deposit insurance applicable to the client’s deposits. Page 12 Through the Bank Sweep Program arrangement, SSI and its affiliates benefit financially. Synovus Bank earns net income from the difference in interest paid to the Bank Sweep Program participants for balances held in their core investment accounts and income received from new lending or investment activity derived from the program deposits (referred to as “spread”). As with any depository institution, Synovus Bank’s income increases when the spread between interest paid and income received widens. Synovus Bank has no obligation to base its interest payments to the Bank Sweep Program participants on the profitability of the income generated from the spread. In addition, SSI receives from Synovus Bank an annual fee ranging from $25 to $50 for each account participating in the Bank Sweep Program. Together, these financial benefits to SSI and its affiliates create a conflict of interest as accounts participating in the program may be more profitable to Synovus than those who do not participate. To address this conflict, clients may decline participation in the Bank Sweep Program and SSI offers alternative choices for core investment vehicles for free credit balances. In addition, SSI excludes eligibility from the Bank Sweep Program any ERISA plan accounts (e.g., 401(k), Pension Plans, Profit Sharing Plans, and Money Purchase Plans, etc.) and any foreign Synovus Securities, Inc. Disclosure Brochure – Appendix 1 domiciled account. Lastly, at the time of account opening, or election into the program, clients eligible for March 31, 2025 W14023V34 participation in the Bank Sweep Program are provided with important disclosure documents and agreements containing further details. These documents may be obtained at any time free of charge upon the request of current or prospective clients. In such instances, clients are exposed to unique risks not otherwise inherent to From time to time, clients may elect to use margin lending or pledge assets held in their advisory accounts as this strategy is not suitable for everyone their advisory accounts and collateral for a loan. . Before a client decides to use margin lending or pledge their advisory assets as collateral for a loan, care must be given to consider the • following: • Changes in market conditions could impact your account at any time and affect the value of the securities in your account to establish and maintain margin or pledged as collateral. Should the value of your assets fall below the amount of your loan or margin maintenance requirement, you may be unable to draw upon your account, pledged securities may need to be sold for less than the original price you paid, and/or other appropriate steps may need to be taken to ensure you can still meet your obligation to your margin lender (NFS) or Synovus. • If you are required to sell some of the margined or pledged securities, any long-term investment strategies and goals may be impacted. Therefore, it is important you discuss with your advisory representative your investment goals, objectives, risk tolerance, strategies and time horizon concerning any advisory account in which you employ margin or pledge as collateral. . • Should loan repayment terms not be met, the lender may instruct us to sell some or all margined or pledged securities as payment against the loan. In this instance, you are not able to choose which securities are liquidated. You would also be responsible for any shortfall in the loan after such sale. It is essential that you carefully review the provisions outlined in your loan agreement and the corresponding collateral control agreement, as it contains details such as who has trading authority, amongst other important information • SSI is not a tax advisor. We encouraged you to discuss with your tax professionals the implications of using margin or pledging securities as collateral. • SSI is an affiliate of Synovus Bank (the “Bank”), and both are subsidiaries of Synovus Financial Corp. By establishing an investment advisory account used to collateralize a loan, you will be responsible for paying to SSI any advisory/management fees, and any other fees as outlined in Item 5 of this Brochure, in addition to paying to the Bank any interest, fees, or other agreed upon expenses. Your SSI advisory representative may also be a dual employee of the Bank, and your Bank loan officer may also be an advisory representative of SSI. SSI advisory representatives and/or the Bank’s loan officers may receive incentive compensation relating to loans and advisory accounts used as collateral. There is no guarantee that returns of any advisory account will meet or exceed your loan costs. Carefully consider the interest rate and repayment terms of the loan before making a final decision. As part of its relationship with NFS, SSI’s clients have access to margin lending financed through NFS. Clients must apply and qualify for this additional service. Use of margin introduces additional risks and it not a strategy suitable for everyone. These special risks are covered in more detail under Item 8 of this brochure. Moreover, clients electing the use of margin will be subject to interest charges on any amount borrowed. The interest paid by the investor is in addition to the asset management fees paid. SSI receives from NFS a portion of the margin interest paid by investors. This creates a conflict of interest whereby SSI receives an economic benefit from both margin interest and the asset management fees charged. SSI mitigates this conflict by limiting the use of margin within advisory accounts to only a select number of overlay programs that employ the use of option securities and further limits the availability of such programs to investors meeting eligibility requirements such as a high liquid net worth and investible assets. Margin borrowing is not allowed in advisory accounts outside of these select overlay programs. Page 13 Synovus Securities, Inc. Disclosure Brochure – Appendix 1 March 31, 2025 W14023V34 Code of Ethics SSI’s Code of Ethics (the “Code”) sets forth a professional business standard to guide SSI and its employees to place our clients’ interests before our own. No SSI associated person shall prefer his or her own interest to that of the advisory client. SSI requires its associated persons to act in accordance with applicable federal, state and regulatory agency regulations governing investment advisory practices. The standards of conduct outline our fiduciary responsibilities and the Code includes our policies related to insider trading, personal securities transactions, privacy of client information and reporting requirements. SSI’s employees may purchase and sell securities for their own accounts that have also been recommended to clients. The Code is designed to prevent personal securities transactions and interests of SSI employees from interfering with making decisions in the best interest of clients. Nonetheless, because the Code permits employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client. Certain security types, such as Initial Public Offerings and Private Placements, may be prohibited or subject to a pre-clearance requirement. SSI’s associated persons are required to provide a quarterly report to the Firm’s Compliance Department showing investment transactions in their personal accounts, as well as disclosing annually all securities held on their behalf. Governing regulations provide that certain securities are exempt from this reporting requirement based upon the determination such securities would not pose any material conflicts. These reports are monitored regularly in an effort to reasonably prevent conflicts of interest between SSI and its clients. Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting SSI’s Chief Compliance Officer, Gene Gunderson, at 706-644-0298. Participation or Interest in Client Transactions SSI or its associated persons may engage in principal transactions and/or agency cross transactions, subject to Section 206(3) of the Investment Advisers Act of 1940. In accordance with the regulation, SSI will disclose the capacity in which it acted and will obtain client consent from both parties involved in the transaction prior to the trade settlement date. These disclosures and consents are required to make all necessary facts known and to alert clients to SSI’s potential conflicts of interest in a principal, riskless principal, or agency cross transaction. Review of Accounts New accounts are reviewed by an SSI Designated Principal to ensure all information is in order and documentation is complete. SSI Representatives provide a regular review of client accounts, the frequency of which is determined based upon the client’s preferences and expectations. Nonetheless, SSI Representatives are expected to initiate contact with clients at least annually in order to confirm the accuracy of information regarding the client’s financial situation and the investment objective(s) of an account. Clients receive account statements and transaction confirmations directly from the account custodian usually monthly, but not less than quarterly. Clients may request quarterly reports from SSI providing such information as asset allocation and account performance data. Depending on the Program selected, performance information is prepared by the individual managers and may not be calculated on a uniform and Client Referral and Other Compensation consistent basis. Page 14 SSI and its representatives do not receive any economic benefits from any third party with respect to the advisory services offered to clients other than the fees described in this Brochure. Product sponsors, mutual fund companies or other third parties may offer SSI Representatives invitations to training sessions, due diligence visits or other meeting or events at the expense of the third party. These invitations are not offered directly as a result of any amount of business placed with the third party, but the volume of business placed with a particular sponsor may be indirectly related. Synovus Securities, Inc. Disclosure Brochure – Appendix 1 March 31, 2025 W14023V34 Envestnet may reduce its fees to SSI upon SSI reaching certain levels of assets under management in its various programs. Therefore, SSI may have a financial incentive to recommend this program over other Programs or services. SSI entered into a promotional agreement (the “agreement”) with GLOBALT, an unaffiliated investment adviser, on a limited basis. Pursuant to this agreement, representatives of SSI can refer clients directly to GLOBALT and receive a referral fee. The fee paid to SSI by GLOBALT is a percentage of the advisory fee GLOBALT collects from the referred client. The client does not pay a higher fee as a result of the referral; rather, GLOBALT shares with SSI a percentage of the fee they receive from the client. The client enters into an investment advisory agreement directly with GLOBALT. SSI or its representative provides no additional advisory services to the client. SSI has entered into promotional agreements with various unaffiliated third-party professionals such as attorneys, certified public accountants, or investment advisers (collectively “promotors”). The promotors can refer clients to SSI and receive a referral fee. SSI pays a percentage of its fees collected from advisory clients to the promotor who originated the client referral. The client does not pay a higher fee as a result of the referral, however. The client enters into an investment advisory agreement directly with SSI. Any other financial services provided by these promotors to clients are separate from their promotional arrangement with SSI, and neither SSI nor its representatives make any claim or warranty regarding such services. The promotors have a financial incentive to promote the advisory services provided by SSI, creating a conflict of interest whereby the advisory services SSI provides are recommended over those offered by other investment advisers. Investors should independently evaluate the advisory offerings of competing firms before engaging SSI as a result of a promotor’s recommendation. Synovus Bank makes investment products available to its customers, including the advisory services offered by SSI and revenues generated and/or expenses occurred may be shared between the affiliated companies. Nevertheless, SSI’s advisory clients do not pay a higher fee as a result of these revenue sharing or expense arrangements. Conversely, SSI Representatives may refer clients to Synovus Bank for banking services. Synovus Bank may, at its discretion, pay an incentive to SSI and/or its Representatives for referrals made for banking services. Notwithstanding referral incentive programs, if any, sponsored by Synovus Bank, SSI customers are under no obligation to utilize Synovus Bank for any banking services, and the establishment of an advisory relationship with SSI is not contingent upon a client opening or maintaining a banking relationship with Synovus Bank. In the normal course of its business, SSI Representatives may refer clients that are in need of Trust services to Synovus Trust Company. SSI is compensated for these referrals and such compensation is shared with the Financial Information Representative. Neither SSI nor its Representatives provide additional advisory services to the client. Synovus Securities, Inc. is required to provide you with certain financial information or disclosures about its financial condition. SSI has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. (space intentionally blank) Page 15 Synovus Securities, Inc. Disclosure Brochure – Appendix 1 March 31, 2025 W14023V34