Common use of PORTFOLIO MANAGER SELECTION AND EVALUATION Clause in Contracts

PORTFOLIO MANAGER SELECTION AND EVALUATION. ‌ In PWP, LPL and IAR are responsible for the overall investment advice and management services offered to clients, and the client selects the IAR who manages the account. LPL generally requires that individuals involved in determining or giving investment advice have at least 2 years financial planning, advisory or brokerage-related experience. Each IAR is also generally required to possess a FINRA Series 6, 7, 62, 65, or 66 license (to the extent required). For more information about the IAR managing the account, client should refer to the Brochure Supplement for the IAR available from the IAR. LPL makes available Models designed by PWP Advisors. LPL selects and reviews on an ongoing basis the PWP Advisors available on PWP based on quantitative, qualitative and infrastructure criteria, which include: Quantitative Criteria LPL evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style group, including but not limited to: • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP Advisor can handle operational requirements including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable • Back office review • Client servicing resources • Firm-wide program commitment LPL reviews PWP Advisors currently participating in the program and reviews new PWP Advisors prior to the addition of their Models to the program. LPL may elect to remove a PWP Advisor should it determine that the PWP Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in management staff). In making a decision to remove a PWP Advisor, LPL’s Research Department takes into consideration all criteria; no one criteria is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove a PWP Advisor. PWP Advisor Performance LPL’s Research Department uses information provided by the PWP Advisor and also may use independent, third party databases when evaluating a PWP Advisor. In order for a PWP Advisor to be selected for the program, LPL generally requires a third party verification letter related to compliance of the PWP Advisor’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performance. However, LPL provides clients with individual quarterly performance information. Performance information distributed by LPL is compiled using third party portfolio accounting and reporting software. Client performance information is calculated by LPL on a uniform and consistent basis using a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that PWP Advisors provide Models to LPL, and, except in the case of Muni Models, LPL is the party with discretion for trade implementation and execution in PWP accounts. Therefore, Models submitted to LPL by PWP Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisor. Because of this fact and because LPL (and not the PWP Advisor) has discretionary authority to implement trades, performance of a PWP account will differ from the performance of PWP Advisor’s discretionary accounts. LPL Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL’s Research Department. LPL’s Research Department provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap program, Manager Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The IAR selects the Portfolio and provides advice based on the client’s individual needs. LPL’s Research Department uses various investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL’s Research Department determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the IAR of the change in status and provide alternatives for the account from which the IAR will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. Types of Investments and Risks The Portfolios include different types of securities, such as mutual funds, closed end funds, ETFs and ETNs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. • Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Issuer‐Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed.

PORTFOLIO MANAGER SELECTION AND EVALUATION. ‌ In PWPthe Platforms, LPL and IAR are responsible for the overall investment advice advisory services related to the selection and management services offered to clients, retention of the SMA Portfolio Manager (in the case of the SMA Platform) and Model Advisor (in the case of the MP Platform). The client selects the IAR who manages services the account. LPL generally requires that individuals involved in determining or giving investment advice have at least 2 two years financial planning, advisory or brokerage-related experience. Each IAR is also generally required to possess a FINRA Series 6, 7, 62, 65, or 66 license (to the extent required). For more information about the IAR managing servicing the account, client should refer to the Brochure Supplement for the IAR available from the IAR. LPL makes available Models designed by PWP Advisorsthe advisory services of SMA Portfolio Managers. LPL does not act as a portfolio manager for the SMA Platform. LPL does, however, act as portfolio manager for the MP Platform. Criteria for Participating and Recommended SMA Portfolio Managers and Model Advisors LPL selects and reviews on an ongoing basis SMA Portfolio Managers and Model Advisors for the PWP Advisors available on PWP Platforms based on quantitative, qualitative and infrastructure criteria, which include: include the criteria listed below. Quantitative Criteria LPL Research evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style groupcriteria, including but not limited to: • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP SMA Portfolio Manager or Model Advisor can handle operational requirements requirements, including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable policy • Back office review • Client servicing resources • Firm-wide program commitment Additional Criteria for Recommended Managers or Model Advisors SMA Portfolio Managers or Model Advisors that are “Recommended” by LPL reviews PWP Research are subject to a more rigorous selection and review process than the criteria set out above that applies to all SMA Portfolio Managers and Model Advisors currently participating available in the program and reviews new PWP Advisors prior to the addition of their Models to the program. In addition to the criteria noted above, additional evaluation criteria for Recommended SMA Portfolio Managers or Model Advisors include: • Sound investment philosophy and process that drives performance • Consistency of returns and risk • Qualitative assessment of the investment manager and team Clients should speak to the IAR regarding whether the SMA Portfolio Manager or Model Advisor being considered for selection or that has been selected by the client is Recommended or Participating. LPL as a Model Advisor Clients may invest in Model Portfolios designed by LPL’s Research Department (“LPL Research”). It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Model Portfolios to meet different investor needs. LPL Research Model Portfolios are built by seeking certain quantitative characteristics for each portfolio. LPL Research has built three large-cap-oriented Model Portfolios, which have holdings that are constituents of the S&P 500 Index. One is designed to have index-like representation to reasonably track large cap index returns. Another is designed with a dividend focus in mind, to have index-like representation, but seeking a yield premium over the large cap index. The third Model Portfolio is designed to allocate to companies that have had substantial insider buying, but have not experienced significant stock price appreciation. The LPL Research Model Portfolios are managed tactically, which means they are flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of trading as frequently as monthly. The participation of LPL’s Research Department as a Model Advisor under the MP Platform also gives rise to potential conflicts of interests because LPL has a financial incentive to select its internal team and further grow its assets under management. Although LPL does not charge a separate fee for its services as Model Advisor, as assets under management at LPL increase, the firm is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. In addition, because LPL does not charge a fee for its services as Model Advisor, LPL and IAR have a financial benefit if IAR recommends a Model Portfolio designed by LPL Research, because LPL and IAR will retain a greater portion of the Account Fee than if a Model Portfolio designed by an unaffiliated Model Advisor or if a SMA Portfolio Manager is selected. Removal of a SMA Portfolio Manager or Model Advisor LPL may elect to remove or replace a PWP SMA Portfolio Manager or Model Advisor should it determine that the PWP Advisor firm has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in if the SMA Portfolio Manager or Model Advisor has failed to maintain sufficient assets under management staff)at LPL to maintain profitability on the SMA Platform. In making a decision to remove or replace a PWP SMA Portfolio Manager or Model Advisor, LPL’s Research Department LPL takes into consideration all criteria; no one criteria criteria, other than the maintenance of assets under management at LPL, is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove or replace a PWP SMA Portfolio Manager or Model Advisor. PWP Advisor While LPL would have the authority to remove the LPL Research Department as a Model Advisor, it is unlikely to do so. Portfolio Manager Performance LPL’s Research Department uses information provided by the PWP Advisor portfolio manager and may also may use independent, third party databases when evaluating a PWP SMA Portfolio Manager or Model Advisor. In order for a PWP SMA Portfolio Manager or Model Advisor to be selected for the programPlatforms, LPL Research generally requires a third party verification letter related to compliance of the PWP Advisorfirm’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP This requirement may be waived by LPL for various reasons including alternative methods of verifying the experience and/or performance of the SMA Portfolio Manager or Model Advisor. SMA Portfolio Manager and Model Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performancethe performance record of the SMA Portfolio Manager or Model Advisor. However, LPL provides clients with individual quarterly performance information. Performance information distributed by LPL is compiled using third party portfolio accounting and reporting software. Client performance information is calculated by LPL reported on a uniform and consistent basis using a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that PWP third-party Model Advisors provide Models Model Portfolios to LPL, and, except in the case of Muni Models, and it is LPL is the party with that has discretion for trade implementation and execution in PWP MP Platform accounts. Therefore, Models Model Portfolios submitted to LPL by PWP third-party Model Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisorsuch Model Advisors. Because of this fact and because LPL (and not the PWP third-party Model Advisor) has discretionary authority to implement trades, performance of a PWP an MP Platform account will differ from and may be worse than the performance of PWP such Model Advisor’s discretionary accounts. LPL Investment Strategies Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL’s Research Department. LPL’s Research Department provides various types of managers provide advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap program, Manager Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The IAR selects the Portfolio and provides advice services based on the client’s individual needs. LPL’s Research Department uses various following types of investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time framestrategies. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL’s Research Department determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the IAR of the change in status and provide alternatives for the account from which the IAR will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. All Cap Core Global Equity Large Cap Value Small Cap Blend All Cap Growth Growth Equity Mid Cap Core Small Cap Growth All Cap Value Income Preferred Mid Cap Growth Small Cap Value Balanced Large Cap Core Mid Cap Value Tax Free Fixed Income Convertibles Large Cap Foreign REIT Taxable Fixed Income Global Balanced Large Cap Growth Sector Types of Investments and Risks The Portfolios include In the Platforms, SMA Portfolio Managers (in the case of the SMA Platform) or LPL (in the case of the MP Platform) invest in many different types of securities, such as including equities, fixed-income securities, options, mutual funds, closed end funds, ETFs funds and ETNsETFs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. • Interest Rate Risk. This is the risk that fixed fixed-income securities will decline in value because of an increase in interest rates; a bond or a fixed fixed-income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed fixed-income security is unable or unwilling to meet its financial obligations. • Issuer‐Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed.

PORTFOLIO MANAGER SELECTION AND EVALUATION. ‌ In PWPManager Access Select, LPL and IAR are Advisor is responsible for the overall investment advice advisory services related to the selection and management services offered to clients, retention of the SMA Portfolio Manager (in the case of the SMA Platform) and selection of the Model Portfolio (in the case of the MP Platform). The client selects the IAR Advisor who manages services the account. LPL generally requires that individuals involved in determining or giving investment advice have at least 2 years financial planning, advisory or brokerage-related experience. Each IAR is also generally required to possess a FINRA Series 6, 7, 62, 65, or 66 license (to the extent required). For more information about the IAR managing Advisor servicing the account, client should refer to Advisor’s Firm Brochure, which client should have received from Advisor at the Brochure Supplement for time client opened the IAR available from the IARaccount. LPL makes available Models designed by PWP Advisorsthe advisory services of SMA Portfolio Managers. LPL does not act as a portfolio manager for the SMA Platform. LPL does, however, act as portfolio manager for the MP Platform. Criteria for Participating and Recommended SMA Portfolio Managers and Model Advisors LPL selects and reviews on an ongoing basis SMA Portfolio Managers and Model Advisors for the PWP Advisors available on PWP program based on quantitative, qualitative and infrastructure criteria, which include: may include the criteria listed below. Quantitative Criteria LPL Research evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style groupcriteria, including but not limited to: • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP an SMA Portfolio Manager or Model Advisor can handle operational requirements requirements, including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable policy • Back office review • Client servicing resources • Firm-wide program commitment Additional Criteria for Recommended SMA Managers or Model Advisors SMA Portfolio Managers and Model Advisors that are “Recommended” by LPL reviews PWP Research are subject to a more rigorous selection and review process than the criteria set out above that applies to all SMA Portfolio Managers and Model Advisors currently participating available in the program and reviews new PWP Advisors prior to the addition of their Models to the program. In addition to the criteria noted above, additional evaluation criteria for Recommended SMA Portfolio Managers and Model Advisors include: • Sound investment philosophy and process that drives performance • Consistency of returns and risk • Qualitative assessment of the investment manager and team Clients should speak to Advisor regarding whether the SMA Portfolio Manager or Model Advisor being considered for selection or that has been selected by the client is Recommended or Participating. LPL as a Model Advisor Clients may invest in Model Portfolios designed by LPL Research. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Model Portfolios to meet different investor needs. LPL Research Model Portfolios are built by seeking certain quantitative characteristics for each portfolio. LPL Research has built three large-cap-oriented Model Portfolios, which have holdings that are constituents of the S&P 500 Index. One is designed to have index-like representation to reasonably track large cap index returns. Another is designed with a dividend focus in mind, to have index-like representation, but seeking a yield premium over the large cap index. The third Model Portfolio is designed to allocate to companies that have had substantial insider buying, but have not experienced significant stock price appreciation. The LPL Research Model Portfolios are managed tactically, which means they are flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of trading as frequently as monthly. The participation of LPL’s Research Department as a Model Advisor under the MP Platform also gives rise to conflicts of interests because LPL has a financial incentive to select its internal team and further grow its assets under management. Although LPL does not charge a separate fee for its services as Model Advisor, as assets under management at LPL increase, the firm is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. In addition, because LPL does not charge a fee for its services as Model Advisor, LPL and Advisor have a financial benefit if Advisor recommends a Model Portfolio designed by LPL Research, because LPL and Advisor will retain a greater portion of the Account Fee than if a Model Portfolio designed by an unaffiliated Model Advisor or if a SMA Portfolio Manager is selected. Removal of a SMA Portfolio Manager or Model Advisor LPL may elect to remove or replace a PWP SMA Portfolio Manager or Model Advisor should it determine that the PWP SMA Portfolio Manager or Model Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in if the SMA Portfolio Manager or Model Advisor has failed to maintain sufficient assets under management staff)at LPL to maintain profitability on the Manager Access Select platform. In making a decision to remove or replace a PWP SMA Portfolio Manager or Model Advisor, LPL’s Research Department LPL takes into consideration all criteria; no one criteria criteria, other than the maintenance of assets under management at LPL, is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove or replace a PWP SMA Portfolio Manager or Model Advisor. PWP While LPL would have the authority to remove LPL Research as a Model Advisor, it is unlikely to do so. SMA Portfolio Manager and Model Advisor Performance LPL’s Research Department uses information provided by the PWP SMA Portfolio Manager or Model Advisor and may also may use independent, third party databases when evaluating a PWP an SMA Portfolio Manager or Model Advisor. In order for a PWP SMA Portfolio Manager or Model Advisor to be selected for the program, LPL Research generally requires a third party verification letter related to compliance of the PWP Advisor’s performance information of the SMA Portfolio Manager or Model Advisor with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor This requirement may be waived by LPL for various reasons including alternative methods of verifying the experience and/or performance of the SMA Portfolio Manager or Model Advisor. Performance information used by SMA Portfolio Managers and Model Advisors is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performancethe performance record of SMA Portfolio Managers or Model Advisors. However, LPL provides clients with clients, if so directed by Advisor, individual quarterly performance information. Performance information distributed is prepared by LPL is compiled using third party portfolio accounting and performance reporting software. Client performance information is calculated by LPL reported on a uniform and consistent basis using a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that PWP third-party Model Advisors provide Models Model Portfolios to LPL, and, except in the case of Muni Models, and it is LPL is the party with that has discretion for trade implementation and execution in PWP MP Platform accounts. Therefore, Models Model Portfolios submitted to LPL by PWP third-party Model Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisorsuch Model Advisors. Because of this fact and because LPL (and not the PWP third-party Model Advisor) has discretionary authority to implement trades, performance of a PWP an MP Platform account will differ from and may be worse than the performance of PWP such Model Advisor’s discretionary accounts. LPL Investment Strategies SMA Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL’s Research Department. LPL’s Research Department provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios Managers and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap program, Manager Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The IAR selects the Portfolio and provides advice Advisors may provide advisory services based on the client’s individual needs. LPL’s Research Department uses various following types of investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time framestrategies. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL’s Research Department determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the IAR of the change in status and provide alternatives for the account from which the IAR will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. All Cap Core Global Equity Large Cap Value Small Cap Blend All Cap Growth Growth Equity Mid Cap Core Small Cap Growth All Cap Value Income Preferred Mid Cap Growth Small Cap Value Balanced Large Cap Core Mid Cap Value Tax Free Fixed Income Convertibles Large Cap Foreign REIT Taxable Fixed Income Global Balanced Large Cap Growth Sector Types of Investments and Risks The Portfolios include In the Platforms, SMA Portfolio Managers (in the case of the SMA Platform) or LPL (in the case of the MP Platform) invest in many different types of securities, such as including equities, fixed-income securities, options, mutual funds, closed end funds, ETFs funds and ETNsETFs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. • Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Issuer‐Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed.

PORTFOLIO MANAGER SELECTION AND EVALUATION. ‌ In PWP, LPL and IAR Advisor are responsible for the overall investment advice and management services offered to clients, and the client selects the IAR Advisor who manages services the account. LPL generally requires that individuals involved in Advisor is responsible for determining or giving investment advice have at least 2 years financial planning, advisory or brokerage-related experience. Each IAR is also generally the standards required to possess a FINRA Series 6, 7, 62, 65, or 66 license (to the extent required)for its associated persons. For more information about the IAR managing the accountAdvisor, client should refer to the Brochure Supplement for Advisor’s Firm Brochure, which client should have received at the IAR available from time client opened the IARaccount. LPL makes available Models designed by PWP Advisors. LPL selects and reviews on an ongoing basis the PWP Advisors available on PWP based on quantitative, qualitative and infrastructure criteria, which may include: Quantitative Criteria LPL evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style group, including but not limited to: • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP Advisor can handle operational requirements including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable • Back office review • Client servicing resources • Firm-wide program commitment LPL reviews PWP Advisors currently participating in the program and reviews new PWP Advisors prior to the addition of their Models to the program. LPL may elect to remove a PWP Advisor should it determine that the PWP Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in management staff). In making a decision to remove a PWP Advisor, LPL’s Research Department takes into consideration all criteria; no one criteria is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove a PWP Advisor. PWP Advisor Performance LPL’s Research Department uses information provided by the PWP Advisor and also may use independent, third party databases when evaluating a PWP Advisor. In order for a PWP Advisor to be selected for the program, LPL generally requires a third party verification letter related to compliance of the PWP Advisor’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performance. However, LPL provides clients Advisor, and clients, if so directed by Advisor, with individual quarterly performance information. Performance information distributed is prepared by LPL is compiled using third party portfolio accounting and reporting software. Client performance information is calculated by LPL on a uniform and consistent basis using a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that PWP Advisors provide Models to LPL, and, except in the case of Muni Models, LPL is the party with discretion for trade implementation and execution in PWP accounts. Therefore, Models submitted to LPL by PWP Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisor. Because of this fact and because LPL (and not the PWP Advisor) has discretionary authority to implement trades, performance of a PWP account will differ from the performance of PWP Advisor’s discretionary accounts. LPL Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL’s Research Department. LPL’s Research Department provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap programprograms, Manager Select and Manager Access Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The IAR Advisor, or the client with the assistance of Advisor, selects the Portfolio and provides advice based on the client’s individual needs. LPL’s Research Department uses various investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid mid-caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL’s Research Department determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the IAR Advisor of the change in status and provide alternatives for the account from which the IAR Advisor, or the client with the assistance of the Advisor, will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. Types of Investments and Risks The Portfolios may include different types of securities, such as mutual funds, closed end funds, ETFs and ETNs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. • Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Issuer‐Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed.

PORTFOLIO MANAGER SELECTION AND EVALUATION. ‌ In PWPManager Access Select, LPL and IAR are Advisor is responsible for the overall investment advice advisory services related to the selection and management services offered to clients, retention of the SMA Portfolio Manager (in the case of the SMA Platform) and selection of the Model Portfolio (in the case of the MP Platform). The client selects the IAR Advisor who manages services the account. LPL generally requires that individuals involved in determining or giving investment advice have at least 2 years financial planning, advisory or brokerage-related experience. Each IAR is also generally required to possess a FINRA Series 6, 7, 62, 65, or 66 license (to the extent required). For more information about the IAR managing Advisor servicing the account, client should refer to Advisor’s Firm Brochure, which client should have received from Advisor at the Brochure Supplement for time client opened the IAR available from the IARaccount. LPL makes available Models designed by PWP Advisorsthe advisory services of SMA Portfolio Managers. LPL does not act as a portfolio manager for the SMA Platform. LPL does, however, act as portfolio manager for the MP Platform. Criteria for Participating and Recommended SMA Portfolio Managers and Model Advisors LPL selects and reviews on an ongoing basis SMA Portfolio Managers and Model Advisors for the PWP Advisors available on PWP program based on quantitative, qualitative and infrastructure criteria, which include: may include the criteria listed below. Quantitative Criteria LPL Research evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style groupcriteria, including but not limited to: • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP an SMA Portfolio Manager or Model Advisor can handle operational requirements requirements, including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable policy • Back office review • Client servicing resources • Firm-wide program commitment Additional Criteria for Recommended SMA Managers or Model Advisors SMA Portfolio Managers and Model Advisors that are “Recommended” by LPL reviews PWP Research are subject to a more rigorous selection and review process than the criteria set out above that applies to all SMA Portfolio Managers and Model Advisors currently participating available in the program and reviews new PWP Advisors prior to the addition of their Models to the program. In addition to the criteria noted above, additional evaluation criteria for Recommended SMA Portfolio Managers and Model Advisors include: • Sound investment philosophy and process that drives performance • Consistency of returns and risk • Qualitative assessment of the investment manager and team Clients should speak to Advisor regarding whether the SMA Portfolio Manager or Model Advisor being considered for selection or that has been selected by the client is Recommended or Participating. LPL as a Model Advisor Clients may invest in Model Portfolios designed by LPL Research. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. LPL Research designs different types of Model Portfolios to meet different investor needs. LPL Research Model Portfolios are built by seeking certain quantitative characteristics for each portfolio. LPL Research has built three large-cap-oriented Model Portfolios, which have holdings that are constituents of the S&P 500 Index. One is designed to have index-like representation to reasonably track large cap index returns. Another is designed with a dividend focus in mind, to have index-like representation, but seeking a yield premium over the large cap index. The third Model Portfolio is designed to allocate to companies that have had substantial insider buying, but have not experienced significant stock price appreciation. The LPL Research Model Portfolios are managed tactically, which means they are flexible and are designed to help take advantage of short-, mid-, and long-term opportunities the markets present and are intended for clients who wish to take advantage of shorter-term market opportunities and are not opposed to the prospect of trading as frequently as monthly. The participation of LPL’s Research Department as a Model Advisor under the MP Platform also gives rise to potential conflicts of interests because LPL has a financial incentive to select its internal team and further grow its assets under management. Although LPL does not charge a separate fee for its services as Model Advisor, as assets under management at LPL increase, the firm is able to achieve greater efficiencies and economies of scale with regards to the research and management services that it provides to clients. In addition, because LPL does not charge a fee for its services as Model Advisor, LPL and Advisor have a financial benefit if Advisor recommends a Model Portfolio designed by LPL Research, because LPL and Advisor will retain a greater portion of the Account Fee than if a Model Portfolio designed by an unaffiliated Model Advisor or if a SMA Portfolio Manager is selected. Removal of a SMA Portfolio Manager or Model Advisor LPL may elect to remove or replace a PWP SMA Portfolio Manager or Model Advisor should it determine that the PWP SMA Portfolio Manager or Model Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in if the SMA Portfolio Manager or Model Advisor has failed to maintain sufficient assets under management staff)at LPL to maintain profitability on the Manager Access Select platform. In making a decision to remove or replace a PWP SMA Portfolio Manager or Model Advisor, LPL’s Research Department LPL takes into consideration all criteria; no one criteria criteria, other than the maintenance of assets under management at LPL, is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove or replace a PWP SMA Portfolio Manager or Model Advisor. PWP While LPL would have the authority to remove LPL Research as a Model Advisor, it is unlikely to do so. SMA Portfolio Manager and Model Advisor Performance LPL’s Research Department uses information provided by the PWP SMA Portfolio Manager or Model Advisor and may also may use independent, third party databases when evaluating a PWP an SMA Portfolio Manager or Model Advisor. In order for a PWP SMA Portfolio Manager or Model Advisor to be selected for the program, LPL Research generally requires a third party verification letter related to compliance of the PWP Advisor’s performance information of the SMA Portfolio Manager or Model Advisor with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor This requirement may be waived by LPL for various reasons including alternative methods of verifying the experience and/or performance of the SMA Portfolio Manager or Model Advisor. Performance information used by SMA Portfolio Managers and Model Advisors is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performancethe performance record of SMA Portfolio Managers or Model Advisors. However, LPL provides clients with clients, if so directed by Advisor, individual quarterly performance information. Performance information distributed is prepared by LPL is compiled using third party portfolio accounting and performance reporting software. Client performance information is calculated by LPL reported on a uniform and consistent basis using a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that PWP third-party Model Advisors provide Models Model Portfolios to LPL, and, except in the case of Muni Models, and it is LPL is the party with that has discretion for trade implementation and execution in PWP MP Platform accounts. Therefore, Models Model Portfolios submitted to LPL by PWP third-party Model Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisorsuch Model Advisors. Because of this fact and because LPL (and not the PWP third-party Model Advisor) has discretionary authority to implement trades, performance of a PWP an MP Platform account will differ from and may be worse than the performance of PWP such Model Advisor’s discretionary accounts. LPL Investment Strategies SMA Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL’s Research Department. LPL’s Research Department provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios Managers and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap program, Manager Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The IAR selects the Portfolio and provides advice Advisors may provide advisory services based on the client’s individual needs. LPL’s Research Department uses various following types of investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time framestrategies. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL’s Research Department determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the IAR of the change in status and provide alternatives for the account from which the IAR will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. All Cap Core Global Equity Large Cap Value Small Cap Blend All Cap Growth Growth Equity Mid Cap Core Small Cap Growth All Cap Value Income Preferred Mid Cap Growth Small Cap Value Balanced Large Cap Core Mid Cap Value Tax Free Fixed Income Convertibles Large Cap Foreign REIT Taxable Fixed Income Global Balanced Large Cap Growth Sector Types of Investments and Risks The Portfolios include In the Platforms, SMA Portfolio Managers (in the case of the SMA Platform) or LPL (in the case of the MP Platform) invest in many different types of securities, such as including equities, fixed-income securities, options, mutual funds, closed end funds, ETFs funds and ETNsETFs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. • Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Issuer‐Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed.

PORTFOLIO MANAGER SELECTION AND EVALUATION. ‌ In PWP, LPL and IAR Advisor are responsible for the overall investment advice and management services offered to clients, and the client selects the IAR Advisor who manages services the account. LPL generally requires that individuals involved in Advisor is responsible for determining or giving investment advice have at least 2 years financial planning, advisory or brokerage-related experience. Each IAR is also generally the standards required to possess a FINRA Series 6, 7, 62, 65, or 66 license (to the extent required)for its associated persons. For more information about the IAR managing the accountAdvisor, client should refer to the Brochure Supplement for Advisor’s Firm Brochure, which client should have received at the IAR available from time client opened the IARaccount. LPL makes available Models designed by PWP Advisors. LPL selects and reviews on an ongoing basis the PWP Advisors available on PWP based on quantitative, qualitative and infrastructure criteria, which may include: Quantitative Criteria LPL evaluates quantitative criteria both in terms of the PWP Advisor’s absolute performance and performance relative to the PWP Advisor’s investment style group, including but not limited to: • Rate of return • Consistency of returns and risk • Number of employees and accounts • Years in the business • Assets under management Qualitative Criteria LPL evaluates qualitative criteria, including but not limited to: • Sound Investment philosophy and process that drives performance • Assessment of the investment manager and team • Risk controls • Legal and compliance issues Infrastructure Criteria LPL reviews infrastructure criteria to assess whether a PWP Advisor can handle operational requirements including but not limited to: • Composite calculation methodology • Trade rotation policy, if applicable • Back office review • Client servicing resources • Firm-wide program commitment LPL reviews PWP Advisors currently participating in the program and reviews new PWP Advisors prior to the addition of their Models to the program. LPL may elect to remove a PWP Advisor should it determine that the PWP Advisor has failed to meet one or more of the above selection criteria or other pertinent criteria (e.g., significant change in management staff). In making a decision to remove a PWP Advisor, LPL’s Research Department takes into consideration all criteria; no one criteria is necessarily determinant in the replacement decision. Additionally, in its review process, LPL places emphasis on long term overall PWP Advisor performance from a qualitative and/or quantitative viewpoint. Short-term developments are monitored but are not necessarily sufficient for a decision to remove a PWP Advisor. PWP Advisor Performance LPL’s Research Department uses information provided by the PWP Advisor and also may use independent, third party databases when evaluating a PWP Advisor. In order for a PWP Advisor to be selected for the program, LPL generally requires a third party verification letter related to compliance of the PWP Advisor’s performance information with Global Investment Performance Standards (GIPS) or a similar letter indicating that the performance information has been audited by an independent auditor. PWP Advisor performance information is not calculated on a uniform and consistent basis. LPL does not calculate PWP Advisor performance. However, LPL provides clients Advisor, and clients, if so directed by Advisor, with individual quarterly performance information. Performance information distributed is prepared by LPL is compiled using third party portfolio accounting and reporting software. Client performance information is calculated by LPL on a uniform and consistent basis using a time weighted basis. Performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. It is important to note that PWP Advisors provide Models to LPL, and, except in the case of Muni Models, LPL is the party with discretion for trade implementation and execution in PWP accounts. Therefore, Models submitted to LPL by PWP Advisors may represent activity that has already been implemented on behalf of other clients of the PWP Advisor. Because of this fact and because LPL (and not the PWP Advisor) has discretionary authority to implement trades, performance of a PWP account will differ from the performance of PWP Advisor’s discretionary accounts. LPL Portfolio Design Services In PWP, clients invest in Portfolios designed by LPL’s Research Department. LPL’s Research Department provides various types of advisory services. LPL Research provides research recommendations on asset allocation, money managers, mutual funds and ETFs. LPL Research provides investment advice on mutual fund selection and allocation through other LPL advisory programs, such as Optimum Market Portfolios and Model Wealth Portfolios. LPL Research also reviews and recommends outside portfolio management firms for LPL’s separately managed account wrap programprograms, Manager Select and Manager Access Select. LPL Research designs different types of Portfolios for PWP to meet the varying needs of clients. The IAR Advisor, or the client with the assistance of Advisor, selects the Portfolio and provides advice based on the client’s individual needs. LPL’s Research Department uses various investment strategies in designing Portfolios, including those described below. All Portfolios seek to generate capital appreciation while assuming a reasonable amount of risk. The Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. • Standard. This investment strategy invests in more traditional asset classes (e.g., large cap growth, large cap value, small cap growth, small cap value, foreign and fixed income). LPL Research designs different versions of Standard Portfolios, for example, for investors who wish to allocate to mid mid-caps or who do not want explicit allocations to foreign markets. • Core. This investment strategy also invests in more traditional asset classes, however the traditional equity asset classes are combined between blends of growth and value. • Diversified. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. • Diversified Plus. This investment strategy invests in traditional asset classes but may also invest in less traditional asset classes (e.g., emerging markets, high yield bonds). This investment strategy is subject to minimal constraints. LPL Research designs different versions of these Portfolios, for example, for investors who want allocation to tax-free bonds. In addition, this strategy has a tactical allocation for investors who wish to have an allocation that is more tactically managed and allocated by LPL Research to mutual funds, ETFs and/or ETNs. The tactical allocation is intended to be more flexible and to help take advantage of short-, mid-, and long-term opportunities the markets present. Other than in the context of a change in a tactical sleeve of Diversified Plus, when LPL’s Research Department determines that a Model, ETF or mutual fund is no longer acceptable for a Portfolio, LPL will notify the IAR Advisor of the change in status and provide alternatives for the account from which the IAR Advisor, or the client with the assistance of the Advisor, will select, which may include selection of 1) an ETF until a replacement Model, ETF or mutual fund has been selected by the Research Department, 2) the replacement Model, ETF or mutual fund, or 3) one of the remaining choices within the asset class. Types of Investments and Risks The Portfolios may include different types of securities, such as mutual funds, closed end funds, ETFs and ETNs. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some particular risks associated with investing and with some types of investments available in the program. • Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. • Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Issuer‐Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. • Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed.