Barbara I. Luttenberger

• Asset-based fees. You will pay an on-going fee at the end of each quarter based on the value of the cash and investments in your advisory account.

• The amount paid to our firm and your financial professional generally does not vary based on the type of investments we select on your behalf. The asset based fee will be deducted from your account and reduces the value of your account.

• For some advisory accounts, called wrap fee programs, the asset-based fee will include most transaction costs and custody services, and as a result wrap fees are typically higher than non-wrap advisory fees.

• Some investments (such as mutual funds and variable annuities) impose additional fees that will reduce the value of your investment over time. Also, with certain investments such as variable annuities, you may have to pay fees such as “surrender charges” to sell the investment.

• Our fees vary and some are negotiable. The amount you pay will depend, for example, on the services you receive and the amount of assets in your account.

• For accounts not part of the wrap fee program, you will pay a transaction fee when we buy and sell an investment for you. You will also pay fees to a brokerdealer or bank that will hold your assets (called “custody”). Although transaction fees are usually included in the wrap program fee, sometimes you will pay an additional transaction fee (for investments bought and sold outside the wrap fee program).

• The more assets you have in the advisory account, the more you will pay us. We therefore benefit if assets in your account increase. You pay our fee quarterly even if you do not buy or sell in that period. Paying for a wrap fee program could cost more than separately paying for advice and for transactions if there are infrequent trades in your account.

• An asset-based fee may cost more than a transactionbased fee, but you may prefer an asset-based fee if you want continuing advice or want someone to make investment decisions for you. You may prefer a wrap fee program if you prefer the certainty of a quarterly fee regardless of the number of transactions you have.

• You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

• When we act as your investment adviser, we must act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendations and investment advice that we provide you.

• We are held to a fiduciary standard that includes duties of loyalty and care that cover our entire investment advisory relationship with you. For example, we are required to monitor your portfolio, investment strategy and investments on an ongoing basis.

• Our interests can conflict with your interests. We must eliminate these conflicts or tell you about them in a way you can understand, so that you can decide whether or not to agree to them.

• Our financial advisors (“FAs”) receive compensation in the form of various recruitment incentives, including equity grants in SAS’ parent company Snowden Capital Partners LLC, as well as forgivable employee loans. These elements of compensation increase in value as assets and/or revenue attributable to the FA increase.

Our FAs receive a percentage of the fee received by the Adviser based on assets under management, according to respective arrangements between the Adviser and each individual financial professional. Additionally, some of our supervised persons accept compensation for the sale of securities or other investment products, in their individual capacities as registered representatives of our affiliated broker-dealer, Snowden Account Services LLC. Some of our supervised persons also accept trailer fees pertaining to grandfathered existing positions of certain mutual fund shares.