David Lum

The following summarizes the principal fees and costs associated with engaging our firm for investment advisory services.

For investment advisory services, we typically charge an ongoing quarterly fee (sometimes referred to as an asset based fee). This fee is a percentage of the value of your account. You pay this fee even if you don’t buy or sell investments. The more assets you have in an asset-based fee account, the more you’ll pay us in fees. This creates an incentive to encourage you to increase the size of your account, including by transferring or rolling over assets from other accounts.

• Hourly and Fixed Fees: We may also charge an hourly fee or fixed fee for additional services such as financial planning and consulting services that are of limited duration or nature.

• Wrap Program Fees: Generally, the ongoing asset-based fee you will pay us will be a single “wrap” fee that covers the applicable advisory fee, third-party manager fees, execution charges on trades, and custody and clearing services. The wrap fee does not include commissions and other charges for trades that a third-party manager directs to another broker/dealer. If you expect to trade infrequently or to pursue a “buy and hold” strategy, a wrap fee program may cost you more than paying for the program’s services separately, and you may want to consider a brokerage relationship rather than an advisory relationship.

• Clients pay the additional fees and/or expenses: Examples of common fees and costs applicable to our clients are custodian fees, account maintenance fees, margin interest, fees related to mutual funds and exchange-traded funds, transaction charges when purchasing or selling securities; fees related to variable annuities, including surrender charges; and other product level fees associated with your investments. If you participate in the third-party programs, your total fee will be comprised of advisory fees charged by the third-party manager in addition to our fees.

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

For additional information regarding fees and compensation for our services, please refer to the terms of your advisory agreement and visit the Regulatory Information and Disclosures page at www.stewardpartners.com to review our Fee Schedules and Form ADV Part 2A.

When providing advisory services, we are held to a fiduciary standard that covers our investment advisory relationship with you. As fiduciaries, investment advisors must act in their clients' best interest and not place their interests ahead of their clients. However, at times, our interests can conflict with your interests. When we provide recommendations, we must eliminate, mitigate, or inform you of these conflicts, depending on the nature of the conflict. You should understand and ask us about these conflicts. Here are some examples to help you understand what this means.

• Third-party payments: We receive payments from third parties when you invest in certain products and services (e.g., mutual funds, insurance products). The amount of this compensation varies by product. These payments represent additional compensation to us or provide compensation for ongoing support activities we perform on behalf of third parties, such as product servicing, tax reporting, statement and trade confirmation mailings, or recordkeeping. This results in a financial incentive to recommend products that provide additional compensation to us over those that pay lesser amounts or none at all. Such payments may also affect products we make available.

• Revenue sharing: The companies that sponsor, manage, and/or promote certain investments we offer earn revenue by charging you a fee, such as a management fee in a mutual fund. A portion of these fees may be shared with us. We use the payments in part to support activities related to servicing client accounts, to provide educational programs and technology applications to financial professionals, and to provide ongoing product support for certain investments. We have an incentive to promote the product sponsors that share the most revenues over those that share less revenues or none at all. We also have a revenue sharing agreement with our affiliate, Steward Partners Investment Solutions, LLC.

• Third-Party Payments; Registered Representatives: To the extent persons providing advice on behalf of our firm are registered representatives with a broker-dealer, these persons receive compensation in connection with the purchase and sale of securities or other investment products. Compensation earned by these persons is separate and in addition to our advisory fees. This practice presents a conflict of interest because they have an incentive to recommend investment products to generate commissions.

• Third-Party Payments; Insurance Agents: Some persons providing investment advice on behalf of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products. Insurance commissions are separate and in addition to our advisory fees. This practice presents a conflict of interest because they have an incentive to recommend insurance products to you to generate commissions.

This summary does not identify all of our conflicts of interest. For additional information about our conflicts of interest, please visit the Regulatory Information and Disclosures page at www.stewardpartners.com to review our Form ADV Part 2A. Please refer to your Financial Professional’s Form ADV Part 2B, as applicable.

Our financial professionals are directly and indirectly compensated based on a variety of factors including the amount of client assets they service, the product sold, equity ownership and production-related awards, revenue the firm earns from the financial professional’s advisory services or recommendations, and noncash compensation such as credits toward training and funding of business expense accounts. Financial professionals are incentivized to recommend you transition your brokerage services account to an advisory account that will generate ongoing revenue. When financial professionals are affiliated with us, they may receive compensation in connection with transitioning from their prior firm. This includes an upfront payment and additional compensation based on the revenues generated from client accounts and the growth of the assets they manage. This creates incentives for financial professionals to encourage you to move your assets to SPIA and to produce greater revenues by charging higher fees.