United Planners: Advisory Business and Services, Lecture notes of Geology

Download United Planners: Advisory Business and Services and more Lecture notes Geology in PDF only on Docsity! 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL. 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Contact Person: Billy Oliverio, EVP-Chief Marketing Officer UNITED PLANNERS FINANCIAL SERVICES FORM ADV PART 2A THIS BROCHURE PROVIDES INFORMATION ABOUT THE QUALIFICATIONS AND BUSINESS PRACTICES OF UNITED PLANNERS FINANCIAL SERVICES. IF YOU HAVE ANY QUESTIONS ABOUT THE CONTENTS OF THIS BROCHURE PLEASE CALL US AT (480) 991-0225 OR EMAIL US AT RIA@UNITEDPLANNERS.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. REGISTRATION AS AN INVESTMENT ADVISOR DOES NOT IMPLY A CERTAIN LEVEL OF SKILL OR TRAINING. ADDITIONAL INFORMATION ABOUT UNITED PLANNERS FINANCIAL SERVICES IS AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV. 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 2 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version Item 2: Material Changes A. This United Planners Form ADV Part 2A Disclosure Brochure (UP Disclosure Brochure) was revised on 11.01.21 and the following material changes were made: 1. Item 5: Fees and Compensation: Added new paragraph (#4) in regards to the implementation of a new Administration Fee for TPC accounts in section D. Fees for Third Party Custodian Account (TPC Account): ***the remainder of this page was intentionally left blank*** 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 5 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version respective IAR’s Form ADV Part 2B. In some cases, an IAR may have a DBA (Doing Business As) Name that he/she operates under and in certain cases, United Planners may add that DBA Name to our Form ADV. 3. The specific types of advisory services to be provided to you will be determined between you and the IAR. IARs may not provide all advisory services available from United Planners. However, the advisory services provided to you will be based upon your individual financial needs and objectives, which may be different than the advisory services provided to other clients. 4. Transition Support via Loans & Non-Loans to IARs: On occasion, UP may provide transition support to IARs as part of the process to recruit an IAR to join United Planners. This transitional support may create a conflict of interest for IARs in determining which BD and/or IA to join. Transition support is in the form of money to help the IAR with the fees & costs that the IAR incurs when changing from one BD or IA to another. This transition support helps the IAR offset some of these transition costs; which may include, but are not limited to: registration & licensing fees, account transfer and/or termination fees, insurance costs and other internal affiliation fees. The type and amount of this transitional support is unique to each individual IAR based on various facts & circumstances. There are two ways that transitional support is provided:  Loans: United Planners may provide an IAR a forgivable or non-forgivable loan to pay for transitional costs. These loans are either repaid by the IAR or forgiven by United Planners based on the IAR satisfying the terms & conditions of the loan.  Non-Loans: United Planners may pay certain fees and/or costs or waive certain fees and/or costs that the IAR would incur to transition to United Planners and the IAR is not required to repay United Planners for covering such transitional fees and/or costs. The receipt of such transitional support (as described above) requires the IAR to agree to specific terms & conditions such as the requirement to maintain their affiliation with United Planners, comply with United Planners’ policies & procedures, and generate revenue for United Planners. Regardless of whether an IAR received transitional support or not, the IAR has a fiduciary obligation to act in the best interests of the clients and the IAR’s activity is supervised & monitored by United Planners supervisory & compliance staff. IARs who receive transitional support from United Planners are required to disclose the receipt of such transitional support on their respective Form ADV Part 2B. C. IARs Can Offer and Provide the Following Investment Advisor Services 1. Financial Planning and Consulting Services a. Financial Services Firms: In providing financial planning and consulting services to you, your IAR may utilize one or more of the several programs that United Planners has authorized through relationships with other financial services firms that are financial technology companies. United Planners has agreements with these financial services firms to provide various services, including but not limited to: financial planning services, risk assessment services, and investment research services, which are further described as follows:  Financial planning services that involve the development of financial plans (whether it be goals-based or cash-flow based).  Risk assessment services that involve the measurement of client risk (i.e., risk tolerance at household or account level) and investment risk at the security level or strategy level.  Investment research that involves the analysis of securities and/or strategies. b. Financial Planning and Consulting Services: Pursuant to a Financial Planning & Consultation Services Agreement, your IAR will meet with you, whether you are an individual or business entity, to gather important financial information including but not limited to: outline financial goals, identify potential financial problems, assess investment risk tolerance, and define investment objectives based on the specific needs. Areas for discussion and planning for individuals may include but are not limited to: cash flow management, budgeting, insurance/risk management, financial strategies, investment modeling, portfolio construction, portfolio rebalancing, taxes, education savings, social security, charitable strategies, retirement income planning, retirement and/or estate planning. Areas for discussion and planning for businesses may focus on cash flow management, taxes, employee benefits and/or succession planning. IARs will gather specific financial information from you in order to provide you with 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 6 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version a written financial plan and/or provide ongoing consulting services. Generally, such financial planning & consulting services involve the preparation & delivery of a financial plan. However, in other cases this service can also be to merely provide you various financial analyses through various reports on topics such as asset allocation, insurance/risk assessments, financial review/assessment, social security optimization, retirement income planning, securities analysis, cash flow analysis, budgeting, etc. Or, in other cases, the service can also be to merely provide you advice, insights and guidance to consult you on your financial needs, circumstances and objectives in conjunction with actionable items that you may have to execute on your own (such as managing your participant account at an employer retirement plan (i.e., 401k, 403b, 457). Analyses may encompass a variety of factors, including but not limited to: contribution amounts, asset allocation, investment time horizon, current and anticipated assets and liabilities, insurance, savings, investments and anticipated retirement or other employee benefits (such as 401k, 403b, pensions, etc.). The IAR has the discretion and flexibility to provide all of the aforementioned services, in whole or in part, based on your specific needs & objectives. The specific financial planning arrangement will be agreed upon by you and your IAR in accordance to a Financial Planning & Consultation Services Agreement. 2. Portfolio Management Programs a. Financial Services Firms: In providing portfolio management services to your account, your IAR may utilize one or more of the several programs that United Planners has authorized through relationships with other financial services firms that are custodians and/or IAs. United Planners has agreements with these financial services firms to provide various services, including but not limited to: custodial services, brokerage services, investment management services and reporting/billing services, which are further described as follows:  Custodial services that involve the safekeeping of your assets in an account for your benefit.  Brokerage services that involve the buying and selling of investments in your account.  Investment management services that involve the management of assets for your benefit.  Reporting/Billing services that involve account related reporting and fee billing for various fees. b. Portfolio Management Programs: These programs can be provided in different capacities. Below is a brief description of the main types of programs. A more detailed description is provided further down in this section. The brief descriptions are as follows:  Pershing Accounts: Accounts that are held at Pershing LLC (Pershing). United Planners relationship to Pershing is further described below in “4 – Pershing Accounts” in this section.  Third Party Custodian (TPC) Accounts: Accounts that are held at TPCs. TPCs consist of the institutional divisions of the following TPCs: Axos Advisor Services, Fidelity Institutional, Schwab Advisor Services, and TD Ameritrade Institutional.  Directly Held Accounts: In limited situations, an IAR may also provide portfolio management services to clients who have an account held directly at product sponsor such as mutual fund and/or variable annuity company.  Third Party Money Manager (TPMM) Accounts: Accounts that are serviced through an arrangement that involves the utilization of a TPMM to assist the IAR with investment management services (i.e., risk assessments, portfolio strategies, construction, rebalancing) and portfolio management services (i.e., proposals, billing, reporting, technology, etc.). c. In any of the aforementioned Portfolio Management Programs, the client will enter into an IA Agreement (This term may vary depending on its context and can also be referred to as the Investment Management Services Agreement; Client Services Agreement, IA Agreement, etc.) with United Planners and the IAR. Please refer to Item 12 for additional information about Brokerage Practices. d. Wrap Fee Programs: United Planners is not a sponsor of any sort of proprietary wrap fee program. However, wrap fee programs may be available through an approved Portfolio Management Programs (as stated immediately above in “b – Portfolio Management Programs”). 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 7 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version 3. General Discussion About Portfolio Management Services a. Background Relating to Portfolio Management Services: IARs may provide personalized portfolio management services in which your assets are held in an individual account maintained by a custodian. b. Suitability & Risk Assessment: After obtaining information from you about your financial situation, investment objectives, investment experience, risk tolerance, other investments, liquidity needs, tax status, and investment time horizon and any special instructions that you want to incorporate into the management of the account, your IAR will provide recommendations to invest in various securities, such as: equities (stocks), fixed income (bonds), options, mutual funds, exchange traded funds, convertible securities, direct participation programs, and American Depository Receipts. You will enter into an agreement with United Planners and your IAR which authorizes, among other things, your IAR to place trades in your account to manage those assets on your behalf. c. Changes to Your Financial Situation: You should keep your IAR informed of changes in your financial situation, income, investment objectives, risk tolerance levels or other information that may affect how your account should be managed. d. Client Meetings: It is important that your IAR meet with you at least annually to review your situation and discuss various items such as: suitability, services being provided, performance, fees & costs, etc. e. Special Instructions: You may work with your IAR to incorporate any special instructions on the management of your assets, including the ability to keep from purchasing/selling particular securities. For example, you may not want your IAR to invest in a specific security that is associated with a particular industry, country, environmental concern or government. You should specifically identify any such special instructions that you wish to incorporate into your agreement with your IAR. You should keep in mind that any special instructions that you incorporate may cause your IAR to deviate from investment decisions your IAR would otherwise make. If you do not incorporate special instructions on your account, it is likely that your assets will be managed and/or allocated in a manner very similar to that of the IAR’s other clients with similar investment objectives and risk tolerances. f. Investment Discretion: Your IAR may provide portfolio management services to you on either a discretionary or non-discretionary basis, as further explained in Item 16. g. Investment Performance: You should keep in mind that United Planners and your IAR cannot guarantee that your investment objectives will be met, and past performance is not a guarantee of future results. Additionally, active management services like those provided by your IAR will likely cost more than a self- managed passive buy and hold strategy. 4. Pershing Accounts a. Pershing is a SEC registered BD and a member of FINRA, New York Stock Exchange (NYSE) and SIPC. Pershing is United Planners’ clearing firm and acts as custodian and executing broker. For accounts that United Planners introduces to Pershing (i.e., opening an account), Pershing and its affiliates provide various services to United Planners that include but are not limited to the following: technology support, brokerage services, advisory services, and custodial services. Pershing is not affiliated with United Planners. b. United Planners has different types of advisory accounts available through Pershing, which include programs called UPlan, UPlan II and Do-It-Yourself (DIY). These different types of accounts have varying features, benefits and costs associated with them which are discussed in more detail in Item 5 and elsewhere in this brochure. c. Private Lending Services: Pershing offers various private lending services to their account holders via their parent company BNY Mellon. If the IAR determines that a client can benefit from any of Pershing’s various private lending services, the IAR may facilitate the introduction to their private lending services team. United Planners and the IAR are not compensated for such introductions, nor are United Planners or the IAR compensated for any such private lending services that the client actually engages in with BNY Mellon. Making such private lending services available to a client is purely a value-added benefit that a client can take advantage of as being an account holder at Pershing. Private lending services may include services such as Securities-Backed Line of Credit (SBLOC or SBL for Securities-Backed Lending), 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 10 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version g. Digital Investment Solutions: Some TPMMs offer digital investment solutions that are designed to be operationally cost efficient. So long as the particular digital investment solution has been approved by United Planners, IARs can offer these digital investment solutions to their clients. D. Retirement Plan Services 1. IARs have the ability to and may provide fiduciary and/or non-fiduciary services to retirement plans (i.e., 401k, 403b, etc.). Retirement plans may or may not be subject to the U.S. Department of Labor’s Employee Retirement Income Security Act (ERISA). Regardless of whether the retirement plan is subject to ERISA, IARs can provide fiduciary and/or non-fiduciary services to a retirement plan. 2. Retirement plan documents typically designate one or more persons, such as the plan trustee(s), to undertake fiduciary responsibility for the operation of the retirement plan. Such persons are known as Responsible Plan Fiduciaries (RPFs). Pursuant to a Retirement Plan Services Agreement (RPSA), an IAR can offer the following types of services to a retirement plan. Please refer to the agreement for a more detailed description of these different types of services. a. ERISA Fiduciary Services  Selection of Investments  Assessment of Investments  Participant Investment Advice  Investment Policy Statement (Individually Designed) b. Non-ERISA Fiduciary Services  Investment Policy Statement (Review)  Performance Monitoring  Third Party Service Provider Liaison  Employee Enrollment  Employee Education  Vendor Review/Conversion 3. IAR is not permitted to act in the capacity of an RPF on behalf of a client’s retirement plan. E. Seminars 1. IARs are permitted to conduct seminars that are educational in nature and/or promote the services of the particular IAR. The topics of the seminar may vary, but should be general in nature and will not include any individualized investment advice or recommendations based on the specific needs of any person. ***the remainder of this page was intentionally left blank*** 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 11 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version Item 5: Fees and Compensation A. Fees for Financial Planning and Consulting Services 1. The fee for financial planning and consultation services is commonly referred to as the “Financial Planning/Consulting Fee”. Financial Planning/Consulting Fees for individual and business financial plans and consultations are based upon the complexity of the work, the professional level of the IAR providing the service and other general market factors. The amount and payment of Financial Planning/Consulting Fees is determined in your individual arrangement with your IAR. Because your Financial Planning/Consulting Fee may be negotiated, it therefore may be higher or lower than the Financial Planning/Consulting Fees paid by other clients of your IAR or the Financial Planning/Consulting Fee charged by other United Planners IARs for similar services. You and your IAR will agree to a fixed or hourly Financial Planning/Consulting Fee that is established in your Financial Planning and Consultation Services Agreement. 2. The IAR may request that up to half of the estimated total Financial Planning/Consulting Fee be due upon the signing of the agreement (i.e., a deposit) with the balance due upon the delivery of the recommendations or financial plan. If this deposit for services to be rendered is more than $1,200, the IAR will render services within six (6) months of the date of the agreement that equal or exceed the deposit. This process should be evidenced on billing statements for this six-month period. If such services do not equal the amount of the deposit during this six-month period, then a prompt refund of any unused portion should be refunded to you. 3. You may terminate your agreement without penalty within five (5) business days of when you sign it. Thereafter, either you or United Planners may terminate the agreement upon written notice to the other party. After this 5-day grace period, you are entitled to a refund of any prepaid Financial Planning/Consulting Fees less a charge for the time your IAR has already spent on preparing the plan up to the point of termination based upon the rate agreed upon in the agreement. 4. Implementation of Recommendations: a. Commission-Based Products: As previously referenced in Item 4, your IAR is also a Registered Representative of United Planners (in its BD capacity) and may also be a licensed insurance agent of United Planners or an independent insurance agency. If you purchase commission-based securities products or commission-based insurance products from your IAR, they will be acting in the capacity of a RR and will likely receive a sales commission and may also receive ongoing compensation in the form of a trail/servicing fee from the product sponsor. Any commissions paid to United Planners may be higher or lower than at other BDs. Registered Representatives are only permitted to offer those commission- based products that have been approved by United Planners in the capacity of a BD. b. Compensation Conflicts of Interest: You are not required to implement recommendations from a financial plan and/or consultation through your IAR and may use the BD, IA or insurance company of your choice. However, if the financial plan is implemented through your IAR and compensation (via commissions or fees) is earned, such compensation may be used to offset some or all the cost of the financial plan, as negotiated and agreed upon between you and your IAR. Because United Planners and/or the IAR may receive compensation when implementing a financial plan (i.e., commission-based compensation as a RR or fee-based compensation as an IAR), please be advised these different forms of compensation can present a conflict of interest. c. Insurance Products: Financial plans will not include specific recommendations concerning the purchase, termination or exchange of any particular life insurance contract. Such services are provided only in the IAR’s separate capacity as a licensed insurance agent. B. Fees for Portfolio Management Services 1. The fee for portfolio management services is commonly referred to as the Advisory Fee (aka Management Fee). The Advisory Fee for portfolio management services is based upon the complexity of knowledge, skill, technology, and access warranted to satisfy the needs of a client. The Advisory Fee may also include other ancillary financial planning and consulting services as previously referenced. The amount and payment of the Advisory Fee is determined in your individual arrangement with your IAR. Because your Advisory Fee may be negotiated and varies based upon the complexity of services warranted, it may be higher or lower than the 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 12 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version Advisory Fee paid by other clients of your IAR or the Advisory Fee charged by other United Planners IARs for similar services. You and your IAR will agree to an Advisory Fee that is established in your IA agreement. 2. Factors that affect the Advisory Fee a particular client pays include, but are not limited to: a. The types of accounts to be used, the types of securities to be used, the platforms or technologies to be employed, or the investment strategies to be employed (whether they are simplistic, complex, active, passive, or a combination of all factors). b. The amount of assets under management and/or numbers of accounts to be managed. c. Any other client-related services to be provided by the IAR, which may include but not limited to, financial planning, financial analysis, or financial consulting. If such additional services are provided, the IAR and client should document the details of such services in the IA agreement. 3. Your IAR may separately provide and bill for other services as otherwise agreed to by you and your IAR. 4. Although United Planners does not have a minimum Advisory Fee, the maximum Advisory Fee may not exceed 3.0% on an annual basis. However, in the case of Pershing Accounts, the maximum Advisory Fee is lower due to a separate United Planners’ Program Fee that is associated with these offerings that United Planners receives as compensation for program administration. There are no United Planners’ Program Fees associated TPMM offerings. These details are further outlined in a subsequent section. 5. Advisory Fees are commonly debited from your account; and, if you have multiple accounts, Advisory Fees can be debited from of each respective account or the Advisory Fee can be debited from of one of your accounts for house-holding purposes. Advisory Fees may only be debited from your account with your specific written authorization. If Advisory Fees are directly debited from your account, you will receive an account statement from your custodian that indicates the amount of the Advisory Fee that was deducted. C. Fees for Pershing Accounts 1. United Planners, in its BD capacity, is a clearing correspondent firm of Pershing. This means that commission- based brokerage accounts that United Planners establishes in its BD capacity must be held in custody at Pershing. Since United Planners is also an IA, United Planners, in its IA capacity, has the flexibility to establish fee-based brokerage accounts at Pershing. a. General Pershing Fees i. Pershing Ticket Charges & Ancillary Account Charges: Securities transactions in accounts held at Pershing are subject to transaction charges, known as “ticket charges”. These are charges assessed by Pershing for their execution of transactions in your account. The Pershing Ticket Charge Schedule is disclosed to you prior to signing your IA Agreement. You are responsible for paying any Pershing ticket charges on transactions placed in your account. In addition to the Advisory Fee and ticket charges, clients are also responsible for any other ancillary account charges (such as custodial maintenance fees for retirement accounts, wire transfers, account transfers, etc.). These ticket charges & ancillary account charges are Pershing’s costs for their services and are not shared with United Planners. In some cases, the IAR may cover a ticket charge or ancillary account charge on behalf of a client as a customer service gesture for certain facts & circumstances and these arrangements are individually negotiated between you and your IAR. Such customer service gestures are not designed nor intended to be viewed as a wrap fee program. ii. Mutual Fund Service Fees: Some mutual funds pay SEC Rule 12b-1 fees to BDs for providing record keeping, shareholder communication and other services on behalf of the mutual fund. The 12b-1 fee is an internal expense of the mutual fund. If you hold a mutual fund in a Pershing fee-based account that pays a 12b-1 fee, these 12b-1 fees will be credited to your account to avoid the conflict of interest if such compensation was paid to your IAR. If you hold a mutual fund in a TPC account that pays a 12b-1 fee, these 12b-1 fees are be paid to the TPC and not paid or shared to United Planners or its IARs; therefore, there is no compensation conflict of interest with United Planners or its IARs. ***the remainder of this page was intentionally left blank*** 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 15 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version ABP is only assessed to the account typically on a quarterly basis and based on the size of the account. In either case, the transaction costs (TBP or ABP) will be disclosed to the client during the account opening process and billed in accordance to the schedule of fees provided by the TPC. These transaction costs are those of the respective TPC for their services and are not shared with United Planners or its IARs; therefore, there is no compensation conflict of interest with United Planners or its IAR. In some cases, the IAR may cover the transaction costs or other account related fees of the TPC on behalf of a client as a customer service gesture for certain facts & circumstances and these arrangements are individually negotiated between you and your IAR. Such customer service gestures are not designed nor intended to be viewed as a wrap fee program. 3. Advisory Fee: Aside from the various TPC fees (i.e., transaction costs or other account related fees) that go to the TPC for custodial services, the Advisory Fee paid to your IAR is for his/her advisory services, such as: investment advice, research services, portfolio construction, investment management and any other services provided to you by your IAR. 4. Administration Fee: Orion is a portfolio service bureau that assists United Planners in managing its IA business. Orion provides services that include but are not limited to: portfolio accounting/billing, portfolio reporting, and portfolio management (i.e., modeling, trading and rebalancing). For accounts held at certain TPCs where there is no embedded portfolio service bureau (i.e., Fidelity, Schwab, TDA), Orion is applied and there is a cost for this Orion administration. United Planners charges $6 per account per month for this Orion administration. The Administration Fee (aka Admin Fee) covers back-office services, including but not limited to: custodian data feed & reconciliation services, fee-calculation & billing processes, performance & reporting services, technology management & integrations, etc. The Admin Fee will be debited from your investment advisory account at the same time your IAR’s Advisory Fee is debited (either monthly or quarterly), which is pursuant to your existing investment advisory agreement. The Admin Fee is refundable on a pro-rated (when necessary) in the event of account termination. The Admin Fee is paid to United Planners for its back-office services to support the investment advisory program that your IAR uses to provide you investment management services. This Admin Fee is separate and in addition to the Advisory Fee you already pay to your IAR. Furthermore, your IAR does not receive any part of this Admin Fee. E. Fees for Third Party Money Managers (TPMM Account) 1. Your IAR will provide you the disclosure brochure (if/when applicable) for each TPMM that is recommended that includes, but is not limited to, the TPMM’s fee schedule, services provided, termination provisions and other aspects of the TPMM’s program. For each TPMM that you ultimately decide to engage, you will complete the respective account opening documents, authorization forms, and/or TPMM agreements. As previously mentioned in Item 4, there are different types of TPMM arrangements that have different fee structures, such as Solicitors, Sub-Advisors, TAMPs, or Wrap-Fee Programs). a. Solicitor Arrangements: In these arrangements, the IAR is a solicitor for the TPMM and is still your primary point of contact for servicing. The TPMM will manage the client’s account and charge the client an Advisory Fee. The TPMM will pay a portion of their Advisory Fee to your IAR as a Solicitor Fee (aka referral fee). The TPMM’s Advisory Fee and Solicitor Fee are fully disclosed in the TPMM’s account opening documents (proposals, agreements, and/or addendums). These fees (i.e., TPMM Advisory Fee and Solicitor Fee) may be debited from your account as one bundled fee or separate itemized fees. These fees vary across TPMMs and may or may not be negotiable. b. Sub-Advisor Arrangements: In these arrangements, the IAR is managing your overall account and is still your primary contact for servicing. However, the IAR is engaging a TPMM to manage a portion or all of your account. The IAR and TPMM will each bill Advisory Fees for their respective services and do not share in any portion of each other’s Advisory Fees. These respective Advisory Fees are fully disclosed in the respective account opening documents (proposals, agreements and/or addendums). The Advisory Fees may be debited from your account as one bundled fee or separate itemized fees. These fees vary across TPMMs and may or may not be negotiable. 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 16 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version c. TAMP Arrangements: In these arrangements, the IAR is managing your overall account and is still your primary contact for servicing. Your IAR will be compensated for his/her services through his/her Advisory Fee. The TAMP will be compensated for their respective services through their Platform Fee (for such services such as technology, reporting, billing, account services, infrastructure costs to support the TPMM roster). The TAMP’s Platform Fee may also include the fees associated to any TPMMs that have been further engaged for their investment strategies (i.e., operating expense). These fees (i.e., the IAR Advisory Fee, TAMP Platform Fee and TPMM Fees) may be debited from your account as one bundled fee or separate itemized fees. Each fee is for each party’s respective services. In either case, all these fees are fully disclosed in the TAMP’s account opening documents (proposals, agreements, and/or addendums). These fees vary across TAMPs and may or may not be negotiable. d. Wrap Fee Programs: If the TPMM offers a wrap fee program, a detailed description of this offering will be summarized in a specific disclosure brochure and will be provided to you by your IAR. The TPMM’s “wrap fee” is inclusive of the Advisory Fee for investment management, brokerage trading costs, clearing & custody, administrative services and ancillary account services. These types of wrap fee programs are generally beneficial to the client if there is a higher volume of trading activity, complex portfolio investment management strategies and high degree of account servicing to warrant the all-inclusive wrap fee. If your account does not trade at a certain level or is not complicated from an overall management and servicing perspective, you may not get the full benefit of the all-inclusive wrap fee. Therefore, it is important for you and your IAR to evaluate and determine if a wrap fee program is appropriate for you. 2. Internal Product Fees: In cases, where the TPMM manages mutual funds, exchange traded funds, variable annuity sub-accounts or other investment company securities, please be advised that these products have their own internal expenses that you will also be paying indirectly through the administration of those products (i.e., operating expenses). Please see United Planners Fees v. Other Product Fees below for more complete information about these fees. 3. You, your IAR, United Planners, or the TPMM may terminate the advisory relationship in accordance with the provisions of the applicable agreements. You will typically receive a pro-rata refund of any prepaid Advisory Fees upon termination of the TPMM’s agreement. Additionally, the client may terminate its advisory relationship with United Planners without penalty within five (5) business days of signing an agreement. F. Fees for Retirement Plans 1. As previously referenced in Item 4, IARs can provide fiduciary and/or non-fiduciary services to retirement plans (i.e., 401k, 403b, etc.). Pursuant to the Retirement Plan Services Agreement (RPSA), the IAR and Responsible Plan Fiduciary (RPF) will select the various services to be provided along with the respective fee to be paid for such services. Fees can structure in various ways, such as: an Advisory Fee based on a percentage of plan assets, an hourly fee, a flat rate or a rate per participant. 2. The IAR may, with the consent of the RPF, bill for out-of-pocket expenses (such as overnight mailings, messenger, translation fees, etc.) at cost. All fees shall be paid by the RPF or the Plan (provided it is authorized in the governing Plan documents) within 30 days of delivery of invoice to RPF. 3. The Retirement Plan may also incur certain fees imposed by third parties other than United Planners and the IAR in connection with investments made through an account, including among others, the following types of charges: mutual fund management fees, administration service fees, recordkeeping service fees, and other service fees. Further information regarding fees assessed by mutual funds are available in the appropriate prospectus. 4. The IAR may request a retainer to begin work on the engagement with the RPF. If this retainer for services to be rendered is more than $1,200, the IAR will render services within six (6) months of the date of the agreement that equal or exceed the deposit. This process should be evidenced on billing statements for this six-month period. If such services do not equal the amount of the deposit during this six-month period, then a prompt refund of any unused portion should be refunded to you. 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 17 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version 5. If you have engaged your IAR for ERISA fiduciary services, the compensation arrangement must be levelized. Your IAR’s compensation will be stipulated pursuant to your RPSA. United Planners or its IAR will not directly or indirectly receive any additional compensation from investments of Retirement Plan assets over and above the compensation specified in the RPSA. Should United Planners or the IAR receive additional compensation from any of these sources, United Planners or the IAR will credit such compensation directly to an account designated by the RPF for the Retirement Plan’s sole and exclusive benefit, or such amount shall be offset against the IAR’s compensation. G. United Planners Fees v. Other Product Fees 1. Fees that you pay to United Planners for IA services are separate and distinct from the fees charged by other products that you may invest in, such as mutual funds (MFs), Exchange Traded Funds (ETFs), American Depository Receipts (ADRs), Global Depository Receipts (GDRs) or Real Estate Investments Trust (REITs). These types of investments also have special investment considerations and may be subject to different risks. You are encouraged to carefully read the prospectus and talk to your IAR regarding these risks and the impact they may have to your overall investment objectives. Please refer to Item 8 of this UP Disclosure Brochure for more information about risks. 2. The fees associated with these products are described in their respective prospectuses. These fees will generally cover expenses related to investment management, transactions, administration, distribution, transfer agent, custodial, legal, audit and other customary fees. If your account holds any such product, you will be indirectly paying these fees, which are in addition to the Advisory Fee to your IAR. You should read the respective prospectuses for these products that are purchased in your advisory account for a more complete explanation. 3. In some cases, you may be able to invest directly in one of these products without the services of United Planners and having to pay an Advisory Fee to your IAR. In that case, you would not receive the services provided by United Planners which are designed to, among other things, assist you in determining which products are most appropriate for your financial condition and to satisfy your objectives and risk tolerance. Accordingly, you should review both the fees charged by these products and the fees charged by United Planners to fully understand the total amount of fees that you will pay to fully evaluate the value of services being provided. Lower fees for comparable advisory services may be available through other sources. 4. In regards to mutual funds, please be advised that the Advisory Fee to your IAR is typically imposed on all mutual fund shares that you place in your managed account, including mutual fund shares on which you may have previously paid a sales charge. You may also be charged redemption fees from certain mutual funds that were redeemed or short-term redemption fees on mutual funds that were bought and sold within your managed account within a time-frame specified by the mutual fund. You should be aware that any redemptions and exchanges between mutual funds in your managed account might have tax consequences, which you should discuss with your independent tax advisor. Neither United Planners nor its IARs provide tax advice as part of their IA services. H. Limitations on Fee-Based Accounts and Assets To avoid or minimize certain conflicts of interest, United Planners has established the following guidelines. IARs are subject to fiduciary standards and may not recommend a commissionable product knowing that he/she may plan to subsequently place such commission-based products under a fee-based arrangement. The receipt of both a commission (as a RR selling a product under the BD) and an Advisory Fee (as an IAR providing advisory services un the IA) on the same investment creates conflict of interest (i.e., getting paid twice on the same investment). United Planners does not generally permit the receipt of a commission on an investment that is also being managed by your IAR for an Advisory Fee. 1. Commission-Based Mutual Fund and Variable Annuity Products: These types of commission-based products may not be conducive to managed accounts and are typically not permitted to be held in a fee-based account or placed under management, except in limited circumstances. Examples of such commission-based products, include but are not limited to the following: 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 20 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version Item 6: Performance-Based Fees and Side-By-Side Management A. United Planners does not charge fees based on a share of the capital gains or capital appreciation of the assets (aka Performance Fees) in your account. B. However, certain TPMMs may have programs for certain highly qualified clients that charge fees based on a share of the capital gains or capital appreciation of clients account. If you meet the qualification requirements and choose a TPMM program in which the advisory fee is based upon a share of the capital gains and/or appreciation of your assets, please be advised that this fee arrangement may create an incentive for the TPMM to make riskier or more speculative investments than would be made under a different fee arrangement. You will receive full disclosure of the fee arrangement in TPMM’s disclosure brochure, agreement and account opening documents. Item 7: Types of Clients A. Type of Clients 1. United Planners can provide IA services to a variety of different types of clients, such as: individuals, trusts, estates, charitable organizations, corporations, pensions, retirement plans and profit-sharing plans. IARs may provide advisory services to all these types of clients or just a subset depending upon their individual business model. B. Account Minimums 1. Pershing Accounts a. DIY has a minimum initial account size of $10,000. b. UPlan has a minimum initial account size of $25,000. c. UPlan II has a minimum initial account size of $100,000. d. Exceptions to these account minimums may be granted on a case-by-case basis at the sole discretion of United Planners. 2. TPC Accounts a. United Planners has a general guideline of $10,000 account minimum for accounts held at TPCs (i.e., Axos, Fidelity, Schwab, TD Ameritrade). However, low balance accounts may be acceptable if they are part of a larger household portfolio management arrangement (i.e., household and/or large family relationships). Additionally, the TPC may also have a minimum account size guideline for the opening and maintenance of different types of accounts. These account minimums may vary among TPCs. Please refer to the respective TPC’s account opening documentation for details. 3. TPMM Accounts a. United Planners does not establish account minimums for accounts held at TPMMs because that is customarily governed by the TPMM and account minimums will vary across TPMMs. Please refer to the respective TPMM’s account opening documentation for details. ***the remainder of this page was intentionally left blank*** 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 21 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version Item 8: Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis, Investment Strategies 1. An IAR may utilize various methods of analysis to develop and support his/her investment strategies, which may include, but are not limited to: charting analysis, fundamental analysis, quantitative analysis, technical analysis and cyclical analysis. 2. An IAR’s investment strategies may include, but are not limited to: strategic allocations, tactical allocations, absolute return, constrained and unconstrained strategies, various income strategies, long-term purchases, short-term purchases, trading of securities within 30 days of purchase, margin transactions and option writing. 3. An IAR may use the above methods of analysis and investment strategies to design a client portfolio to meet the following: a. Investment Objectives:  Capital Preservation: Seeks preservation of capital as the primary objective. Market risk (fluctuation of principal) should be minimized, regardless of the effects of inflation.  Income: Seeks current income as the primary objective. Market risk, while reflecting the desired income stream and risk tolerance, should be modest.  Growth and Income: Seeks current income with the opportunity to also experience long-term capital appreciation as the primary objective. Client can accept additional fluctuations in the initial investment amount to seek potential appreciation while generating some current income.  Growth: Seeks long-term capital appreciation of initial principal investment as the primary objective. Client has a long-term time frame and does not need investments to provide an income stream. Investments that have the potential for growth generally have increased risk and client understands that the investment value will fluctuate and may be worth less than the original investment.  Speculation: Seeks a high return of initial investment as primary objective. Client understands that a speculative investment objective means that investments will be in higher risk, more volatile securities and require an aggressive risk tolerance. b. Risk Tolerances:  Conservative: Seeks to preserve initial principal, with minimal risk, even if that means that client does not generate significant income or returns and may not keep pace with inflation.  Moderately Conservative: Seeks to accept low risk to initial principal, including low volatility, to seek a modest level of portfolio returns.  Moderate: Seeks to accept some risk to initial principal and tolerate some volatility to seek higher returns and could lose a portion of initial principal.  Moderately Aggressive: Seeks to accept high risk to initial principal, including high volatility, to seek high returns over time and could lose a substantial amount of principal invested.  Aggressive: Seeks to accept maximum risk to initial principal investment to aggressively seek maximum returns and could lose most, or all, of the money invested. B. Risk of Loss 1. All investments in mutual funds, exchange traded funds, stocks, bonds, and other securities entail risk, including the loss of the initial investment. Some investment decisions made by your IAR may result in profits and others in losses. United Planners and your IAR do not and cannot guarantee that your investment objectives will be realized. 2. It is your responsibility to ensure that you understand the risks associated with your investments or investment program by asking questions of your IAR. 3. As each IAR’s approach to investment management is unique to that IAR, it is not possible to specify the types of risks for each IAR’s investment management approach. However, following are the types of risks that may be present in any given investment management program: 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 22 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version a. Business Risk: The risk that the price of an investment will change due to factors unique to that company, investment or market segment and not the market in general. b. Liquidity Risk: The risk associated with the ease of being able to quickly convert the value of a security into an equivalent amount of cash. For example, money market funds are readily convertible (liquid) while certain limited partnership units or real estate are not. c. Financial Risk: The risk to specific companies’ future earnings due to their use of debt. Companies that borrow money must pay it back at some future date, plus the interest charges. This increases the uncertainty about the company because it must have enough income to pay back this amount at some time in the future. d. Exchange Rate (Currency) Risk: The risk that investors in foreign investments may be subject to different exchange rates at the time they wish to convert investment proceeds back to their home currency. If exchange rate risk is high, even though substantial profits may have been made in the foreign markets, a less favorable exchange rate may reduce or eliminate these profits. e. Country (Political) Risk: The risk that a major change in the political or economic environment of a country may devalue investments made in that country. This risk is typically related to foreign emerging or developing countries that do not have stable economic or political environments. f. Market Risk: The risk that the price of a particular investment will change as a result of overall market conditions that are not specific to that particular company or investment. g. Interest Rate Risk: The risk that interest rate changes will affect the price of a particular investment. For example, when interest rates rise, the price of bonds generally fall. 4. The aforementioned risks also apply to TPMM investment programs. Please review the TPMM account opening documentation for any specific risks associated with a particular TPMM investment program. Item 9: Disciplinary Information A. On July 26, 2012, United Planners consented to an Acceptance, Waiver & Consent (AWC) due to an insufficient supervisory system to reasonably achieve compliance with applicable securities laws, procedures and FINRA rules with respect to variable annuity transactions of field Office of Supervisory Jurisdiction (OSJ) Supervisors. In resolving this matter, United Planners, without admitting or denying the FINRA findings, agreed to pay a $200,000 fine and revised its supervisory system to be in compliance with applicable securities laws, procedures and FINRA rules in regard to its variable annuity transactions of OSJ Supervisors. B. On September 23, 2016 United Planners consented to an Acceptance, Waiver & Consent (AWC) due to an insufficient supervisory system to supervise the use of consolidated reports prepared by its representatives. In resolving this matter, United Planners, without admitting or denying the FINRA findings, agreed to pay a $225,000 fine. C. On February 14, 2019, United Planners agreed to a settlement in regards to an administrative complaint filed by the Massachusetts Securities Division alleging United Planners failed to supervise an outside business activity of one of its representatives. In resolving this matter, United Planners, without admitting or denying the allegation, agreed to pay an administrative fine of $100,000. Item 10: Other Financial Industry Activities and Affiliations A. As previously referenced in Item 4, United Planners is an SEC IA, BD, and a member of the FINRA and SIPC. United Planners has been a BD since 1987 and an IA since 2000. B. United Planners, as a BD, is a full-service financial organization that offers services, such as: securities transactions which include general securities, load and no-load mutual funds, fixed and variable annuities, variable life insurance and direct participation programs. C. Generally, United Planners requires that all management personnel be Registered Representatives under the United Planners’ BD registration. There may be certain exceptions to this requirement on a case-by-case basis if the person’s roles and responsibilities do not directly relate to United Planners’ BD business. 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 25 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version 3. Pershing LLC a. As stated above in Item 5, Pershing LLC, is a SEC registered BD and a member of FINRA, New York Stock Exchange (NYSE) and SIPC. Pershing acts as custodian, executing broker, and clearing firm for United Planners. Pershing and its affiliate’s roles include the provision of information and software to United Planners, and the provision of brokerage and custodial services in connection with accounts introduced by United Planners. b. There is no direct link between the investment advice and/or management style an IAR provides in connection to the utilization of Pershing; however, United Planners and its IARs do receive certain additional benefits through the use of Pershing as the clearing firm. Furthermore, these benefits are generally available to any BD that utilizes Pershing as a custodian for their custody and brokerage services. These benefits include the following products and services which are provided without cost or at a discount:  the receipt of duplicate client statements and confirmations;  research-related products and tools;  practice management consulting services;  access to a trading desk serving institutional program participants;  the ability to place aggregated trades for client accounts;  the ability to offer fees (i.e., Advisory Fee, Program Fee, etc.) deducted from client accounts;  access to electronic communications networks for client order entry and account information;  access to mutual funds with no transaction fees and institutional money managers;  discounts on compliance, marketing, research, technology and practice management products or services provided to United Planners or its IARs by third-party vendors c. Some of these products and services may benefit United Planners and may also benefit its client accounts. These products or services may assist United Planners and/or its IARs to manage and administer client accounts, including accounts not maintained at Pershing. Other products and services are intended to help United Planners and/or its IARs to manage and/or further develop their businesses. d. Pershing may provide various types of support to United Planners and/or its IARs. This support includes, but is not limited to: research, training, educational, financial support for conferences & due diligence meetings and client events. The receipt of this type of support may be viewed as a conflict of interest. United Planners and its IARs have an inherent fiduciary obligation to serve the client’s best interest. Please refer to Item 14: Client Referrals and Other Compensation for the full explanation of the financial support. e. Additional Revenue  Aside from Pershing acting in the capacity of a custodian, Pershing also acts in the capacity of a clearing firm for United Planners. As part of our Department of Labor compliance initiatives, we made adjustments to the Pershing IA offerings (DIY, UPlan and UPlan II) in 2017. The adjustments removed all mark-ups and/or revenue share related to ancillary account servicing fees to avoid any indirect and variable compensation (via ticket charges, IRA fees, 12b-1 or any other ancillary account servicing fee). United Planners is compensated via the Program Fees associate to the various Pershing IA offerings in addition to the override on the IAR’s compensation. These program adjustments enable United Planners to operate as a level-fee fiduciary.  United Planners charges its IARs an association fee of $35 per month for the IAR to be affiliated with United Planners’ IA.  While not directly related to the above compensation from Pershing, United Planners provides a variety of ancillary services to its RRs and IARs, which otherwise could not be provided or which provision would be limited, if United Planners did not receive additional revenue from Pershing. These services include, but are not limited to, access to information, software, trade support services, 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 26 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version fee processing, operational services, technology services and oversight (compliance/supervision) support. Some of these services are not available from TPCs or available at the level provided by United Planners. C. Aggregated (Block) Orders 1. When placing transactions for your account at about the same time and for the same security as for other client accounts, your IAR may aggregate (or combine) trades for your account with trades of other clients. This can provide certain advantages to clients who are participating in the aggregated trade. The following information does not apply to aggregate trading of mutual funds, as they are priced once per day, at the end of the day, and not throughout the day like stocks and ETFs: 2. Aggregated trading provides each client with average pricing for the transaction, so that no client is disadvantaged when his/her account is traded versus when another client’s account is traded. 3. If an aggregated order is only partially filled, United Planners has procedures in place to ensure that no client is systematically disadvantaged in its allocation process. 4. In instances when your IAR is individually placing multiple client trades in the same security at approximately the same time, United Planners has procedures in place to ensure that no single client is systematically disadvantaged. Even so, because each transaction is placed separately, not all clients will pay or receive the same price for the security and the price a particular client pays or receives may be higher or lower than that of other clients based on moving market conditions. D. Conflicts of Interest United Planners has articulated various conflicts of interest throughout this document that exist in our business due to customary practices in our industry. Please be advised that the IAR has an inherent fiduciary obligation to serve the client’s best interest. It is important for the client to understand such conflicts of interest in order to take them into consideration to make a well-informed decision. An important aspect of United Planners is that we maintain an open-architecture business model that makes available a vast array of IA investment management service providers (i.e., TPCs and TPMMs). We do not mark-up or revenue-share with any of our IA investment management service providers, nor do we have different compensation structures to our IARs for the various IA investment management service providers. This business philosophy is core to being proactive to avoid such conflicts of interests from existing. E. TPMM Brokerage Practices TPMMs engaged by IARs have their own brokerage practices that you may review in their respective disclosure brochures. Item 13: Review of Accounts A. Review of Accounts: Your account will be reviewed periodically by your IAR; however, the timing of your review may vary and it is dependent on various factors such as: investment strategy, portfolio complexity, market activity, world events, breaking news on products and/or investments, and most importantly, the agreed upon services between you and your IAR. Regardless of the aforementioned, if you request your account to be reviewed, such request should be honored by your IAR. At a minimum, your IAR should review your account with you on an annual basis. B. Regular Reports to Clients 1. Account Statements: This is applicable when you have a brokerage account being managed in any of the following capacities: Pershing Account, TPC Account, or a TPMM Account. a. If there is activity in your account, you will receive a statement from your custodian on a monthly basis. b. If there is no activity in your account, you will receive a statement from your custodian at least quarterly. 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 27 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version 2. Performance Reports: This is applicable when you have a brokerage account being managed in any of the following capacities: Pershing Account, TPC Account, or a TPMM Account. a. If you have an UPlan, UPlan II or DIY account, you will receive a quarterly performance report from Pershing or the IAR. b. If you have a TPC Account, you will receive a performance report from your IAR or via a service provider that your IAR has engaged. c. If you have a TPMM Account, you will receive a performance report from the TPMM. d. Please be advised that it is a highly recommended practice that you compare and verify the information on any performance report to the official account statement(s) from the respective custodian(s) to ensure accuracy. If you have any questions, your first contact should be your IAR for an explanation. 3. Financial Plans: a. If you contracted the IAR for the preparation of a financial plan and/or consultation services, depending on level of service you agreed upon with your IAR, you may or may not receive regular ongoing financial planning reports, financial analysis or consultation reports.  If you engaged your IAR to provide a one-time financial planning, financial analysis and/or consultation service, then once the financial plan is delivered and/or the agreed upon consultation service has been completed and payment for such services has been satisfied, this service relationship will expire, and the agreement is automatically terminated.  If you engaged your IAR in an ongoing financial planning, financial analysis and/or consultation service, you may receive the agreed upon service for an ongoing period of time pursuant to your agreement with your IAR. Item 14: Client Referrals and Other Compensation A. Solicitors to United Planners 1. United Planners and its IARs may utilize unaffiliated referral agents to refer potential clients to United Planners. These unaffiliated referral agents are known as solicitors. This type of solicitor arrangement is common practice in the industry. An example of a solicitor may be an accountant that may refer clients to a United Planners’ IAR. 2. In return for such client referrals, United Planners will provide compensation to the solicitor. Such arrangements are established pursuant to a solicitor agreement and are in compliance with the solicitor requirements pursuant to Rule 206(4)-3 of the Investment Advisers Act of 1940. At the time of solicitation, the solicitor is required to disclose to the client the particulars of the solicitor arrangement with United Planners and the client is required to provide written acknowledgement/acceptance of this solicitor arrangement (aka solicitor disclosure statement). 3. Pursuant to industry regulations, solicitors are required to be affiliated as an IAR of United Planners or with another IA entity unless the solicitor qualifies from a regulatory exemption. B. Sponsor Compensation to United Planners 1. United Planners has Strategic Partnerships with various Service Providers who are core to the products & services that our Financial Professionals use to service their clients. Service Providers include but are not limited to mutual fund companies, insurance companies, direct participation companies (real estate investment trusts, oil & gas programs, business development companies, etc.), money managers, custodians and financial technology companies. 2. These Strategic Partnerships take shape in different ways, but they typically involve the Service Provider paying compensation to United Planners for access to its Financial Professionals for the purposes of marketing, business development and training & education. The form of compensation paid to United Planners also takes shape in different ways: a.) it could be a fixed dollar amount (Third-Party Payment); b.) it could be a percentage of business sold or business on the books via a Revenue-Sharing* arrangement; or c.) it could be a combination of both – a Third-Party Payment and Revenue-Sharing. Either way, the amount 7333 E. DOUBLETREE RANCH ROAD, SUITE 120, SCOTTSDALE, AZ 85258 TEL: 800.966.8737 / FAX: 480.503.8173 / UNITEDPLANNERS.COM Page 30 of 30 Version: 11.01.21-v13b / IAS-075 Please refer to www.unitedplanners.com for the most current version 4. In practice, the IAR makes the recommendation to the client in regards to the selection of a custodian, not United Planners. Furthermore, United Planners does not provide any direct or indirect incentive to IARs to recommend one custodian over another or the products and/or services of such custodians. Item 15: Custody A. United Planners permits IARs to get written authorization from their clients for the purposes of debiting Advisory Fees directly from their accounts. This type of scenario does not deem United Planners to have custody. B. Based on the SEC’s 02/21/17 No-Action Letter in regards to the Custody Rule (Rule 206(4)-4) and its new opinion on Standing Letters of Instructions (SLOAs), United Planners does take custody in cases whereby the client has signed a SLOA to move money from their account to a third-party. However, United Planners and its respective custodians will adhere to and satisfy the seven conditions set forth by the SEC to not be subject to the independent verification requirements set forth under Rule 206(4)-2(a)(4). IARs that have such SLOAs on file to disburse funds to a third-party are required to maintain records that the recipient of such disbursed funds is not UP or any of its IARs (inclusive of themselves), nor is the recipient located at the same address of UP or any of its IARs (inclusive of themselves). Item 16: Investment Discretion A. An IAR, with your consent, may have discretionary authorization over the placing of recommended trades in your account. Your discretionary authorization will specify the investments or accounts to be managed and will include authority to select the price, time and security to be bought or sold for your account. This discretionary authority is limited to trading in an effort to more efficiently manage your account. B. This discretionary trading authorization does not include the ability to withdraw funds or securities from your account. Item 17: Voting Client Securities A. United Planners and its IARs do not perform proxy-voting services on your behalf. You should read through the information provided with the proxy voting documents to make a determination based on the information provided. In some instances, at your request, an IAR may give limited clarification based on their understanding of issues presented in the proxy-voting materials. However, you will have the ultimate responsibility for making all proxy- voting decisions. Item 18: Financial Information A. United Planners does not require or solicit the prepayment of any fees more than six months in advance of services rendered. B. United Planners does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to you. ***the remainder of this page was intentionally left blank*** Form ADV Part 2B Disclosure Brochure Supplement for ERIC HEMINGWAY 14550 EXCELSIOR BLVD SUITE 200 MINNETONKA, MN 55345 Phone: (952) 232-0230 Fax: (952) 392-3656 United Planners Financial Services of America 7333 E. Doubletree Ranch Rd., Suite 120 Scottsdale, AZ 85258 Phone: (800) 966-8737 Fax: (480) 503-8173 Updated: June 08, 2020 This brochure supplement provides information about the Investment Adviser Representative (IAR), ERIC HEMINGWAY, which supplements the United Planners disclosure brochure. You should have received a copy of that brochure. Please contact ERIC HEMINGWAY if you did not receive United Planners’ disclosure brochure or if you have any questions about the contents of this supplement. Additional information about ERIC HEMINGWAY is available on the SEC’s website at www.adviserinfo.sec.gov. 2 Item 2. Educational Background and Business Experience ERIC HEMINGWAY Born: July 16, 1975 Education: MUHLENBURG COLLEGE 1993 – 1997 B.A./COMMUNICATIONS Business Background: United Planners Financial Services 08/2015 – Present Registered Rep Eric Hemingway 08/2010 – Present Independent Insurance Agent Hemingway Wealth Management, LLC 08/2010 – Present Managing Partner/Insurance Agent Professional Business Consortium 01/2002 – Present Co-Founding Member MidAmerica Financial Services, Inc. 01/2011 – 09/2015 Registered Representative Monticello Investment Services 01/2011 – 09/2015 Investment Advisor Representative Professional Designations: Accredited Investment Fiduciary® (AIF®): Completion of web-based or Capstone program plus minimum score of 75% on closed book exam. No prerequisite. Continuing Education: six hours per year. Item 3. Disciplinary Information FINRA RULE 2010, NASD RULES 2110, 3030: HEMINGWAY WAS PERMITTED TO RESIGN WHILE UNDER INTERNALREVIEW FOR SELLING UNREGISTERED EQUITY INDEXED ANNUITIES (A/K/AFIXED INDEXED ANNUITIES) IN VIOLATION OF FIRM POLICY. WITHOUT ADMITTING OR DENYING THE FINDINGS, HEMINGWAY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, WAS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR FOUR MONTHS. THE SUSPENSION WAS IN EFFECT FROM JULY 16, 2012 THROUGH NOVEMBER 15, 2012. MR. HEMINGWAY WAS LICENSED TO SELL EQUITY INDEXED ANNUITIES. FIRM ALLOWED SALES OF EQUITY INDEXED ANNUITIES IN THE PAST. MR. HEMINGWAY DID NOT ATTEMPT TO CONCEAL HIS OFFERING OF THIS PRODUCT TO CERTAIN CLIENTS WHERE, IN HIS VIEW, IT WAS THE MOST APPROPRIATE AND SUITABLE PRODUCT AVAILABLE FOR A CLIENT. Additional information regarding ERIC HEMINGWAY can also be found by visiting FINRA’s website at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ Item 4. Other Business Activities Hemingway Wealth Management, LLC 02/2017 – Present Chief Manager/Leasing Office Space Form ADV Part 2B Disclosure Brochure Supplement for Richard Hemingway, CFP®, CLU, ChFC 14550 EXCELSIOR BLVD SUITE 200 MINNETONKA, MN 55345 Phone: (952) 232-0230 Fax: (952) 392-3655 United Planners Financial Services of America 7333 E. Doubletree Ranch Road, Suite 120 Scottsdale, AZ 85258 Updated: July 20, 2020 This brochure supplement provides information about the Investment Adviser Representative (IAR), Richard Hemingway, that supplements the United Planners’ disclosure brochure. You should have received a copy of that brochure. Please contact Richard Hemingway if you did not receive United Planners’ disclosure brochure or if you have any questions about the contents of this supplement. Additional information about Richard Hemingway is available on the SEC’s website at www.adviserinfo.sec.gov. 2 Item 2. Educational Background and Business Experience Richard Hemingway Born: February 02, 1949 Education: THE AMERICAN COLLEGE 1983 – 1983 MS – FINANCIAL SERVICES WILLIAMS COLLEGE 1967 – 1971 BA – POLITICAL SCIENCE Business Background: UNITED PLANNERS' FINANCIAL SERVICES 09/2015 – PRESENT REGISTERED REP HEMINGWAY WEALTH MANAGEMENT 11/2013 – PRESENT ASSOCIATE / AGENT RICHARD HEMINGWAY INDEPENDENT INSURANCE 08/1997 – PRESENT INSURANCE AGENT MIDAMERICA FINANCIAL SERVICES, INC. 11/2013 – 09/2015 REGISTERED REP MONTICELLO INVESTMENT SERVICES, INC. 11/2013 – 09/2015 INVESTMENT ADVISOR REPRESENTATIVE Professional Designations:  Certified Financial Planner™ (CFP®): Successful completion of CFP-board registered education program and successful passing of 10-hour closed book exam. Prerequisites: Bachelor’s degree and minimum three years full-time relevant personal financial planning experience. Continuing Education: 30 hours every two years.  Chartered Financial Consultant (ChFC): Successful completion of nine courses and exams of ChFC curriculum. Prerequisites: Three years (equal to 6,000 hours) of acceptable professional industry experience. Continuing Education: 30 hours every two years.  Charted Life Underwriter (CLU). Successful completion of five core and three elective courses, equivalent of 24 semester credit hours with final closed-book, proctored exam for each course. Prerequisites: Three years of full-time business experience within the five years preceding the awarding of the designation. Continuing Education: 30 hours every two years. Item 3. Disciplinary Information Richard Hemingway has not been involved in any legal or disciplinary events that are material to a client’s evaluation of his integrity. Additional information regarding Richard Hemingway can also be found anytime by visiting FINRA’s website at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ Item 4. Other Business Activities Hemingway Wealth Management, LLC 11/2013 – Present Certified Financial Planner / DBA Name for Marketing Purposes Only Hemingway Wealth Management, LLC 11/2013 – Present Insurance Agent / Licensed Insurance Agency 3 Richard Hemingway is also associated with United Planners Financial Services of America (United Planners) as a registered representative. United Planners is a registered broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA). As a United Planners registered representative, Richard Hemingway may offer clients the option to purchase securities and investment products distributed by that firm including, but not limited to, mutual funds, variable annuities, variable life insurance, stocks and bonds, and limited partnerships. If Richard Hemingway purchases or sells securities products on behalf of a client in this capacity, then he will receive commissions and related compensation, such as mutual fund service fees (12b-1 fees). This poses a conflict of interest, as his receipt of compensation from such recommendations can give him an incentive to recommend investment products based on the compensation received, rather than on the needs of the client. Item 5. Additional Compensation Other than commissions and other compensation from his affiliation with United Planners and insurance activities, as disclosed in Item 4 above, Richard Hemingway does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through United Planners. To the extent Richard Hemingway recommends you to use United Planners for such services, it is because Richard Hemingway believes that it is in your best interest to do so based on the quality of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services provided by United Planners. Richard Hemingway is also a licensed insurance agent appointed with various insurance companies. As a licensed insurance agent, the IAR may offer investment advisory clients the option to purchase insurance products. If the IAR sells insurance products to a client, he will receive commission and related compensation, such as insurance trail fees as a result of the sale. This is a conflict of interest, as his receipt of compensation from such recommendations can give Richard Hemingway an incentive to recommend investment products based on the compensation received, rather than on the needs of the client. Richard Hemingway makes every effort to recommend securities and insurance products that are most appropriate for the client, without consideration of compensation arrangements. Further, should clients elect to implement financial planning recommendations through Richard Hemingway, IAR and United Planners may waive or reduce the amount of the client’s advisory fee as a result of the additional fees and/or commissions being earned. Any adjustment to the financial planning fee is at the discretion of United Planners and will be disclosed to the client prior to implementing transactions. Finally, clients are under no obligation to purchase recommended securities or insurance products through United Planners or Richard Hemingway and may purchase such products through the broker-dealer or insurance agency of their choice. Item 6. Supervision As a First Line Supervisor and designated principal of United Planners, Carla Reid has ultimate and direct supervisory responsibility over all personnel and functional areas of Richard Hemingway’s Branch Office. Carla Reid regularly reviews required reports and activities of Richard Hemingway’s Branch Office and its personnel for compliance with applicable requirements. Carla Reid may be reached at: CARLA REID First Line Supervisor Phone: 480-624-0306