COMMONWEALTH EQUITY SERVICES, LLC

About Us Joseph S. Deitch founded Commonwealth Financial Network (“Commonwealth”) in 1979 under the original name of The Cambridge Group as an outgrowth of his retail financial planning practice. After the company began to prosper, Joe adopted the Commonwealth name in 1981 to reflect the firm’s desire to foster the common good of its employees and advisors. Commonwealth was acquired by LPL Holdings, Inc. on August 1, 2025, and continues to operate under the Commonwealth brand. Commonwealth serves approximately 2,950 advisors registered as investment adviser representatives with its Registered Investment Adviser, many of whom are also registered representatives with its broker/dealer. Most Commonwealth advisors operate under their own “doing business as” (“DBA”) trade name and logo, which they use for marketing and which may appear on client statements. Clients should understand that even though Commonwealth’s advisors often operate under their own DBA and market through their own website, when those advisors offer or provide advisory services through Commonwealth, they do so under the name and supervision of Commonwealth. When Joe founded Commonwealth, his desire was to create an open and supportive environment where professionals could be true to themselves and to their clients, follow their dreams, and grow to their hearts’ content. Joe structured Commonwealth with the goal of providing indispensable service to Commonwealthaffiliated advisors so that they, in turn, could provide the same level of indispensable service to their clients. To that end, Commonwealth acts as a “back office” to our advisors, providing support, guidance, and oversight over many functional areas, including operations, trading, technology, investment management, marketing, compliance, practice management, and more. Commonwealth does not manufacture or sell proprietary products. Rather, Commonwealth’s advisors have the freedom to evaluate their clients’ individual financial objectives, risk tolerance, and investment time horizons and recommend those products and services that they believe will help their clients meet their financial goals. This Brochure is designed to provide detailed and clear information relating to each item noted in the table of contents. Certain disclosures are repeated in one or more items, and/or other items are referred to in an effort to be as comprehensive as possible on the broad subject matters discussed. Within this Brochure, certain terms in uppercase or lowercase are used as follows: • “We,” “us,” and “our” refer to Commonwealth. • “Advisor” refers to a person who provides investment recommendations or advice to clients. • “You,” “yours,” and “client” refer to clients of Commonwealth and its advisors. Description of Services Available Commonwealth offers a suite of investment advisory services and programs to advisors for use with their clients. Commonwealth’s investment advisory services and programs are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. Through our various advisory programs and services, clients have access to a wide range of securities products, including, but not limited to, common and preferred stocks; municipal, corporate, and government fixed income securities; mutual funds; exchange-traded products (“ETPs”); options and derivatives; unit investment trusts (“UITs”); and variable and fixed-indexed insurance products, as well as other products and services, including a variety of asset allocation services, financial planning, and consulting services. Commonwealth advisors may also offer advice related to Commonwealth-approved direct participation programs, private placements, and other alternative investments, such as alternative energy programs, research and development programs, leasing programs, real estate programs, and pooled commodities futures programs.

Commonwealth’s investment advisory services and programs consist of our suite of Preferred Portfolio Services® programs (“PPS Program”), wealth management and retirement consulting services, and advisory services programs available through unaffiliated third-party asset managers. Commonwealth is the sponsor of the following PPS programs: • PPS Custom: The PPS Custom Program enables an advisor to assist the client in developing a personalized investment portfolio using one or more investment types, including, but not limited to, stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), UITs, variable and fixed-indexed annuities, structured products, and alternative investments. The advisor typically acts as portfolio manager, with full investment discretion, though clients may elect to have the advisor manage the account on a nondiscretionary basis. • PPS Select: The PPS Select Program offers a variety of model portfolios from which investors may choose. The PPS Select model portfolios are created and managed on a discretionary basis by our Investment Management and Research team and, in the case of Personalized Indexing, Orion Portfolio Solutions, LLC. The advisor will help the client determine which PPS Select models are best suited for the client based on their risk profile, investment objectives, and preferences, leaving the actual trading decisions to the Investment Management and Research team. PPS Select offers a variety of model portfolios with varying investment product types, including mutual fund and ETF portfolios, equity portfolios, fixed income portfolios, and variable annuity subaccount portfolios. • PPS Direct: The PPS Direct Program offers clients access to a variety of model portfolios involving a range of risk levels from which they may choose. Generally, apart from the PPS Direct Third-Party Fund Strategist Program and the PPS Direct Mutual Fund/ETF Program, the PPS Direct portfolios are not managed by Commonwealth or the advisor. Rather, PPS Direct model portfolios are managed by one or more third-party portfolio managers on a discretionary basis. PPS Direct portfolios may consist of mutual funds or ETFs, or they may be made up of individual equities, fixed income securities, or other types of investments. There are four types of PPS Direct Program accounts, which are broadly described as follows: o PPS Direct Mutual Fund/ETF: As the name suggests, these accounts will be allocated among mutual funds or ETFs. o PPS Direct Separately Managed Account (“SMA”): This SMA strategy invests in individual securities (e.g., stocks and bonds). o PPS Direct Third-Party Fund Strategist (“Strategist”): Third-party investment advisers provide asset allocation model strategies comprising mutual funds and ETFs. o PPS Direct Unified Managed Account (“UMA”): This is best described as multiple SMAs in a single account. Available consulting services include: • Wealth Management Consulting: Advisors provide advisory consulting services on a wide range of topics, including, but not limited to, comprehensive financial planning, budgeting and cash flow analysis, major purchases, education planning, retirement income/longevity planning, portfolio analysis, estate planning analysis, investment analysis, business succession planning, and fringe benefit analysis. Clients also elect to enter into consulting or financial planning engagements with advisors separately from, in addition to, or as part of their PPS managed account program, as may be agreed between the client and advisor. • Retirement Plan Consulting: Advisors provide a fee-for-service consulting program whereby advisors offer onetime or ongoing advisory services to employer-sponsored retirement plans. Through the Retirement Plan Consulting Program, advisors may assist plan sponsors with their fiduciary duties and provide individualized advice and/or investment management, based on the needs of the plan and/or plan participants, regarding matters such as: o Investment policy statement support o Plan menu design and monitoring o Service provider support o Participant advice programs

• Plan Participant Consulting: Advisors provide a fee-for-service consulting program whereby advisors offer ongoing advisory services to an individual retirement account (“IRA”) formed under a SIMPLE IRA Plan. Through the Plan Participant Consulting Program, advisors assist clients with a variety of advisory services, such as: o Financial planning and portfolio analysis o Education on the options available through the SIMPLE IRA Plan o Recommended asset allocation • Health Savings Account (“HSA”) Consulting for Employers: Advisors provide a fee-for-service consulting program whereby advisors offer onetime or ongoing investment consulting and related HSA consulting services to employers. Through the HSA Consulting for Employers Program, advisors assist employers with matters such as: o Consultation with the employer on the selection and monitoring of the HSA program’s service provider o Collaboration with the company’s benefits consultant regarding the HSA program design o Development of an employee education strategy o Delivery of employee education Other investment advisory-related services include: Third-Party Order Management System Advisors provide ongoing discretionary advisory services to participant 401(k), 403(b), 457(b), 457(f), and 401(a) accounts using an Order Management System (“OMS”) to implement asset allocation and rebalancing advice. Advisors regularly review and monitor the available investment options in participant’s 401(k), 403(b), 457(b), 457(f), and 401(a) accounts and may rebalance the account(s) through the OMS. The investments in the account will be tailored to participant’s particular needs and will consist of a mix of asset classes with weightings based on participant’s risk profile, investment objective, and individual preferences. Commonwealth and advisors do not have direct access to participant’s retirement plan assets since Commonwealth and the advisor do not have access to participant’s login credentials. Commonwealth is not affiliated with the OMS provider and does not receive any compensation from the OMS provider. Third-Party Asset Manager (“TPAM”) Programs TPAM programs offer clients access to a variety of portfolio managers who create and implement model portfolios with varying levels of risk from which investors may choose. TPAM Program accounts are not managed by Commonwealth. Rather, TPAM Program accounts are managed by one or more unaffiliated third-party portfolio managers on a discretionary basis, and they may consist of a variety of different securities types, including stocks, bonds, ETFs, mutual funds, and derivatives. Commonwealth acts in either a “promoter” or “subadviser” capacity when making TPAM programs available to clients, as described below: • Promoter: When Commonwealth acts as a compensated promoter (“Promoter”) for the TPAM Program sponsor, neither Commonwealth nor the advisor is appointed by the client as an investment adviser in relation to the TPAM Program. Instead, the advisor will assist the client in selecting one or more TPAM programs believed to be suitable based on the client’s stated financial situation, investment objectives, and financial goals. Commonwealth and the advisor are compensated for referring the client to the ongoing advisory services provided within the TPAM Program. This compensation generally takes the form of the TPAM sharing with Commonwealth and the advisor a percentage of the advisory fee that the client pays to the TPAM Program sponsor. When Commonwealth and the advisor act as Promoter for a TPAM Program, the client will receive a Promoter disclosure statement (“Disclosure Statement”) describing the nature of the relationship with the TPAM Program, if any; and the terms of our compensation arrangement with the TPAM Program, including a description of the compensation that we receive for referring the client to the TPAM Program. • Adviser or Subadviser: Under an adviser or subadviser relationship between Commonwealth and the sponsor of the TPAM Program, Commonwealth and the advisor will act as an investment

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How You’re Charged and How We’re Compensated Clients who elect to receive asset management services through one or more of PPS programs or TPAM programs will generally pay Commonwealth and their advisor percentage-based fees calculated as a

percentage of account AUM, including cash and money market positions. The maximum allowable fee schedules for Commonwealth’s various PPS programs are provided below. The fee schedules for TPAM programs are provided in the respective TPAM sponsor’s Form ADV Part 2A and advisory client agreements. Certain managed account programs have lower maximum annual fee amounts, and fee schedules will vary among programs. Clients are urged to carefully review and discuss the contents of this Brochure with their advisor, including descriptions of the various programs and services offered, the fees and charges clients will pay, the means by which Commonwealth and your advisor are compensated, and the conflicts of interest that exist between the client and Commonwealth and their advisor with respect to each program or service offered, to determine the most appropriate programs or services for their specific needs. In most cases, the annual account management fees are payable quarterly in advance and are computed as one-quarter of the annual fee based on the account’s AUM on the last business day of the previous calendar quarter. In some cases, the annual account management fee will be payable monthly in advance, computed as one-twelfth of the annual fee based on the AUM on the last business day of the previous month-end, and in other cases, clients will pay an annual flat dollar fee, payable quarterly in advance. Commonwealth receives quarter-end values, which are used when calculating billable AUM, from alternative investment issuers or other service providers. Commonwealth does not engage in an independent valuation of your account assets and relies on valuations provided by the investment issuers or other service providers. Commonwealth will provide (through NFS) periodic account statements which include the market value of the alternative investment based on information received from the investment issuer or other service provider. In providing these account statements, or any other valuation information to you, (i) Commonwealth relies on the valuation information provided by the manager of the alternative investment or other service provider, (ii) the valuation information used to determine the management fee is based on estimates that may be outdated as of the dates of the account statements, (iii) the product’s final valuations may be higher or lower than the values reflected in the periodic account statements and (iv) while Commonwealth will adjust material estimated fee billings, Commonwealth is under no obligation to provide notice or compensation to you for differences in estimated alternative investment valuations. Certain managed account programs charge fees in arrears and will have differing methods of computation. Please refer to the respective program description in this Brochure, the respective client agreement, and the respective TPAM Program Brochure (if applicable) for specific information about the fees that will be paid, the varying fee schedules of each program, and the methods of fee billing for the program(s) you select. Clients who elect to open a margin account acknowledge and agree that margin may be exercised against their account for purposes including, but not limited to, covering debits, management fees, and/or other billing and administrative costs. Management fees on margin accounts will be assessed on the equity (e.g., ownership) portion of the account and not on the account’s total market value. NFS will credit to Commonwealth a substantial portion of the margin interest income NFS receives from client margin debits. Commonwealth’s receipt of a substantial portion of the margin interest creates a conflict of interest because Commonwealth has a greater incentive to make margin available in your account because it provides additional compensation to Commonwealth. Commonwealth may charge differing margin interest rates to clients. Commonwealth does not share any portion of the margin interest it receives with your advisor. All Commonwealth advisory program management fees are negotiable between the advisor and client. This means that advisors can negotiate lower fees with certain clients when similar services are provided to other clients at a higher fee rate. Platform fees, transaction charges, and other account-related fees assessed by NFS or Commonwealth are not negotiable, however. In the event a client terminates an advisory agreement with Commonwealth and the advisor, any unearned fees resulting from payments made by clients in advance will be refunded to the client. Likewise, in the event Commonwealth bills clients in arrears for services that have already been rendered, Commonwealth will prorate such fees up to the termination date of the advisory agreement.

Commonwealth generally offers two types of fee schedules for use in PPS Program accounts, which are generally referred to as “blended” schedules and “breakpoint” schedules. Unless a billing group is created, the blended or breakpoint schedule is applied at the account level. Billing groups are maintained by the advisor. Blended Schedule A blended schedule looks at the account value and compares it to a set fee schedule. Based upon the value of the account at the end of the billing period, the fee schedule identifies specific portions of the account value to be charged at different fee rates. The total value of the account is compared against this schedule and, based on the account size, the different fee rates are blended to determine the total account fee for that period. For example, assume the advisor and client negotiate the following blended fee schedule: Account Value Greater than or equal to $0 Next $50,000 Next $100,000 Next $250,000

Fee Less than $50,000 $100,000 $250,000 —

2.25% 2.00% 1.75% 1.50%

Also, assume that the account value at the end of the billing period is $200,000. In this hypothetical example, and assuming an advanced quarterly billing cycle is applied, the account fee for the upcoming quarter would be assessed as follows: First $49,999 of the account value would be billed at a rate of 2.25 percent ($49,999 x 2.25% = $1,125; $1,125 ÷ 4 = $281.25); the next $50,000 would be billed at a rate of 2 percent ($50,000 x 2.00% = $1,000; $1,000 ÷ 4 = $250); and the next $100,000 would be billed at a rate of 1.75 percent ($100,000 x 1.75% = $1,750; $1,750 ÷ 4 = $437.50). Each of the different fee rate amounts is added together to determine the total quarterly account fee for that period, as follows: $281.25 + $250 + $437.50 = $968.75 advance quarterly account fee Breakpoint Schedule A breakpoint schedule looks at the account value and compares it to a set fee schedule. Based upon the value of the account at the end of the billing period, the billable fee rate will decline as the value of the account reaches the next fee rate, or “breakpoint.” The total value of the account is compared against the fee rate for the respective value range that corresponds with the account value to determine the total account fee for that period. For example, assume the advisor and client negotiate the following breakpoint fee schedule: Account Value Greater than or equal to $0 $50,000 $100,000 $250,000

Fee Less than $50,000 $100,000 $250,000 —

2.25% 2.00% 1.75% 1.50%

Also, assume the account value at the end of the billing period is $200,000. In this hypothetical example, and assuming an advanced quarterly billing cycle is applied, the account fee for the upcoming quarter would be assessed as follows: The $200,000 account value falls within the fee schedule value range of $100,000 to less than $250,000, which corresponds with a fee rate of 1.75 percent. Therefore, $200,000 x 1.75% = $3,500; $3,500 ÷ 4 = an $875 advance quarterly account fee.

PPS Program Fee Schedules Following are the maximum allowable fee schedules for the various PPS programs. PPS Custom Program (Transactions) The maximum allowable annual management fee schedule for a new PPS Custom Program (Transactions) account is: Account Value Greater than or equal to $0 $750,000 $1,000,000 $2,000,000

Maximum Annual Management Fee Less than $750,000 $1,000,000 $2,000,000 —

2.25% 2.00% 1.75% 1.50%

In addition to the annual management fee, and unless otherwise agreed between the client and the advisor, clients participating in the PPS Custom Program (Transactions) will pay transaction charges as described in the “Other Fees and/or Costs” section below. Clients participating in the PPS Custom Program (Transactions) may pay more or less than clients might otherwise pay if purchasing the services separately or participating in a different version of the PPS Custom Program. There are several factors that determine whether such costs would be more or less, including, but not limited to, the following: • Size of the account • Types of securities and strategies involved • Amount of trading effected by the advisor • Actual costs of such services if purchased separately The advisory fees charged for the services provided by Commonwealth and the advisor, including research, supplemental advisory, and client-related services offered through the PPS Custom Program (Transactions), may exceed those of other similar programs. PPS Custom Program (Platform) Unless otherwise agreed between the client and the advisor, clients participating in the PPS Custom Program (Platform) will pay a total account fee that consists of a combination of a management fee, which is negotiable, and a platform fee. Depending upon the mutual fund families selected, transaction charges will also apply as described below. The maximum allowable management fee schedule for a new PPS Custom Program (Platform) account is: Account Value Greater than or equal to $0 $750,000 $1,000,000 $2,000,000

Maximum Annual Management Fee Less than $750,000 $1,000,000 $2,000,000 —

2.25% 2.00% 1.75% 1.50%

The maximum platform fee schedule for a new PPS Custom Program (Platform) account is: Account Value First $250,000 Next $250,000 Next $500,000 Next $1,500,000 More than $2,500,000

Maximum Platform Fee1 0.05% 0.04% 0.03% 0.02% 0.01%

1 The platform fee is household based and calculated on a blended basis, with a minimum annual account fee of $60 (minimum quarterly fee

of $15), which may exceed the maximum annual platform fee percentage based on account size. Households are maintained by the advisor.

Transaction and other charges. In addition to the platform fee, transaction charges of $15 for buys and sells and a maximum of $3 for periodic investment plans and systematic withdrawal plans will apply in the following mutual fund families: Dodge & Cox, Vanguard, and Dimensional Fund Advisors (DFA), except that DFA sells are $0. For trader-assisted transactions, an additional $5 fee is charged to the advisor. A transaction charge of $1 per contract for purchases and sales of options will apply. A $5 quarterly paper document fee will apply account by account to all accounts not enrolled in electronic delivery of statements and confirmations. PPS Select Program Clients participating in the PPS Select Program will pay a total account fee that consists of a combination of an advisor fee and a program fee. The maximum allowable advisor fee in the PPS Select Program is as follows: Account Value Up to $499,999 $500,000–$999,999 $1,000,000–$4,999,999 Next $5,000,000 or more

Maximum Advisor Fee1 2.00% 1.75% 1.50% 1.25%

In addition to the annual advisor fee, clients participating in PPS Select will pay an annual program fee. There are several different PPS Select model portfolios with program fees that vary; however, the maximum fee within the PPS Select program is as follows: Account Value First $250,000 Next $250,000 Next $500,000 Next $1,000,000 Next $3,000,000 Next $5,000,000 or more

Maximum Program Fee2 0.60% 0.50% 0.45% 0.40% 0.35% 0.30%

The maximum annual advisor fee for certain account sizes and types may be negotiated.

2 Commonwealth will charge a minimum annual program fee of $600 ($150 quarterly) for certain accounts, which may exceed the maximum

annual program fee percentage based on account size.

PPS Direct Program Clients participating in the PPS Direct Program will pay an annual fee that consists of a combination of an advisor fee and a program fee not to exceed 3 percent. In the event the combination of the advisor fee and the program fee for a particular money manager and investment strategy exceeds 3 percent, the advisor fee will be reduced such that the annual fee will not exceed 3 percent.

The maximum allowable advisor fee in the PPS Direct Program is as follows: Account Value Up to $250,000 Next $250,000–$499,999 Next $500,000–$999,999 Next $1,000,000–$1,999,999 Next $2,000,000–$4,999,999 Next $5,000,000 or more

Maximum Advisor Fee 2.21% 2.25% 2.27% 2.29% 2.31% 2.33%

The maximum program fee in the PPS Direct Program is as follows: Account Value Up to $250,000 Next $250,000–$499,999 Next $500,000–$999,999 Next $1,000,000–$1,999,999 Next $2,000,000–$4,999,999 Next $5,000,000–$9,999,999 Next $10,000,000–$19,999,999 Next $20,000,000-$39,999,999 More than $40,000,000

Maximum Program Fee 1.07% 1.02% 1.01% 1.00% 0.99% 0.98% 0.97% 0.96% 0.95%

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Methods of Analysis and Investment Strategies Investing in securities involves risk of loss that investors should be sure they understand and are prepared to bear. Commonwealth primarily serves retail investors. Commonwealth advisors have the independence to take the approach they believe is most appropriate when analyzing investment products and strategies for clients. There are several sources of information that Commonwealth and the advisor may use as part of the investment analysis process. These sources include, but are not limited to:

• Prospectuses and offering materials • Product and sponsor sales materials • Sponsor due diligence meetings and product presentations • Financial publications • Research, software, and materials prepared by third parties • Corporate rating services • SEC filings (e.g., annual reports, prospectus, and 10-K) • Company news releases As a firm, Commonwealth does not favor any specific method of analysis over another and, therefore, would not be considered to have one approach deemed to be a “significant strategy.” There are, however, a few common approaches that may be used by Commonwealth or your advisor, individually or collectively, in the course of providing advice to clients. It is important to note that there is no investment strategy that will guarantee a profit or prevent loss. Following are some common strategies employed by Commonwealth and its advisors in the management of client accounts: • Dollar-cost averaging (“DCA”): This is the technique of buying a fixed dollar amount of a particular investment on a regular schedule, regardless of the share price. More shares are purchased when prices are low, and fewer shares are bought when prices are high. DCA is believed to lessen the risk of investing a large amount in a single investment at a higher price. DCA strategies do not prevent loss in declining markets. • Asset allocation: This is an investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes— equities (stocks), fixed income (bonds), and cash/cash equivalents—each of which has different risk and reward profiles/behaviors. Asset classes are often further divided into domestic and foreign investments, and equities are often divided into small, intermediate, and large capitalization. The general theory behind asset allocation is that each asset class will perform differently from the others in different market conditions. By diversifying a portfolio of investments among a wide range of asset classes, advisors seek to reduce the overall volatility and risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. Asset allocation does not guarantee a profit or protect against loss. • Technical analysis (aka “charting”): This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that performance of the stock, rather than performance of the company itself, has more to do with the company’s future stock price. It is important to understand that past performance does not guarantee future results. • Fundamental analysis: This is a method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis does not guarantee a profit or protect against loss. • Quantitative analysis: This is an analysis technique that seeks to understand behavior by using complex mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. Quantitative analysis does not guarantee a profit or protect against loss. • Qualitative analysis: This securities analysis uses subjective judgment based on nonquantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. This type of analysis technique is different from quantitative analysis, which

focuses on numbers. The two techniques, however, are often used together. Qualitative analysis does not guarantee a profit or protect against loss. • Tax harvesting: Commonwealth accommodates requests in certain PPS Select and PPS Direct strategies to perform tax harvesting, with the intention to offset gains or losses in the client’s account to reduce tax liabilities. All PPS Select Personalized Indexing accounts utilize tax harvesting. The PPS Select Program is based on asset allocation concepts and modern portfolio theory. The PPS Select portfolios are designed to provide long-term, risk-adjusted returns for investors across the risk/return spectrum. Depending on the program and model selected by a client, the program may invest in open-end mutual funds, closed-end funds, ETFs, individual municipal fixed income securities, and individual equity securities managed by our Investment Management and Research team. When selecting investments for inclusion or removal from the PPS Select portfolios, the Investment Management and Research team conducts extensive due diligence. Commonwealth’s investment philosophy process has five steps: screening, evaluation, analysis, portfolio construction, and ongoing monitoring: • Step 1—Screening: An initial screening process based on quantitative criteria is used as a starting point for further research. Its purpose is to narrow down the universe of investments that meet our objective criteria. • Step 2—Evaluation: After screening, the investment (or group of investments) under consideration is evaluated by applying a scoring system based on returns that are adjusted to take into account quantifiable risk. The investment is also evaluated based on its peer group ranking, benchmark relative performance, and consistency of investment management style. • Step 3—Analysis: The objective of this step is to build a solid understanding of how the investment operates. During this stage, the Investment Management and Research team spends a great deal of time evaluating the investment’s philosophy and process to ensure that they are consistent. After the in-depth quantitative and qualitative analysis is complete, the team meets with the potential investment’s key decision makers—either on-site or over the phone—to gain a greater understanding of their process for managing the portfolio. • Step 4—Portfolio construction: After our portfolio managers have determined that the investment is attractive on a stand-alone basis, they assess how well the investment complements and fits with other PPS Select portfolio holdings. A review of certain metrics, such as excess-return correlation, is performed to reasonably ensure that holdings will perform as expected in different market environments. • Step 5—Ongoing monitoring: The PPS Select portfolios are monitored on an ongoing basis. The Investment Management and Research team continually conducts performance reviews, holdingsbased attribution analysis, firm commentary reviews, and conference calls and meetings to determine whether a portfolio is meeting the team’s risk-adjusted return expectations and an investment’s stated objective. Risk of Loss Regardless of what investment strategy or analysis is undertaken, investing in securities involves risk of loss that clients must be prepared to bear; in fact, some investment strategies could result in total loss of your investment. Some risks may be avoided or mitigated, while others are completely unavoidable. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not be all inclusive but should be considered carefully by a prospective client before retaining our services. Some of the common risks you should consider prior to investing include, but are not limited to: • Market risks: The prices of, and the income generated by, the common stocks, bonds, and other securities you own may decline in response to certain events taking place around the world,

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Commonwealth generally provides advisory services to the following types of clients: • Individuals (other than high-net-worth individuals) • High-net-worth individuals • Corporations or other businesses • Pension and profit-sharing plans • State or municipal government entities • Charitable organizations Most Commonwealth clients are retail clients who fall under the “Individuals (other than high-net-worth individuals)” category. This category includes, but is not limited to, individual, joint, trust, IRA, 401(k) participant, and custodial accounts. Charitable organizations sponsor donor-advised-funds (“DAFs”). DAFs are planned giving vehicles where clients make an irrevocable gift into an account owned by a charitable organization and can recommend distributions to charities of their choice thereafter. Clients have the option to request Commonwealth serve as the investment adviser on the account and pay Commonwealth and the advisor an investment advisory fee based on assets in the DAF. In such case, the advisor has an incentive to advise a client to make a distribution directly to a DAF in lieu of a charity and advise against distributions from the DAF to eligible charities because doing so would dilute the amount of assets managed when Commonwealth and the advisor are paid on a percentage of such assets. However, advisors are obligated to act in the best interests of the client when providing investment advice to a DAF. Our various managed account programs generally require clients to meet certain program account minimums. In some cases, account balances may be combined at the household level to satisfy the account minimum. Commonwealth and the respective Program Sponsors may waive account minimum requirements for their respective programs at their sole discretion. The following is a description of the account minimums in the various managed accounts available through Commonwealth: • The PPS Custom Program generally involves a $25,000 account minimum. • The account minimums for the PPS Select programs generally start at $1,000 for Passive model portfolios and $10,000 for Active model portfolios. • The PPS Select DFA Program minimum is generally $50,000. The PPS Select Equity SMA Program and PPS Select Personalized Indexing Program minimum is generally $100,000. The PPS Select Fixed Income SMA Program minimum is generally $500,000. • The account minimums for PPS Direct programs vary and are typically determined by third-party portfolio managers. In general, the PPS Direct Mutual Fund/ETF account minimums are $25,000. The PPS Direct SMA account minimums are typically $100,000–$250,000. The PPS Direct UMA Program minimum is generally $250,000. • Commonwealth also offers clients access to certain TPAM programs. Account minimums for TPAM Program accounts vary but are generally $25,000–$50,000.

Commonwealth does not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client).

Commonwealth, the Broker/Dealer, and Material Conflicts of Interest As mentioned in the “About Us” section, Commonwealth is registered as an investment adviser and a broker/dealer. Commonwealth’s registration as a broker/dealer is material to its advisory business because substantially all of its managed accounts are held with Commonwealth’s broker/dealer. Depending upon the securities registrations held by each individual advisor, our advisors offer a variety of securities and investments to their clients, including, but not limited to, mutual funds, ETFs, 529 college savings plans, HSAs, annuities, individual stocks and bonds, options, limited partnerships, UITs, real estate investment trusts, DAFs, structured products, alternative investments, and a variety of other securities and insurance products approved for sale by Commonwealth. Several of our principal executive officers and management persons, including Commonwealth’s CEO, president, and CFO, are each individually registered with Commonwealth as a broker/dealer. As discussed in Item 5. Fees and Compensation and Item 12. Brokerage Practices of this Brochure, Commonwealth’s relationship as a broker/dealer presents a variety of material conflicts of interest with its clients. Commonwealth has separate, fully disclosed clearing arrangements with NFS and Pershing LLC (“Pershing”), a Bank of New York Mellon company. As part of the investment advisory programs offered to clients, Commonwealth, in its capacity as a broker/dealer, provides brokerage execution services to its advisory clients participating in the PPS programs. Commonwealth and its advisors make securities and insurance recommendations to clients (or, in the case of discretionary services, make investment decisions for clients) regarding our investment advisory programs and services. Where permitted by law, Commonwealth and/or your advisor will receive transaction-based commissions, insurance commissions, mutual fund 12b-1 fees, distributor fees, service fees, due diligence fees, marketing reimbursements, revenue sharing, and other payments relating to your investment in or otherwise supporting Commonwealth’s or your advisor’s activities regarding the securities and insurance products recommended, purchased, or held within your Commonwealth advisory program account or pursuant to the advisory services provided. To the extent Commonwealth is the investment adviser, sponsor, or other service provider to your investment advisory program, Commonwealth receives compensation for its services. Clients should be aware that Commonwealth’s or your advisor’s receipt of commissions, fees, payments, and other compensation presents a conflict of interest because Commonwealth and your advisor have an incentive to make available or to recommend those products, programs, or services or make investment decisions regarding investments, that provide additional compensation to Commonwealth or your advisor over other investments that do not provide additional compensation to Commonwealth or your advisor. See also Item 5. Fees and Compensation and Item 12. Brokerage Practices of this Brochure to review information with respect to certain material conflicts of interest between Commonwealth and its clients due to its business as a broker/dealer. Additionally, Commonwealth and/or its IARs may refer clients to unaffiliated firms for either investment or non-investment products or services, in exchange for a referral fee. These may include referrals for investment banking, business exit planning, trust services, accounting, tax preparation, financial technology tools, or other similar products and services that may be requested by the client. Where appropriate, clients will receive additional disclosure outlining these arrangements and the related compensation at the time of the referral.

Other Commonwealth-Related Companies Commonwealth has a related company that is licensed as an insurance agency under the name of CES Insurance Agency. Several Commonwealth management persons, and a large majority of its advisors, are licensed insurance agents of CES Insurance Agency. Commonwealth has a related company, Commonwealth Investment Partners, which purchases minority interests in advisor practices or provides loans for advisor liquidity. Commonwealth is a wholly owned subsidiary of 1979 Holding Company, LLC, an indirect and wholly owned subsidiary of LPL Financial Holdings Inc. (“LPLH”), a publicly held company. LPLH is the parent company of other investment adviser and broker-dealer firms, including LPL Financial LLC (“LPL”).

Trading Pursuant to Rule 204A-1 under the Advisers Act, Commonwealth has adopted a Code of Ethics that governs a number of conflicts of interest we have when providing our advisory services to you. Our Code of Ethics is designed to ensure that we meet our fiduciary obligations to you and to foster a culture of compliance throughout our firm. Our Code of Ethics is comprehensive and is designed to help us detect and prevent violations of securities laws and to help ensure that we keep your interests first at all times. We distribute our Code of Ethics to each supervised person at the time of their initial affiliation with our firm; we make sure it remains available to each supervised person for as long as they remain associated with our firm; and we communicate updates to our Code of Ethics as changes are made. The Code of Ethics sets forth certain standards of conduct and addresses conflicts of interest among Commonwealth and its employees, agents, advisors, and advisory clients. We will provide a copy of our Code of Ethics to any client or prospective client upon request. Commonwealth and its advisors often invest in the same securities that we recommend to clients and also recommend securities to, and buy and sell securities for, client accounts at or about the same time that we buy or sell the same securities for our own accounts. These activities create a conflict of interest between us and our clients. Commonwealth policy prohibits “trading ahead” of clients’ transactions to the detriment of clients. When Commonwealth and its advisors are purchasing or selling securities for their own accounts, priority will be given to client transactions, or trades will be aggregated to obtain an average execution price for the benefit of all parties. Commonwealth has implemented surveillance and exception reports that are designed to identify and correct situations in which firm or advisor transactions are intentionally placed ahead of client transactions to the detriment of clients. Commonwealth does not permit its advisors to recommend or purchase LPL Financial Holdings Inc. (LPLH) securities in PPS Custom accounts unless expressly directed to do so by the client. Advisors may recommend or purchase an ETF or mutual fund that holds LPLH securities as an underlying investment, for example, an ETF that seeks to replicate the performance of an index that includes LPLH.

General Overview Commonwealth renders investment advice to a large majority of its PPS Program clients on a discretionary basis pursuant to written authorization granted by the client. Commonwealth maintains a primary clearing relationship for the execution of client transactions with NFS as the account custodian. Commonwealth maintains a secondary clearing relationship for the execution of client transactions with Pershing as the account custodian. In some cases, Commonwealth will approve the use of other account custodians for its PPS accounts and at its discretion, will assess an additional administrative fee to the advisor which may result in a higher management fee to the client. Substantially all of PPS advisory clients must select Commonwealth as the broker/dealer of record and NFS as the clearing firm for their PPS managed accounts. NFS and Pershing offer their broker/dealer clients substantial financial strength and stability, economies of scale, and reliable technology. PPS clients do not generally have the option to direct securities brokerage transactions to other broker/dealers or other account custodians. This constitutes a conflict of interest as Commonwealth receives compensation on trading and other activities for accounts held at NFS. If, however, a client should request, and Commonwealth approve, the use of a broker/dealer other than NFS or Pershing for securities transaction execution, the client should be aware that Commonwealth will generally be unable to negotiate commissions or other fees and charges for the client’s account, and Commonwealth would not be able to combine the client’s transactions with those of other Commonwealth clients purchasing or selling the same securities (“batched trades”), as discussed further below. As a result, Commonwealth would be unable to reasonably ensure that the client receives “best execution” with respect to such directed trades. Commonwealth may also be unable to provide timely monitoring of transaction activity or provide the client with quarterly performance reporting and other operational or administrative services. Not all investment advisers that are dually registered as broker/dealers or that have affiliated broker/dealers require their clients to use the adviser’s related broker/dealer to execute transactions. Although Commonwealth is often able to obtain price improvement through its trade executions with NFS that it believes is beneficial to its clients, its clearing relationship with NFS provides Commonwealth’s broker/dealer with substantial economic benefits by using itself as the broker/dealer and NFS as the clearing firm for its PPS Program accounts rather than an unaffiliated broker/dealer. For example, Commonwealth pays NFS an asset-based fee for custody, clearing, and account-related charges and assesses transaction costs and certain other brokerage account charges and fees to PPS accounts. Commonwealth has also received compensation for continuing to use NFS as its clearing firm in the form of a contract renewal credit. Additionally, Commonwealth receives continuous revenue-sharing payments from NFS that are derived from certain types of positions and assets in client accounts held at NFS, including mutual funds and money market funds. In the case of mutual funds, Commonwealth receives revenue sharing on assets held in non-Fidelity NTF funds and non-Fidelity TF funds that participate in Fidelity’s TF program. This presents a conflict of interest because Commonwealth has a financial incentive to make available, recommend, or make investment decisions to select mutual funds and share classes that result in revenue sharing payments to Commonwealth over mutual funds, share classes, similarly managed ETFs, and other types of investments that do not result in revenue sharing. In the case of money market fund sweep vehicles, Commonwealth receives revenue sharing from NFS based on the average fund balances held in certain Fidelity money market funds for grandfathered accounts that were formerly ineligible or opted out of the bank sweep programs, including Fidelity Government Capital Reserves Money Market Fund (FZAXX) and Fidelity Treasury Money Market Capital Reserves Fund (FSRXX). These money market funds have higher internal expenses than the money market funds available as the sweep option for currently ineligible accounts, which reduce returns over time. This presents a conflict of interest because Commonwealth has continued to use these other money market funds as the sweep vehicle for grandfathered accounts, when lower cost money market funds that do not pay Commonwealth additional compensation are available to be used and are used as sweep vehicles. Commonwealth does not share this compensation with advisors. For information about a money market mutual fund, including interest

rates and yield, all charges and expenses, investment objectives, and risks, refer to the fund’s prospectus. Read the prospectus carefully before you invest or send money. Commonwealth also maintains a Core Account Sweep Program with NFS. This program creates substantial financial benefits for Commonwealth and NFS as described here in Item 12. This additional compensation received by Commonwealth in its broker/dealer capacity creates a significant conflict of interest with its clients because Commonwealth has a substantial economic incentive to use NFS as its clearing firm for trade execution and custody over other firms that do not or would not revenue share with Commonwealth. Additionally, by using itself as the broker/dealer for its PPS Program accounts, Commonwealth may be unable to achieve the most favorable execution for client transactions, which may cost clients more money. Further detailed discussion of the substantial economic benefits Commonwealth receives from its relationship with NFS can be found in Item 5. Fees and Compensation, here in Item 12 and in Item 14. Client Referrals and Other Compensation. Clients are urged to read and consider the contents of this Brochure carefully and to inquire about Commonwealth’s and the advisor’s various sources of compensation and conflicts of interest in making a fair and reasonable assessment of the fees and charges clients will pay for the services rendered by Commonwealth and their advisor. Lastly, in some cases, Commonwealth will use market intermediaries to execute your orders. The benefit of using market intermediaries is to increase access and liquidity. This is typically the case for bond trades. These market intermediaries embed their costs into the price they are willing to buy or sell bonds. Commonwealth reviews the execution prices its customers receive as part of its best execution review process. Best Execution Commonwealth seeks to obtain, through its clearing firms, the best combination of net price and execution when effecting brokerage transactions for client accounts. Commonwealth periodically and systematically reviews NFS’s and Pershing’s brokerage execution quality and Commonwealth’s processes to ensure that it continues to meet its best execution obligations for its clients. A number of judgmental factors are used by Commonwealth in analyzing overall trade execution quality and its selection of clearing firms. Such factors include, but are not necessarily limited to: • The nature of the securities being purchased or sold • Access to market participants, which may be limited due to thin or no trading activity for a particular security • The size of the transaction • The speed of the transaction • The size of the spread • The ability to obtain price improvement • The desired timing of the transaction • The activity existing and anticipated in the market for the particular security • The execution, clearance, and settlement capabilities of the executing broker/dealer • The overall trade execution quality of the executing broker/dealer as compared with other leading executing broker/dealers • The executing broker/dealer’s financial stability and industry reputation • The efficiency and reliability of the executing broker/dealer’s systems and technologies • The quality of Commonwealth’s access to the executing broker/dealer’s senior management and the executing broker/dealer’s responsiveness to Commonwealth • The extent to which Commonwealth can leverage the strength of its relationship with the clearing broker/dealer to improve overall service and technology

Aggregation of Trade Orders Because advisors generally manage their client’s accounts independently of one another based on each client’s specific needs and objectives, transactions for each client account are often executed independently. When advisors believe it is appropriate or beneficial to do so, however, they will aggregate the purchase or sale of multiple clients’ securities together to help facilitate best execution and provide each client with the same execution price. Aggregating multiple client orders together is particularly useful when Commonwealth or your advisor is using model portfolio management strategies. When Commonwealth and its advisors aggregate orders, they do so in a manner reasonably designed to ensure that no participating client obtains a more favorable execution price than other clients. When Commonwealth or your advisor aggregates multiple client orders, transactions are typically allocated pro rata to the participating client accounts in proportion to the size of the order placed for each account. Commonwealth or your advisor may increase or decrease the amount of securities allocated to each account, if necessary, to avoid holding odd lot or small numbers of shares for particular clients. Additionally, if Commonwealth is unable to fully execute an aggregated order and determines it would be impractical to allocate a small number of securities among the accounts participating in the transaction on a pro-rata basis, Commonwealth will allocate such securities in a manner determined in good faith to be fair and equitable to the clients involved. Clients should understand that in instances where their assets are maintained at Pershing, Commonwealth is not able to aggregate client orders with those placed for accounts held at NFS. In the event a money manager (“Manager”) through the PPS Direct SMA/UMA Program elects to use brokers/dealers other than Commonwealth to effect a transaction in a security (commonly referred to as “stepping out” a trade), brokerage commissions, markups and markdowns, and other charges for those transactions are generally charged to the client by the executing broker/dealer, whereas the wrap fees assessed by Commonwealth cover the costs of brokerage commissions and other charges on transactions effected through Commonwealth. Clients in the PPS Direct SMA/UMA Program should be aware that, in cases where a Manager engages in step-out trades, the executing broker/dealer may assess a commission markup or markdown or other charge for having executed the transaction, which will be in addition to the wrap fee assessed by Commonwealth. In such cases, the net purchase or sale price reflected on trade confirmations and brokerage statements provided by Commonwealth for those trades will include the cost of brokerage commissions or dealer markups or markdowns charged by the executing broker and paid for by the client. Due to the additional costs often incurred by clients when Managers engage in step-out trades, Managers who elect to engage in step-out trades will generally cost clients more than Managers who don’t engage in step-out trades. Some Managers have historically directed most, if not all, of their program trades to outside brokers/dealers. In the selection of brokers/dealers to effect transactions, the Manager is expected to comply with best-execution obligations and consider all relevant factors, including, but not limited to, the speed and efficiency, execution quality, commission rates, and responsiveness of the executing broker/dealer. The Manager may select brokers/dealers that provide the Manager research or other transaction-related services and may cause the client to pay such brokers/dealers commissions or other transaction-related fees in excess of those that other brokers/dealers may have charged, including Commonwealth. Such research and other services may be used for the benefit of the Manager’s accounts where permitted by rule or regulation. Managers who specialize in fixed income, international, small-cap, or ETP disciplines may be more likely to trade away from Commonwealth due to market conditions, liquidity, exchange availability, or other factors they consider relevant in satisfying their best-execution obligations to clients. Clients should understand that Commonwealth does not evaluate whether a Manager is meeting their best-execution obligations to clients when trading away, as it is not a party to those transactions and is not able to negotiate the prices obtained or transaction-related charge(s) assessed between the Manager and the executing broker/dealer. Commonwealth does not discourage or restrict a Manager’s ability to trade away. Clients participating in the PPS Direct SMA/UMA Program should review the respective Manager’s Form ADV Disclosure Brochure carefully prior to deciding to do business with any particular Manager.

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Other Compensation Received from Product Sponsors Through our national network of advisors, Commonwealth offers access to a broad selection of securities products, including mutual funds, ETFs, UITs, variable insurance products, 529 college savings plans, direct participation programs, HSAs, DAFs, structured products, and nontraded alternative investments. Some companies that advise or distribute these products (“Sponsor Companies”) participate in activities that are designed to help facilitate the distribution of their products. These companies often pay the travel,

meals, and lodging expenses for advisors to attend educational programs and due diligence meetings designed to help advisors be more knowledgeable about those companies’ products, operations, and management. These companies also often provide other forms of compensation to advisors relating to, but not contingent upon, the sale and distribution of their products, including merchandise, gifts, prizes, and entertainment, such as tickets to sporting events and leisure activities, as well as payment or reimbursement for the costs of business development expenses, client seminars, client appreciation events, software, and marketing materials designed to help promote the advisor’s business. The financial support, marketing support, participation in due diligence meetings and educational activities, and gifts and entertainment received by advisors that are paid by Sponsor Companies create a conflict of interest for advisors who receive this compensation because they incentivize advisors to focus more on or otherwise recommend or promote the products of those Sponsor Companies that provide this compensation to the advisor over those that do not. These activities are reviewed, and require approval, by Commonwealth. In addition to the support Sponsor Companies provide directly to advisors, Commonwealth receives additional compensation from certain product sponsors, retirement plan recordkeepers, and DAF administrators including open- and closed-end mutual fund, ETF, UIT, insurance, DAFs, and private fund companies (“Core Partners”), typically in the form of annual payments, paid in quarterly installments, directly from these companies. Capital Client Group payments are based upon factors set forth in American Funds’ prospectuses and statements of additional information, including an assessment of the quality of the relationship with Commonwealth during the period covered by the arrangement. The level of payments during any given year will vary depending on the amount of Commonwealth client assets invested in mutual funds from Capital Client Group. Assets invested in retirement or qualified investment advisory accounts play no role in determining the amount of payments made by Capital Client Group. Core Partner compensation is in addition to the customary commissions, 12b-1 fees, distribution fees, and other fees that are paid to Commonwealth by these Core Partners and constitutes a conflict of interest. Most compensation is a direct payment but in certain instances, indirect compensation is received in the form of reduced or waived transaction costs. The annual payments are made from the Core Partner’s or an affiliate’s own assets and not from investor assets. No portion of the annual payments made by Core Partners to Commonwealth is paid from brokerage commissions generated by the purchases of any specific investment. In exchange for the annual payments it receives from its Core Partners, Commonwealth provides a variety of benefits to these companies. These benefits include, but are not limited to, direct access to our senior leadership, research, and product support staff; invitations to Commonwealth-sponsored meetings and events, which include direct access to advisors; ability to post product marketing and educational materials to Commonwealth’s internal web portal used by advisors; access to Commonwealth’s proprietary investment models, research, and analysis; and contact information for advisors. The existence of these additional benefits provided by Commonwealth to Core Partners, in exchange for the annual payments these Core Partners provide to Commonwealth, creates a conflict of interest because Commonwealth or your advisor is more likely to recommend or promote the products of Core Partners that make such payments to Commonwealth over those product sponsors that do not. However, none of the annual payments received by Commonwealth from Core Partners are paid to or shared with any advisor who sells a Core Partner’s products. Advisors do not receive a greater or lesser commission or advisory fee for sales of these sponsors’ products for which Commonwealth receives annual payments. Additional information describing the support and annual payments provided by Core Partners to Commonwealth is provided on the Revenue Sharing Disclosure, which is available on our website at www.commonwealth.com/for-clients/disclosure/revenue-sharing. Investment Adviser/Asset Management Programs Commonwealth and/or its advisors receive reimbursements, marketing and distribution allowances, business and client development, educational enhancement, due diligence fees, gifts and entertainment, and other compensation (“additional compensation”) directly from third-party investment advisory program sponsors (collectively, “Program Sponsors”) based on the amount of client deposits and/or client assets

under management with the Program Sponsors. This additional compensation is provided to Commonwealth and/or the advisor as an incentive to promote the sale of the Program Sponsor’s products or services. In all cases, such reimbursements, marketing allowances, or other compensation will be paid to Commonwealth and/or the advisor from the Program Sponsor’s own resources and not from client funds or assets. Program Sponsors may also opt to pay Commonwealth a quarterly fee based upon deposits or AUM and/or some combination thereof on an annual basis based upon certain allowable assets. These payments to Commonwealth and/or its advisors present a conflict of interest because they provide a financial incentive for Commonwealth or its advisors to recommend clients use a particular Program Sponsor that provides this additional compensation over other programs that do not provide this additional compensation. Clients are urged to read and consider the contents of this Brochure carefully (and the Brochures of any other Program Sponsors, as applicable) and to inquire about Commonwealth and their advisor’s various sources of compensation and conflicts of interest in making a fair and reasonable assessment of the fees and charges clients will pay for the services rendered by Commonwealth and their advisor. Further information about Commonwealth’s and your advisor’s sources of compensation and conflicts of interest is described in this Brochure. Other Payments to Commonwealth Advisors In addition to receiving asset-based fees in their capacity as an investment adviser or Promoter, Commonwealth advisors receive reimbursements or marketing allowances for marketing expenses and business development costs incurred by the advisor. Some third-party asset managers provide advisors with model management consultative services that use the asset manager’s funds. In addition, advisors receive invitations to conferences and meetings that are sponsored by third-party firms that offer managed account or advisory programs or services to the advisor. Portfolio strategists, investment managers, and product manufacturers typically contribute to the cost of the conferences and meetings, are identified as a sponsor of the conference or meeting, and often have the opportunity to promote their products, programs, and services directly to the advisor. Additionally, the advisor’s travel-related costs and expenses, meals, and entertainment are usually paid for or subsidized by the firms. These benefits and indirect payments to advisors present a conflict of interest because they provide a financial incentive for advisors to recommend clients use a particular managed account program or advisory service that offers these payments and opportunities to the advisor over others that do not. Commonwealth and its affiliates offer advisors one or more forms of financial benefits based on the advisor’s total assets under advisement held at Commonwealth or in PPS Program accounts and/or for transitioning from another firm to Commonwealth. The types of financial benefits that your advisor receives from Commonwealth and its affiliated companies include, but may not be limited to, forgivable or unforgivable loans provided at below-market rates; debt or equity ownership investments in the advisor’s business; increased payouts; and discounts or waivers on transaction, platform, and account fees, technology fees, research package fees, financial planning software fees, administrative fees, brokerage account fees, account transfer fees, licensing and insurance costs, referral fees for recruiting new advisors to Commonwealth, and the eligibility for and cost of attending conferences and events. If your advisor is newly associated with Commonwealth, these benefits commonly include loans that are forgiven in installments over multiyear terms subject to the advisor’s continued affiliation with Commonwealth or its affiliates. Terms and conditions for advisors to qualify for loan forgiveness or to receive loans vary based on one or more criteria, including, but not limited to, the size of the advisor’s business at their prior firm; exceeding certain client asset levels moved to or maintained at Commonwealth over specified periods; or exceeding certain client asset levels moved to or held with Commonwealth’s primary clearing firm over specified periods. In addition, in connection with the acquisition of Commonwealth by LPLH on August 1, 2025, Commonwealth advisors received loans that are forgiven over a multi-year term subject to continued affiliation with Commonwealth, LPL or its affiliates after the acquisition. Some advisors who received a forgivable loan before May 2020 also have production targets that incentivize them to encourage more trading and the purchase of additional investments so the loan will be forgiven by Commonwealth. In addition, Commonwealth has a program to purchase an advisor’s legacy commission business to aid in the transition to one of Commonwealth’s fee-only affiliation channels. These financial benefits, which can

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Information on disciplinary history and registration of Commonwealth and persons associated with Commonwealth may be obtained online at adviserinfo.sec.gov or brokercheck.finra.org or by contacting state regulatory authorities. Following is a list of those legal or disciplinary events that may be material to your evaluation of Commonwealth or the integrity of Commonwealth’s management. On March 23, 2026, the U.S. District Court of Massachusetts entered a final judgment in the matter, Securities and Exchange Commission vs. Commonwealth Equity Securities, LLC, in connection with alleged violations of the Advisers Act related to disclosures of conflicts of interest from revenue sharing Commonwealth received with respect to certain mutual fund share classes during the time period 2014 to 2018. Without admitting or denying the allegations, Commonwealth consented to pay a civil penalty of $5,000,000. The judgment did not determine that Commonwealth violated any provisions of the federal securities laws. During the period January 1, 2014, to March 27, 2014, Commonwealth purchased, recommended, or held for advisory clients’ mutual fund share classes that charged 12b-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible. Commonwealth and its associated persons received 12b-1 fees in connection with these investments. The SEC found that Commonwealth failed to

disclose in its Form ADV or otherwise the conflicts of interest related to its receipt of 12b-1 fees and/or its selection of mutual fund share classes that pay such fees. As a result of these disclosure failures, the SEC found that Commonwealth violated Sections 206(2) and 207 of the Advisers Act. Pursuant to the Division of Enforcement’s Share Class Selection Disclosure Initiative, Commonwealth self-reported these violations to the SEC. On March 11, 2019, the SEC accepted Commonwealth’s offer of settlement and entered an administrative order. Without admitting or denying the findings, Commonwealth consented to a cease and desist, censure, and disgorgement of $1,426,700.16 and prejudgment interest of $210,603.29.

Commonwealth home office Compliance and Operations principals, senior members of our Advanced Planning team, and/or designated supervisors periodically review client accounts and financial plans to identify situations that may warrant either a more detailed review or a specific action on behalf of an advisory client. Commonwealth uses a series of surveillance, exception, trade, and other transaction reports, and collectively obtains and analyzes the results of periodic data requests, to help facilitate the ongoing review of its managed accounts. In addition, advisors provide continual and regular investment advice or investment supervisory services to clients, routinely review client portfolios, and are responsible for contacting clients at least annually. There are various reports, data analytics, and supervisory controls used by Commonwealth to review accounts. Following are some of the reports and data requests used to conduct these reviews: Report

Review Frequency

Nature of Report

State Licensing Report

As transactions occur

Conflict Trading

Daily

Options Account Analysis

Quarterly

PPS Custom Activity Analysis

Quarterly

PPS Out of Balance Analysis

Quarterly

Review of transactions to confirm proper state licensing To identify potential violations of the Code of Ethics To identify accounts with a high volume of option trades To conduct trading activity analysis on PPS accounts and advisors To identify accounts out of balance from a client’s stated objectives

Custody Services Commonwealth maintains a primary clearing relationship for the execution of client transactions with NFS as the account custodian. Commonwealth maintains a secondary clearing relationship for the execution of client transactions with Pershing as the account custodians. In some cases, Commonwealth will approve the use of other account custodians for its PPS accounts and at its discretion, will assess an additional administrative fee to the advisor that may result in a higher management fee to the client. Substantially all of PPS advisory clients must select Commonwealth as the broker/dealer of record and NFS as the clearing firm for their PPS managed accounts. The name and address of the account custodian used for the account will be identified in the respective PPS managed account client agreement. Clients who establish a managed account with Commonwealth as the broker/dealer of record will receive custodial account statements directly from the respective custodian that holds those assets, such as NFS, Pershing, or a direct product sponsor. Clients are urged to carefully review the statements they receive from the account custodian, and, if applicable, from Commonwealth or their advisor, and should promptly report material discrepancies to Commonwealth directly at 800.237.0081. Performance Reporting Clients may also receive portfolio summary or performance reporting for their Commonwealth managed accounts from Commonwealth or their advisor that are in addition to the account statements clients receive directly from the respective account custodian. Commonwealth urges you to compare the account statements you receive from your account custodian with any account summary statements or reports you receive from us or your advisor. If you believe there are material discrepancies between your custodial statement and the summary statements or reports you receive from Commonwealth or your advisor, please call Commonwealth directly at 800.237.0081.

General Commonwealth renders investment advice to the vast majority of its managed account clients on a discretionary basis, pursuant to written authorization granted by the client to Commonwealth and/or your advisor in a Commonwealth client agreement. This authorization grants the advisor and/or Commonwealth discretionary authority to determine appropriate account investments based on the client’s financial circumstances, investment objectives, risk tolerance, prevailing market conditions, and other factors, and to receive product prospectuses on the client’s behalf as the client’s agent. An account may be assigned to one or more advisors, and clients are notified if there is a new advisor assigned to service the account.

This authorization grants to Commonwealth and your advisor the discretion to buy, sell, exchange, convert, or otherwise trade in securities and/or insurance products that are approved by Commonwealth, and to execute orders for such securities and/or insurance products with or through any distributor, issuer, or broker/dealer as Commonwealth or your advisor may select. Your advisor may determine which products to purchase or sell for your managed account, as well as when to purchase or sell such products, and the prices to be paid. Neither Commonwealth nor your advisor is granted authority to take possession of your assets or direct the delivery of your assets to anywhere other than your address of record without your written consent. Under the Retirement Plan Consulting Program, Commonwealth may serve as a discretionary investment manager, as defined in section 3(38) of ERISA, pursuant to written authorization granted by the client to Commonwealth or your advisor. Neither Commonwealth nor your advisor is granted any authority to take custody or possession of any plan assets. Level of Authority Clients may request reasonable restrictions on their managed account, including, but not limited to, the type, nature, or specific names of securities to be bought, sold, or held in the account, as well as the type, nature, or specific names of securities that may not be bought, sold, or held in the account. Clients generally grant Commonwealth and their advisor discretionary trading authority over their PPS Program accounts. If not specifically requested otherwise by the client, discretionary authority will be established at the time the account is first opened. The PPS Custom Program does, however, permit the client to choose to have Commonwealth and the advisor provide investment advice and recommendations to the client on a nondiscretionary basis. Clients who wish to receive advice with respect to their PPS Custom account on a nondiscretionary basis must execute an amendment to the PPS Custom Client Agreement to modify the agreement to be nondiscretionary. Clients should request a copy of the nondiscretionary amendment form from their advisor if they want to exercise this option. Miscellaneous Authority As a matter of firm policy, neither Commonwealth nor its advisors have or will accept the authority to file class action claims on behalf of clients. This policy reflects our recognition that we do not have the requisite expertise to advise clients about participating in class actions. Commonwealth and its advisors have no obligation to determine if securities held by the client are subject to a pending or resolved class action settlement or verdict. Commonwealth and its advisors also have no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Commonwealth and its advisors have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. The decision to participate in a class action or to sign a release of claims when submitting a proof of claim may involve the exercise of legal judgment, which is beyond the scope of services provided to clients by Commonwealth or your advisor. In all cases, clients retain the responsibility for evaluating whether it is prudent to join a class action or to opt out.

General Policy As a matter of firm policy, and in accordance with this Brochure and our advisory client agreements, neither Commonwealth nor its advisors have or will accept the authority to vote proxies on behalf of advisory clients or ERISA clients in any situation where Commonwealth or the adviser acts as investment adviser to the client. Commonwealth or its advisors may, but are not obligated to, provide advice to clients regarding the clients’ voting of proxies. In all cases, clients must either retain the responsibility for receiving and voting proxies for any and all securities maintained in their managed accounts, or they must appoint a third-party investment adviser or other person who is not associated with Commonwealth to vote proxies for the accounts.

In the event the advisor chooses to provide advice to clients designed to assist them in deciding how to vote their proxies, the advisor has a fiduciary duty to disclose to the client any material conflicts of interest the advisor may have with respect to such advice. In all cases, Commonwealth or the advisor will send, or will cause to be sent, all such proxy and legal proceedings information and documents it receives to the client or a third party authorized and directed by the client to receive such information and documents on the client’s behalf, so that the client or a third-party appointed by the client may take whatever action the client deems advisable under the circumstances. PPS Direct and TPAM Programs In situations when the client uses a PPS Direct or unaffiliated TPAM Program to manage their portfolio, where permissible, the client may grant the program’s designated third-party asset manager discretion to vote proxies with respect to any securities purchased or held in the account; to execute waivers, consents, and other instruments with respect to such securities; and to consent to any plan of reorganization, merger, combination, consolidations, liquidation, or similar plan with reference to such securities. In such cases, all proxy and legal proceedings information and documents received by Commonwealth or the advisor relating to the securities within PPS Direct or TPAM Program accounts must be forwarded to the designated asset manager as the client’s agent and attorney-in-fact with respect to proxy voting. If the client has not appointed a third-party asset manager as the client’s agent and attorney-in-fact with respect to proxy voting, such proxies must be provided directly to the client, who shall have the exclusive responsibility to take whatever action the client deems appropriate.

Some advisors who provide Wealth Management Consulting or Retirement Plan Consulting services to clients may require prepayment of more than $1,200 in fees six (6) months or more in advance. Commonwealth also maintains custody of certain client assets and in certain instances, as defined in SEC Rule 206(4)-2. Additionally, pursuant to the trading authorization granted by managed account clients to Commonwealth and their advisor, Commonwealth has discretionary trading authority over the funds and securities of clients. Commonwealth neither has a financial commitment that would impair its ability to meet its contractual and fiduciary commitments to clients, nor has Commonwealth been the subject of a bankruptcy proceeding.

Commonwealth Financial Network® Statements of Financial Condition December 31, 2025, and 2024 Assets

2025

Cash and cash equivalents

$185,912,765

$84,607,034

$97,020,438

$98,825,228

Brokers and clearing organizations

$52,012,117

$54,728,744

Employees and registered representatives, net

$25,589,384

$164,541,849

Other receivables

$10,062,821

$8,130,846

Securities owned, at fair value

$20,492,611

$64,210,776

Property and equipment, net

$11,875,300

$5,952,625

Right of use leases, net

$25,317,704

$7,755,582

Other assets, net

$29,781,269

$44,775,789

$50,000

$50,000

$1,665,025,297

Goodwill

$423,302,465

Total Assets

$2,546,442,171

$533,578,473

Accrued liabilities

$50,238,554

$40,543,887

Accrued deferred compensation

$10,181,359

$7,545,613

Brokers and clearing organizations

$26,307,917

$24,872,976

Trade and reimbursements

$1,762,464

$11,439,966

Sales tax liabilities

$9,283,091

$0

Lease liabilities

$29,517,389

$8,162,982

Contingent liabilities

$97,020,438

$96,633,210

Other liabilities

$8,916,824

$941,430

Total Liabilities

$233,228,036

$390,295,064

$2,313,214,135

$143,283,409

Total Members’ Equity

$2,313,214,135

$143,283,409

Total Liabilities and Members’ Equity

$2,546,442,171

$533,578,473

Restricted cash

2024

Receivables:

Deposits with clearing organizations Intangible assets, net

Liabilities and Members’ Equity

Payables:

Members’ Equity Members’ Units—100 issued and outstanding

March 30, 2026

Form ADV Part 2A—Appendix 1: The Wrap Fee Program Brochure Commonwealth Financial Network® 275 Wyman Street Suite 400 Waltham, MA 02451-1200 Toll-Free: 800.237.0081 Phone: 781.736.0700 commonwealth.com This Wrap Fee Program Brochure provides information about the qualifications and business practices of Commonwealth Financial Network® (“Commonwealth”). If you have any questions about the contents of this Brochure, please call 800.237.0081 or email FormADVPart2@commonwealth.com. The information in this Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or any state securities authority. Additional information about Commonwealth is available on the SEC’s website at adviserinfo.sec.gov. Commonwealth is a Registered Investment Adviser. This registration does not imply any level of skill or training.

Item 2: Material Changes The following is a summary of the material changes made to this Brochure since the annual update on March 27, 2025: • • •

As previously notified, Commonwealth changed its address to 275 Wyman Street, Suite 400, Waltham, MA 02451-1200. Commonwealth also updated Item 9 to provide disclosures related to the acquisition of Commonwealth by LPL Financial Holdings, Inc. (“LPLH”), a publicly held company. Commonwealth updated Item 9 to disclose resolution of the matter, Securities and Exchange Commission vs. Commonwealth Equity Securities, LLC, in the U.S. District Court for the District of Massachusetts. Commonwealth, without admitting or denying the allegations, consented to a judgment that imposed a civil penalty of $5,000,000.

You may request a copy of our current Brochure at any time, without charge, by contacting your advisor, visiting us at www.commonwealth.com/for-clients, emailing FormADVPart2@commonwealth.com,or by calling 800.251.0080, option 3. Additional information about Commonwealth is available via the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with Commonwealth who are registered, or required to be registered, as Investment Adviser Representatives of Commonwealth.

Item 3: Table of Contents Item 2: Material Changes ............................................................................................................................ 50 Item 3: Table of Contents ............................................................................................................................ 51 Item 4: Services, Fees, and Compensation ................................................................................................ 52 Item 5: Account Requirements and Types of Clients .................................................................................. 67 Item 6: Portfolio Manager Selection and Evaluation ................................................................................... 69 Item 7: Client Information Provided to Portfolio Managers ......................................................................... 73 Item 8: Client Contact with Portfolio Managers ........................................................................................... 74 Item 9: Additional Information ..................................................................................................................... 74

Item 4: Services, Fees, and Compensation PPS Direct SMA/UMA and Strategist Program Services, Fees, and Compensation The PPS Direct SMA/UMA and Strategist Program provides clients access to an investment platform that facilitates ownership of individual securities managed at the discretion of one or more money managers (“Money Managers”). Certain services in the PPS Direct SMA/UMA and Strategist Program are provided by Envestnet Asset Management, Inc. (“Envestnet”). Envestnet is a Registered Investment Adviser and has been chosen by Commonwealth to provide access to a wide range of Money Managers within the Separately Managed Account Program (“SMA Program”), the Unified Managed Account Program (“UMA Program”), and the Third-Party Fund Strategist program (“Strategist Program”). Additionally, Envestnet acts as the “overlay manager” in the UMA Program, which means that Envestnet may, at its discretion, place trades within client accounts based on the trading instructions provided by the selected Money Managers. Clients who participate in the PPS Direct SMA/UMA and Strategist Program are required to grant full discretionary authorization to Commonwealth and Envestnet to hire and fire portfolio managers and to invest, reinvest, sell, exchange, and otherwise deal with client assets at their discretion, including, without limitation, the authority to select, allocate, and reallocate the client assets in the client’s accounts to different Money Managers and to delegate discretion to the respective Money Managers. For the SMA and UMA programs, Commonwealth and Envestnet generally will only use this discretionary authorization to: • Replace investment vehicles, including Money Managers, when they determine such a change is necessary • Rebalance a client’s account in accordance with the investment strategy chosen by the client • Liquidate sufficient assets to pay the program and advisor fee, as well as other fees and charges associated with the account, when necessary The SMA Program enables Commonwealth, as sponsor of the program, to leverage Envestnet’s established relationships with Money Managers and to make the services of Money Managers available to clients. Envestnet provides SMA Program clients with the ability to access the money management services of one or more Money Managers, either directly using a separately managed account for each Money Manager or indirectly using a single managed account traded by Envestnet based on the instructions of the relevant Money Manager. The advisor will help their clients select one or more Money Managers and investment strategies for use within the SMA Program. If the client chooses to use the SMA Program, the client will establish a separate brokerage account for each Money Manager or strategy selected. PPS Direct SMA offers a direct indexing option. This program allows clients to create customized portfolios that seek to closely track the characteristics, exposures, and performance of a specific market index using a representative sampling strategy to buy a subset of the securities in the index that collectively will have a similar investment profile. The strategy will not hold all of the underlying market index constituents but will allow it to reflect the client’s unique preferences and investment goals. This approach enables clients to tailor their investments based on factors such as risk tolerance, investment time horizon, and tax considerations. A portfolio tailored for an SMA Program account may consist of any combination of the following types of securities that are managed by one or more Money Managers, as chosen by the client: • Individual equity and fixed income securities • Mutual funds • Exchange-traded funds (“ETFs”) The Strategist Program enables Commonwealth to leverage Envestnet’s established relationships with various third-party Money Managers who provide asset allocation portfolios for investments in mutual funds and ETFs. Envestnet will manage the asset allocation portfolio on a discretionary basis based on

the investment recommendations of the Money Manager(s) selected by the client. If the client chooses to use the Strategist Program, the client will establish a separate brokerage account for each strategist or strategy selected. For each Money Manager, Envestnet provides overlay management of the portfolios, whereby Envestnet performs model management, administrative, and/or trading implementation duties pursuant to the direction of the Money Manager. A portfolio tailored for a Strategist Program account may consist of any combination of the following types of securities that are managed by one or more Money Managers, as chosen by the client: • ETFs • Mutual funds The UMA Program enables the advisor to construct a single portfolio by selecting specific, underlying investment vehicles within asset allocation models defined by Commonwealth. The UMA Program offers clients an asset management account in which advisors, in their capacity as Investment Adviser Representatives of Commonwealth, are responsible for selecting the specific, underlying investment vehicles in the appropriate model to meet their client’s needs. Commonwealth’s Investment Management and Research team determines the target asset mix, and Envestnet provides overlay management with respect to the account. The UMA Program may be used by clients in combination with the SMA Program described above. If the client selects the UMA Program, the client will establish one brokerage account in which multiple Money Managers or strategies will be implemented. A portfolio tailored for a UMA Program account may consist of any combination of the following types of securities that are managed by one or more Money Managers, as chosen by the client: • Individual equity and fixed income securities • Mutual funds • ETFs The PPS Direct SMA/UMA and Strategist Program are offered to interested clients by advisors. Through consultation with the client, the advisor will obtain necessary financial data from the client to assist in determining the appropriateness of the account, and to help the client select one or more Money Managers or investment strategies based on the client’s stated goals and objectives. The client will have the opportunity to meet with their advisor periodically to review the assets in the account. At any time, subject to Envestnet’s, the Money Manager’s, or Commonwealth’s judgment, specific investments will periodically be reallocated within the client’s account to reestablish the targeted percentages of the assets and the appropriate investment strategy. This reallocation could be based on market conditions, specific client circumstances, or other factors that suggest reallocation may be appropriate. The client will be responsible for all tax consequences resulting from any account rebalancing or reallocation initiated by the client, Envestnet, Commonwealth, or a Money Manager. Clients participating in the PPS Direct SMA/UMA and Strategist Program will pay an annual fee that consists of a combination of an advisor fee and a program fee. In the event the combination of the advisor fee and the program fee for a particular Money Manager and investment strategy exceeds 3 percent the advisor fee will be reduced such that the annual fee will not exceed 3 percent. The program fee comprises a platform fee, a sponsor fee, a Money Manager fee, and custody and clearing charges and will vary based upon the selected Money Manager and investment strategy. Commonwealth retains the sponsor fee portion of the program fee with respect to SMA and UMA Program accounts. Commonwealth retains a portion of the program fee with respect to Strategist Program accounts, a portion of which Commonwealth uses to offset custody and clearing costs. The advisor fee is negotiated between the client and the advisor, a portion of which is retained by Commonwealth.

The maximum allowable annual advisor fee in the PPS Direct SMA/UMA and Strategist Program is as follows: Account Value Up to $250,000 Next $250,000–$499,999 Next $500,000–$999,999 Next $1,000,000–$1,999,999 Next $2,000,000–$4,999,999 Next $5,000,000 or more

Maximum Advisor Fee 2.21% 2.25% 2.27% 2.29% 2.31% 2.33%

The maximum annual program fee in the PPS Direct SMA/UMA and Strategist Program is as follows: Account Value Up to $250,000 Next $250,000–$499,999 Next $500,000–$999,999 Next $1,000,000–$1,999,999 Next $2,000,000–$4,999,999 Next $5,000,000–$9,999,999 Next $10,000,000–$19,999,999 Next $20,000,000-$39,999,999 More than $40,000,000

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