Northland Asset Management: investment adviser

is privately held by First National of Nebraska, Inc. (FNNI). First National of Nebraska, Inc. (“FNNI”) is a multi-state holding company that owns, among other entities, First National Bank of Omaha. Northland operates as a separate subsidiary under FNNI. FNNI is a holding company with nearly $30 billion in assets, nearly 5,000 employees, locations across 14 states, and a proud history of serving customers for more than 160 years. FNNI is a sixth-generation, family-owned financial holding company with banking, insurance, and financial services companies and allows Northland to better serve you, our valued client. Type of Advisory Services Offered Northland provides discretionary and non-discretionary investment advisory services that typically involve individualized financial goal analysis, asset allocation, formulation of an investment strategy, assistance with implementation of the investment strategy, and ongoing review of performance measures for the strategy adopted. Reviews generally consist of multiple checks such as a comparison between a client’s portfolio and relevant benchmarks, an analysis of the portfolio’s estimated annual income and current yield along with an analysis of the client’s realized and unrealized gains and losses. In addition, a review of the clients’ goals and investment objectives versus the performance and investments in the portfolio. Northland offers a variety of approaches to investing, which are based on the individual needs of each client. We do not specialize in any particular investment strategy. Northland provides investment advice to individuals, trusts, corporations, and other business entities. Tailoring Advice to Individual Clients Northland will custom tailor an investment portfolio specifically designed for the client based on the client’s investment objectives and goals. The process begins when the client fills out a confidential Client Profile. The Client Profile will allow the client to clarify their financial objectives and goals, establish the client’s tolerance for risk, and identify their preferred style of management. The client may also indicate any special instructions or limits that the client requires Northland to follow in managing the client assets. The Client Profile is used by Northland as the primary reference for managing the client portfolio. For portfolios that are managed in-house by Northland, the client may designate specific securities or industries that should be avoided. For accounts that are handled by Outside Managers, this is not always possible. Clients should make their Northland investment advisor representative aware of any restrictions they would impose on investments in order for their representative to develop an appropriate investment strategy or select an Outside Manager who will agree to implement these requests. Clients pay for Northland’s advisory services based on a fee as a percentage of assets in the account. Most clients participate in a general wrap fee program in which the fee covers advisory services, trading and other transaction

costs. However, there are costs that are passed through to the client by third party investment managers and respective custodian(s). Those costs outlined in Item 5 of this brochure. Northland is paid a fee as a percentage of assets. The RIA Client Services Agreement, which is signed by each investor, specifies what portion of the fees goes to Northland, as well as what portion goes towards the services of a third party investment manager and/or custodian program fees. Some third party outside managers require funds to be held at a separate custodian, which will cause clients to incur additional transaction fees. Clients should discuss their preferences regarding transaction fees and expenses with their Northland representative to ensure their chosen program best meets their specific needs. Discretion It is the client’s choice whether to allow discretionary trading in their accounts. If the client wishes to retain full discretion over the account, the investment advisor representative will provide investment advice, but the client makes all final decisions. The client may elect to allow an advisor to exercise full discretion in trading the client’s account. Discretion will be exercised by an Outside Manager, if the client elects to participate in an outside manager program. As of 12/31/2025, discretionary regulatory assets under management at Northland Asset Management were $387,310,427 and non-discretionary regulatory assets under management were $18,174,756.

Northland’s basic asset-based fee schedules for Investment Advisory Services are shown below: Investment Advisory Representative (IAR) Managed Program Northland offers an open architecture advisory account to allow client flexibility. Northland Management Fee: Custodian Program Fee: Total Asset Management Fees:

Up to 2.00% per annum Up to 0.09% per annum Up to 2.09% plus rebillable fees

Custodian Program Fee: HOUSEHOLD First $100K Next $150K Next $250K Next $500K Next $1M Next $3M Over $5M

Basis Points

The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee, which varies based on the total household assets under management, includes a range of a 4 basis point markdown to a 3 basis point markup, as applied by Northland. The markup is considered revenue to the firm. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management Fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 9 basis points or 0.09% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. Northland Asset Management ’NAM’ Model Strategy Program In the Northland Asset Management Model Strategy Program, Northland provides asset allocation models designed to allocate funds into a diversified mix of fixed income and/or equity market investments. The allocation may be adjusted to allow for a 10% inclusion of mutual funds which primarily invest in alternative asset classes. With every model, the mix affects the volatility and performance of your portfolio. Each model mix adjusts the equity to fixed income ratio going from 100% Equity/0% Fixed Income to 50% Equity/50% Fixed Income. Additional expenses will be associated with specific instruments held, such as mutual fund and exchange traded fund expense ratios. Northland Management Fee: Custodian Program Fee: Total Asset Management Fees:

Up to 2.00% per annum Up to 0.12% per annum Up to 2.12% plus rebillable fees

Custodian Program Fee: HOUSEHOLD First $100K Next $150K Next $250K Next $500K Next $1M Next $3M Over $5M

Basis Points 5.5 2.5

The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee, which varies based on the total household assets under management, includes a range of a 3.5 basis point markdown to a 3 basis point markup, as applied by Northland. The markup is considered revenue to the firm. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 12 basis points or 0.12% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter.

Third Party Strategists Models and Separately Managed Accounts (SMAs) Northland provides access to Third Party Portfolio Managers who manage accounts on a discretionary basis. Each Manager offers a specific style or strategy that Northland and the client may select. Northland also provides access to asset allocation models created by Third Party Model Providers. Generally, these models allocate funds into a diversified mix of fixed income and/or equity market investments that are based on the client’s desired risk/return parameters, goals, risk tolerance, etc. Northland Management Fee: Third Party Manager Fee : Custodian Program Fee: Total Asset Management Fees:

Up to 2.00% per annum Up to 1.00% per annum Up to 0.20% per annum Up to 3.20% plus rebillable fees

Custodian Program Fee: HOUSEHOLD First $100K Next $150K Next $250K Next $500K Next $1M Next $3M Over $5M

Basis Points

The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee, which varies based on the total household assets under management, includes up to a 6 basis point markup, as applied by Northland. The markup is considered revenue to the firm. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 20 basis points or 0.20% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. BNYMA Portfolios BNY Mellon Target Risk Focus Portfolios (formerly known as Lockwood WealthStart Portfolios) is a discretionary mutual fund and ETF wrap account product with a $10,000 minimum account size that seeks to assist emerging and mass- affluent investors grow their wealth. BNY Mellon / American Funds Core Portfolios (formerly known as Lockwood/American Funds Core Portfolios) are a discretionary mutual fund and ETF wrap account product with a $10,000 minimum account size. BNYMA, serving as the Portfolio Manager, allocates investor assets systematically across multiple asset classes and styles using American Fund’s mutual funds and other select ETFs in a single account.

Northland Management Fee: Custodian Program Fee: Total Asset Management Fees:

Up to 1.00% per annum Up to 0.37% per annum Up to 1.37% plus rebillable fees

Custodian Program Fee: HOUSEHOLD First $500,000 Next $500,000 Over $1,000,000

Basis Points

The Custodian Program Fee arrangement with Northland Asset Management’s custodian is applied to client’s account and is included in the Total Asset Management Fee. The Custodian will assess fees associated with services provided for the utilization of the investment advisory program you and your advisor selected. The Custodian Program Fee varies based on the total household assets under management. The services covered by the custodian fee include performance reporting, clearance and execution costs, and billing services. The Custodian Program Fee portion of the Total Asset Management fee is subject to change based on the total household assets within Northland Asset Management, but will not exceed 37 basis points or 0.37% of assets. Client(s) will absorb the increase or decrease in the Custodian Program Fee(s) due to household asset level changes. All accounts are subject to a minimum annual Custodian Program Fee of $35.00, with $8.75 assessed per quarter. Disclosure of Additional Expenses, Costs and Revenue Sharing Arrangements Clients understanding our fees, charges and other compensation is important to us. Fees such as annual IRA maintenance fees, wire fees, outgoing transfer fees, and others, are not included as part of the management or custodian program fees and will be paid by the client. These rebillable fees are outlined in the Northland Securities fee schedule and can also be found on the “Policies & Disclosures” page of the Northland Securities’ website (www.northlandsecurities.com) under “SEC RIA Program Disclosures.” If client assets are invested in mutual funds (including money market funds), exchange-traded funds, unit investment trusts, annuities or similar investment vehicles, internal management expenses and 12b1 fees will be part of the overall fees that the client will bear. The fees associated with these products will be disclosed in the applicable product’s prospectus. Clients who invest in these types of investment products will therefore pay two levels of advisory fees on these assets, one to the firm managing the assets and one to the investment product’s advisor at the fund level. Northland Securities retains a portion of the total fee assessed for specific rebillable fees; additional details are provided on the RIA Client Services Agreement executed between Northland and the client(s). Options The pass-through cost from Northland Asset Management’s custodian for option trades is currently $9 per trade, plus $0.50 per contract, and will be paid by the client. Use of Margin Margin investing allows you to have more assets available in your account to buy marginable securities. Your buying power consists of your money available to trade in your account, plus the amount that can be borrowed against securities held in your margin account.

The use of margin in advisory accounts creates conflicts of interest that you should understand. First, margin debit balances do not reduce the market value of assets in your account and therefore increase the asset-based advisory fee you pay. This increased fee creates an incentive for your advisor to recommend margin strategies. Second, Northland receives a portion of the margin interest charged by BNY Pershing on client margin debit balances. This revenue sharing creates a conflict of interest because Northland has a financial incentive to encourage clients to maintain margin loans rather than liquidating assets to pay for securities purchases, as maintaining margin loans increases our revenue. The use of margin is not suitable for all investors, as it increases leverage and risk in your account. Additional details regarding margin are provided in the advisory agreement executed between Northland and the client. Foreign Securities Clients will also be responsible for fees or expenses related to trading in foreign securities, which will include pass-through fees charged by third parties (portfolio managers and custodians), with respect to foreign securities. Clients will also be responsible for any additional cost and fees associated with cash management services that will be outlined under separate agreements, including but not limited to check-writing, debit and credit card services. Northland does not receive compensation or have a revenue sharing arrangement with BNY Pershing for cash sweep money market products offered in our investment advisory program. Fundvest® Platform Northland offers products from BNY Pershing’s Fundvest® mutual fund platform featuring no-transaction-fee mutual funds (e.g., no commissions, no front-end sales loads or deferred sales charges) subject to certain restrictions on short term trading and below minimum purchase amounts. Once certain asset thresholds of Fundvest® mutual funds are met, we receive revenue-sharing fees from BNY Pershing related to certain Fundvest investments. Our customers do not pay these fees directly but the revenue-sharing fees are often deducted from the total assets in the fund and therefore reduce investment returns. The receipt of revenuesharing fees by Northland creates a conflict of interest because it creates an incentive for Northland to support these products on its platform. Northland advisors do not directly receive the revenue-sharing fees nor are they compensated more for selling a Fundvest® product. Under the current agreement with BNY Pershing, Northland also receives 12b-1 fees from BNY Pershing on certain share classes in the Fundvest® mutual fund platform. As with all 12b-1 fees received for customers in our advisory platform, Northland credits back 12b1 fees paid to our customer accounts. Relationship with our Sole Clearing/Custody Firm BNY Pershing BNY Pershing LLC serves as the clearing and custody firm for Northland's brokerage and advisory business. Northland introduces client accounts to BNY Pershing on a fully disclosed basis, and BNY Pershing executes and clears transactions for these accounts. Clients are charged various fees for these services, as detailed in Northland's Fee Schedule, which is provided at account opening, published on our website, and available upon request. Conflicts of Interest Related to BNY Pershing Relationship Northland's agreement with BNY Pershing includes financial terms that create conflicts of interest regarding our continued use of BNY Pershing as our clearing and custody provider. These include:

Termination Fees and Deconversion Costs: If Northland terminates its relationship with BNY Pershing, we would incur termination fees and deconversion-related expenses. These costs create a financial disincentive for Northland to change clearing firms, which conflict with our obligation to use custodians that are in our clients' best interests.

Minimum Fee Requirements: Our agreement with BNY Pershing requires minimum quarterly fees, creating a financial incentive to maintain sufficient business volume with BNY Pershing.

Material Adverse Economic Impact Provisions: Our agreement contains provisions that allow BNY Pershing to revise pricing if certain "material adverse economic impact events" occur. These events could include changes in our business volume, regulatory requirements, or market conditions. The potential for price increases creates uncertainty and an additional incentive to avoid actions that might trigger such adjustments.

These financial arrangements create an incentive for Northland to continue our exclusive relationship with BNY Pershing even if alternative custodians might offer lower costs or other advantages that would better serve our clients’ interests. Northland addresses these conflicts through our compliance program and written supervisory procedures, which include:

Regular evaluation of BNY Pershing's services, pricing, and platform capabilities Periodic assessment of alternative custody and clearing providers Oversight to ensure clients receive expected services and benefits from our BNY Pershing relationship

However, clients should understand that the financial penalties and commitments described above influence our decision-making regarding our clearing relationship Selected Third Party Outside Managers Northland Asset Management currently has agreements in place with two outside managers that provide our clients with unique investment opportunities. These accounts are not held at BNY Pershing, our custodian.

Minneapolis Portfolio Management Group (MPMG)

SEI Investments

All clients will receive the applicable ADV documents relating to each outside manager upon solicitation and/or account opening. Management and advisory fees are outlined in applicable client agreements. Northland Management Fee: Third Party Manager Fee Total Asset Management Fees:

2.00% per annum 1.50% per annum 3.50% plus applicable fees of selected custodian.

Fees charged by Northland may be negotiated and agreed to based upon factors such as the overall complexity of the client’s financial situation, the types of investments, and the number of investing entities. Fees paid to Northland do not necessarily include fees and expenses charged by independent third party managers for certain investments such as mutual funds, exchange traded funds, and/or other index-based investments selected by clients, nor any fees due to brokers or to custodians of those assets including those that are related to Northland. Either party may terminate the investment advisory agreement by written notice and will be effective upon receipt. Any fees that have been prepaid by the client shall be refunded on a pro-rata basis based upon the number of calendar days remaining after the termination date in the period for which fees have been prepaid. Northland may provide financial planning or other advisory services on an hourly basis or based on a one-time charge for service, as agreed to by written agreement. Additional information regarding various options in the Wrap Fee Program can be found in Appendix 1. More information about brokerage fees can be found in Item 12 of this brochure. Northland generally does not receive additional compensation for advisory accounts, other than from its basic fee. However, one exception involves the payment of due diligence fees or other fees from a product originator(s). An example of this would be a Real Estate Investment Trust that provides compensation to Northland to assist with costs in completing our due diligence on the product. Due diligence fees of this nature do not provide a significant source of revenue for the firm. Any fee of this type is fully disclosed in the product prospectus. Northland does not receive any ‘soft dollar’ benefits or other types of compensation that would be unknown to the client. If any additional fee or compensation is received by Northland, as a consequence of the advisory business, it is not used to offset or discount the client fees. Investment Advisor Representatives at Northland receive compensation based on the amount of revenue they generate for the firm. They are rewarded for bringing clients to the firm and for increasing assets under management. While representatives are to serve the best interests of their clients, they are also motivated to receive personal compensation and to contribute to the profitability of the firm. A conflict of interest could occur if the representative or the firm promoted products and services based on a profit motive rather than service to the client. The primary way to address this potential conflict is through transparency of information regarding investment options and fees.

Northland Asset Management ’NAM’ Model Strategy and Third Party Managed Programs Northland may utilize a variety of different managers, both internal, (within Northland) and external. This gives our clients access to different managers and strategies, in order to provide the best opportunities for our clients. A Northland Investment Advisor Representative will evaluate a client’s investment profile and will work with them to determine a strategy and manager that will help fulfill the client’s investment goals. Northland’s programs offer clients tailored options to meet their investment goals. In general, risk in client’s portfolios are reduced through diversification of investments. Entire markets and sectors can decline, and there can be no assurance that the client will not suffer a loss. By working closely with their Investment Advisor Representative, clients will develop portfolios that are designed to meet their needs and are adjusted for risk concerns. ************************************************************************ Northland Asset Management ’NAM’ Model Strategy In the Northland Asset Management Model Strategy Program, Northland provides asset allocation models designed to allocate funds into a diversified mix of fixed income and/or equity market investments. The allocation may be adjusted to allow for a 10% inclusion of mutual funds which primarily invest in alternative asset classes. With every model, the mix affects the volatility and performance of the portfolio. Each model mix adjusts the equity to fixed income ratio going from 100% Equity/0% Fixed Income to 50% Equity/50% Fixed Income. The higher the equity percentage, the more an investor is seeking to take advantage of higher potential for growth. This also means there is more exposure to risk and therefore more potential for fluctuation. The more a model is weighted with a fixed income position, the investor is seeking more opportunities for stable growth and less volatility but with less upside potential than its higher equity counterpart. When choosing which model fits your needs, there are many factors that you and your advisor will discuss such as your risk tolerance, investment time horizon, and personal goals. Each strategy may be implemented within a separate account managed by your advisor to help achieve a range of personal goals. Model Mix

Strategy This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 100% equity assets. The portfolio manager invests exclusively in various Equity Mutual Funds and Equity Exchange Traded Funds. Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request

90/10

This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 90% equities and 10% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request

80/20

This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 80% equities and 20% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request

70/30

This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 70% equities and 30% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request

60/40

This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 60% equities and 40% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request

50/50

This investment strategy seeks total return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 50% equities and 50% fixed income assets. The portfolio manager invests exclusively in various Mutual Funds (equity, fixed income and multi- asset) and Exchange Traded Funds (equity and fixed income). Selection of this strategy indicates a willingness to assume risk of principal loss. More detailed information on this strategy is available upon request ************************************************************************

Our third-party program is available to our investors through our custodial relationship with BNY Pershing, and BNYMA Advisors. Northland’s responsibility as Sponsor for these programs include gathering a full description of client financials, risk tolerance and investment objectives to assist in determining the suitability of the program that Northland and the client select. Northland will also facilitate account opening and continued monitoring of

client financial situation and investment objectives. The client will agree to provide discretionary authority to BNYMA to facilitate trading of their selected portfolio and/or strategy. BNYMA’s range of investment offerings includes, but is not limited to the following:

Separately Managed Accounts (“SMA”) – Researched SMA managers and open architecture managers; Third Party Model Providers – Open architecture mutual fund and ETF models; BNY Mellon Target Risk Focus Portfolios – A fixed mutual fund and ETF wrap product with a low minimum account size; The BNY Mellon/American Funds Core Portfolios – a mutual fund and ETF wrap product constructed using American Funds mutual funds;

Third Party Separately Managed Accounts (SMAs) Northland Asset Management has access to Managers through the BNYMA Managed Account Command program. These managers specialize in investment strategies that are expected to meet the client’s goal. Northland Asset Management conducts due diligence on the Managers as part of the selection process to evaluate what Managers are best suited to meet our client’s goals and objectives. Northland’s Investment Advisor representatives make recommendations to each client, based on an individual suitability analysis. The selected Outside Manger is granted limited discretionary trading authority, with respect to assets in the clients account(s), however the client and Northland retains final authority for the Manager selection. Based on the Manager’s policies, clients may have the option to restrict investments in their accounts, to avoid certain companies and/or industries. Disclosure of fees and costs will be specified in the RIA Client Services Agreement, along with the standard fee schedule and this document. Third Party Strategists Model Providers Northland will make available to its client, Third Party Model Portfolios, which are open architecture mutual fund and ETF models. These portfolio models and managers are available through an agreement between Northland, BNYMA, and the Model Providers. The models are designed to invest assets according to the selected model that the client and Northland believe will achieve certain objectives and investment goals. Each Model consists of a unique asset class mix, and has a distinctive risk profile. Assets are invested in accordance with the client’s investment objective and level of risk. Once the client has selected the Third Party Model Providers Models program, the account is invested in a combination of some or all of the following investment products, pursuant to the Model you have selected: Equity or fixed income securities; ETFs; and mutual funds. Certain Third Party Model Providers have a minimum account size of $10,000. BNYMA is granted limited discretionary trading authority with respect to assets in the clients Third Party Model Providers Model account(s). The client and Northland retain final authority for the Third Party Model Providers and Model selections. Pursuant to its discretionary trading authority, BNYMA will invest the assets in the account according to the Model the client has selected. BNYMA will also periodically buy and sell securities in the account so that the assets owned are in line with the Model without receiving prior approval from the client. This process is known as “rebalancing.” Asset allocations will differ depending on the Model selected. Once a particular Third Party Model Provider notifies BNYMA of model portfolio changes, BNYMA will make corresponding changes to the account. BNYMA reserves the right to not accept a particular change to a Model.

For example, if a security is subject to a reasonable restriction imposed, BNYMA will not purchase that security for the account. When a Third Party Model Provider makes model portfolio changes, the Third Party Model Providers may notify BNYMA after the Third Party Model Providers has bought and sold securities in its other clients’ accounts. As a result of the timing of Model change notifications and BNYMA’s processes, Third Party Model Providers may effect trades on behalf of their other clients’ accounts before BNYMA effects corresponding trades in your account. Therefore, in connection with model portfolio changes, due to the potential for the markets to react to the trades effected by a Third Party Model Provider, you may be at a disadvantage when compared to the Third Party Model Provider’s other clients with respect to the timing of the trades. Third Party Model Providers are not responsible for determining the appropriateness or suitability of investment model(s), or of any of the securities included in the investment model(s) for the client specifically. Notwithstanding the foregoing, the client and Northland may wish to review each Third Party Model Provider’s ADV Part 2A or alternative disclosure document for more information regarding a Third Party Model Provider. BNY Mellon Target Risk Focus Portfolios BNY Mellon Target Risk Focus Portfolios allow advisors and their clients access to multi-manager solutions and strategies. With this solution, advisors will be able to assist clients in growing their wealth. Investors have access to mutual fund and / or exchange traded fund accounts that allocates client assets across multiple asset classes and styles and bundles them into one single account. BNYMA is the Discretionary Portfolio Manager for BNY Mellon Target Risk Focus Portfolios. Northland is the Sponsor of the program The minimum account size is $10,000, with minimum subsequent investment of $1,000 each. BNYMA/American Funds Core Portfolios The BNYMA/American Funds Core Portfolio is a discretionary mutual fund and ETF wrap account product with a $10,000 minimum account size. BNYMA, serving as the Portfolio Manager, allocates investor assets systematically across multiple asset classes and styles using American Funds mutual funds and other select ETFs in a single account. BNYMA determines the asset allocation strategy and selects investment vehicles for each investment style in the portfolio, based upon proprietary modeling strategies, economic outlook and investment research discipline. BNYMA is solely responsible for the fund selection and construction of the BNYMA/American Funds Core Portfolios and neither American Funds Distributors, Inc. or its affiliates are involved in such activities, nor do American Funds Distributors, Inc. or its affiliates serve as investment adviser to client accounts. The BNYMA/American Funds Core Portfolios consist of three models designed to align with key stages of the investor lifecycle, which may consist of open and closed-end mutual funds, exchange-traded funds and other types of securities. BNYMA is the Discretionary Portfolio Manager for the BNYMA/American Funds Core Portfolios. Northland is the Sponsor of the program ************************************************************************ Northland Asset Management currently has agreements in place with the following two strategic outside third party managers: Minneapolis Portfolio Management Group (MPMG) • MPMG invests in both domestic and international small, mid and large-cap value equity securities.

SEI Investments • SEI is a global asset manager that provides diversified portfolios and strategies across equity, fixed income and alternative investments.

A full description of these violations can be found in the Investors section of the Financial Industry Regulatory Authority’s (“FINRA”) web site by accessing their BrokerCheck® link, which can be found at: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ . Or you may request a copy of the disciplinary action from your Investment Advisor Representative or by sending a request to the following address: Northland Securities, Inc. Attn: Compliance 150 South 5th Street Suite 3300 Minneapolis, MN 55402

Investment opportunities must be offered first to clients before Northland or its associated persons may participate in such transactions; Associated persons or their immediate family members shall not buy or sell securities for their personal portfolio(s) where their decision is derived in whole or in part, by reason of the associated person's employment, unless the information is also available to the investing public upon reasonable inquiry; Northland and its employees will not participate in private placements or initial public offerings (IPOs) without prior approval from Northland’s senior management; Northland requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices; Records will be maintained of all securities bought or sold by Northland and its associated persons. A qualified representative of Northland will review these records on a regular basis; Fee discounts not generally available to our advisory clients may be offered to family members and friends of associated persons of our firm. Any individual not in observance of the above may be subject to disciplinary action up to and including termination. The full text of Northland’s Code of Ethics is available to you upon request.

Best execution does not necessarily mean the lowest available price. It is important to understand that Northland only uses a single custodian, as such the firm cannot choose between custodians to obtain the least clearing and execution costs so consequently the client could be paying more per transaction. In very limited circumstances, trades are routed to Northland Securities equity trading desk for execution, and that would only be in circumstances where a large trade over 10,000 shares would require execution. In those circumstances the client could pay higher costs for execution, but Northland feels the client would receive a more favorable execution versus sending it via BNY Pershing’s trading system for execution. We have determined that having BNY Pershing execute most trades is consistent with our duty to seek “best execution” of client trades. Best execution means seeking the most favorable terms for a transaction based on all relevant factors, including products and services available through our custodian to assist us in managing and administering our client’s accounts. The custodian makes available software and other technology that provide access to client account data, facilitates

trade execution for client accounts, provides pricing and other market data, facilitates payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. Northland Asset Management does not receive any ‘soft dollar’ compensation from any third party. Northland does not receive any referral fees from broker dealers for directed brokerage. Policies for order aggregation would generally follow the procedures of Outside Managers. Northland internal account management is not of a volume to necessitate aggregation procedures. We may utilize cross trades for securities that are hard to purchase or sell in the open market (ie small bond lots or thinly traded stocks or bonds). Cross trades will be done through Northland Securities trading desk at current bid/ask pricing. Northland Asset Management or Northland Securities will receive no compensation for these trades. Written client notification will be provided in these limited circumstances. There are other fees that Northland will mark up from what the clearing firm charges. These are marked up to defray Northland’s processing costs. Those fees are outlined and identified in the fee schedule that is provided at account opening, and on Northland’s public website. Northland charges up to $140.00 (dependent on account type) termination fee when clients transfer their accounts to another investment advisory firm.

If an exception is identified during a quarterly review, the firm will take steps to remediate, if necessary. Remediation could include a conversion to a different share class, or refund/rebate of compensation (if deemed material) received by the firm and the investment advisor. A supplemental review is conducted by the Chief Compliance Officer or delegate as part of the inspection process. Clients or their independent representatives are provided with a statement from the custodian holding the client's funds/securities at least quarterly and may be provided with a monthly written report generated by Northland, showing client holdings. Investment advice may only be rendered by qualified investment advisory professionals who have been approved by Northland. Generally, a college degree and/or equivalent business experience is required for investment advisory professionals, other than those performing clerical or ministerial services. Most states require licensing. The independent custodian provides clients with a statement (at least quarterly) identifying the amount of funds and of each security in their accounts at the end of the reporting period and setting forth all transactions in the account during the reporting period. Northland also makes various reports and quarterly performance evaluations accessible to its clients. Trade Confirmations: Individual trade confirmations and reports of account activity will be provided by the custodian. Northland will generally communicate with its clients via letters, market up-dates and other Northland generated literature.

Under circumstances where the client has expressly consented, client correspondence and notifications may be sent via electronic means (such as e-mail). In addition, when an outside manager is selected, the client may choose suppression of confirmations on the RIA Client Services Agreement.

The custodian maintains the underlying records for the assets held in the account. Northland does not serve as the custodian for those clients’ managed assets. The client is solely responsible for paying all the fees and charges of the custodian as stated in the third party agreement with the custodian. Northland strives to maintain the account data as accurately as possible; however, the firm must rely on accurate reporting provided to it by the custodian through electronic or other means. Northland is not responsible for inaccurate data provided by a custodian. Clients are requested to promptly submit to Northland in writing any changes to the Client Profile, or any changes to any information that was provided to the firm regarding management of the client assets. Maintaining proper records and documentation regarding each account is vitally important.

In cases where Northland determines the broker or dealer to be used, the firm will seek to obtain the best execution possible under the circumstances. This discretionary authority in no way restricts clients, from establishing special limitations on the types of investments that may be recommended or made on the client’s behalf. Clients may send Northland specific written instruction at any time regarding securities that may be purchased or sold, and may also instruct the firm not to purchase specific securities or types of securities. If Northland is unable to accommodate client requests for any reason, the Investment Advisor Representative will notify the client promptly.

Upon termination of the Firm’s investment management services, Northland has no obligation or authority to recommend or take any action with regard to the previously managed assets.