Edelman Financial Services, LLC Investment Advisory Services

Transcription

1 Edelman Financial Services, LLC Investment Advisory Services This brochure provides information about the qualifications and business practices of Edelman Financial Services, LLC. If you have any questions about the contents of this brochure, please contact us at 888-PLAN-RIC ( ) or you may us at or write us at the address below. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission ( SEC ) or any state securities authority, nor does registration with the SEC imply a certain level of skill or training. Additional information about Edelman Financial Services, LLC is also available on the SEC s website at Legato Road, 9 th Floor Fairfax, VA EdelmanFinancial.com RicEdelman.com 888-PLAN-RIC ( ) (fax) info@ricedelman.com January 17, 2018

2 Item 2: Material Changes Significant changes to this updated brochure are contained in this section. Future brochures will contain similar summaries. The following are material changes to this brochure that were made since the last annual amendment was filed March 31, 2017: We have revised Item 11 to describe our joint marketing arrangement with Morningstar (as defined below) and the potential conflict of interest resulting from this relationship. In addition, Jon Isaacson joined EFS on November 27th as the Chief Financial Officer. Rene Chaze was the CFO and has assumed a new role as Chief Development Officer, leading the firm s inorganic growth strategy. We review our brochure and revise existing disclosure when we believe our clients would benefit from an enhanced description of EMAP (as defined below) and our services. In addition to the material changes summarized above, we have made a number of immaterial changes to this brochure to enhance existing disclosure. Under SEC rules, we ll give you a new brochure within 120 days of the end of our fiscal year. You may also receive updates at other times if material information changes. You may request a new brochure at any time and at no charge. You can request a free brochure by calling us at 888-PLAN-RIC. You can also find out more about us and receive our current brochure from the SEC s website: The site can also give you information about people who are registered, or about to be registered, as Investment Adviser Representatives of our firm. Form ADV 2 January 17, 2018

3 Item 3: Table of Contents Edelman Financial Services, LLC Investment Advisory Services... 1 Item 2: Material Changes... 2 Item 3: Table of Contents... 3 Item 4: Advisory Business... 7 Background of Edelman Financial Services, LLC... 7 Advisory Services Offered... 7 Wrap Fee Asset Allocation Program... 7 Financial Planning... 8 Edelman Retirement Program... 9 Asset Allocation Models... 9 Additional ERP Services EFS May Provide in the Future IRA Rollover Considerations College Education Savings Financial Education Institutional Advisory Services Assets Under Management Item 5: Fees and Compensation Retail Turnkey Asset Management Program (TAMP) Institutional Edelman Retirement Program (ERP) Other Fees Earned by EFS Financial Plans Seminars Form ADV 3 January 17, 2018

4 Speaking Engagements Educational Products RIC-E Trust Item 6: Performance-Based Fees and Side-by-Side Management Item 7: Types of Clients Minimum Account Size EMAP Institutional ERP Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Investment Strategy Methods of Analysis and Investment Selection Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations Related Persons Affiliated Broker-Dealer Other Affiliated Investment Advisers and Broker-Dealers Insurance Agencies Equity Investors The Retirement InCome for Everyone Trust (RIC-E Trust ) Item 11: Code of Ethics, Participation of Interest in Client Transactions and Personal Trading Code of Ethics Related Person May Invest in the Same Securities Agency Cross Procedures Conflicts of Interest and Other Disclosures Form ADV 4 January 17, 2018

5 College Education Savings (Item 4) IRA Rollover Considerations (Item 4) Educational Products and Promotional Materials (Items 4 and 5) Affiliated Broker-Dealer Related Conflicts (Items 5 and 10) Fees and Expenses (Items 5, 8 and 12) Involvement with the NANR and XT ETFs (Items 8 and 14) Insurance Related Conflicts (Item 10) Related Person May Invest in the Same Securities (Item 11) Economic Benefit from Third Parties (Item 12) Institutional Alliance Related Conflicts (Items 12 and 14) Sponsorship of The Truth About Money Television Program (Item 14) Dimensional Funds Related Conflicts (Item 14) Item 12: Brokerage Practices Brokerage Selection ERP Step-Out Trades Best Execution Trade Errors Soft Dollars Client Referrals Trade Aggregation Policy Item 13: Review of Accounts Non-Advisory Account Aggregation Technology Services Investment Committee ERP Item 14: Client Referrals and Other Compensation Form ADV 5 January 17, 2018

6 Turnkey Asset Management Program (TAMP) Client Referrals TD Ameritrade Institutional Program Compensation for Other Products and Services TD Ameritrade Advisory Panels Orion and Salentica Advisory Panels Dimensional Fund Advisory Panels Sponsorship of The Truth About Money Television Program Evaluation of NANR, XT and Other ETFs TDA Sponsorship of EFS Corporate Events EFS Participation in the Financial Planner Reentry Initiative Evaluation of Dimensional Funds Products Item 15: Custody Item 16: Investment Discretion EMAP Risks Trading Authorization Reallocations Rebalancing Liquidations Contributions ERP Designated Investment Alternatives, Qualified Default Investment Alternatives, and Models Model Reallocations Model Rebalancing Item 17: Proxy Voting Client Securities Form ADV 6 January 17, 2018

7 Item 18: Financial Information Item 4: Advisory Business Background of Edelman Financial Services, LLC Edelman Financial Services, LLC (sometimes referred to as EFS, Firm or We ) is an investment advisory firm registered with the United States Securities and Exchange Commission under the Investment Advisers Act of EFS provides investment advisory services and financial education to consumers, institutions and other entities throughout the country. EFS was founded in the late 1980s by Ric and Jean Edelman. Today we are headquartered in Fairfax, Virginia and have branch offices located throughout the country. H&F Corporate Investors VII, Ltd. is the ultimate controlling party for a series of limited partnerships that indirectly own approximately 71.5% of The Edelman Financial Center, LLC, the direct parent of EFS. Other investors, including The Edelman Financial Center, Inc., whose sole shareholder is Ric Edelman, Executive Chairman of EFS, also have indirect ownership interests in EFS. Advisory Services Offered EFS provides financial planning, investment management, financial education, and insurance services to individuals; trusts; estates; charitable organizations; foundations; high net worth individuals; individual retirement accounts; pensions, retirement and profit-sharing plans; institutions; and small to mid-sized businesses, including corporations. Our wrap fee program, discussed below, is available to our clients and to unaffiliated registered investment advisers and their clients. EFS advisory personnel are also registered representatives of EF Legacy Securities, LLC ( EFLS ), an affiliated registered broker-dealer. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Wrap Fee Asset Allocation Program The Edelman Managed Asset Program ( EMAP ) is a wrap fee asset allocation program sponsored by EFS. Through EMAP, we create diversified asset allocation models for clients. The investments in these models include: mutual fund shares of no-load, open-end registered investment companies, exchange-traded funds (ETFs), and occasionally, variable annuities and 529 College Savings Plans. EFS Investment Adviser Representatives ( Advisors ) meet with clients to discuss their needs. Investment objectives and risk tolerance are the main factors that help us recommend an asset allocation model. We also consider the client s personal situation, including age, health, family Form ADV 7 January 17, 2018

8 circumstances, income, expenses, assets, debts, liquidity needs, goals, personal objectives, suitability, time horizon and other relevant factors. Alternatively, the client may choose to use the Edelman Guide to Portfolio Selection ( GPS ) to guide them through the process and help them select an appropriate EMAP asset allocation model, based on their investment experience, risk tolerance, age, primary investment objectives, time horizon, and the amount of money they have to invest. Also referred to as Edelman Online or simply the client portal, GPS utilizes more of a riskbased approach, as opposed to the goals-based and risk-based approach typically taken when the client meets directly with an Advisor. Working directly with an Advisor or using GPS has no bearing on the advisory fees that the client pays, since even if the client chooses GPS they still have access to an Advisor. If a client s investment objectives or financial situation changes, they are instructed and reminded to contact an Advisor. Clients are allowed to place reasonable restrictions on the management of their accounts. This includes deciding to sell or not to buy particular securities or types of securities. However, a client cannot require us to buy particular securities or types of securities. We reserve the right, at our sole discretion, to close an account if unreasonable or overly restrictive conditions are requested. Either a client or EFS can end the relationship with written notice to the other. We receive a wrap fee for our services and we bill clients quarterly in arrears. If the relationship ends before the quarter does, the client will pay only a prorated amount. In addition to the advisory services described above, EFS offers to clients a personal finance information management tool, designed to aggregate information regarding a client s account(s) at EFS and other investment accounts, bank accounts, credit cards, 401(k) accounts, brokerage accounts, frequent flyer miles and other financial account information established through or held with third parties. Please see Item 11 for further information. Financial Planning EFS Advisors prepare a financial plan for clients based on their financial and personal circumstances and charge a one-time fee, when the plan is created, that can be waived in part or in whole at the Advisor s discretion. Each financial planning client has the choice of selecting EFS to invest on his/her behalf on a limited discretionary basis (meaning we can carry out some financial transactions in accordance with the asset allocation model selected by the client without first consulting the client) by establishing an EMAP account, or the client can implement the financial plan elsewhere or on his/her own. Clients who choose to implement the financial plan elsewhere will not receive ongoing investment advice from EFS. Advisors provide ongoing financial planning services to clients who participate in EMAP. We do not provide individualized legal or tax advice. As discussed above, financial planning services are tailored to the needs of each client and based on their financial situation and personal circumstances. The Advisor may also, at his/her sole discretion, decline to assist the client with the implementation of investment strategies or choices that have not been recommended or that the Advisor deems not to be in the client s best interest. Form ADV 8 January 17, 2018

9 EFS may create an arrangement with a corporation or other organization where a combination of financial planning, advice and/or educational services are provided to employees or members. Individuals who receive a financial plan are under no obligation to implement the plan with EFS. Edelman Retirement Program EFS makes the Edelman Retirement Program ( ERP ) available to plan sponsors of 401(k), profitsharing, non-qualified deferred compensation and retirement plans ( Plans ), subject to the Employee Retirement Income Security Act of 1974 ( ERISA ), as amended, and other employee retirement plans that are not subject to ERISA ( Plans ). These Plans include both participantdirected and trustee-directed Plans. Through ERP, EFS currently creates and maintains model asset allocation portfolios ( Models ) to be made available to Plans. ERP anticipates that in the future, it will make available the following additional services: Assistance with respect to the preparation of investment policy statements ( IPSs ) for Plans; Discretionary or non-discretionary advice with respect to the selection, monitoring and replacement of a Plan s designated investment alternatives ( DIAs ); Discretionary or non-discretionary advice with respect to the selection, monitoring and replacement of a Plan s qualified default investment alternatives ( QDIAs ); and Retirement plan consulting services that include administrative aspects of plan investments, service provider, and investment monitoring support, as well as participant investment and financial education. Generally, our Advisor holds an initial meeting with the Plan sponsor (or other Plan fiduciary or agent) to explain the services available through the ERP, and applicable fees, and to collect detailed financial data about the Plan. Emphasis is placed on identifying the Plan s investment objectives and determining the financial situation of the Plan. If the Plan sponsor (or other Plan fiduciary or agent) determines that the ERP is appropriate for the Plan, then the Plan sponsor (or other Plan fiduciary or agent) will establish an ERP account on behalf of the Plan. See Item 5 for Fees and Compensation associated with the Edelman Retirement Program. Asset Allocation Models Through ERP, EFS creates and makes available a range of asset allocation models, each consisting of a diversified mix of asset classes (each a Model ). Consistent with the Plan s investment objectives and financial situation, EFS will recommend one or more Models to Plan sponsors (or other Plan fiduciaries or agents). EFS offers Plan sponsors the option of delegating discretionary authority to EFS with respect to the selection of particular Models on behalf of the Plans using the ERP. In addition, EFS will select the underlying asset classes for the Models and the underlying investment securities for each underlying asset class. Usually, the investment securities consist of funds including, but not limited to, shares of open-end registered investment companies, such as mutual funds and ETFs (collectively, the Underlying Funds ). Form ADV 9 January 17, 2018

10 The Plan sponsor (or other Plan fiduciary or agent) will then approve one or more Models to be used for the investment of the Plan s assets. EFS will then use its discretion to invest the Plan s assets in the Underlying Funds pursuant to the Models selected by the Plan sponsor (or other Plan fiduciary or agent), as documented in the Plan s investment policy statement (or otherwise). Using the authority granted by the Plan sponsor (or other Plan fiduciary or agent), EFS rebalances the asset classes and Underlying Funds used in each Model periodically, in order to maintain the desired asset allocation for each Model. In addition, EFS will occasionally modify the strategic asset allocations and reallocate the asset classes and Underlying Funds for each Model, based on revisions to the Models recommended by EFS Investment Committee. The Plan sponsor (or other Plan fiduciary or agent) will generally receive notice of changes to the strategic asset allocations after they are implemented. In the case of a participant-directed Plan, after the Plan sponsor (or other Plan fiduciary or agent) reviews and approves our recommended Models, the Models are offered to Plan participants as investment options (the Investment Options ). Participants will select an Investment Option for their Plan accounts. The Underlying Funds will also be available to Plan participants who do not select an Investment Option for direct investments, if the Plan sponsor (or other Plan fiduciary or agent) permits it. With the Plan sponsor s (or other Plan fiduciary s or agent s) permission, we make general educational information regarding saving for retirement and asset allocation, and the Investment Options available to the Plan s participants. We do not have discretion to choose particular Investment Options for participants, and are not responsible for reviewing or changing any participant s decision to invest in a particular Investment Option. Moreover, if the Plan makes available investment alternatives other than the Investment Options and Underlying Funds, including, but not limited to, a self-directed brokerage window, we do not assume any responsibility with respect to a participant s decision to invest in such options. On an ongoing basis, we work with the Plan s Third-Party Administrator ( TPA ) and recordkeeper to ensure that the selected Investment Options are properly implemented. With the Plan sponsor s (or other Plan fiduciary s or agent s) permission, we give instructions to the recordkeeper to do the following: Invest the Investment Options in the underlying asset classes and Underlying Funds pursuant to the applicable Model; Periodically rebalance each Investment Option in accordance with the applicable Model; and Strategically modify the allocations for the Investment Option to reallocate the mix of investments in accordance with changes to the asset allocations recommended by the EFS Investment Committee. Plan sponsors (or other Plan fiduciaries or agents) are permitted to impose reasonable restrictions on the underlying assets used in the Investment Options recommended to the Plan. With respect to such restrictions, a Plan sponsor (or other Plan fiduciary or agent) may request that particular securities or types of securities not be purchased, or that such securities be sold. Plan sponsors (and other Plan fiduciaries or agents) should know that we are unable to influence or change the mix of Form ADV 10 January 17, 2018

11 securities held by any Underlying Fund in which the Plan is invested. We reserve the right, at our sole discretion, to reject any Plan account where unreasonable or overly restrictive conditions are requested. Plan sponsors (and other Plan fiduciaries or agents) are reminded to inform their Advisor if the Plan s investment objectives or financial situation changes. The professional relationship between the Plan sponsor (or other Plan fiduciary or agent) and EFS may be terminated at will by either party upon written notice. Plans that make EFS Models and Underlying Funds available through the ERP may make other investment options available for the investment of Plan assets, including, but not limited to, funds other than the Underlying Funds and self-directed brokerage windows. EFS does not currently have any discretionary or non-discretionary authority or responsibility with respect to such other investment options. EFS anticipates that it will in the future offer discretionary and nondiscretionary investment advisory services with respect to other investment options available under Plans enrolled in the ERP. Plan sponsors (and other Plan fiduciaries or agents) may be introduced to ERP through other unaffiliated registered investment advisers. The unaffiliated registered investment adviser initiates and maintains the relationship with the Plan sponsor. Specifically, the unaffiliated adviser does the following: Collects detailed financial data about the Plan; Provides educational guidance to Plan participants regarding saving for retirement and asset allocation models; and Meets with the Plan sponsor (or other Plan fiduciary or agent) on a periodic basis to discuss suitability and any reasonable restrictions. The unaffiliated adviser assists the Plan sponsor (or other Plan fiduciary or agent) with the completion of the new account documentation, including the ERP Investment Management Agreement. After the ERP Models, asset classes, and Underlying Funds have been approved by the Plan sponsor (or other Plan fiduciary or agent), the unaffiliated adviser promptly communicates the information to EFS. The unaffiliated adviser remains responsible for assessing initial and ongoing suitability of ERP and for introducing the appropriate Models and Underlying Funds to the Plan sponsor (or other Plan fiduciary or agent). The unaffiliated advisor may offer ERP or any other financial planning product(s) that meets the needs and goals of a prospective Plan. The unaffiliated adviser may charge a separate fee for its services, and does not share in the advisory fee generated from any Plan assets that are invested in ERP. We receive no compensation or economic benefit from products or services offered by the unaffiliated adviser to Plans, other than ERP. In addition, neither will receive any additional compensation related to the Underlying Funds. See Item 5 for Fees and Compensation associated with the Asset Allocation Model. Form ADV 11 January 17, 2018

12 Additional ERP Services EFS May Provide in the Future EFS anticipates that it will provide the following additional discretionary and non-discretionary services in the future: Investment Policy Statements: Based on the Plan s investment objectives, financial situation, and other relevant factors, the Advisor will provide recommendations to assist the Plan sponsor (or other Plan fiduciary or agent) with respect to establishing or revising an investment policy statement ( IPS ) for the Plan. The Plan sponsor (or other Plan fiduciary or agent) will be responsible for approving and adopting the IPS (or any revisions thereto). Designated Investment Alternatives: Based on the Plan s IPS and the available investment options, our Advisor will select (in the case of discretionary services), or recommend the selection of (in the case of non-discretionary services), the DIAs to be made available under the Plan. Once selected, the Advisor will monitor the DIAs on a periodic basis, and replace or remove, or recommend the replacement or removal of, DIAs that no longer satisfy the criteria set forth in the IPS, or otherwise are not consistent with the Plan s investment objectives or financial situation. Qualified Default Investment Alternatives: Based on the Plan s IPS and the available Investment Options, our Advisor will select (in the case of discretionary services), or recommend the selection of (in the case of non-discretionary services), the QDIA(s) to be made available under the Plan. A participant s Plan account may be invested by default in the QDIA where the participant does not provide an investment direction for his or her Plan account. Once selected, the Advisor will monitor the QDIA(s) on a periodic basis, and replace or remove, or recommend the replacement or removal of, QDIA(s) that no longer satisfy the criteria set forth in the IPS, or otherwise are not consistent with the Plan s investment objectives or financial situation. Retirement Plan Consulting Services: Consistent with the options selected by the Plan sponsor (or other Plan fiduciary or agent), EFS will make available a variety of retirement plan consulting services to Plans and Plan sponsors (or other Plan fiduciaries or agents). These services include assistance (1) with administrative aspects of plan investments, including, but not limited to, reviews of the Plan s investment objectives and available options, reviews of the plan s committee structure and policies and procedures, general fiduciary compliance, and coordination of participant communications; (2) selecting and monitoring Plan service providers, including performance and fee benchmarking; (3) monitoring and replacing Plan investment options, managers, and third-party investment advice providers; and (4) participant plan enrollment, investment education, financial wellness education, retirement planning, and gap analysis. IRA Rollover Considerations As part of our investment advisory services, EFS Advisors may make recommendations regarding the rollover of the participant s employer sponsored retirement plan assets or an IRA that a client holds outside of EFS. In the case where an EFS Advisor recommends a retirement plan rollover into EMAP, Form ADV 12 January 17, 2018

13 we will charge an advisory fee based on the amount of assets subject to the rollover, as described in Item 5. This presents a conflict of interest because EFS Advisors have an economic incentive to recommend a client rollover of retirement plan assets into an EMAP account. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Plan participants are under no obligation to rollover their retirement assets to an IRA with EFS and should carefully consider all relevant factors, such as penalty-free withdrawals starting as early as age 55, whether loans are permitted, legal protections, required minimum distributions (RMDs), account-related fees and expenses, service levels, available investment options, rebalancing, employer stock considerations and state taxes. Military and government employees should pay particular attention to fees and expenses, because their retirement plan expenses are very low. College Education Savings EFS Advisors often work with clients to determine how to save for anticipated future educational expenses. State sponsored 529 college savings plans are recommended, as well as traditional taxable EMAP accounts, based on the circumstances and needs of the client. The advisory fees that a client would pay on an EMAP account may be higher than the fees and expenses that they would pay on a 529 Plan. EFS and/or the Advisor may have an economic incentive to recommend an EMAP account, since the commission on a 529 Plan executed with EFLS may be less than the advisory fee payable to EFS. In addition, if the client executed the 529 Plan directly with a state, EFLS would not receive a commission. This incentive creates a conflict of interest with clients. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Financial Education EFS is a strong advocate of consumer education and financial literacy. To support this mission, Ric Edelman and the EFS team of financial educators provide seminars to consumers, corporations, associations, nonprofit organizations and community and religious groups on a variety of personal finance topics. Presentations are typically created by Ric Edelman or based on his financial planning and investment management philosophy. They are designed to explain complex financial concepts in plain English in a way that is educational, informational and entertaining. Groups may qualify to receive presentations free of charge as part of our community service program. These groups could learn about presentations from planners, the radio show hosted by Ric Edelman, webinars, the Firm s website, or our outreach. In addition to the educational seminars, Ric Edelman speaks to financial industry groups on a variety of topics and writes financial articles and books on personal finance. See Item 5 for a discussion of fees and the Conflicts of Interest and Other Disclosures section within Item 11 for further details on the conflict. Institutional Advisory Services Utilizing EMAP, EFS provides investment management services to a variety of small and mid-sized companies, organizations, endowments and associations. The services offered include the following: Form ADV 13 January 17, 2018

14 Investment Policy Statement EFS assists in creating, rewriting and/or reviewing the Investment Policy Statement that reflects the investment needs of the entity. Asset Allocation Model EFS assists in developing a diversified asset allocation strategy in accordance with the investment objectives, goals, need for liquidity and risk tolerance of the entity. Financial Profile EFS performs a review of the entity s investment objectives and financial situation in order to provide an accurate assessment of the appropriate level of acceptable risk in accordance with the stated time horizon and goals. Investment Management EFS provides ongoing management of assets, including review for potential rebalancing opportunities and evaluation of EMAP performance for potential changes to or reallocation of asset classes, or changes to securities as market or other conditions warrant. Assets Under Management EFS had the following assets under management as of December 31, Accounts Assets Discretionary 76,781 $ 17,783,000,000 Non-discretionary 0 0 Total 76,781 $ 17,783,000,000 Item 5: Fees and Compensation Retail EMAP Retail Fee Schedule Fee First $150, % Next $250, % Next $350, % Next $250, % Next $2 million 0.75% Next $7 million 0.60% Next $15 million 0.50% Amounts above $25 million negotiable Form ADV 14 January 17, 2018

15 Above is a schedule of the investment advisory fees that retail clients pay on an EMAP account. Since EMAP is a wrap fee program, the terms advisory fee and wrap fee may be used interchangeably when referring to an EMAP account. In addition to the above fee schedule, EFS employees and the Firm s TAMP Advisors (see Item 14) pay a deeply discounted flat rate. The EMAP wrap fee includes ongoing financial planning advice by an EFS Advisor and limited discretionary investment management, including periodic review of all investments in the EMAP asset allocation model as described above in Item 4. The fee also includes account transaction costs associated with transactions placed through a Custodian (as defined below) (Please refer to the discussion in Item 12 below regarding step-out trades which result in additional costs to the client.), custody of assets, a subscription to Ric Edelman s Inside Personal Finance newsletter, online access and free admission to seminars. EMAP Clients pay a wrap fee, which covers brokerage execution costs associated with trades placed through one of the program Custodians (as defined below), without regard to the number of transactions executed during the billing period. EFS has negotiated fees with TD Ameritrade, Fidelity, and Pershing Advisor Solutions ( PAS ) (each, a Custodian ) for clearing and execution services. Transaction costs imposed by TD Ameritrade, Fidelity, and PAS are covered as part of the wrap fee. The wrap fee does not include certain account and securities-related costs, including the fees embedded in the mutual funds, ETFs or annuities in which EMAP accounts invest. These underlying fees vary between investments and are deducted by the particular fund company directly from invested assets. Further information on these fees can be found in the prospectuses of the particular mutual fund, ETF, or annuity in which the account invests. In addition, the fee does not include debit balances, related margin interest, IRA and retirement plan fees, transfer fees, fees imposed by regulators, 12b-1 fees for certain money market funds and mutual funds, wire transfer fees, overnight check fees, account closing fees, paper statement delivery fees, non-standard asset fees, insufficient fund fees, returned check fees, transaction charges for fund level asset allocation model trades, expenses charged by the mutual funds (including management fees, transaction charges incurred for fund-level asset allocation model trades, custody of fund assets and other fund expenses), expenses charged by the variable annuities and exchange-traded funds, or other fees or taxes that are required by law. EFS may from time to time, at its sole discretion reimburse clients for certain fees or charges which are not due to the client s error. EFS may negotiate a reduction in fees or other costs on services provided by third-party service providers based on size, volume or other factors. Because the cost to the client of these services is included in the wrap fee, any negotiation of lower costs to EFS will not be reflected in the client s costs. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this disclosure. As noted above, we anticipate that transactions placed in a client s account will be executed through one of the program Custodians (currently, either TD Ameritrade, Fidelity, or PAS.) However, in the limited circumstances described below, e.g. step-out trades, EFS may choose to execute trades for EMAP client accounts with a broker-dealer other than one of the Custodians, if we reasonably believe that another broker-dealer can obtain a more favorable execution under the circumstances. Specifically, occasionally (typically less than 5% of the time on a transactional basis), EFS will utilize a Form ADV 15 January 17, 2018

16 broker-dealer other than TD Ameritrade, Fidelity, or PAS to execute large transactions if we determine that it is in our clients' best interest and that the other broker-dealer has the capability to handle such large transactions and to reduce or eliminate potential negative price fluctuation. This generally will occur when the size of the transaction in any one security is so large that it could cause the price of the security to fluctuate, up or down, resulting in an unfavorable execution price for our clients. Where EFS trades through a broker-dealer other than one of the Custodians, the EMAP wrap fee does not include the compensation that is paid to that broker-dealer. This compensation is embedded into the price of the security which is paid by the client. These additional costs are in addition to the wrap fee paid to EFS by the client. Transactions executed on behalf of EMAP clients are executed for a single wrap fee (except with respect to step-out trades, as noted above in this section and in Item 12), which reduces the potential conflict of interest associated with executing a large number of orders for client accounts and earning transaction-based compensation following each order. In addition, EMAP invests client assets in no-load shares of open-end registered investment companies (mutual funds), ETFs and nocommission variable annuities. EFS and its Advisors receive compensation based on the assets under management the client has invested in the program. Neither EFS nor its Advisors earn any additional revenue from EMAP accounts beyond the wrap fee. A portion of the advisory fee is paid to the Advisor, however such compensation does not vary based on which securities are bought, sold or held in a particular EMAP account. The advisory fee earned may be more or less than what EFS or its Advisors might earn from other programs available in the financial services industry or if the services were purchased separately. Therefore, EFS and its Advisors have a financial incentive to recommend EMAP to clients and prospective clients. However, compensation paid to Advisors from the EMAP fee does not vary depending upon the number of trades made in EMAP client accounts. We do not earn more if fewer trades are placed. This arrangement gives us no economic incentive to place more or fewer trades for EMAP accounts. When calculating advisory fees, household accounts that are managed as one relationship are aggregated to determine the lowest percentage per the above fee schedule. Also, when calculating advisory fees, we exclude, at our discretion certain assets if they are unable to be invested in EMAP, for whatever the reason. In addition, EFS does not provide investment advisory services or charge advisory fees on certain unmanaged accounts, which are assets held in a separate account from EMAP assets. Fees are not negotiable, other than as disclosed in the fee schedule above. Accounts with less than $5,000 (the minimum household account size) may effectively pay a fee that is greater than 2.00% due to our minimum annual fee. Full fee details are discussed in the Client Services Agreement that is signed by each client. The above advisory fee schedules are based on the assets under management the client invests in the program and are not dependent on the amount of trading in the account or the advice given in any particular time period. The client should be aware that lower fees for comparable services may be available from other sources. Clients authorize the Custodian, on behalf of EFS, to deduct the EMAP fee from their accounts. The fee is based on the average daily balance of the EMAP account. The first payment is calculated based Form ADV 16 January 17, 2018

17 on the number of days assets are placed in the account during a calendar quarter. Subsequent fees are determined based on the average daily balance for the quarter ending on the last day of each calendar quarter. Fees are deducted from the client s account no later than the fifteenth (15th) day after the end of each quarter, in arrears. For margined accounts, the fee may be added to the margin balance unless the client elects to deposit cash or liquidate securities. If an account is terminated prior to the end of a calendar quarter, the terminating client will pay prorated fees due up to the termination date. Turnkey Asset Management Program (TAMP) As discussed in Item 14, EFS has established a Turnkey Asset Management Program ( TAMP ), whereby the Firm makes the EMAP asset allocation models available to clients of select unaffiliated investment advisors ( TAMP Advisors ). The EMAP fee, per the above fee schedule, is shared between EFS and the TAMP Advisors on a negotiated basis. The client does not pay an increased fee for EMAP because of this arrangement. Clients will pay the same fee, regardless of whether the client selects an EMAP asset allocation model through an EFS Advisor or a TAMP Advisor. EFS pays a negotiated percentage, up to 60% of the annual account fee, to TAMP Advisors on EMAP accounts initiated and serviced by their Advisors. Also, at no additional cost to the client, EFS may occasionally pay additional basis points to the TAMP Advisor. Institutional EMAP Institutional Fee Schedule Fee Up to $999, % $1 million to $1,999, % $2 million to $4,999, % $5 million to $9,999, % $10 million to $24,999, % $25 million + negotiable Above is a schedule of the investment advisory fees that EFS institutional clients pay on an EMAP account. Since EMAP is a wrap fee program, the terms advisory fee and wrap fee may be used interchangeably, when referring to an EMAP account. The EMAP wrap fee includes periodic access to an EFS Advisor and the Institutional Advisory Services as described in Item 4 above. EMAP Clients pay a wrap fee, which covers brokerage execution costs associated with trades placed through one of the program Custodians, without regard to the number of transactions executed during the billing period. EFS has negotiated fees with TD Ameritrade, Fidelity and PAS, each a Custodian, for clearing and execution services. Also, for ERP clients, the Plan s recordkeeper, custodian or other service provider may charge a separate fee to cover the administrative, trust, custody and other record-keeping costs associated with Plan accounts invested in the Investment Options. Transaction costs imposed by TD Ameritrade, Fidelity, and PAS are covered as part of the wrap fee. The wrap fee does not include certain account and securities-related costs, including the Form ADV 17 January 17, 2018

18 fees embedded in the mutual funds, ETFs or annuities in which EMAP accounts invest. These underlying fees vary between investments and are deducted by the particular fund company directly from invested assets. Further information on these fees can be found in the prospectuses of the particular mutual fund, ETF, or annuity in which the account invests. In addition, the fee does not include debit balances, related margin interest, IRA and retirement plan fees, transfer fees, fees imposed by regulators, 12b-1 fees for certain money market funds and mutual funds, wire transfer fees, overnight check fees, account closing fees, paper statement delivery fees, non-standard asset fees, insufficient fund fees, returned check fees, transaction charges for fund level asset allocation model trades, expenses charged by the mutual funds (including management fees, transaction charges incurred for fund-level asset allocation model trades, custody of fund assets and other fund expenses), expenses charged by the variable annuities and exchange-traded funds, or other fees or taxes that are required by law. EFS may from time to time, at its sole discretion reimburse clients for certain fees or charges which are not due to the client s error. EFS may negotiate a reduction in fees or other costs on services provided by third-party service providers based on size, volume or other factors. Because the cost to the client of these services is included in the wrap fee, any negotiation of lower costs to EFS will not be reflected in the client s costs. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this disclosure. As noted above, we anticipate that transactions placed in a client s account will be executed through one of the program Custodians (currently, either TD Ameritrade, Fidelity, or PAS). However, in the limited circumstances described below, e.g. step-out trades, EFS may choose to execute trades with a broker-dealer other than one of the Custodians, if we reasonably believe that another brokerdealer can obtain a more favorable execution under the circumstances. Specifically, occasionally (typically less than 5% of the time on a transactional basis), EFS will utilize broker-dealers other than TD Ameritrade, Fidelity, or PAS to execute large transactions if we determine that it is in our clients' best interest and that the other broker-dealer has the capability to handle such large transactions and to reduce or eliminate potential negative price fluctuation. This generally will occur when the size of the transaction in any one security is so large that it could cause the price of the security to fluctuate, up or down, resulting in an unfavorable execution price for our clients. Where EFS trades through a broker-dealer other than one of the Custodians, the EMAP wrap fee does not include the compensation that is paid to that broker-dealer. This compensation is embedded into the price of the security which is paid by the client. These additional costs are in addition to the wrap fee paid to EFS by the client. Transactions executed on behalf of EMAP clients are executed for a single wrap fee (except with respect to step-out trades, as noted above in this section and in Item 12 below), which reduces the potential conflict of interest associated with executing a large number of orders for client accounts and earning transaction-based compensation following each order. In addition, EMAP invests client assets in no-load shares of open-end registered investment companies (mutual funds), ETFs and nocommission variable annuities. EFS and its Advisors receive compensation based on the assets under management the client has invested in the program. Neither EFS nor its Advisors earn any additional revenue from EMAP accounts beyond the wrap fee. A portion of the advisory fee is paid to the Form ADV 18 January 17, 2018

19 Advisor, however such compensation does not vary based on which securities are bought, sold or held in a particular EMAP account. The advisory fee earned may be more or less than what EFS or its Advisors might earn from other programs available in the financial services industry or if the services were purchased separately. Therefore, EFS and its Advisors have a financial incentive to recommend EMAP to clients and prospective clients. However, compensation paid to Advisors from the EMAP fee does not vary depending upon the number of trades made in EMAP client accounts. We do not earn more if fewer trades are placed. This arrangement gives us no economic incentive to place more or fewer trades for EMAP accounts. Fees are not negotiable, other than as disclosed in the fee schedule above. Full fee details are discussed in the Client Services Agreement that is signed by each client. The above advisory fee schedules are based on the assets under management the client invests in the program and are not dependent on the amount of trading in the account or the advice given in any particular time period. The client should be aware that lower fees for comparable services may be available from other sources. Clients authorize the Custodian, on behalf of EFS, to deduct the EMAP fee from their accounts. The fee is based on the average daily balance of the EMAP account. The first payment is calculated based on the number of days assets are placed in the account during a calendar quarter. Subsequent fees are determined based on the average daily balance for the quarter ending on the last day of each calendar quarter. Fees are deducted from the client s account no later than the fifteenth (15th) day after the end of each quarter, in arrears. For margined accounts, the fee may be added to the margin balance unless the client elects to deposit cash or liquidate securities. If an account is terminated prior to the end of a calendar quarter, the terminating client will pay prorated fees due up to the termination date. Edelman Retirement Program (ERP) ERP Plan Assets Fee $0 to $2 million 1.00% $2 million to $5 million 0.85% $5 million to $10 million 0.70% $10 million to $15 million 0.60% $15 million to $20 million 0.50% $20 million + negotiable Above is a schedule of the investment advisory fees that EFS ERP clients pay on an EMAP account. Since EMAP is a wrap fee program, the terms advisory fee and wrap fee may be used interchangeably, when referring to an EMAP account. The EMAP wrap fee includes periodic access to an EFS Advisor and the services provided to the Plan on behalf of the Plan sponsor (or other Plan fiduciary or agent) as described above in Item 4. Form ADV 19 January 17, 2018

20 EMAP Clients pay a wrap fee, which covers brokerage execution costs associated with trades placed through one of the program Custodians, without regard to the number of transactions executed during the billing period. EFS has negotiated fees with TD Ameritrade, Fidelity and PAS, each a Custodian, for clearing and execution services. Also, for ERP clients, the Plan s recordkeeper, custodian or other service provider may charge a separate fee to cover the administrative, trust, custody and other record-keeping costs associated with Plan accounts invested in the Investment Options. Transaction costs imposed by TD Ameritrade, Fidelity, or PAS are covered as part of the wrap fee. The wrap fee does not include certain account and securities-related costs, including the fees embedded in the mutual funds, ETFs or annuities in which EMAP accounts invest. These underlying fees vary between investments and are deducted by the particular fund company directly from invested assets. Further information on these fees can be found in the prospectuses of the particular mutual fund, ETF, or annuity in which the account invests. In addition, the fee does not include debit balances, related margin interest, IRA and retirement plan fees, transfer fees, fees imposed by regulators, 12b-1 fees for certain money market funds and mutual funds, wire transfer fees, overnight check fees, account closing fees, paper statement delivery fees, non-standard asset fees, insufficient fund fees, returned check fees, transaction charges for fund level asset allocation model trades, expenses charged by the mutual funds (including management fees, transaction charges incurred for fund-level asset allocation model trades, custody of fund assets and other fund expenses), expenses charged by the variable annuities and exchange-traded funds, or other fees or taxes that are required by law. EFS may from time to time, at its sole discretion reimburse clients for certain fees or charges which are not due to the client s error. EFS may negotiate a reduction in fees or other costs on services provided by third-party service providers based on size, volume or other factors. Because the cost to the client of these services is included in the wrap fee, any negotiation of lower costs to EFS will not be reflected in the client s costs. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this disclosure. As noted above, we anticipate that transactions placed in a client s account will be executed through one of the program Custodians (currently, either TD Ameritrade, Fidelity, or PAS). However, in the limited circumstances, e.g. step-out trades, described below, EFS may choose to execute trades with a broker-dealer other than one of the Custodians, if we reasonably believe that another brokerdealer can obtain a more favorable execution under the circumstances. Specifically, occasionally (typically less than 5% of the time on a transactional basis), EFS will utilize broker-dealers other than TD Ameritrade, Fidelity, or PAS to execute large transactions if we determine that it is in our clients' best interest and that the other broker-dealer has the capability to handle such large transactions and to reduce or eliminate the potential negative price fluctuation. This generally will occur when the size of the transaction in any one security is so large that it could cause the price of the security to fluctuate, up or down, resulting in an unfavorable execution price for our clients. Where EFS trades through a broker-dealer other than one of the Custodians, the EMAP wrap fee does not include the compensation that is paid to that broker-dealer. This compensation is embedded into the price of the security which is paid by the client. These additional costs are in addition to the wrap fee paid to EFS by the client. Form ADV 20 January 17, 2018

21 Transactions executed on behalf of EMAP clients are executed for a single wrap fee (except with respect to step-out trades, as noted above and in Item 12), which reduces the potential conflict of interest associated with executing a large number of orders for client accounts and earning transaction-based compensation following each order. In addition, EMAP invests client assets in noload shares of open-end registered investment companies (mutual funds), ETFs and no-commission variable annuities. EFS and its Advisors receive compensation based on the assets under management the client has invested in the program. Neither EFS nor its Advisors earn any additional revenue from EMAP accounts beyond the wrap fee. A portion of the advisory fee is paid to the Advisor, however such compensation does not vary based on which securities are bought, sold or held in a particular EMAP account. The advisory fee earned may be more or less than what EFS or its Advisors might earn from other programs available in the financial services industry or if the services were purchased separately. Therefore, EFS and its Advisors have a financial incentive to recommend EMAP to clients and prospective clients. However, compensation paid to Advisors from the EMAP fee does not vary depending upon the number of trades made in EMAP client accounts. We do not earn more if fewer trades are placed. This arrangement gives us no economic incentive to place more or fewer trades for EMAP accounts. Fees are not negotiable, other than as disclosed in the fee schedule above. Full fee details are discussed in the Client Services Agreement that is signed by each client. The above advisory fee schedules are based on the assets under management the client invests in the program and are not dependent on the amount of trading in the account or the advice given in any particular time period. The client should be aware that lower fees for comparable services may be available from other sources. Except as otherwise agreed to by the Plan sponsor (or other Plan fiduciary or agent) and EFS, the Plan sponsor (or other Plan fiduciary or agent) agrees that the Plan s recordkeeper, custodian or other service provider will deduct the wrap fee from Plan accounts and remit such amounts to EFS prior to the due date as provided under the ERP Investment Management Agreement, which is the standard ERP client contract. The fee is based on the balance of the total assets of the Plan accounts invested in the Models and Underlying Funds as of the end of each calendar quarter, and does not include Plan assets that are invested in other options (such as those available through self-directed brokerage windows or funds or securities other than the Underlying Funds). The first payment is prorated for assets that are placed in Plan accounts during a calendar quarter. Subsequent fees will be determined based on the last day of each quarter. Fees are deducted from the client s account no later than the thirtieth (30th) day after the end of each quarter, in arrears. If an account is terminated prior to the end of a calendar quarter, the terminating client will pay prorated fees due up to the termination date. The fee schedule above shows the annual percentages. If a Plan sponsor (or other Plan fiduciary or agent) is introduced to ERP through an unaffiliated registered investment adviser, EFS services will be limited to discretionary management of the Models. In such cases, EFS charges an annual fee of 0.35% of Plan assets invested in the Models and Underlying Funds. The unaffiliated adviser is not paid any portion of the wrap fee and may charge a separate fee for its services that is in addition to the EFS fee. Form ADV 21 January 17, 2018

22 Other Fees Earned by EFS Financial Plans EFS charges a one-time initial fee of $800 for financial plan development and presentation. Clients who pay for a plan are under no obligation to implement the plan with our Firm. The financial planning fee is waived for employees of EFS and may also be waived in part or in whole for clients at the discretion of the Advisor and/or the Firm. The Firm currently waives financial planning fees for those working in certain industries or for members of professional associations in certain industries. The Firm may also, at its discretion, waive financial planning fees that are contingent upon the client making a pledge, or other philanthropic donation, to unaffiliated non-profits, such as PBS. The value of these donations or pledges may or may not be equal to the one-time initial fee of $800. EFS Advisors are also EFLS registered representatives and may receive upfront and/or annual commissions on products sold outside of EMAP as part of an implemented financial plan. Lower fees for financial planning and securities transactions may be available from other sources. EFS Advisors have a financial incentive to recommend products that result in commission revenue. However, financial planning clients are under no obligation to implement their financial plans through us. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. EFS may create an arrangement with a corporation or other organization where a combination of financial planning, advice and/or educational services are provided to employees or members. Bundled services of this type may be offered at a reduced fee. Nominal costs for additional products or services may be charged at the discretion of EFS. The EFS Advisor may further waive that subsidized fee, in whole or in part, at their discretion. Seminars Seminars are offered to the public on a variety of financial topics. Attendance fees range from $5 to $25, with satisfaction guaranteed or 100% of the registration fee is refunded. EFS clients receive free seminar admission for them and their guests. In some instances, non-clients are provided with an opportunity to attend a seminar for discounted or free admission. Speaking Engagements Ric Edelman is a public speaker, radio, television and webinar host covering topics related to investing and financial education. Generally, fees for his speaking engagements range from free to $30,000 plus first-class travel expenses, depending on sponsor, date, location and program requested. For all speeches, 50% of the fee is required prior to the event, with the balance due at the conclusion of the event. Speaker fees are nonrefundable. Educational Products EFS publishes and sells the newsletter Ric Edelman s Inside Personal Finance on a subscription basis for $39.95 annually. Subscribers may cancel at any time and receive a full refund of the unused subscription. Ric Edelman s books include The Truth About Money (4th ed.); The New Rules of Form ADV 22 January 17, 2018

23 Money; Ordinary People, Extraordinary Wealth; Discover the Wealth Within You; What You Need to Do Now; The Lies About Money; Rescue Your Money; The Truth About Retirement Plans and IRAs and The Truth About Your Future. Books, including audio books and ebooks, are available for sale through booksellers, with prices ranging up to $ EFS may provide books at a discount or for no cost to organizations, individual clients or prospective clients. EFS and/or Ric Edelman receive book royalties or other revenue from the sale of any books written by Ric. Any direct receipt of revenue by Ric from the sale of books, as well as the indirect receipt of economic benefit as the Founder and Executive Chairman by promotion of the Firm in books, the radio show, seminars, etc. could result in a conflict of interest in how Ric promotes the Firm or its products. TD Ameritrade and Orion have bought or have agreed to buy a large number of copies of The Truth About Your Future, which may present a conflict of interest, as it could indirectly influence EFS to recommend TD Ameritrade to clients for custody and brokerage services. EFS has asked other vendors to buy copies of the book and we anticipate that there may be more purchases. EFS may also ask vendors to buy copies of a current or future book or provide financial incentive for doing so. Such vendor purchases may also be a conflict of interest. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict and similar conflicts related to the radio show, seminars or promotional materials in general. Those who read Ric Edelman s books, listen to our radio show or attend our seminars should know that they contain financial advice for purposes of general financial education and marketing. This information is not tailored to a consumer s financial needs, investment objectives, risk tolerance, personal situation or other relevant factors. The consumer should not use the content as the basis for any investment decisions, but should instead consult a financial advisor or do their own due diligence. The statements in the books do not necessarily reflect the current practices of EFS. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this disclosure. RIC-E Trust The Retirement InCome for Everyone Trust (RIC-E Trust ) is an individual grantor trust enabling the grantor to set aside assets for another s retirement. The assets of the trust are invested in a variable annuity, which is a broker-dealer product offered by EFS Advisors, acting solely in their capacity as registered representatives of EFLS and not in their capacity as an investment advisor representative of EFS, which could potentially lead to client confusion. The assets in the variable annuity grow taxdeferred. The trustee is named by the grantor. The issuer of the underlying annuity is American General Life Insurance Company, a subsidiary of American International Group, Inc. ( AIG ). Edelman Business Services, LLC ( EBS ), a wholly owned subsidiary of The Edelman Financial Center, LLC, receives an administrative fee of $200 for each RIC-E Trust established, to offset in part the administrative costs of establishing the trust. This administrative fee is waived for EFS clients with an EMAP account and may be waived or modified in other cases at the sole discretion of EFLS. This administrative fee is not associated with investment advisory services offered by EFS. Ongoing commissions from the underlying variable annuity are received by EFLS for the life of the variable Form ADV 23 January 17, 2018

24 annuity and not by the registered representative. Nevertheless, because EFLS does receive commissions, this may create a conflict of interest. Please see the Conflicts of Interest and Other Disclosures section within Item 11 for information on this conflict. Item 6: Performance-Based Fees and Side-by-Side Management EFS does not charge any performance-based fees (fees based on a share of capital gains on, or capital appreciation of, the assets of a client). We do not engage in side-by-side management. See Item 5: Fees and Compensation for further details on advisory services offered. Item 7: Types of Clients EFS provides financial planning, investment management, financial advice, educational services and insurance services to individuals, individual retirement accounts, trusts, estates, charitable organizations, foundations, associations, pensions, high net worth individuals, retirement and profitsharing plans, institutions, and small to mid-sized businesses including corporations. Minimum Account Size EMAP Client household minimum account size is $5,000. We may waive the minimum account size at our sole discretion. Minimum annual fee is $100. We may waive the minimum annual fee at our sole discretion. EFS Employee and Advisor minimum account size is $3,000. Institutional The minimum account size is $500,000, which may be waived at our sole discretion. ERP There is no minimum account size. Form ADV 24 January 17, 2018

25 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Investment Strategy EMAP relies on an investment philosophy that is based on established academic research, such as Modern Portfolio Theory and the Fama-French Five-Factor Model, and established discoveries in behavioral finance. Modern Portfolio Theory advocates that it is not enough to look at the expected risk and return of one particular asset class. By investing in more than one asset class, an investor may be able to reap the benefits of diversification chief among them, a reduction in the risk level of the portfolio. The Fama-French Five-Factor Model, through research, found that over long periods of time, value stocks outperform growth stocks, small cap stocks tend to outperform large cap stocks and stocks with high profitability outperform stocks with low profitability. In addition, capturing price momentum can add to returns. The EFS investment philosophy is based on the following basic principles: Develop highly diversified portfolios that feature a broad range of asset classes and market sectors. Use market-based investments, not manager-based investments. Hold the investments for long periods of time. Periodically reallocate investments as conditions warrant. Strategically rebalance as needed. EMAP is diversified, invests in no-load mutual funds and ETFs, and features as many as nineteen (19) asset classes and market sectors. This approach cannot ensure investment success or prevent loss in a declining market. Past performance is no guarantee of future results. Methods of Analysis and Investment Selection Based on the EMAP client agreement that clients execute, EFS is granted limited discretionary authority to implement client-approved investment strategies. Investments are selected based on a number of qualitative and quantitative factors, including, but not limited to past performance (as applicable), diversification characteristics, fees and a variety of academic statistics including beta, standard deviation, R-Squared and Sharpe Ratio, as well as qualitative considerations including, but not limited to, exposure to particular asset classes or market sectors in which the firm and the Investment Committee have conviction, internal characteristics, trading impact, liquidity and manager reputation. The quantitative statistics identified above are provided by third-party vendors and the investment sponsors, and are evaluated by the Portfolio Manager as well as the EFS Investment Committee, on both an absolute and a relative basis. Form ADV 25 January 17, 2018

26 We obtain and utilize information and data from a wide variety of public and private sources. Neither EFS nor our Advisors independently verify or guarantee such information and data. In categorizing the asset classes of investments, we rely on prospectuses and information obtained from the issuer or its agents, or through publicly available sources. Neither EFS nor our Advisors are liable for any misstatement or omission contained in the information from these sources, or for any loss, liability, claim, damage or expense incurred, arising out of, or attributable to, such misstatement or omission. Transactions for different accounts or for other clients accounts might not be made at the same time, may be made on different days, and may be made over multiple days. In handling purchases and liquidations, we will execute transactions without regard to pending dividend or capital gains distributions, stock splits, mergers, or other corporate or financial events. Clients are permitted to impose reasonable restrictions on the management of their accounts. When imposing restrictions, clients may request that particular securities or types of securities not be purchased, not be sold or that such securities (if held in the account) be sold. Clients, however, cannot request that particular securities be purchased for their accounts. Additionally, EFS has no influence or control over the mix of securities held by any mutual fund, variable annuity or ETF in which client accounts may be invested. We reserve the right, at our sole discretion, to reject any account for which unreasonable or overly restrictive conditions are requested. Risk of Loss EMAP holdings consist of a combination of no-load mutual funds, exchange-traded funds (ETFs) and, occasionally, variable annuities and 529 College Savings Plans, all of which are subject to some or all of the risk factors noted below. Certain models available through EMAP include positions in the SPDR S&P North American Natural Resources ETF (NANR) and the ishares Exponential Technologies ETF (XT). Ric Edelman became interested in how new economy innovation and technology disruption would change investing and initially articulated the principles that BlackRock later used in creating XT. EFS played a similar role with respect to NANR. XT and NANR are sponsored and managed by BlackRock and State Street Global Advisors, respectively. Neither Ric Edelman nor EFS receives any direct or indirect compensation from either of the funds or their respective affiliates based on the sale of, or investment in, either fund. For each of these funds, a very high percentage of each ETF s total assets is held by EMAP clients. There is a conflict of interest regarding the initial role that EFS and/or Ric Edelman played in the suggestion for or the creation of these two ETFs, as well as any promotion of NANR or XT by EFS and/or Ric Edelman, in that EFS may receive indirect economic and other benefits from the association of its name with that ETF. That conflict could influence our decision to use either State Street Global Advisors SPDRs or BlackRock s ishares to provide ETFs in EMAP. There could also potentially be such a conflict in the future, if EFS and/or Ric Edelman were to play a role in the creation of a third party s index or other product. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Please also see the Risks Associated with Positions in ETFs with Which EFS was Involved and Risks Associated with Changes to Underlying Investments risk categories below for further information on the associated risks. Form ADV 26 January 17, 2018

27 The Investment Committee provides ongoing monitoring of these risks and recommends action to mitigate them, as appropriate. Market Risk - Even a long-term investment approach cannot guarantee a profit. Economic, political and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that a client will lose money and their investment may be worth more or less upon liquidation. Business Risk - The risks associated with a particular industry or market sector, e.g. oildrilling companies carry a higher risk of profitability than an electric company that generates steady income no matter what the economic environment is like. Foreign Securities and Currency Risk - Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. Capitalization Risk - Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services, and their stocks have historically been more volatile than the stocks of larger, more established companies. Interest Rate Risk - In a rising rate environment, the value of fixed-income securities generally declines and the value of equity securities may be adversely affected. Reinvestment Risk - The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return. This risk is primarily related to fixed income securities. Inflation Risk - Also referred to as purchasing power risk, it is the chance that the cash flows from an investment won't be worth as much in the future because of changes in purchasing power due to inflation. Credit Risk - Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer s credit rating or a perceived change in an issuer s financial strength may affect a security s value and, thus, impact the fund s performance. Concentration Risk - Holdings may be subject to any number of concentrations, e.g. in a mutual fund or ETF, industry sector or geographical region. Concentration risk may be further compounded by factors such as asset correlation or performance. Risks Associated with Positions in ETFs with Which EFS was Involved Certain models available through EMAP include positions in the NANR and XT ETFs. Ric Edelman became interested in how new economy innovation and technology disruption would change investing and initially articulated the principles that BlackRock later used in creating XT. EFS played a similar role with respect to NANR. XT and NANR are sponsored and managed by BlackRock and State Street Global Advisors, respectively. Neither Ric Edelman nor EFS Form ADV 27 January 17, 2018

28 receives any direct or indirect compensation from either of the funds or their respective affiliates based on the sale of, or investment in, either fund. For each of these funds a very high percentage of each ETF s total assets is held by EMAP clients. Such large concentrations present a variety of risks, should the Firm decide to transition out of one of these funds, including liquidity risk and reputational risk. Risks Associated with Changes to Underlying Investments - Because any mutual fund, ETF and annuity held in a client s EMAP account has its own internal expenses, changing one or more investment funds in an EMAP model and, as a result, the relevant client accounts, will likely result in a change to the expense ratio of the overall portfolio. The resulting expense ratio may be higher than the expense ratio of the original portfolio. If a change is made and the expense ratio of the new fund is in fact higher than that of the fund or investment that was replaced, clients will incur a greater expense than previously incurred. Clients should understand that, while EFS takes the cost of particular investments into account when making investment decisions for the models and accounts in EMAP, cost is but one of many factors that are considered. Other factors that are considered include: overall diversification, return, risk adjusted return, exposure to particular asset classes or market sectors in which the firm and Investment Committee have conviction, internal characteristics, trading impact, liquidity and manager reputation. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Securities Lending Risk - Securities lending involves the risk that the fund loses money because the borrower fails to return the securities in a timely manner, or at all. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. Derivatives - Derivatives are securities, such as futures contracts, whose value is derived from that of other securities or indices. Derivatives can be used for hedging (attempting to reduce risk by offsetting one investment position with another) or non-hedging purposes. Hedging with derivatives may increase expenses, and there is no guarantee that a hedging strategy will achieve the desired results. Hedging - While hedging can reduce or eliminate losses, it can also reduce or eliminate gains. Derivative securities are subject to a number of risks, including the following: o o o o o Liquidity risk Interest rate risk Market risk Credit and management risks Risk of improper valuation Changes in the value of the derivative may not correlate perfectly with the underlying asset, rate or index, and the fund could lose more than the principal amount. Form ADV 28 January 17, 2018

29 Exchange-Traded Funds - ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the creation/redemption process of the ETF. Any of these factors may lead to liquidity risk and/or the fund s shares trading at either a premium or a discount to its net asset value. Performance of Underlying Managers - We select the mutual funds and ETFs in the asset allocation models. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. Item 9: Disciplinary Information Registered investment advisers are required to disclose all legal or disciplinary events that are material in a client s evaluation of the advisor or the integrity of the advisor s management. EFS has no material legal or disciplinary events to disclose. Item 10: Other Financial Industry Activities and Affiliations Related Persons Affiliated Broker-Dealer EF Legacy Securities, LLC ( EFLS ) is the affiliated registered broker-dealer which performs an accommodation role for EFS advisory clients. The Edelman Financial Center, LLC is the sole member of EFLS and therefore EFLS shares the same ownership structure as EFS. The President of EFS also serves as a manager of EFLS. EFS Advisors, acting solely in their capacity as registered representatives of EFLS and not as Advisors of EFS, accept orders for EFLS accounts from EFLS clients who may or may not be clients of EFS. When acting as registered representatives for clients, EFS Advisors execute transactions for clients through EFLS and receive upfront and/or annual brokerage commissions from EFLS on certain products sold in this capacity or held in the EFLS account. Thus, a conflict of interest could exist between the interests of EFS Advisors, EFLS, and EFLS clients if the EFS Advisor receives commissions as part of an implemented financial plan for a client. EFS clients are advised that they are under no obligation to effect securities transactions with EFLS or through their Advisor and that similar services may be less expensive elsewhere. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Other Affiliated Investment Advisers and Broker-Dealers Although EFS is under common indirect ownership and control with other investment advisers and broker-dealers (this excludes EFLS), there is no material relationship between EFS and any one of these other investment advisor or broker-dealer entities. Form ADV 29 January 17, 2018

30 Insurance Agencies EFS is a licensed insurance agency and is licensed in most states. EFS Advisors generally refer clients who wish to buy insurance products, such as life, long-term disability and long-term care insurance to Crump Life Insurance Services, an unaffiliated insurance agency that specializes in insurance brokerage and provides insurance to clients. EFS and its Advisors who are licensed insurance agents are compensated with a percentage of the revenues generated on the sale of such insurance products. As such, EFS and its Advisors who are licensed insurance agents have a conflict of interest because of the economic incentive to sell policies that result in commissions or other sales revenue. Clients are advised that they are under no obligation to purchase any insurance products through EFS or Crump Life Insurance Services and that those products may be less expensive elsewhere. Please refer to the Conflicts of Interest section within Item 11 for further information on this conflict. EFLS is also a licensed insurance agency and EFS Advisors may be licensed insurance agents of EFLS. They are therefore able to sell variable and fixed insurance products and receive insurance commissions from client transactions through EFLS. As such, EFS Advisors have a conflict of interest because of the economic incentive to recommend products that result in commissions or other sales revenue. Clients are advised that they are under no obligation to purchase any insurance products through EFS or EFLS and that those products may be less expensive elsewhere. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Equity Investors H&F Corporate Investors VII, Ltd. is the ultimate controlling party for a series of limited partnerships that indirectly own approximately 71.5% of The Edelman Financial Center, LLC, the direct parent of EFS. Other investors, including The Edelman Financial Center, Inc., whose sole shareholder is Ric Edelman, the Executive Chairman of EFS, also have indirect ownership interests in EFS. The Retirement InCome for Everyone Trust (RIC-E Trust ) As discussed in Item 5 above, the Retirement InCome for Everyone Trust (RIC-E Trust ) is an individual grantor trust enabling the grantor to set aside assets for another s retirement. It is a broker-dealer product offered by EFS Advisors, acting in their capacity as registered representatives of EFLS. Assets in the trust are invested in a variable annuity and grow tax-deferred. The trustee is named by the grantor. The issuer of the annuity is American General Life Insurance Company, a subsidiary of American International Group, Inc. ( AIG ). Commissions from the underlying variable annuity are received by EFLS, which may create a conflict of interest. Please see the Conflicts of Interest and Other Disclosures section within Item 11 for information on this conflict. Form ADV 30 January 17, 2018

31 Item 11: Code of Ethics, Participation of Interest in Client Transactions and Personal Trading Code of Ethics EFS has adopted a Code of Ethics (the Code ) that is designed to ensure that all employees adhere to high standards of ethical conduct. The Code states that all of our employees must act in the best interest of the client at all times. It also states that employees should avoid any practice that creates or appears to create a material conflict of interest that could potentially harm a client. The Firm has established a Conflicts of Interest Committee ( Committee ). It is chaired by the CCO and members of senior management serve on the Committee. The Committee, or other such committees as the Firm might decide, has the responsibility to identify, assess and manage potential and actual conflicts of interest. Employees have the responsibility to escalate any potential or actual conflicts of interest immediately upon identifying them to their manager, who is responsible for notifying the CCO. In addition, the Code requires, among other things, that employees do the following: Submit their personal and related trading accounts to the Compliance Department for review. Refrain from purchasing Initial Public Offerings (IPOs). Refrain from trading on insider information. Get approval prior to purchasing a private placement. Comply with ethical restraints, including restrictions on giving and receiving gifts. Report any conduct that could potentially harm a client. EFS has also adopted supervisory procedures that are designed to detect the following abusive behavior: Front-running, or trading ahead of or opposite clients Trading in securities on the EFLS and EFS Restricted or Watch Lists Trading that appears to be based on insider information Short-term or day trading Trading during designated EFLS blackout periods The above mitigants are designed to detect any potential abuse of insider information by members of the Investment Committee or other employees involved with any EMAP reallocations. Any officer or employee of the Firm who fails to observe the Code risks serious sanctions, including personal liability and/or termination of employment. Form ADV 31 January 17, 2018

32 A copy of the Code is available upon request by contacting us using the information on the cover page of this brochure. Related Person May Invest in the Same Securities EFS Advisors may invest their personal funds and establish an EMAP account for themselves. They may also participate in the EFS Employee 401(k) Plan that includes EMAP asset allocation models. In that regard, employees buy and sell for themselves the same underlying securities as clients and will have interests in securities owned by or recommended to our clients, including mutual funds, ETFs or insurance products. Although all employees get the benefit of a fee reduction on EMAP accounts, those accounts are not given preferential trading treatment. Employee accounts are monitored and rebalanced on the same basis as all other unrestricted client accounts invested in accordance with the same EMAP asset allocation model strategy. We have adopted procedures relating to personal securities transactions, insider trading and internal trading that are designed to prevent client harm resulting from this conflict of interest. Please refer to the Conflicts of Interest and Other Disclosures section below for further information on this conflict. Agency Cross Procedures In order to comply with the agency cross provisions of the Investment Advisers Act, EFS has policies and procedures in place to ensure that transactions introduced on behalf of EMAP clients are not crossed with transactions introduced to the clearing firm on behalf of EFLS customers. Cross transactions do not apply to mutual funds and to variable annuities since shares of mutual funds and variable annuities are purchased from their issuers and are not exchange-traded. Although ETFs are exchange-traded, EFS does not, acting as investment adviser, recommend that such shares be crossed from one advisory client account to another and does not act as a broker-dealer with respect to any such potential cross transaction. Conflicts of Interest and Other Disclosures This section highlights certain conflicts of interest that are noted elsewhere in the ADV. The entire ADV should be read in order to fully understand all conflicts. Please refer to those sections of the ADV indicated for the proper context and further detail. College Education Savings (Item 4) EFS Advisors often work with clients to determine how to save for anticipated future educational expenses. State sponsored 529 college savings plans are recommended, as well as traditional taxable EMAP accounts, based on the circumstances and needs of the client. The advisory fees that a client would pay on an EMAP account may be higher than the fees and expenses that they would pay on a 529 Plan. EFS and/or the Advisor may have an economic incentive to recommend an EMAP account, since the commission on a 529 Plan executed with EFLS may be less than the advisory fee payable to EFS. In addition, if the client executed the 529 Plan directly with a state, EFLS would not receive a commission. This incentive creates a conflict of interest with clients. Form ADV 32 January 17, 2018

33 IRA Rollover Considerations (Item 4) EFS Advisors may recommend that an employer sponsored retirement plan or an IRA that a client holds outside of EFS be rolled over into EMAP. This presents a conflict of interest because EFS Advisors have an economic incentive to do so. Educational Products and Promotional Materials (Items 4 and 5) EFS and/or Ric Edelman receive book royalties or other revenue from the sale of any books written by Ric. Any direct receipt of revenue by Ric from the sale of books, as well as the indirect receipt of economic benefit as the Founder and Executive Chairman by promotion of the Firm in books, the radio show, seminars, etc. could result in a conflict of interest in how Ric promotes the Firm or its products. TD Ameritrade and Orion have bought or have agreed to buy a large number of copies of The Truth About Your Future, which may present a conflict of interest, as it could indirectly influence EFS to recommend TD Ameritrade to clients for custody and brokerage services. EFS has asked other vendors to buy copies of the book and we anticipate that there may be more purchases. EFS may also ask vendors to buy copies of a current or future book or provide financial incentive for doing so. Such vendor purchases may also be a conflict of interest. Those who read Ric Edelman s books, listen to our radio show or attend our seminars should know that they contain financial advice for purposes of general financial education and marketing. This information is not tailored to a consumer s financial needs, investment objectives, risk tolerance, personal situation or other relevant factors. The consumer should not use the content as the basis for any investment decisions, but should instead consult a financial advisor or do their own due diligence. The statements in the books do not necessarily reflect the current practices of EFS. Affiliated Broker-Dealer Related Conflicts (Items 5 and 10) EFS Advisors, acting as registered representatives of EFLS, may receive upfront and/or annual commissions as part of an implemented plan not conducted through EMAP. Advisors have a financial incentive to recommend non-emap broker-dealer products that result in commission revenue, creating a conflict of interest with their clients. Ongoing commissions from the underlying variable annuity for the Retirement InCome for Everyone Trust (RIC-E Trust ) product are received by EFLS for the life of the variable annuity and not by the registered representative. Nevertheless, because EFLS does receive commissions, this may create a conflict of interest. Fees and Expenses (Items 5, 8 and 12) Because any mutual fund, ETF and annuity held in a client s EMAP account has its own internal expenses, changing one or more investment funds in an EMAP model and, as a result, the relevant client accounts, will likely result in a change to the expense ratio of the overall portfolio. The resulting expense ratio may be higher than the expense ratio of the original portfolio. If a change is made and the expense ratio of the new fund is in fact higher than that of the fund or investment that was replaced, clients will incur a greater expense than previously incurred. Clients should understand Form ADV 33 January 17, 2018

34 that, while EFS takes the cost of particular investments into account when making investment decisions for the models and accounts in EMAP, cost is one of the many factors that are considered. Other factors that are considered include: overall diversification, return, risk adjusted return, exposure to particular asset classes or market sectors in which the firm and Investment Committee have conviction, internal characteristics, trading impact, liquidity and manager reputation. EFS may negotiate a reduction in fees or other costs on services provided by third-party service providers based on size, volume or other factors. Because the cost to the client of these services is included in the wrap fee, any negotiation of lower costs to EFS will not be reflected in the client s costs. In certain circumstances, e.g. for step-out trades, EFS may elect to execute trades with a brokerdealer other than TD Ameritrade, Fidelity, or PAS. Generally speaking, the compensation paid to that broker-dealer is embedded in the price of the security being traded and may represent an additional cost that the client pays, which is not included in the wrap fee. Involvement with the NANR and XT ETFs (Items 8 and 14) Certain models available through EMAP include positions in the SPDR S&P North American Natural Resources ETF (NANR) and the ishares Exponential Technologies ETF (XT). Ric Edelman became interested in how new economy innovation and technology disruption would change investing and initially articulated the principles that BlackRock later used in creating XT. EFS played a similar role with respect to NANR. XT and NANR are sponsored and managed by BlackRock and State Street Global Advisors, respectively. Neither Ric Edelman nor EFS receives any direct or indirect compensation from either of the funds or their respective affiliates based on the sale of, or investment in, either fund. For each of these funds, a very high percentage of each ETF s total assets is held by EMAP clients. There is a conflict of interest regarding the initial role that EFS and/or Ric Edelman played in the suggestion for or the creation of these two ETFs, as well as any promotion of NANR or XT by EFS and/or Ric Edelman, in that EFS may receive indirect economic and other benefits from the association of its name with that ETF. That conflict could influence our decision to use either State Street Global Advisors SPDRs or BlackRock s ishares to provide ETFs in EMAP. There could also potentially be such a conflict in the future, if EFS and/or Ric Edelman were to play a role in the creation of a third party s index or other product. In addition, EFS has a joint marketing arrangement with Morningstar, Inc. ( Morningstar ), an unaffiliated third party that created and maintains the Morningstar Exponential Technologies Index. Under the joint marketing arrangement, EFS receives an economic benefit from Morningstar. However, neither Ric Edelman nor EFS receive any direct or indirect economic benefit from Morningstar that is correlated with either XT or the index. Nevertheless, because XT tracks the index, we are disclosing this potential conflict of interest. Insurance Related Conflicts (Item 10) EFS Advisors, acting as licensed insurance agents of EFS and/or EFLS may receive commissions and/or other sales revenue as part of an implemented financial plan. Advisors have a financial incentive to Form ADV 34 January 17, 2018

35 recommend non-emap insurance products that result in commission or other sales revenue, creating a conflict of interest with their clients. Related Person May Invest in the Same Securities (Item 11) EFS Advisors may open an EMAP account for themselves and participate in the EFS 401(k) Plan that includes EMAP. In that regard, Advisors buy and sell the same underlying securities as clients and will therefore have interest in the same securities owned by or recommended to our clients. Economic Benefit from Third Parties (Item 12) From time to time, EFS and/or Ric Edelman may enter into discussions with any third party, including existing vendors or other service providers (including without limitation BlackRock, Dimensional Fund Advisors, Morningstar, Orion, State Street Global Advisors and TD Ameritrade) regarding joint ventures, partnerships, marketing initiatives or other such forms of cooperation. EFS may also use third parties, including existing vendors or service providers in a consultative manner, sounding them out for advice or insight, at no or a reduced cost to EFS, which the Firm could use for its proprietary purposes and/or for the potential benefit of our clients. This activity could create a conflict of interest to the extent that it benefits the Firm and such benefits are not passed on to the client, or EFS otherwise makes decisions with respect to that third party which may adversely affect the client. In addition, to the extent EFS has an arrangement or relationship with a third-party separate and apart from that third party s provision of services to EFS clients, EFS judgment with regard to those services could be affected by its arrangement or relationship. Institutional Alliance Related Conflicts (Items 12 and 14) Orion and Salentica (two vendors EFS uses), along with other companies, have formed an Institutional Alliance with TD Ameritrade. EFS uses Orion as its portfolio accounting system and Salentica as its Client Relationship Management (CRM) system, and may from time to time use other vendors which are part of the Institutional Alliance. Generally speaking, new client accounts are established with TD Ameritrade as the custodian, unless the client directs otherwise. EFS has a tiered fee schedule in the contract with Orion, whereby the fee is calculated based on the number of accounts it maintains with Orion. Orion charges EFS a flat dollar amount up to a fixed number of accounts, and a fixed dollar amount per account over that threshold. The fee schedule does not vary depending on the custodian selected by EFS, in part to address the potential conflict of interest. Orion may directly or indirectly receive an economic benefit due to its Institutional Alliance relationship. The tiered fee schedule in the contract with Orion will remain in force, regardless of which custodian EFS directs business to, or whether Orion receives economic benefit from third parties. The Institutional Alliance makes it less likely for EFS to move away from TD Ameritrade, which creates a potential conflict of interest as a custodian other than TD Ameritrade may be able to provide better quality service or provide services at a lower cost to the client. However, because the cost to the client of these custodial services is included in the wrap fee, lower costs to EFS will not be reflected in the client s costs. Salentica may also directly or indirectly receive an economic benefit Form ADV 35 January 17, 2018

36 due to its Institutional Alliance relationship and there could be other such arrangements in the future. In addition, EFS has had discussions with Orion about receiving an economic benefit, based on payments Orion receives from TD Ameritrade for EFS client accounts where TD Ameritrade acts as custodian. If EFS and Orion agree to any amendment that provides economic benefits to EFS, EFS will further amend this ADV to disclose the economic benefits EFS will receive and the related conflicts of interest. Some of the products or services provided by TD Ameritrade may benefit EFS, but may not benefit client accounts. Receiving these economic benefits creates a conflict of interest and could directly or indirectly influence EFS to recommend TD Ameritrade to clients for custody and brokerage services. EFS employees may serve on TD Ameritrade Advisory Panels and be reimbursed for travel and meal expenses, as well as on Orion or Salentica Advisory Panels and be reimbursed for meals. EFS participation in the AdvisorDirect program could lead to increased client referrals. From time to time, TD Ameritrade may sponsor EFS corporate events. TD Ameritrade is the founding sponsor of the Certified Financial Planner Board of Standards, Inc. and is sponsoring EFS participation in their Financial Planner Reentry Initiative. TD Ameritrade and Orion have bought or have agreed to buy a large number of copies of The Truth About Your Future. Sponsorship of The Truth About Money Television Program (Item 14) TD Ameritrade s past sponsorship of The Truth About Money television show could create a conflict of interest and influence our choice of TD Ameritrade for client account custody and brokerage services. BlackRock, Inc., acting through ishares, in the past has sponsored The Truth About Money television show. This could create a conflict of interest as it could influence our decision to use BlackRock or ishares to provide exchange-traded funds (ETFs) in the EMAP portfolios. Dimensional Funds Related Conflicts (Item 14) Dimensional Fund Advisors LP ( Dimensional ) sponsors a "Find an Advisor" program, which may provide economic benefit to EFS and creates a conflict of interest that could influence EFS to include or continue to include Dimensional products in EMAP. EFS employees may serve on Dimensional Advisory Panels and Dimensional pays or reimburses EFS for meal expenses incurred. Form ADV 36 January 17, 2018

37 Item 12: Brokerage Practices Brokerage Selection Clients who establish an EMAP account with EFS must consent to a custodian with whom we have a clearing arrangement. Currently, we have selected the following unaffiliated registered brokerdealers, which are members of FINRA and SIPC, as Custodians, to execute and clear transactions and to provide custody services for EMAP wrap fee clients: TD Ameritrade Institutional (as cleared through TD Ameritrade Clearing, Inc.), a division of TD Ameritrade, Inc. ( TD Ameritrade ) Fidelity Institutional Wealth Services ( Fidelity ) (as cleared through National Financial Services LLC) Pershing Advisor Solutions ( PAS ) (as cleared through Pershing LLC) As noted in Step-Out Trades below, we anticipate that transactions placed in a client s account will be executed through one of the Custodians associated with EMAP (currently either TD Ameritrade, Fidelity, or PAS), however, in limited circumstances EFS may choose to execute trades with another broker-dealer if we reasonably believe that another broker-dealer can obtain a more favorable execution under the circumstances. Each Custodian also makes available other trading options that EFS is able to select, if deemed necessary, e.g. algorithmic trades, Time Weighted Average Pricing (TWAP) trades, etc. Each Custodian offers services that include custody of securities, trade execution and clearance and settlement of transactions. However, all client accounts are established with TD Ameritrade, unless the client directs otherwise. Each Custodian also provides services that are typically made available to institutional investment managers and generally are not offered to retail clients. These services include duplicate client statements and confirmations, access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to have advisory fees deducted directly from client accounts and access to mutual funds with no transaction fees. Custodians receive compensation for their services either through a fixed percentage fee based on all EMAP account assets that are maintained in the custody of their firm or on a transactional basis. All clients in the Institutional Program and a limited number of EMAP clients are handled on a transactional basis. Because the cost of what each Custodian charges EFS is included in the wrap fee, whether the Custodian charges EFS a fixed percentage or on a transactional basis has no bearing on what the client pays. EFS has an obligation to seek best execution of clients securities transactions. Therefore, in selecting broker-dealers, including Custodians for the Program, we evaluate the full range of services offered, the quality of those services and any costs indirectly borne by clients, to determine if the firm provides overall quality of service for the price. Quality of service includes, among other things, execution capability, commission rate, financial responsibility, responsiveness to the adviser, and the value of any research provided. While we attempt to negotiate favorable rates for transactions and believe that each custodian we select offers competitive rates, we do not select a custodian solely on Form ADV 37 January 17, 2018

38 the basis of cost. While another custodian may offer the same services at a lower overall cost, EFS is not required to move accounts to that custodian. ERP Each recordkeeper used has multiple clearing and custodian broker-dealer choices. EFS primarily uses TD Ameritrade, however, the client can choose another custodian broker-dealer. Neither EFS nor any of our affiliates provide brokerage services in connection with the investment advisory services provided by us to Plan sponsors through ERP. Step-Out Trades As noted in Item 5 and in the Brokerage Selection section above, in certain limited circumstances, EFS may choose to execute trades for EMAP client accounts with a broker-dealer other than TD Ameritrade, Fidelity, or PAS if we reasonably believe that the other broker-dealer can obtain a more favorable execution under the circumstances. Occasionally, typically less than 5% of the time on a transactional basis, EFS will utilize a broker-dealer other than one of the Custodians to execute large transactions if we determine that it is in our clients' best interest and that other broker-dealer has the capability to handle such large transactions and to reduce or eliminate any potential negative price fluctuation. This generally will occur when the size of the transaction in any one security is so large that it could cause the price of the security to fluctuate, up or down, resulting in an unfavorable execution price for our clients. Where EFS trades through a broker-dealer other than one of the Custodians, the EMAP wrap fee does not include the compensation that is paid to that broker-dealer. This compensation is embedded into the price of the security which is paid by the client. These additional costs are in addition to the wrap fee paid by the client. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Best Execution EFS seeks the best available execution for client transactions and monitors transactions (including rebalancing, reallocation, model changes and liquidations) retrospectively to evaluate whether best execution was obtained. The Firm has established a Best Execution Committee, which monitors best execution with its custodians, utilizing reports provided by these custodians and other 3rd party sources. Additionally, EFS reviews each broker-dealer's execution reports to evaluate the services provided, quality of executions, fee rate, and other services. Trade Errors As a fiduciary, EFS has the responsibility to effect trade orders correctly, promptly and in the best interests of its clients. In the event an error occurs in the handling of any client transaction due to EFS' actions or inactions, EFS' policy is to identify and correct the error as promptly as possible and make the client whole. If the error is the responsibility of EFS, any client transaction will be corrected and EFS will be responsible for client losses resulting from an inaccurate or erroneous order. Resulting gains after the client is made whole will be netted against losses in the EFS error account. If the EFS error Form ADV 38 January 17, 2018

39 account reflects a net gain when the custodian reconciles the account, the gains will be donated to a charity designated by EFS. Occasionally, an error is caused by the client. In those situations where EFS can correct it, the error will be corrected promptly in the client s best interest and reviewed on a case-by-case basis to determine the party responsible for potential losses. Clients are to be reminded that EFS cannot guarantee that data presented to them is free from error and that they are also responsible for informing the Firm of any noted inaccuracies in a timely manner. Soft Dollars The custodians that EFS uses (TD Ameritrade, Fidelity, and PAS), offer various services to EFS, including custody of client securities; trade execution; clearance and settlement of transactions; access to platform systems; duplicate client statements; research-related products and tools; access to a trading desk; access to block trading, which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts; the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and use of overnight courier services. Some of these services may benefit EFS but may not benefit our clients and receipt of these economic benefits creates a conflict of interest and could directly or indirectly influence EFS to recommend a certain custodian to clients for custody and brokerage services. These custody services are paid for as part of the client s wrap fee. Orion and Salentica (two vendors EFS uses), along with other companies, have formed an Institutional Alliance with TD Ameritrade. EFS uses Orion as its portfolio accounting system and Salentica as its Client Relationship Management (CRM) system, and may from time to time use other vendors which are part of the Institutional Alliance. Generally speaking, new client accounts are established with TD Ameritrade as the custodian, unless the client directs otherwise. EFS has a tiered fee schedule in the contract with Orion, whereby the fee is calculated based on the number of accounts it maintains with Orion. Orion charges EFS a flat dollar amount up to a fixed number of accounts, and a fixed dollar amount per account over that threshold. The fee schedule does not vary depending on the custodian selected by EFS, in part to address the potential conflict of interest. Orion may directly or indirectly receive an economic benefit due to its Institutional Alliance relationship. The tiered fee schedule in the contract with Orion will remain in force, regardless of which custodian EFS directs business to, or whether Orion receives economic benefit from third parties. The Institutional Alliance makes it less likely for EFS to move away from TD Ameritrade, which creates a potential conflict of interest as a custodian other than TD Ameritrade may be able to provide better quality service or provide services at a lower cost to the client. However, because the cost to the client of these custodial services is included in the wrap fee, lower costs to EFS will not be reflected in the client s costs. Salentica may also directly or indirectly receive an economic benefit due to its Institutional Alliance relationship and there could be other such arrangements in the future. Form ADV 39 January 17, 2018

40 In addition, EFS has had discussions with Orion about receiving an economic benefit, based on payments Orion receives from TD Ameritrade for EFS client accounts where TD Ameritrade acts as custodian. If EFS and Orion agree to any amendment that provides economic benefits to EFS, EFS will further amend this ADV to disclose the economic benefits EFS will receive and the related conflicts of interest. See Item 14 for a more detailed discussion of some of the specific conflicts of interest arising from the Firm s custodian relationship with TD Ameritrade. Please also see the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict with the Institutional Alliance. From time to time, EFS and/or Ric Edelman may enter into discussions with any third party, including existing vendors or other service providers regarding joint ventures, partnerships, marketing initiatives or other such forms of cooperation. EFS may also use third parties, including existing vendors or service providers in a consultative manner, sounding them out for advice or insight, at no or a reduced cost to EFS, which the Firm could use for its proprietary purposes and/or for the potential benefit of our clients. This activity could create a conflict of interest to the extent that it benefits the Firm and such benefits are not passed on to the client, or EFS otherwise makes decisions with respect to that third party which may adversely affect the client. In addition, to the extent EFS has an arrangement or relationship with a third-party separate and apart from that third party s provision of services to EFS clients, EFS judgment with regard to those services could be affected by its arrangement or relationship. Please see the Conflicts of Interest and Other Disclosures section within Item 11 for information on this conflict. Client Referrals EFS participates in the TD Ameritrade Institutional Program known as AdvisorDirect. TD Ameritrade Institutional is a division of TD Ameritrade, an independent and unaffiliated SEC registered brokerdealer, member FINRA/SIPC. There is no employee or agency relationship between TD Ameritrade and EFS. The AdvisorDirect program allows TD Ameritrade to refer its brokerage customers and other investors seeking fee-based personal investment management or financial planning services to other advisors such as EFS. TD Ameritrade has established the referral program as a means of retaining brokerage customers. TD Ameritrade does not supervise EFS and has no responsibility for our management of client asset allocation models or other advice or services. To participate in AdvisorDirect, an advisor must meet certain minimum eligibility criteria; fee-based compensation, education and investment experience, AUM, and licensing and registration. However, AdvisorDirect is not open to all advisors who meet these minimum criteria. TD Ameritrade limits the number of advisors based on the services provided and investment style of the advisor. We receive client referrals from TD Ameritrade through participation in the AdvisorDirect program that result in economic benefit to EFS. We pay TD Ameritrade an ongoing referral fee for each successful client referral. This fee is usually a percentage (not to exceed 25%) of the annual advisory fee that the client pays us. We will also pay TD Ameritrade the referral fee on any advisory fees we Form ADV 40 January 17, 2018

41 receive from any of a referred client s family members, including a spouse, child, or any other immediate family member who resides with the referred client and also becomes an EFS client. Clients who are referred through this program do not pay higher fees or costs than other EFS clients. For more information regarding additional or other fees paid directly or indirectly to TD Ameritrade, please refer to the TD Ameritrade AdvisorDirect Disclosure and Acknowledgment Form. EFS participation in the AdvisorDirect program poses conflicts of interest. TD Ameritrade will most likely refer clients through AdvisorDirect to EFS to encourage clients to custody their assets at TD Ameritrade and maintain client accounts that are profitable to TD Ameritrade. Consequently, in order to obtain client referrals from TD Ameritrade, we have an incentive both to recommend to clients that assets under management be held in custody with TD Ameritrade and to place transactions for client accounts with TD Ameritrade. We have agreed not to solicit clients referred through AdvisorDirect to transfer their accounts from TD Ameritrade nor to establish brokerage or custody accounts at other custodians, except when our fiduciary duties require doing so. EFS participation in AdvisorDirect does not diminish our duty to seek best execution of trades for client accounts. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Trade Aggregation Policy Whenever appropriate, EFS may aggregate same side transactions for certain securities on behalf of all EMAP accounts, including accounts of Advisors and employees. It is the policy of EFS that such transactions will be allocated to all participating client accounts in a fair and equitable manner. There is no preferential treatment given to any account. Transactions may be aggregated together to achieve an average execution price. Mutual funds, variable annuities and 529 College Savings Plans are purchased directly from the issuer, and no aggregation of these transactions occurs. Item 13: Review of Accounts The Investment Committee, as discussed below, oversees rebalancing and the evaluation of EMAP performance. Generally speaking, client accounts are reviewed daily by the trading system for potential rebalancing opportunities, unless certain restrictions have been placed on the account. Funds in the accounts that have exceeded or fallen below their drift parameters are adjusted to get them back to their original asset target(s). Ongoing monitoring includes an evaluation of EMAP performance for potential changes to add or remove asset classes, reallocate asset classes, as well as add, remove, or replace securities as market or other conditions warrant. Securities we buy or sell for accounts are subject to our limited discretionary authority. EFS Advisors generally meet periodically with clients to review economic, tax, financial, political, social and other relevant issues and to determine whether any changes in strategy are warranted. Based on these meetings, client situations and circumstances are reviewed on a periodic basis and recommendations are made as needed. Changes may also be made based on the client s personal circumstances, including health, employment and family status, time horizon or restrictions that the Form ADV 41 January 17, 2018

42 client may place on the investments in the account. On at least an annual basis, EMAP clients are contacted to update their personal and financial information, including health, employment, marital and family status, time horizon, goals and objectives, and risk tolerance. The information is used to determine if there are any changes that could impact the ongoing suitability of the account. Clients may request a review at any time as well. Non-Advisory Account Aggregation Technology Services EFS offers to clients who are users of its secure client portal ( a personal finance information management tool designed to allow clients to aggregate information regarding accounts at EFS and other outside accounts such as investment accounts, bank accounts, credit cards, 401(k) accounts, brokerage accounts, and other financial account information established through or held with third parties. This account aggregation tool allows clients to view their linked outside accounts, as well as their EFS accounts, in one interface. This tool is provided as a free service for clients convenience and is for informational purposes only. Information regarding client outside accounts linked through the account aggregation tool is made available for viewing by the client s financial planner. Information about outside accounts is made available to the financial planner in read only mode, meaning the planner (and EFS) has no ability to access the client s outside accounts or otherwise effect any changes to any outside account. Clients must authorize EFS to access and view their outside account information to use the account aggregation tool. Details regarding client use of the account aggregation tool are provided in the Terms and Conditions which are displayed when clients sign up to use the tool in the client only portal. Clients who link outside accounts through the account aggregation tool should be aware that EFS is under no obligation to review or take into consideration information regarding outside accounts when providing advisory or other financial planning services. Clients may request in writing that their financial planner consider their outside accounts as part of any annual review of their advisory accounts managed by EFS and the planner may choose to do so at their sole discretion. However, clients should understand that their planner s review and consideration of their outside account information is only to better understand their overall financial circumstances and will not be considered when rendering any asset allocation advice or recommendations in connection with the client s advisory accounts managed by EFS. Additionally, client is advised that EFS or their planner is under no obligation to review or monitor any outside account linked through the account aggregation tool on an ongoing basis. As such, outside account information will not be taken into consideration by the financial planner when providing investment or asset allocation advice or other financial planning services unless requested to do so by the client as described above. Client should further understand that EFS does not manage or supervise any outside account linked through the account aggregation portal. Investment Committee The Investment Committee ( Committee ) is an independent advisory body to senior management, which conducts ongoing reviews and makes recommendations with respect to the ongoing portfolio management and construction of new and existing EMAP asset allocation models. The Committee Form ADV 42 January 17, 2018

43 makes recommendations to senior management regarding adjustments to the models available through EMAP that it deems necessary and appropriate considering material changes since the model portfolios were originally constructed or previously modified. The Committee also evaluates recommendations from senior management regarding any such proposed material changes to EMAP and/or the models. ERP ERP Plan assets invested in ERP Models are monitored on an ongoing basis. Plan assets invested in the Models are rebalanced or reallocated based on market or other conditions as warranted, consistent with changes recommended by the EFS Investment Committee. Changes in the Models, which include adding, removing or replacing securities at the recommendation of the EFS Investment Committee, are made infrequently based on a variety of factors, which include but are not limited to changes in the economic, financial or political climate; and the management of the securities used by the Model. Changes may also be made based on the Plan s circumstances or restrictions that the Plan sponsor (or other Plan fiduciary or agent) may place on the investments in the Plan s account. Item 14: Client Referrals and Other Compensation Turnkey Asset Management Program (TAMP) EFS has established a Turnkey Asset Management Program ( TAMP ), whereby the Firm makes the EMAP asset allocation models available to clients of select unaffiliated investment advisors ( TAMP Advisors ). EFS conducts a due diligence review of each TAMP Advisor and each of their investment advisor representatives (IARs) who will be offering EMAP, prior to establishing the relationship and on an ongoing basis thereafter. We provide systems, services, and back-office support to the TAMP advisors. EFS has appointed a Manager to administer the TAMP program, manage the TAMP Advisor relationships and help to ensure proper support of their clients. The TAMP Advisor is responsible for the supervision of its IARs. The TAMP Advisor initiates the relationship with the client and is the ongoing client relationship manager. The TAMP Advisor, through its IARs, compiles personal and financial information about the client, maintains the appropriate books and records, makes an asset allocation model recommendation that will meet the client s goals and objectives, maintains the ongoing client relationship, and meets with the client on a periodic basis to discuss suitability and any reasonable restrictions the client would like to impose on his/her account. The EMAP fee is shared between the two entities on a negotiated basis. The client does not pay an increased fee for EMAP because of this arrangement. Client Referrals From time to time, EFS will enter into agreements to pay other investment advisers ( Solicitors ) for client referrals in accordance with the requirements of the Cash Solicitation Rule of the Investment Advisers Act, the respective federal and state laws governing the same, and ERISA, if applicable. In such cases, the Solicitors will be paid a percentage of the wrap fees EFS receives relating to the Form ADV 43 January 17, 2018

44 client s account with EFS. EMAP wrap fees are based on a percentage of client assets invested in the wrap fee program. Any such referral fee will be paid solely from the investment advisory fee. The client does not pay an increased fee because of these arrangements. Compensation paid to a Solicitor is negotiated between the Solicitor and EFS. The client is provided with a copy of the EFS ADV and a copy of the EFS written disclosure document, which describes the arrangement between EFS and the Solicitor, including the terms, conditions and compensation. TD Ameritrade Institutional Program EFS participates in the TD Ameritrade Institutional Program. We receive services that include custody of client securities, trade execution, clearance and settlement of transactions. The Institutional Program provides additional economic benefits to EFS that are not typically available to TD Ameritrade retail investors. There is no direct link between EFS participation in the program and the investment advice it gives to its clients. The economic benefits include the following products and services, which are provided at no cost or at a reduced cost to EFS: Receipt of duplicate client statements and confirmations Research-related products and tools Consulting services Access to a trading desk serving EFS Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts) The ability to have advisory fees deducted directly from client accounts Access to an electronic communications network for client order entry and account information Access to mutual funds with no transaction fees and to certain institutional money managers Discounts on compliance, marketing, research, technology and/or other services Practice management products or services provided to EFS by third-party vendors Business consulting and professional services received by EFS-related persons (may be paid for by TD Ameritrade) Some of the products and services made available by TD Ameritrade through the Institutional Program may benefit EFS but may not benefit client accounts. These products or services may assist us in managing and administering client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help EFS manage and further develop our business enterprise. The benefits received by EFS or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As disclosed above, EFS participates in TD Ameritrade s Institutional Program and EFS Form ADV 44 January 17, 2018

45 will recommend TD Ameritrade to clients for custody and brokerage services. Therefore, receiving these economic benefits creates a conflict of interest and could directly or indirectly influence EFS to recommend TD Ameritrade to clients for custody and brokerage services. Compensation for Other Products and Services EFS Advisors, acting solely in their capacity as registered representatives of EFLS, may receive upfront and/or annual commissions on non-emap broker-dealer products and/or insurance products purchased by financial planning clients who may choose to implement their financial plan through us. EFS Advisors may also receive 12b-1 fees as a result of placing clients with retail mutual funds. EMAP clients do not incur sales charges, commissions, or 12b-1 fees when purchasing or owning variable annuities or mutual funds in their EMAP account. As a financial planning firm, EFS makes the following statements: (1) Our Advisors are licensed to sell insurance products from several insurance companies and receive sales or referral compensation from any such transactions. (2) Clients are under no obligation to have us or our Advisors implement any suggestions made in the financial plan. (3) If asked to implement the suggestions of the financial plan, we intend to implement such financial planning, in whole or in part, through products selected by us and to clear securities transactions through TD Ameritrade, Fidelity or PAS, as described in Item 12. (4) To the extent EFS Advisors implement recommendations through EFLS, a. they are acting as registered representatives of EFLS; b. they will use only products offered by EFLS; and c. they may earn upfront and/or annual commissions. Clients have total freedom to execute securities and/or insurance transactions with any company of their choice other than with respect to participation in EMAP or the receipt of ongoing, annual financial planning recommendations. TD Ameritrade Advisory Panels EFS employees may serve on TD Ameritrade Institutional Advisory Panels from time to time. The panels are sponsored by TD Ameritrade and consist of independent advisors who advise TD Ameritrade on issues relevant to its service, technology and products provided. In-person meetings are held one to four times a year. Panel members are not compensated for their participation; however, TD Ameritrade may pay or reimburse EFS for the travel, lodging and meal expenses incurred when EFS employees attend panel meetings. The benefits received by EFS and its employees by serving on a panel do not depend on the amount of brokerage transactions directed to TD Ameritrade. Clients should be aware, however, that the receipt of economic benefit by EFS and its employees in and of itself creates a conflict of interest and could indirectly influence EFS recommendation of TD Ameritrade for custody of assets and brokerage services. Please refer to the Form ADV 45 January 17, 2018

46 Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Panel members are selected by TD Ameritrade and appointed to serve for a three-year term. Longer service is permitted at the discretion of TD Ameritrade Institutional sales, service and senior management. At times, panel members are provided with confidential information about TD Ameritrade initiatives. Therefore, panel members are required to sign a confidentiality agreement. Orion and Salentica Advisory Panels EFS employees may serve on Orion or Salentica Advisory Panels from time to time. The panels are sponsored by these vendors and consist of independent advisors who advise the vendors on issues relevant to their products provided. Panel members are not compensated for their participation, however Orion or Salentica pay or reimburse EFS for the travel, lodging and meal expenses incurred when EFS employees attend panel meetings. Clients should be aware that the receipt of these economic benefits by EFS and its employees in and of itself creates a conflict of interest. In addition, as Orion and Salentica are part of the Institutional Alliance, this could indirectly influence EFS to recommend TD Ameritrade to clients for custody and brokerage services. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Dimensional Fund Advisory Panels EFS employees may serve on Dimensional Fund Advisors LP ( Dimensional ) Advisory Panels from time to time. The panels are sponsored by Dimensional and consist of independent advisors who advise Dimensional on issues relevant to its products provided. Panel members are not compensated for their participation and EFS pays for the travel and lodging expenses incurred when EFS employees attend panel meetings; however, Dimensional pays or reimburses EFS for meal expenses. Clients should be aware that the receipt of these economic benefits by EFS and its employees in and of itself creates a conflict of interest and could influence EFS to include or continue to include Dimensional managed mutual funds in the EMAP portfolios or recommend other Dimensional products or services. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Sponsorship of The Truth About Money Television Program Ric Edelman is the host of a syndicated television program, The Truth About Money with Ric Edelman, airing on public television stations. The program covers many aspects of financial education. A portion of the television show is filmed before a studio audience where participants can ask questions. An audience participant may discuss a specific mutual fund, ETF, or insurance product that may be held in the accounts of certain EMAP clients or under consideration at the time of the question. Mr. Edelman does not give specific legal, tax or investment advice, and he may give advice that is the same as or different from the advice EFS has given or may give to its clients. The Truth About Money with Ric Edelman is no longer producing new episodes, but previously produced episodes air on Public Television stations; episodes are also available on Form ADV 46 January 17, 2018

47 In the past, TD Ameritrade sponsored the television show. The decision of TD Ameritrade to act as a sponsor of the television program was made at its sole discretion and expense. Participation by EFS employees in the TD Ameritrade Institutional Operations Panel, EFS participation in the AdvisorDirect program, and TD Ameritrade s agreement to sponsor the television program in the past create conflicts of interest and could influence our choice of TD Ameritrade for client account custody and brokerage services. In selecting custodial and brokerage firms, we evaluate all the services offered, the quality of those services and the cost indirectly borne by clients to determine if a clearing firm provides overall quality of services for the price. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. In the past, ishares, the exchange-traded fund business of BlackRock, Inc., and one of the industry s leading exchange-traded funds platforms, also acted as a sponsor of the aforementioned television show. The decision of BlackRock to act as a sponsor of the television program was made at its sole discretion and its own expense. BlackRock s agreement to sponsor the television program in the past creates a conflict of interest and could influence our decision to use BlackRock or ishares to provide exchange-traded funds (ETFs) in the EMAP portfolios. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. Evaluation of NANR, XT and Other ETFs Certain models available through EMAP include positions in the SPDR S&P North American Natural Resources ETF (NANR) and the ishares Exponential Technologies ETF (XT). Ric Edelman became interested in how new economy innovation and technology disruption would change investing and initially articulated the principles that BlackRock later used in creating XT. EFS played a similar role with respect to NANR. XT and NANR are sponsored and managed by BlackRock and State Street Global Advisors, respectively. Neither Ric Edelman nor EFS receives any direct or indirect compensation from either of the funds or their respective affiliates based on the sale or investment in either fund. For each of these funds, a very high percentage of each ETF s total assets is held by EMAP clients. There is a conflict of interest regarding the initial role that EFS and/or Ric Edelman played in the suggestion for or the creation of these two ETFs, as well as any promotion of NANR or XT by EFS and/or Ric Edelman, in that EFS may receive indirect economic and other benefits from the association of its name with that ETF. That conflict could influence our decision to use either State Street Global Advisors SPDRs or BlackRock s ishares to provide ETFs in EMAP. There could potentially also be such a conflict in the future, if EFS and/or Ric Edelman were to play a role in the creation of a third party s index or other product. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. In addition, EFS has a joint marketing arrangement with Morningstar, an unaffiliated third party that created and maintains the Morningstar Exponential Technologies Index. Under the joint marketing arrangement, EFS receives an economic benefit from Morningstar. However, neither Ric Edelman nor EFS receive any direct or indirect economic benefit from Morningstar that is correlated with Form ADV 47 January 17, 2018

48 either XT or the index. Nevertheless, because XT tracks the index, we are disclosing this potential conflict of interest. In selecting new ETFs for our portfolios or evaluating those currently used, the Portfolio Manager presents the results of any pertinent analysis to the Investment Committee and a decision is reached after consideration of the quantitative results as well as other, more qualitative factors as discussed above in Item 8. The EFS Chief Compliance Officer periodically attends Investment Committee meetings and provides Conflicts of Interest training to the Investment Committee. TDA Sponsorship of EFS Corporate Events From time to time, TD Ameritrade may sponsor EFS corporate events. The decision to act as a sponsor of EFS corporate events is at their sole discretion and expense. The sponsorship of EFS corporate events by TD Ameritrade provides indirect economic benefits to EFS and creates a potential conflict of interest that could indirectly influence EFS to recommend TD Ameritrade to clients for custody of assets and brokerage services. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. EFS Participation in the Financial Planner Reentry Initiative The Certified Financial Planner Board of Standards, Inc. (CFP Board) is a non-profit organization that promotes the value of professional, competent and ethical financial planning services, as represented by those who have attained CFP certification. The CFP Board sponsors an initiative called the Financial Planner Reentry Initiative, to support financial services firms in establishing reentry programs for experienced professionals seeking to return to the workforce. Payment for EFS participation in this program is not required, as a result of the lead founding sponsorship of the CFP Board s Center for Financial Planning by TD Ameritrade Institutional. This arrangement provides indirect economic benefits to EFS and creates a potential conflict of interest that could indirectly influence EFS to recommend TD Ameritrade to clients for custody of assets and brokerage services. Please refer to the Conflicts of Interest section within Item 11 for further information on this conflict. Evaluation of Dimensional Funds Products Dimensional Fund Advisors LP ( Dimensional ) is an SEC registered investment adviser that manages securities and other assets (which are used in EMAP accounts) for mutual funds, institutional investors and clients of independent financial advisers. Dimensional has developed an internet-based tool called "Find an Advisor" to assist investors trying to locate financial advisors through whom they may purchase Dimensional Funds. This program provides direct or indirect economic benefits to EFS and creates a conflict of interest that could influence EFS to include or continue to include Dimensional managed mutual funds in the EMAP portfolios or recommend other Dimensional products or services. Please refer to the Conflicts of Interest and Other Disclosures section within Item 11 for further information on this conflict. As part of our fiduciary duty to clients, we endeavor at all times to put the interests of our clients first. In selecting new mutual funds or ETFs for our portfolios and evaluating those currently used, the Portfolio Manager presents the results of any pertinent analysis to the Investment Committee Form ADV 48 January 17, 2018

49 and a decision is reached after consideration of the quantitative results as well as other, more qualitative factors. Please refer to Item 8 above for further discussion on the firm s investment selection methodology. The EFS Chief Compliance Officer periodically attends Investment Committee meetings and provides Conflicts of Interest training to the Investment Committee. Item 15: Custody EFS does not maintain custody of client funds or securities. We establish relationships with various non-affiliated third-party clearing/custodian broker-dealers who are responsible for taking custody of and maintaining all client funds and securities, as discussed in Item 12. Confirmations and account statements are sent directly to the client by the applicable Custodian on at least a quarterly basis and should be reviewed carefully by the client. Item 16: Investment Discretion EMAP Based on a written, signed agreement, EMAP clients give EFS limited discretionary authority to execute client-approved investment strategies in their accounts. We are granted limited discretionary authority that allows us to place orders through one of several custodians mentioned in Item 12. Clients give us the ability to make the following determinations in accordance with the client s specified investment objectives, without client consultation or consent before a transaction is effected: Invest client assets into a diversified mix of asset classes and investment securities, primarily in the form of shares of open-end registered investment companies, exchange-traded funds, variable annuities, and 529 College Savings Plans. Modify or change the mix of asset classes and investment securities within the account. Rebalance the account periodically. Clients are permitted to impose reasonable restrictions on the management of their accounts. When imposing restrictions, clients may request that particular securities or types of securities not be purchased, not be sold or that such securities (if held in the account) be sold. Clients, however, cannot request that particular securities be purchased for their accounts. Additionally, EFS has no influence or control over the mix of securities held by any mutual fund, variable annuity or ETF in which client accounts may be invested. We reserve the right, at our sole discretion, to reject any account for which unreasonable or overly restrictive conditions are requested. Form ADV 49 January 17, 2018

50 Risks EFS does not assume market risk on behalf of the client. EFS does not guarantee the performance of the client s account or any specific level of performance. Market values of the securities within the account will fluctuate with market conditions. When the account is liquidated, it may be worth more or less than the original amount invested. Trading Authorization Once an asset allocation model has been selected, EFS has limited discretionary authority to invest the assets in the account in accordance with the asset allocation model selected by the client. Such discretionary authority includes the ability to select (and modify) the investments underlying each asset allocation model available in EMAP. EMAP clients must establish brokerage accounts with one of the custodians associated with EMAP, which currently include TD Ameritrade, Fidelity and PAS. When EFS transacts purchases or sales for a particular client s account through a Custodian, the transaction costs associated with such trading activity are covered by the EMAP fee. (Please refer to the discussion of Step-Out Trades in Item 12 above for information about instances when clients will incur transaction costs in addition to the EMAP fee.) The Custodians perform all the necessary brokerage services for accounts maintained with them and provide custody services of client assets. In choosing which Custodian to use for EMAP, we generally select TD Ameritrade, which in turn provides certain economic benefits to EFS, as discussed in Items 12 and 14. On occasion EFS may direct a transaction to a broker-dealer other than one of the Custodians for execution, as discussed further in Step-Out Trades in Item 12 above. In these cases, the broker-dealer is acting as an executing broker-dealer and delivers the transaction to the applicable Custodian for allocation to client accounts, as discussed in Item 5. Reallocations EFS has the limited discretionary authority to reallocate assets in models and client accounts. In a reallocation, we change the target percentages of some or all of the asset classes or types of assets relative to the total model. Models and accounts are monitored on an ongoing basis and assets reallocated based on market or other conditions as warranted. Changes in the asset allocation model, which include adding, removing or replacing securities at the discretion of EFS, are made based on a variety of factors, including but not limited to changes in the economic, financial or political climate; changes in the tax code; new economy innovation and technological disruption; and the management of the underlying securities used by the asset allocation model. EFS may replace a particular security (or securities) if it significantly diverges from its relevant index in terms of risk or return with a security that is more in line with the risk/return profile of the relevant index, or if there is a different security that, in our opinion, would be better suited for the client s account or a model portfolio in general. Reallocations occur with less frequency than rebalancing. Clients are sent confirmations by the relevant Custodian for any transactions effected in their accounts. Rebalancing Each EMAP account is invested in accordance with the client s asset allocation strategy. At the inception of an account, EMAP assets are invested in specific asset types, including mutual funds (including funds that are used as funding vehicles for variable annuity contracts) or ETFs that invest Form ADV 50 January 17, 2018

51 in a variety of equity securities or fixed income or cash instruments. Amounts invested in each fund are determined in accordance with the set asset allocation targets associated with the client s model. Afterwards, as markets fluctuate and values change, amounts originally allocated to a fund will either exceed or fall below the target allocations. We periodically adjust account holdings to be in line with the asset allocation targets, or rebalance the account. We do not rebalance accounts constantly, and asset allocations may drift away from the target asset allocation associated with the client s model before EFS, within our sole authority and judgment, brings those allocations back in line with the target percentages. The investment philosophy of an asset allocation strategy is to be positioned in various asset types so that if the asset type becomes profitable, the account is positioned to take advantage of the upturn. Liquidations Except in certain limited circumstances (e.g. suspected elder abuse), EFS will accept and follow all liquidation instructions given by clients and will seek to execute client orders in a timely manner on a best-efforts basis. Occasionally, due to market conditions and time constraints imposed by custodians, trades may be executed the following business day. In handling liquidations and purchases, we will execute transactions without regard to pending dividend or capital gains distributions, stock splits, mergers, or other corporate or financial events. Contributions Contributed cash or money market fund shares in client accounts may remain uninvested in securities for a period of time. Although clients may deposit freely tradable securities in their accounts to meet the EMAP minimum account size, we will liquidate those securities positions and invest the proceeds in securities matching the client s selected investment strategy. Tax consequences associated with this liquidation and reinvestment process will likely occur, and clients should consult with their tax professional before depositing securities in their EMAP accounts. EFS invests assets in an orderly manner and believes it is to each client s benefit to invest in an aggregated fashion rather than piecemeal. For this reason, a period of time may elapse between the deposit of cash, liquid assets or security positions to the account and the account reaching a fully invested position. EFS does not provide legal or tax advice to clients. Clients are advised to discuss the possible legal or tax consequences of their investment decisions with their legal or tax advisors prior to effecting any transaction. ERP Designated Investment Alternatives, Qualified Default Investment Alternatives, and Models EFS offers discretionary services with respect to the selection and monitoring of designated investment alternatives ( DIAs ), qualified default investment alternatives (QDIAs), and Models made available to Plans. If these services are selected by the Plan sponsor (or other Plan fiduciary or agent) under the ERP agreement, EFS will have discretionary authority to select, replace, and remove Form ADV 51 January 17, 2018

52 DIAs, QDIAs, and Models available under the Plan. DIAs, QDIAs, and Models will be monitored on an ongoing basis for consistency with the Plan s IPS, investment objectives, and financial circumstances, as well as market conditions and other relevant factors. Plan sponsors (or other Plan fiduciaries or agents) will generally be notified of any additions to or removals of the Plan s DIAs, QDIAs, and Models. Model Reallocations Under the ERP Investment Management Agreement, EFS has the limited discretionary authority to change a Model s asset allocations and its Underlying Investments. Models are monitored on an ongoing basis and reallocations are made based on market or other conditions as warranted pursuant to the EFS Investment Committee s recommendations, and/or the Plan s circumstances or restrictions imposed by the Plan sponsor (or other Plan fiduciary or agent). We will notify the Plan sponsor (or other Plan fiduciary or agent) when replacing an Underlying Fund from the Plan s investment menu, if it significantly diverges from its relevant index in terms of risk or return, with another Underlying Fund that is more in line with the risk/return profile of the relevant index. Reallocations occur with less frequency than rebalancing. Generally, Plan sponsors (or other Plan fiduciaries or agents) are notified of reallocations after the transactions are made. Model Rebalancing Each Investment Option is invested in a mix of Underlying Funds in accordance with the corresponding Model approved by the Plan sponsor (or other Plan fiduciary or agent) and the target allocation percentages determined by that Model. As markets fluctuate and values change, the actual percentage allocations of some or all of the Underlying Funds for the Investment Option s Model will either exceed or fall below the target percentage allocations. At EFS discretion, we may periodically rebalance an Investment Option s holdings in Underlying Funds to return the Investment Option to be in line with its target percentage allocations under the Model. However, we do not rebalance Investment Options constantly. Actual percentage allocations may drift away from the target asset allocation associated with the Model before EFS, within our authority and judgment based on market or other conditions as warranted, brings those allocations back in line with the target percentage allocations. Item 17: Proxy Voting Client Securities EFS does not accept proxy voting responsibility for client accounts. Therefore, we have no obligation or authority to take action or render any advice with respect to the voting of proxies solicited by or with respect to issuers of securities held in client accounts. We expect clients to expressly retain the authority and responsibility for proxy voting. With respect to ERISA accounts, we generally expect the Plan sponsor to expressly retain the authority and responsibility for proxy voting and to specify in writing who has voting authority. All clients will receive proxies directly from the custodian. Clients may direct any questions to their Advisor should the need arise. Form ADV 52 January 17, 2018

53 Item 18: Financial Information Registered investment advisers are required to provide clients with financial information or disclosures about their financial condition under certain circumstances. We are not aware of any financial condition that would impair our ability to meet contractual or fiduciary commitments to clients. We have not been the subject of any bankruptcy proceeding. Form ADV 53 January 17, 2018

54 Edelman Managed Asset Program (EMAP) Wrap Fee Brochure This wrap fee brochure provides information about the qualifications and business practices of Edelman Financial Services, LLC. If you have any questions about the contents of this brochure, please contact us at 888-PLAN-RIC ( ), or you may us at or write to us at the address below. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission ( SEC ) or by any state securities authority, nor does registration with the SEC imply a certain level of skill or training. Additional information about Edelman Financial Services, LLC is also available on the SEC s website at Legato Road, 9 th Floor Fairfax, VA EdelmanFinancial.com RicEdelman.com 888-PLAN-RIC ( ) (fax) info@ricedelman.com January 17, 2018

55 Item 2: Material Changes Significant changes to this updated wrap fee brochure are contained in this section. Future wrap fee brochures will contain similar summaries. The following are material changes to this brochure that were made since the last annual amendment to this brochure was filed on March 31, 2017: We have revised Item 9 to describe our joint marketing arrangement with Morningstar (as defined below) and the potential conflict of interest resulting from this relationship. In addition, Jon Isaacson joined EFS on November 27th as the Chief Financial Officer. Rene Chaze was the CFO and has assumed a new role as Chief Development Officer, leading the firm s inorganic growth strategy. We review our brochure and revise existing disclosure when we believe our clients would benefit from an enhanced description of EMAP (as defined below) and our services. In addition to the material changes summarized above, we have made a number of immaterial changes to this brochure to enhance existing disclosure. Under SEC rules, we ll give you a new wrap fee brochure within 120 days of the end of our fiscal year. You may also receive updates at other times if there are any material changes. You can also request a new wrap fee brochure at any time and at no charge. You can request a free brochure by calling us at 888-PLAN-RIC ( ). You can also find out more about us and receive our current brochure from the SEC s website, The site can also give you information about people who are registered or about to be registered as Investment Advisor Representatives of our firm. Wrap Fee Brochure 2 January 17, 2018

56 Item 3: Table of Contents Edelman Managed Asset Program (EMAP) Wrap Fee Brochure... 1 Item 2: Material Changes... 2 Item 3: Table of Contents... 3 Item 4: Services, Fees and Compensation... 6 Services... 6 Trading Authorization... 7 Rebalancing... 7 Reallocation... 7 Edelman Retirement Program... 8 Institutional Advisory Services... 8 Fees and Compensation... 9 Retail Clients... 9 Institutional Clients ERP Clients Disclosures Relevant to All Clients Other Fees and Expenses Step-Out Trades Best Execution Item 5: Account Requirements and Types of Clients Account Requirements Minimum Account Size Types of Clients Item 6: Portfolio Manager Selection and Evaluation Performance Calculation Investment Strategy Rebalancing Reallocations Trade Aggregation Policy Wrap Fee Brochure 3 January 17, 2018

57 Trade Allocation Policy Trade Errors Methods of Analysis and Investment Selection Risk of Loss Soft Dollars Performance-Based Fees and Side-by-Side Management Voting Client Securities Item 7: Client Information Provided to Portfolio Manager Item 8: Client Contact with Portfolio Managers Item 9: Additional Information Disciplinary Information Other Financial Industry Activities and Affiliations Related Persons Affiliated Broker-Dealer Other Affiliated Investment Advisers and Broker-Dealers Insurance Agencies Equity Investors The Retirement InCome for Everyone Trust (RIC-E Trust ) Code of Ethics Related Person May Invest in the Same Securities Agency Cross Procedures Conflicts of Interest and Other Disclosures Affiliated Broker-Dealer Related Conflicts (Item 9 / Part 2A Items 5 and 10) Fees and Expenses (Item 4 / Part 2A Items 8 and 12) Involvement with the NANR and XT ETFs (Item 9 / Part 2A Items 8 and 14) Related Person May Invest in the Same Securities (Item 9 / Part 2A Item 11) Economic Benefit from Third Parties (Item 6 / Part 2A Item 12) Institutional Alliance Related Conflicts (Item 9 / Part 2A Items 12 and 14) Dimensional Funds Related Conflicts (Item 9 / Part 2A Item 14) Review of Accounts Wrap Fee Brochure 4 January 17, 2018

58 Investment Committee Nature and Frequency of Client Reports Client Referrals and Other Compensation Turnkey Asset Management Program (TAMP) Client Referrals Relationship with TD Ameritrade and Others Financial Information Wrap Fee Brochure 5 January 17, 2018

59 Item 4: Services, Fees and Compensation Services The Edelman Managed Asset Program ( EMAP ) is a wrap fee asset allocation program sponsored by Edelman Financial Services, LLC (sometimes referred to as EFS, Firm or We ). Our wrap fee program is available to our clients and to unaffiliated registered investment advisors and their clients. The client retains EFS and an Investment Adviser Representative ( Advisor ) for the purpose of opening an investment advisory account and participating in EMAP. We will invest participating client assets in one or more diversified asset allocation models consisting of open-end registered investment companies (commonly referred to as mutual funds) and closed-end registered investment companies (commonly referred to as exchange-traded funds, or ETFs) and occasionally variable annuities and 529 College Savings Plans in exchange for an all-inclusive asset-based advisory fee. We offer EMAP asset allocation models that consist of no-load mutual funds and ETFs in a broad range of asset classes and market sectors, including domestic stocks, international stocks, global bonds and alternative investments. EMAP portfolios range from conservative to aggressive. EFS Investment Adviser Representatives ( Advisors ) meet with clients to discuss their needs. Investment objectives and risk tolerance are the main factors that help us recommend an asset allocation model. We also consider the client s personal situation, including age, health, family circumstances, income, expenses, assets, debts, liquidity needs, goals, personal objectives, suitability, time horizon and other relevant factors. Alternatively, the client may choose to use the Edelman Guide to Portfolio Selection ( GPS ) to guide the client through the process and help him/her select an appropriate EMAP asset allocation model, based on the client s investment experience, risk tolerance, age, primary investment objectives, time horizon and the amount of money they have to invest. Also referred to as Edelman Online or simply the client portal, GPS utilizes more of a risk-based approach, as opposed to the both goals-based and risk-based approach typically taken when the client meets directly with an Advisor. Working directly with an Advisor or using GPS has no bearing on the advisory fees that the client pays, since even if the client chooses GPS they still have access to an Advisor. If a client s investment objectives or financial situation changes, they should contact an Advisor. Clients are allowed to place reasonable restrictions on the management of their accounts. This includes deciding to sell or not to buy particular securities or types of securities. However, a client cannot require us to buy particular securities or types of securities. We reserve the right, at our sole discretion, to close an account if unreasonable or overly restrictive conditions are requested. Either a client or EFS can end the relationship with written notice to the other. We receive a wrap fee for our services and we bill clients quarterly in arrears. If the relationship ends before the quarter does, the client will pay only a prorated amount. Wrap Fee Brochure 6 January 17, 2018

60 Trading Authorization Once an asset allocation model has been selected, EFS has limited discretionary authority to invest the assets in the account in accordance with the asset allocation model selected by the client. Such discretionary authority includes the ability to select (and modify) the investments underlying each asset allocation model available in EMAP. EMAP clients must establish brokerage accounts with one of the custodians associated with EMAP, which currently include TD Ameritrade, Fidelity and Pershing Advisor Solutions ( PAS ) (each, a Custodian ). When EFS transacts purchases or sales for a particular client s account through a Custodian, the transaction costs associated with such trading activity are covered by the EMAP fee. (Please refer to the discussion of Step-Out Trades in this same Item below for information about instances when clients will incur transaction costs in addition to the EMAP fee.) The Custodians perform all of the necessary brokerage services for accounts maintained with them and provide custody services of client assets. In choosing which Custodian to use for EMAP, we generally select TD Ameritrade, which in turn provides certain economic benefits to EFS. On occasion, EFS may direct a transaction to a broker-dealer other than one of the Custodians for execution, as discussed further in Step-Out Trades in this same Item below. In these cases, the broker-dealer is acting as an executing broker-dealer and delivers the transaction to the applicable Custodian for allocation to client accounts. Rebalancing Each EMAP account is invested in accordance with the client s asset allocation model. At the inception of an account, EMAP assets are invested in specific asset types, including mutual funds (including funds that are used as funding vehicles for variable annuity contracts) or ETFs that invest in a variety of equity securities or fixed income or cash instruments. Amounts invested in each fund are determined in accordance with the set asset allocation targets associated with the client s model. Afterwards, as markets fluctuate and values change, amounts originally allocated to a fund will either exceed or fall below the target allocations. We periodically adjust account holdings to be in line with the asset allocation targets, or rebalance the account. We do not rebalance accounts constantly, and asset allocations may drift away from the target asset allocation associated with the client s model before EFS, within our sole authority and judgment, brings those allocations back in line with the target percentages. The investment philosophy of an asset allocation strategy is to be positioned in various asset types so that if the asset type becomes profitable, the account is positioned to take advantage of the upturn. Reallocation EFS has the limited discretionary authority to reallocate assets in models and client accounts. In a reallocation, we change the target percentages of some or all of the asset classes or types of assets relative to the total model. Models and accounts are monitored on an ongoing basis and assets reallocated based on market or other conditions as warranted. Changes in the asset allocation model, which include adding, removing or replacing securities at the discretion of EFS, are made based on a variety of factors, including but not limited to changes in the economic, financial or political climate; changes in the tax code; new economy innovation and technological disruption; and the management of the underlying securities used by the asset allocation model. EFS may replace a Wrap Fee Brochure 7 January 17, 2018

61 particular security (or securities) if it significantly diverges from its relevant index in terms of risk or return with a security that is more in line with the risk/return profile of the relevant index, or if there is a different security that, in our opinion, would be better suited for the client s account or a model portfolio more generally. Reallocations occur with less frequency than rebalancing. Clients are sent confirmations by the relevant Custodian for any transactions effected in their accounts.. Edelman Retirement Program EFS makes the Edelman Retirement Program ( ERP ) available to plan sponsors of 401(k), profitsharing, non-qualified deferred compensation and retirement plans ( Plans ), subject to the Employee Retirement Income Security Act of 1974 ( ERISA ), as amended, and other employee retirement plans that are not subject to ERISA ( Plans ). These Plans include both participantdirected and trustee-directed Plans. Through ERP, EFS currently creates and maintains model asset allocation portfolios ( Models ) to be made available to Plans. Generally, our Advisor holds an initial meeting with the Plan sponsor (or other Plan fiduciary or agent) to explain the services available through the ERP, and applicable fees, and to collect detailed financial data about the Plan. Emphasis is placed on identifying the Plan s investment objectives and determining the financial situation of the Plan. If the Plan sponsor (or other Plan fiduciary or agent) determines that the ERP is appropriate for the Plan, then the Plan sponsor (or other Plan fiduciary or agent) will establish an ERP account on behalf of the Plan. See Fees and Compensation below for fees and expenses associated with the Edelman Retirement Program. Institutional Advisory Services Utilizing EMAP, EFS provides investment management services to a variety of small and mid-sized companies, organizations, endowments and associations. The services offered include the following: Investment Policy Statement EFS assists in creating, rewriting and/or reviewing the Investment Policy Statement that reflects the investment needs of the entity. Asset Allocation Model EFS assists in developing a diversified asset allocation strategy in accordance with the investment objectives, goals, need for liquidity and risk tolerance of the entity. Financial Profile EFS performs a review of the entity s investment objectives and financial situation in order to provide an accurate assessment of the appropriate level of acceptable risk in accordance with the stated time horizon and goals. Investment Management EFS provides ongoing management of assets, including review for potential rebalancing opportunities and evaluation of EMAP performance for potential changes to or reallocation of asset classes, or changes to securities as market or other conditions warrant. Wrap Fee Brochure 8 January 17, 2018

62 Fees and Compensation Below are schedules of the investment advisory fees that EFS retail, institutional and ERP clients pay on an EMAP account. Since EMAP is a wrap fee program, the terms advisory fee and wrap fee may be used interchangeably when referring to an EMAP account. EFS may change the fee schedule at any time by giving 30 days prior written notice to the client. Following the 30-day notice period, the new fee schedule will become effective unless the client terminates the Client Services Agreement. The client s continued acceptance of the services will constitute consent to changes in the advisory fee, including an increase in the amount charged, if any. Retail Clients EMAP Retail Fee Schedule Fee First $150, % Next $250, % Next $350, % Next $250, % Next $2 million 0.75% Next $7 million 0.60% Next $15 million 0.50% Amounts above $25 million negotiable Above is a schedule of the investment advisory fees that retail clients pay on an EMAP account. In addition to the above fee schedule, EFS employees and the Firm s TAMP advisors (see below) pay a deeply discounted flat rate. The EMAP wrap fee includes ongoing financial planning advice by an EFS Advisor and limited discretionary investment management, including periodic review of all investments in the EMAP asset allocation model. The fee also includes account transaction costs associated with transactions placed through a Custodian (please refer to the discussion below regarding step-out trades which will result in additional costs to the client), custody of assets, a subscription to Ric Edelman s Inside Personal Finance newsletter, online access and free admission to seminars. When calculating advisory fees, household accounts that are managed as one relationship are aggregated to determine the lowest percentage per the above fee schedule. Accounts with less than $5,000 (the minimum household account size) may effectively pay a fee that is greater than 2.00%, due to our minimum annual fee discussed in Item 5. Turnkey Asset Management Program (TAMP) EFS has established a Turnkey Asset Management Program ( TAMP ), whereby the Firm makes the EMAP asset allocation models available to clients of select unaffiliated investment advisors ( TAMP Advisors ). The EMAP fee, per the above retail fee schedule, is shared between EFS and the TAMP Wrap Fee Brochure 9 January 17, 2018

63 Advisors on a negotiated basis. The client does not pay an increased fee for EMAP because of this arrangement. Clients will pay the same fee, regardless of whether the client selects an EMAP asset allocation model through an EFS Advisor or a TAMP Advisor. EFS pays a negotiated percentage, up to 60% of the annual account fee, to TAMP Advisors on EMAP accounts initiated and serviced by their Advisors. Also, at no additional cost to the client, EFS may occasionally pay additional basis points to the TAMP Advisor. Institutional Clients EMAP Institutional Fee Schedule Fee Up to $999, % $1 million to $1,999, % $2 million to $4,999, % $5 million to $9,999, % $10 million to $24,999, % $25 million + negotiable Above is a schedule of the investment advisory fees that EFS institutional clients pay on an EMAP account. The EMAP wrap fee includes periodic access to an EFS Advisor and the Institutional Advisory Services as described above. Payment Method Retail and Institutional Clients authorize the Custodian, on behalf of EFS, to deduct the EMAP fee from their accounts. The fee is based on the average daily balance of the EMAP account. The first payment is calculated based on the number of days assets are placed in the account during a calendar quarter. Subsequent fees are determined based on the average daily balance for the quarter ending on the last day of each calendar quarter. Generally, fees are deducted from the client s account no later than the fifteenth (15th) day after the end of each quarter, in arrears. For margined accounts, the fee may be added to the margin balance unless the client elects to deposit cash or liquidate securities. If an account is terminated prior to the end of a calendar quarter, the terminating client will pay prorated fees due up to the termination date. ERP Clients EMAP ERP Fee Schedule Wrap Fee Brochure 10 January 17, 2018 Fee $0 to $2 million 1.00% $2 million to $5 million 0.85% $5 million to $10 million 0.70% $10 million to $15 million 0.60% $15 million to $20 million 0.50% $20 million + negotiable

64 Above is a schedule of the investment advisory fees that EFS ERP clients pay on an EMAP account. The EMAP wrap fee includes periodic access to an EFS Advisor and the services provided to the Plan on behalf of the Plan sponsor (or other Plan fiduciary or agent) as described above in Item 4. Except as otherwise agreed to by the Plan sponsor (or other Plan fiduciary or agent) and EFS, the Plan sponsor (or other Plan fiduciary or agent) agrees that the Plan s recordkeeper, custodian or other service provider will deduct the wrap fee from Plan accounts and remit such amounts to EFS prior to the due date as provided under the ERP Investment Management Agreement, which is the standard ERP client contract. The fee is based on the balance of the total assets of the Plan accounts invested in the Models and Underlying Funds as of the end of each calendar quarter, and does not include Plan assets that are invested in other options (such as those available through self-directed brokerage windows or funds or securities other than the Underlying Funds). The first payment is prorated for assets that are placed in Plan accounts during a calendar quarter. Subsequent fees will be determined based on the last day of each quarter. Fees are deducted from the client s account no later than the thirtieth (30th) day after the end of each quarter, in arrears. If an account is terminated prior to the end of a calendar quarter, the terminating client will pay prorated fees due up to the termination date. The fee schedule above shows the annual percentages. Disclosures Relevant to All Clients We anticipate that transactions placed in your account will be executed through one of the program Custodians (currently either TD Ameritrade, Fidelity, or PAS). However, in the limited circumstances described below, e.g. step-out trades, EFS may choose to execute trades for EMAP client accounts with a broker-dealer other than one of the Custodians, if we reasonably believe that another brokerdealer can obtain a more favorable execution under the circumstances. Specifically, occasionally (typically less than 5% of the time on a transactional basis), EFS will utilize broker-dealers other than TD Ameritrade, Fidelity, or PAS to execute large transactions if we determine that it is in our clients' best interest and that the other broker-dealer has the capability to handle such large transactions and to reduce or eliminate potential negative price fluctuation. This generally will occur when the size of the transaction in any one security is so large that it could cause the price of the security to fluctuate, up or down, resulting in an unfavorable execution price for our clients. Where EFS trades through a broker-dealer other than one of the Custodians, the EMAP wrap fee does not include the compensation that is paid to that broker-dealer. This compensation is embedded into the price of the security which is paid by the client. These additional costs are in addition to the wrap fee paid to EFS by the client. Transactions executed on behalf of EMAP clients are executed for a single wrap fee (except with respect to step-out trades, as noted above and below), which reduces the potential conflict of interest associated with executing a large number of orders for client accounts and earning transaction-based compensation following each order. In addition, EMAP invests client assets in noload shares of open-end registered investment companies (mutual funds), ETFs and no-commission variable annuities. EFS and its Advisors receive compensation based on the assets under management the client has invested in the program. Neither EFS nor its Advisors earn any additional Wrap Fee Brochure 11 January 17, 2018

65 revenue from EMAP accounts beyond the wrap fee. A portion of the advisory fee is paid to the Advisor, however such compensation does not vary based on which securities are bought, sold or held in a particular EMAP account. The advisory fee earned may be more or less than what EFS or its Advisors might earn from other programs available in the financial services industry or if the services were purchased separately. Therefore, EFS and its Advisors have a financial incentive to recommend EMAP to clients and prospective clients. However, compensation paid to Advisors from the EMAP fee does not vary depending upon the number of trades made in EMAP client accounts. We do not earn more if fewer trades are placed. This arrangement gives us no economic incentive to place more or fewer trades for EMAP accounts. Fees are not negotiable, other than as disclosed in the fee schedule above. Full fee details are discussed in the Client Services Agreement that is signed by each client. The above advisory fee schedules are based on the assets under management the client invests in the program and are not dependent on the amount of trading in the account or the advice given in any particular time period. The client should be aware that lower fees for comparable services may be available from other sources. Other Fees and Expenses Clients pay a wrap fee, which covers brokerage execution costs associated with trades placed through one of the program Custodians, without regard to the number of transactions executed during the billing period. EFS has negotiated fees with TD Ameritrade, Fidelity and PAS, each a Custodian, for clearing and execution services. Also, for ERP clients, the Plan s recordkeeper, custodian or other service provider may charge a separate fee to cover the administrative, trust, custody and other record-keeping costs associated with Plan accounts invested in the Investment Options. Transaction costs imposed by TD Ameritrade, Fidelity and PAS are covered as part of the wrap fee. The wrap fee does not include certain account and securities-related costs, including the fees embedded in the mutual funds, ETFs or annuities in which EMAP accounts invest. These underlying fees vary between investments and are deducted by the particular fund company directly from invested assets. Further information on these fees can be found in the prospectuses of the particular mutual fund, ETF or annuity in which the account invests. In addition, the fee does not include debit balances, related margin interest, IRA and retirement plan fees, transfer fees, fees imposed by regulators, 12b-1 fees for certain money market funds and mutual funds, wire transfer fees, overnight check fees, account closing fees, paper statement delivery fees, non-standard asset fees, insufficient fund fees, returned check fees, transaction charges for fund level asset allocation model trades, expenses charged by the mutual funds (including management fees, transaction charges incurred for fund-level asset allocation model trades, custody of fund assets and other fund expenses), expenses charged by the variable annuities and exchange-traded funds, or other fees or taxes that are required by law. EFS may from time to time, at its sole discretion reimburse clients for certain fees or charges which are not due to the client s error. Because any mutual fund, ETF and annuity held in a client s EMAP account has its own internal expenses, changing one or more investment funds in an EMAP model and, as a result, the relevant client accounts, will likely result in a change to the expense ratio of the overall portfolio. The resulting expense ratio may be higher than the expense ratio of the original portfolio. If a change is Wrap Fee Brochure 12 January 17, 2018

66 made and the expense ratio of the new fund is in fact higher than that of the fund or investment that was replaced, clients will incur a greater expense than previously incurred. Clients should understand that, while EFS takes the cost of particular investments into account when making investment decisions for the models and accounts in EMAP, cost is but one of many factors that are considered. Other factors that are considered include: overall diversification, return, risk adjusted return, exposure to particular asset classes or market sectors in which the firm and Investment Committee have conviction, internal characteristics, trading impact, liquidity and manager reputation. Please refer to the Conflicts of Interest and Other Disclosures section within Item 9 for further information on this disclosure. EFS may negotiate a reduction in fees or other costs on services provided by third-party service providers based on size, volume or other factors. Because the cost to the client of these services is included in the wrap fee, any negotiation of lower costs to EFS will not be reflected in the client s costs. Please refer to the Conflicts of Interest and Other Disclosures section within Item 9 for further information on this disclosure. Step-Out Trades As noted above, in certain limited circumstances, EFS may choose to execute trades for EMAP client accounts with a broker-dealer other than TD Ameritrade, Fidelity, or PAS if we reasonably believe that the other broker-dealer can obtain a more favorable execution under the circumstances. Occasionally, typically less than 5% of the time on a transactional basis, EFS will utilize a brokerdealer other than one of the Custodians to execute large transactions if we determine that it is in our clients' best interest and that other broker-dealer has the capability to handle such large transactions and to reduce or eliminate any potential negative price fluctuation. This generally will occur when the size of the transaction in any one security is so large that it could cause the price of the security to fluctuate, up or down, resulting in an unfavorable execution price for our clients. Where EFS trades through a broker-dealer other than one of the Custodians, the EMAP wrap fee does not include the compensation that is paid to that broker-dealer. This compensation is embedded into the price of the security which is paid by the client. These additional costs are in addition to the wrap fee paid by the client. Please refer to the Conflicts of Interest and Other Disclosures section within Item 9 for further information on this conflict. Best Execution EFS has an obligation to seek the best available execution for client transactions and monitors transactions (including rebalancing, reallocation, model changes and liquidations) retrospectively to evaluate whether best execution was obtained. EFS evaluates quality of service based on the following factors; execution capability, commission rate, financial responsibility, responsiveness to the adviser, and the value of any research provided. The Firm has established a Best Execution Committee, which monitors best execution with its custodians, utilizing reports provided by these custodians and other 3rd party sources. Additionally, EFS reviews each broker-dealer's execution reports to evaluate the services provided, quality of executions, fee rate, and other services. Wrap Fee Brochure 13 January 17, 2018

67 Item 5: Account Requirements and Types of Clients Account Requirements Minimum Account Size Retail Client household minimum account size is $5,000. We may waive the minimum account size at our sole discretion. Minimum annual fee is $100. We may waive the minimum annual fee at our sole discretion. EFS Employee and Advisor minimum account size is $3,000. Institutional The minimum account size is $500,000, which may be waived at our sole discretion. ERP There is no minimum account size. Brokerage Selection Clients who establish an EMAP account with EFS must consent to a custodian with whom we have a clearing arrangement. Currently, we have selected the following unaffiliated registered brokerdealers, which are members of FINRA and SIPC, as Custodians, to execute and clear transactions and to provide custody services for EMAP wrap fee clients: TD Ameritrade Institutional (as cleared through TD Ameritrade Clearing, Inc.), a division of TD Ameritrade, Inc. ( TD Ameritrade ) Fidelity Institutional Wealth Services ( Fidelity ) (as cleared through National Financial Services LLC) Pershing Advisor Solutions ( PAS ) (as cleared through Pershing LLC) As noted above in Item 4 on Step-Out Trades, we anticipate that transactions placed in your account will be executed through one of the Custodians associated with EMAP (currently either TD Ameritrade, Fidelity, or PAS), however, in limited circumstances EFS may choose to execute trades with another broker-dealer if we reasonably believe that another broker-dealer can obtain a more favorable execution under the circumstances. Each Custodian also makes available other trading options that EFS is able to select, if deemed necessary, e.g. algorithmic trades, Time Weighted Average Pricing (TWAP) trades, etc. Each Custodian offers services that include custody of securities, trade execution and clearance and settlement of transactions. However, all client accounts are established with TD Ameritrade, unless the client directs otherwise. Each Custodian also provides Wrap Fee Brochure 14 January 17, 2018

68 services that are typically made available to institutional investment managers and generally are not offered to retail clients. These services include duplicate client statements and confirmations, access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to have advisory fees deducted directly from client accounts and access to mutual funds with no transaction fees. Custodians receive compensation for their services either through a fixed percentage fee based on all EMAP account assets that are maintained in the custody of their firm or on a transactional basis. All clients in the Institutional Program and a limited number of EMAP clients are handled on a transactional basis. Because the cost of what each Custodian charges EFS is included in the wrap fee, whether the Custodian charges EFS a fixed percentage or on a transactional basis has no bearing on what the client pays. EFS has an obligation to seek best execution of clients securities transactions. Therefore, in selecting broker-dealers, including Custodians for the program, we evaluate the full range of services offered, the quality of those services and any costs indirectly borne by clients, to determine if the firm provides overall quality of service for the price. Quality of service includes, among other things, execution capability, commission rate, financial responsibility, responsiveness to the adviser, and the value of any research provided. While we attempt to negotiate favorable rates for transactions and believe that each custodian we select offers competitive rates, we do not select a custodian solely on the basis of cost. While another custodian may offer the same services at a lower overall cost, EFS is not required to move accounts to that custodian. Types of Clients EFS provides financial planning, investment management, financial advice, educational services and insurance services to individuals, individual retirement accounts, trusts, estates, charitable organizations, foundations, associations, pensions, high net worth individuals, retirement and profitsharing plans, institutions, and small to mid-sized businesses including corporations. Item 6: Portfolio Manager Selection and Evaluation We do not select or utilize the services of any third-party portfolio manager in EMAP. The Investment Committee is responsible for investment management of EMAP assets and establishing the EMAP Investment Selection Policy. The EMAP Portfolio Manager is responsible for implementing and monitoring that policy. Performance Calculation EFS, as a matter of policy, prepares information relating to investment performance of the EMAP asset allocation models. The Firm s policies and procedures and methods used in calculating and presenting EMAP performance figures are designed to ensure the Firm is in compliance with the Global Investment Performance Standards ( GIPS ). Firm compliance with GIPS is verified by Ashland Wrap Fee Brochure 15 January 17, 2018

69 Partners & Company LLP, an independent third-party GIPS verification company. Ashland Partners also serves as an ongoing consultant to EFS to ensure the Firm stays in compliance with GIPS standards. Their verification includes, but is not limited to reviewing methods of performance calculation, composite construction and the presentation of performance information. Investment performance figures are determined by utilizing internal portfolio accounting software, which calculates investment performance according to globally accepted industry standards. Performance calculations are based on actual EMAP accounts under management, including those accounts that have been closed. Investment performance is presented net of actual management fees and expenses. Investment Strategy EMAP relies on an investment philosophy that is based on established academic research, such as Modern Portfolio Theory and the Fama-French Five-Factor Model, and established discoveries in behavioral finance. Modern Portfolio Theory advocates that it is not enough to look at the expected risk and return of one particular asset class. By investing in more than one asset class, an investor may be able to reap the benefits of diversification chief among them, a reduction in the risk level of the portfolio. The Fama-French Five-Factor Model, through research, found that over long periods of time, value stocks outperform growth stocks, small cap stocks tend to outperform large cap stocks and stocks with high profitability outperform stocks with low profitability. In addition, capturing price momentum can add to returns. The EFS investment philosophy is based on the following basic principles: Develop highly diversified portfolios that feature a broad range of asset classes and market sectors. Use market-based investments, not manager-based investments. Hold the investments for long periods of time. Periodically reallocate investments as conditions warrant. Strategically rebalance as needed. EMAP is diversified, invests in no-load mutual funds and ETFs, and features as many as nineteen (19) asset classes and market sectors. This approach cannot ensure investment success or prevent loss in a declining market. Past performance is no guarantee of future results. Rebalancing Each EMAP account is invested in accordance with the client s asset allocation strategy. At the inception of an account, EMAP assets are invested in specific asset types, including mutual funds (including funds that are used as funding vehicles for variable annuity contracts) or ETFs that invest in a variety of equity securities or fixed income or cash instruments. Amounts invested in each fund are determined in accordance with the set asset allocation targets associated with the client s model. Afterwards, as markets fluctuate and values change, amounts originally allocated to a fund Wrap Fee Brochure 16 January 17, 2018

70 will either exceed or fall below the original target allocations. We periodically adjust account holdings to be in line with the asset allocation targets, or rebalance the account. We do not rebalance accounts constantly, and asset allocations may drift away from the target asset allocation associated with the client s model before EFS, within our sole authority and judgment, brings those allocations back in line with the target percentages. The investment philosophy of an asset allocation strategy is to be positioned in various asset types so that if the asset type becomes profitable, the account is positioned to take advantage of the upturn. Reallocations EFS has the limited discretionary authority to reallocate assets in models and client accounts. In a reallocation, we change the target percentages of some or all of the asset classes or types of assets relative to the total model. Models and accounts are monitored on an ongoing basis and assets reallocated based on market or other conditions as warranted. Changes in the asset allocation model, which include adding, removing or replacing securities at the discretion of EFS, are made based on a variety of factors, including but not limited to changes in the economic, financial or political climate; changes in the tax code; new economy innovation and technological disruption; and the management of the underlying securities used by the asset allocation model. EFS may replace a particular security (or securities) if it significantly diverges from its relevant index in terms of risk or return, with a security that is more in line with the risk/return profile of the relevant index or if there is a different security that, in our opinion, would be better suited for the client s account or a model portfolio more generally. Reallocations occur with less frequency than rebalancing. Clients are sent confirmations by the relevant Custodian for any transactions effected in their accounts. Trade Aggregation Policy Whenever appropriate EFS may aggregate same side transactions for certain securities on behalf of all EMAP accounts, including accounts of Advisors and employees. It is the policy of EFS that such transactions will be allocated to all participating client accounts in a fair and equitable manner. There is no preferential treatment given to any account. Transactions may be aggregated together to achieve an average execution price. Mutual funds, variable annuities and 529 College Savings Plans are purchased directly from the issuer, and no aggregation of these transactions occurs. Trade Allocation Policy In an effort to seek best execution for clients and treat all clients fairly and equitably over time, EFS utilizes a rotation procedure for executing trades. All client, employee and EFS accounts are included in the rotation. Generally, EMAP equity trades are executed at their respective Custodian and when deemed appropriate will be done on a block basis. The order of the custodians trades will be rotated on a daily basis and in sequential fashion. For example, if there are three custodians and custodian 1 goes first on a particular day, custodian 2 will go first the following day and custodian 3 will go first on the third day. On occasion, EFS may direct a transaction to a broker-dealer other than one of the Custodians if we believe we can obtain better execution, as discussed further in Step-Out Trades in Item 4. EFS reserves the right to modify the rotation procedure for a variety of reasons. An example of this could be if any custodian has a large block order in a particular security. To avoid having a large order Wrap Fee Brochure 17 January 17, 2018

71 unfavorably impact liquidity or the execution price, the order may be executed using various other trading strategies. If EFS elects to execute any orders in this manner, then the rotation schedule for that day will be altered. The normal rotational schedule will continue the following day. In the limited circumstances when sufficient quantities of a particular security are not obtainable, a pro rata allocation may be used when a batch order in the security cannot be fully executed in a single day. The partial order fill is generally allocated among the participating client accounts based on the size of each account s original order, subject to rounding in order to achieve round lots. Unexecuted orders will continue until the block order is completed or until all component orders have been cancelled. New orders for the same security will be aggregated with any remaining unexecuted orders and will continue in the same manner. As previously mentioned, equity orders for all EMAP wrap fee clients, including employees and Advisors, when appropriate may be aggregated to ensure equal pricing for all clients. Trade Errors As a fiduciary, EFS has the responsibility to effect trade orders correctly, promptly and in the best interests of its clients. In the event an error occurs in the handling of any client transaction due to EFS' actions or inactions, EFS' policy is to identify and correct the error as promptly as possible and make the client whole. If the error is the responsibility of EFS, any client transaction will be corrected and EFS will be responsible for client losses resulting from an inaccurate or erroneous order. Resulting gains after the client is made whole will be netted against losses in the EFS error account. If the EFS error account reflects a net gain when the custodian reconciles the account, the gains will be donated to a charity designated by EFS. Occasionally, an error is caused by the client. In those situations where EFS can correct it, the error will be corrected promptly in the client s best interest and reviewed on a case-by-case basis to determine the party responsible for potential losses. Clients are to be reminded that EFS cannot guarantee that data presented to them is free from error and that they are also responsible for informing the Firm of any noted inaccuracies in a timely manner. Methods of Analysis and Investment Selection Based on the EMAP client agreement that clients execute, EFS is granted limited discretionary authority to implement client-approved investment strategies. Investments are selected based on a number of qualitative and quantitative factors, including but not limited to past performance (as applicable), diversification characteristics, fees and a variety of academic statistics including beta, standard deviation, R-Squared and Sharpe Ratio, as well as qualitative considerations including, but not limited to, exposure to particular asset classes or market sectors in which the firm and Investment Committee have conviction, internal characteristics, trading impact, liquidity and manager reputation. The quantitative statistics identified above are provided by third-party vendors and the investment sponsors, and are evaluated by the Portfolio Manager as well as the EFS Investment Committee, on both an absolute and a relative basis. Wrap Fee Brochure 18 January 17, 2018

72 We obtain and utilize information and data from a wide variety of public and private sources. Neither EFS nor our Advisors independently verify or guarantee such information and data. In categorizing the asset classes of investments, we rely on prospectuses and information obtained from the issuer or its agents, or through publicly available sources. Neither EFS nor our Advisors are liable for any misstatement or omission contained in the information from these sources, or for any loss, liability, claim, damage or expense incurred, arising out of, or attributable to, such misstatement or omission. Transactions for different accounts or for other clients accounts might not be made at the same time, may be made on different days, and may be made over multiple days. In handling purchases and liquidations, we will execute transactions without regard to pending dividend or capital gains distributions, stock splits, mergers, or other corporate or financial events. A client may impose reasonable restrictions on the management of their account. When imposing restrictions, a client may request that particular securities or types of securities not be purchased, or that such securities be sold if held in the account. However, the client cannot request that particular securities be purchased for the account. Moreover, the client should note that EFS has no influence or control over the mix of securities held by any mutual fund or ETF included in the client s account. We reserve the right, at our sole discretion, to reject any account should the client request unreasonable or overly restrictive conditions. Risk of Loss EMAP holdings consist of a combination of no-load mutual funds, exchange-traded funds (ETFs) and, occasionally, variable annuities and 529 College Savings Plans, all of which are subject to some or all of the risk factors noted below. Certain models available through EMAP include positions in the SPDR S&P North American Natural Resources ETF (NANR) and the ishares Exponential Technologies ETF (XT). Ric Edelman became interested in how new economy innovation and technology disruption would change investing and initially articulated the principles that BlackRock later used in creating XT. EFS played a similar role with respect to NANR. XT and NANR are sponsored and managed by BlackRock and State Street Global Advisors, respectively. Neither Ric Edelman nor EFS receives any direct or indirect compensation from either of the funds or their respective affiliates based on the sale of, or investment in, either fund. For each of these funds, a very high percentage of each ETF s total assets is held by EMAP clients. There is a conflict of interest regarding the initial role that EFS and/or Ric Edelman played in the suggestion for or the creation of these two ETFs, as well as any promotion of NANR or XT by EFS and/or Ric Edelman, in that EFS may receive indirect economic and other benefits from the association of its name with that ETF. That conflict could influence our decision to use either State Street Global Advisors SPDRs or BlackRock s ishares to provide ETFs in EMAP. There could also potentially be such a conflict in the future, if EFS and/or Ric Edelman were to play a role in the creation of a third party s index or other product. Please refer to the Conflicts of Interest and Other Disclosures section within Item 9 for further information on this conflict. Please also see the Risks Associated with Positions in ETFs with Which EFS was Involved and Risks Associated with Changes to Underlying Investments risk categories below for further information on the associated risks. The Investment Committee provides ongoing monitoring of these risks and recommends action to mitigate them, as appropriate. Wrap Fee Brochure 19 January 17, 2018

73 Market Risk Even a long-term investment approach cannot guarantee a profit. Economic, political and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that a client will lose money and their investment may be worth more or less upon liquidation. Business Risk The risks associated with a particular industry or market sector, e.g. oildrilling companies carry a higher risk of profitability than an electric company that generates steady income no matter what the economic environment is like. Foreign Securities and Currency Risk Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. Capitalization Risk Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services, and their stocks have historically been more volatile than the stocks of larger, more established companies. Interest Rate Risk In a rising rate environment, the value of fixed-income securities generally declines and the value of equity securities may be adversely affected. Reinvestment Risk The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return. This risk is primarily related to fixed income securities. Inflation Risk Also referred to as purchasing power risk, it is the chance that the cash flows from an investment won't be worth as much in the future because of changes in purchasing power due to inflation. Credit Risk Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer s credit rating or a perceived change in an issuer s financial strength may affect a security s value and, thus, impact the fund s performance. Concentration Risk Holdings may be subject to any number of concentrations, e.g. in a mutual fund or ETF, industry sector or geographical region. Concentration risk may be further compounded by factors such as asset correlation or performance. Risks Associated with Positions in ETFs with Which EFS was Involved - Certain models available through EMAP include positions in the NANR and XT ETFs. Ric Edelman became interested in how new economy innovation and technology disruption would change investing and initially articulated the principles that BlackRock later used in creating XT. EFS played a similar role with respect to NANR. XT and NANR are sponsored and managed by BlackRock and State Street Global Advisors, respectively. Neither Ric Edelman nor EFS receives any direct or indirect compensation from either of the funds or their respective affiliates based on the sale of, or investment in, either fund. For each of these funds, a very high percentage of each ETF s total assets is held by EMAP clients. Such large Wrap Fee Brochure 20 January 17, 2018

74 concentrations present a variety of risks, should the Firm decide to transition out of one of these funds, including liquidity risk and reputational risk. Risks Associated with Changes to Underlying Investments - Because any mutual fund, ETF and annuity held in a client s EMAP account has its own internal expenses, changing one or more investment funds in an EMAP model and, as a result, the relevant client accounts, will likely result in a change to the expense ratio of the overall portfolio. The resulting expense ratio may be higher than the expense ratio of the original portfolio. If a change is made and the expense ratio of the new fund is in fact higher than that of the fund or investment that was replaced, clients will incur a greater expense than previously incurred. Clients should understand that, while EFS takes the cost of particular investments into account when making investment decisions for the models and accounts in EMAP, cost is but one of many factors that are considered. Other factors that are considered include: overall diversification, return, risk adjusted return, exposure to particular asset classes or market sectors in which the firm and Investment Committee have conviction, internal characteristics, trading impact, liquidity and manager reputation. Please refer to the Conflicts of Interest and Other Disclosures section within Item 9 for further information on this conflict. Securities Lending Risk Securities lending involves the risk that the fund loses money because the borrower fails to return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. Derivatives Derivatives are securities, such as futures contracts, whose value is derived from that of other securities or indices. Derivatives can be used for hedging (attempting to reduce risk by offsetting one investment position with another) or non-hedging purposes. Hedging with derivatives may increase expenses, and there is no guarantee that a hedging strategy will achieve the desired results. Hedging While hedging can reduce or eliminate losses, it can also reduce or eliminate gains. Derivative securities are subject to a number of risks, including the following: o o o o o Liquidity risk Interest rate risk Market risk Credit and management risks Risk of improper valuation Changes in the value of the derivative may not correlate perfectly with the underlying asset, rate or index, and the fund could lose more than the principal amount. Exchange-Traded Funds ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the Wrap Fee Brochure 21 January 17, 2018

75 Soft Dollars creation/redemption process of the ETF. Any of these factors may lead to liquidity risk and/or the fund s shares trading at either a premium or a discount to its net asset value. Performance of Underlying Managers We select the mutual funds and ETFs in the asset allocation models. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. The custodians that EFS uses (TD Ameritrade, Fidelity, and PAS), offer various services to EFS, including custody of client securities; trade execution; clearance and settlement of transactions; access to platform systems; duplicate client statements; research-related products and tools; access to a trading desk; access to block trading, which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts; the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and use of overnight courier services. Some of these services may benefit EFS but may not benefit our clients and receipt of these economic benefits creates a conflict of interest and could directly or indirectly influence EFS to recommend a certain custodian to clients for custody and brokerage services. These custody services are paid for as part of the client s wrap fee. Orion and Salentica, (two vendors EFS uses) along with other companies have formed an Institutional Alliance with TD Ameritrade. EFS uses Orion as its portfolio accounting system and Salentica as its Client Relationship Management (CRM) system, and may from time to time use other vendors which are part of the Institutional Alliance. Generally speaking, new client accounts are established with TD Ameritrade as the custodian, unless the client directs otherwise. EFS has a tiered fee schedule in the contract with Orion, whereby the fee is calculated based on the number of accounts it maintains with Orion. Orion charges EFS a flat dollar amount up to a fixed number of accounts, and a fixed dollar amount per account over that threshold. The fee schedule does not vary depending on the custodian selected by EFS, in part to address the potential conflict of interest. Orion may directly or indirectly receive an economic benefit due to its Institutional Alliance relationship. The tiered fee schedule in the contract with Orion will remain in force, regardless of which custodian EFS directs business to, or whether Orion receives economic benefit from third parties. The Institutional Alliance makes it less likely for EFS to move away from TD Ameritrade, which creates a potential conflict of interest as a custodian other than TD Ameritrade may be able to provide better quality service or provide services at a lower cost to the client. However, because the cost to the client of these custodial services is included in the wrap fee, lower costs to EFS will not be reflected in the client s costs. Salentica may also directly or indirectly receive an economic benefit due to its Institutional Alliance relationship and there could be other such arrangements in the future. In addition, EFS has had discussions with Orion about receiving an economic benefit, based on payments Orion receives from TD Ameritrade for EFS client accounts where TD Ameritrade acts as Wrap Fee Brochure 22 January 17, 2018

76 custodian. If EFS and Orion agree to any amendment that provides economic benefits to EFS, EFS will further amend this ADV to disclose the economic benefits EFS will receive and the related conflicts of interest. See Relationship with TD Ameritrade and Others in Item 9 for a more detailed discussion of some of the specific conflicts of interest arising from the Firm s custodian relationship with TD Ameritrade. Please also see the Conflicts of Interest and Other Disclosures section within Item 9 for further information on this conflict with the Institutional Alliance. From time to time, EFS and/or Ric Edelman may enter into discussions with any third party, including existing vendors regarding joint ventures, partnerships, marketing initiatives or other such forms of cooperation. EFS may also use third parties, including existing service providers in a consultative manner, sounding them out for advice or insight, at no or a reduced cost to EFS, which the Firm could use for its proprietary purposes and/or for the potential benefit of our clients. This activity could create a conflict of interest, to the extent that it benefits the Firm and is not passed on to the client, or EFS otherwise makes decisions with respect to that third party which may adversely affect the client. In addition, to the extent EFS has an arrangement or relationship with a third-party vendor separate and apart from that vendor s provision of services to EFS clients, EFS judgment with regard to those services could be affected by its arrangement or relationship. Please see the Conflicts of Interest and Other Disclosures section within Item 9 for information on this conflict. Performance-Based Fees and Side-by-Side Management EFS does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). We do not engage in side-by-side management. Voting Client Securities EFS does not accept proxy voting responsibility for client accounts. Therefore, we have no obligation or authority to take action or render any advice with respect to the voting of proxies solicited by or with respect to issuers of securities held in client accounts. We expect clients to expressly retain the authority and responsibility for proxy voting. With respect to ERISA accounts, we generally expect the Plan sponsor to expressly retain the authority and responsibility for proxy voting and to specify in writing who has voting authority. All other clients will receive proxies directly from the custodian. Clients may direct any questions to their Advisor should the need arise. Item 7: Client Information Provided to Portfolio Manager EFS Advisors meet with clients to discuss their needs. Investment objectives and risk tolerance are the main factors that help us recommend an asset allocation model. We also consider the client s personal situation, including age, health, family circumstances, income, expenses, assets, debts, liquidity needs, goals, personal objectives, suitability, time horizon and other relevant factors. Clients are permitted to impose reasonable restrictions on the management of their accounts. When Wrap Fee Brochure 23 January 17, 2018

77 imposing restrictions, clients may request that particular securities or types of securities not be purchased, not be sold or that such securities (if held in the account) be sold. Clients, however, cannot request that particular securities be purchased for their accounts. Additionally, EFS has no influence or control over the mix of securities held by any mutual fund, variable annuity or ETF in which client accounts may be invested. We reserve the right, at our sole discretion, to reject any account for which unreasonable or overly restrictive conditions are requested. On at least an annual basis, EMAP clients are contacted to update their personal and financial information, including health, employment, marital and family status, time horizon, goals and objectives, and risk tolerance. Item 8: Client Contact with Portfolio Managers Clients are generally free to contact EFS and their Advisor or an assigned Advisor at any time during normal business hours via telephone, facsimile, mail or . In-person meetings should be scheduled in advance to ensure that the Advisor is available. Generally, clearing/custodian brokerdealers and the issuers or sponsors of investments used by the program are not available to answer questions or discuss specific investment issues. However, if a client has a specific need, we will make a reasonable attempt to arrange the discussion. Item 9: Additional Information Disciplinary Information Registered investment advisers are required to disclose all legal or disciplinary events that are material in a client s evaluation of the adviser or the integrity of the adviser s management. EFS has no material legal or disciplinary events to disclose. Other Financial Industry Activities and Affiliations Related Persons Affiliated Broker-Dealer EF Legacy Securities, LLC ( EFLS ) is the registered broker-dealer which performs an accommodation role for EFS advisory clients. The Edelman Financial Center, LLC is the sole member of EFLS and therefore EFLS shares the same ownership structure as EFS. The President of EFS also serves as a manager of EFLS. EFS Advisors, acting solely in their capacity as registered representatives of EFLS and not as Advisors of EFS, accept orders for EFLS accounts from EFLS clients who may or may not be clients of EFS. When acting as registered representatives for clients, EFS Advisors execute transactions for clients through EFLS and receive upfront and/or annual brokerage commissions from EFLS on certain products sold in this capacity or held in the EFLS account. Thus, a conflict of interest could exist between the interests of EFS Advisors, EFLS, and EFLS clients if the EFS Advisor receives Wrap Fee Brochure 24 January 17, 2018

78 commissions as part of an implemented financial plan for a client. EFS clients are advised that they are under no obligation to effect securities transactions with EFLS or through their Advisor and that similar services may be less expensive elsewhere. Please refer to the Conflicts of Interest and Other Disclosures section within Item 9 for further information on this conflict. Other Affiliated Investment Advisers and Broker-Dealers Although EFS is under common indirect ownership and control with other investment advisers and broker-dealers (this excludes EFLS), there is no material relationship between EFS and any one of these other investment advisor or broker-dealer entities. Insurance Agencies EFS is a licensed insurance agency and is licensed in most states. EFS Advisors generally refer clients who wish to buy insurance products, such as life, long-term disability and long-term care insurance to Crump Life Insurance Services, an unaffiliated insurance agency that specializes in insurance brokerage and provides insurance to clients. EFS and its Advisors who are licensed insurance agents are compensated with a percentage of the revenues generated on the sale of such insurance products. As such, EFS and its Advisors who are licensed insurance agents have a conflict of interest because of the economic incentive to sell policies that result in commissions or other sales revenue. Clients are advised that they are under no obligation to purchase any insurance products through EFS or Crump Life Insurance Services and that those products may be less expensive elsewhere. Please refer to the Conflicts of Interest section within Item 9 for further information on this conflict. EFLS is also a licensed insurance agency and EFS Advisors may be licensed insurance agents of EFLS. They are therefore able to sell variable and fixed insurance products and receive insurance commissions from client transactions through EFLS. As such, EFS Advisors have a conflict of interest because of the economic incentive to recommend products that result in commissions or other sales revenue. Clients are advised that they are under no obligation to purchase any insurance products through EFS or EFLS and that those products may be less expensive elsewhere. Please refer to the Conflicts of Interest and Other Disclosures section within Item 9 for further information on this conflict. Equity Investors H&F Corporate Investors VII, Ltd. is the ultimate controlling party for a series of limited partnerships that indirectly own approximately 71.5% of The Edelman Financial Center, LLC, the direct parent of EFS. Other investors, including The Edelman Financial Center, Inc., whose sole shareholder is Ric Edelman, the Executive Chairman of EFS, also have indirect ownership interests in EFS. The Retirement InCome for Everyone Trust (RIC-E Trust ) The Retirement InCome for Everyone Trust (RIC-E Trust ) is an individual grantor trust enabling the grantor to set aside assets for another s retirement. It is a broker-dealer product offered by EFS Advisors, acting in their capacity as registered representatives of EFLS. Assets in the trust are invested in a variable annuity and grow tax-deferred. The trustee is named by the grantor. The issuer of the annuity is American General Life Insurance Company, a subsidiary of American International Wrap Fee Brochure 25 January 17, 2018

79 Group, Inc. ( AIG ). Commissions from the underlying variable annuity are received by EFLS, which may create a conflict of interest. Please see the Conflicts of Interest and Other Disclosures section within Item 9 for information on this conflict. Code of Ethics EFS has adopted a Code of Ethics (the Code ) that is designed to ensure that all employees adhere to high standards of ethical conduct. The Code states that all of our employees must act in the best interest of the client at all times. It also states that employees should avoid any practice that creates or appears to create a material conflict of interest that could potentially harm a client. The Firm has established a Conflicts of Interest Committee ( Committee ). It is chaired by the CCO and members of senior management serve on the Committee. The Committee, or other such committees as the Firm might decide, has the responsibility to identify, assess and manage potential and actual conflicts of interest. Employees have the responsibility to escalate any potential or actual conflicts of interest immediately upon identifying them to their manager, who is responsible for notifying the CCO. In addition, the Code requires, among other things, that employees do the following: Submit their personal and related trading accounts to the Compliance Department for review. Refrain from purchasing Initial Public Offerings (IPOs). Refrain from trading on insider information. Get approval prior to purchasing a private placement. Comply with ethical restraints, including restrictions on giving and receiving gifts. Report any conduct that could potentially harm a client. EFS has also adopted supervisory procedures that are designed to detect the following abusive behavior: Front-running, or trading ahead or opposite clients Trading in securities on the EFLS and EFS Restricted or Watch Lists Trading that appears to be based on insider information Short-term or day trading Trading during designated EFLS blackout periods The above mitigants are designed to detect any potential abuse of insider information by members of the Investment Committee or other employees involved with any EMAP reallocations. Any officer or employee of the Firm who fails to observe the Code risks serious sanctions, including personal liability and/or termination of employment. Wrap Fee Brochure 26 January 17, 2018

80 A copy of the Code is available upon request by contacting us using the information on the cover page of this brochure. Related Person May Invest in the Same Securities EFS Advisors may invest their personal funds and establish an EMAP account for themselves. They may also participate in the EFS Employee 401(k) Plan that includes EMAP asset allocation models. In that regard, employees buy and sell for themselves the same underlying securities as clients and will have interests in securities owned by or recommended to our clients, including mutual funds, ETFs or insurance products. Although all employees get the benefit of a fee reduction on EMAP accounts, those accounts are not given preferential trading treatment. Employee accounts are monitored and rebalanced on the same basis as all other unrestricted client accounts invested in accordance with the same EMAP asset allocation model strategy. We have adopted procedures relating to personal securities transactions, insider trading and internal trading that are designed to prevent client harm resulting from this conflict of interest. Please refer to the Conflicts of Interest and Other Disclosures section below for further information on this conflict. Agency Cross Procedures In order to comply with the agency cross provisions of the Investment Advisers Act, EFS has policies and procedures in place to ensure that transactions introduced on behalf of EMAP clients are not crossed with transactions introduced to the clearing firm on behalf of EFLS customers. Cross transactions do not apply to mutual funds and to variable annuities since shares of mutual funds and variable annuities are purchased from their issuers and are not exchange-traded. Although ETFs are exchange-traded, EFS does not, acting as investment adviser, recommend that such shares be crossed from one advisory client account to another and does not act as a broker-dealer with respect to any such potential cross transaction. Conflicts of Interest and Other Disclosures This section highlights certain conflicts of interest that are noted elsewhere in the wrap fee brochure. The entire wrap fee brochure should be read in order to fully understand all conflicts. Please also refer to those sections of this wrap fee brochure and the EFS ADV Part 2A indicated for the proper context and further detail. Affiliated Broker-Dealer Related Conflicts (Item 9 / Part 2A Items 5 and 10) EFS Advisors, acting as registered representatives of EFLS, may receive upfront and/or annual commissions as part of an implemented plan not conducted through EMAP. Advisors have a financial incentive to recommend non-emap broker-dealer products that result in commission revenue, creating a conflict of interest with their clients. Ongoing commissions from the underlying variable annuity for the Retirement InCome for Everyone Trust (RIC-E Trust ) product are received by EFLS for the life of the variable annuity and not by the registered representative. Nevertheless, because EFLS does receive commissions, this may create a conflict of interest. Wrap Fee Brochure 27 January 17, 2018

81 Fees and Expenses (Item 4 / Part 2A Items 8 and 12) Because any mutual fund, ETF and annuity held in a client s EMAP account has its own internal expenses, changing one or more investment funds in an EMAP model and, as a result, the relevant client accounts, will likely result in a change to the expense ratio of the overall portfolio. The resulting expense ratio may be higher than the expense ratio of the original portfolio. If a change is made and the expense ratio of the new fund is in fact higher than that of the fund or investment that was replaced, clients will incur a greater expense than previously incurred. Clients should understand that, while EFS takes the cost of particular investments into account when making investment decisions for the models and accounts in EMAP, cost is but one of many factors that are considered. Other factors that are considered include: overall diversification, return, risk adjusted return, exposure to particular asset classes or market sectors in which the firm and Investment Committee have conviction, internal characteristics, trading impact, liquidity and manager reputation. EFS may negotiate a reduction in fees or other costs on services provided by third-party service providers based on size, volume or other factors. Because the cost to the client of these services is included in the wrap fee, any negotiation of lower costs to EFS will not be reflected in the client s costs. In certain circumstances, e.g. for step-out trades, EFS may elect to execute trades with a brokerdealer other than TD Ameritrade, Fidelity or PAS. Generally speaking, the compensation paid to that broker-dealer is embedded in the price of the security being traded and may represent an additional cost that the client pays, which is not included in the wrap fee. Involvement with the NANR and XT ETFs (Item 9 / Part 2A Items 8 and 14) Certain models available through EMAP include positions in the SPDR S&P North American Natural Resources ETF (NANR) and the ishares Exponential Technologies ETF (XT). Ric Edelman became interested in how new economy innovation and technology disruption would change investing and initially articulated the principles that BlackRock later used in creating XT. EFS played a similar role with respect to NANR. XT and NANR are sponsored and managed by BlackRock and State Street Global Advisors, respectively. Neither Ric Edelman nor EFS receives any direct or indirect compensation from either of the funds or their respective affiliates based on the sale of, or investment in, either fund. For each of these funds, a very high percentage of each ETF s total assets is held by EMAP clients. There is a conflict of interest regarding the initial role that EFS and/or Ric Edelman played in the suggestion for or the creation of these two ETFs, as well as any promotion of NANR or XT by EFS and/or Ric Edelman, in that EFS may receive indirect economic and other benefits from the association of its name with that ETF. That conflict could influence our decision to use either State Street Global Advisors SPDRs or BlackRock s ishares to provide ETFs in EMAP. There could also potentially be such a conflict in the future, if EFS and/or Ric Edelman were to play a role in the creation of a third party s index or other product. In addition, EFS has a joint marketing arrangement with Morningstar, Inc. ( Morningstar ), an unaffiliated third party that created and maintains the Morningstar Exponential Technologies Index. Under the joint marketing arrangement, EFS receives an economic benefit from Morningstar. However, neither Ric Edelman nor EFS receive any direct or indirect economic benefit from Wrap Fee Brochure 28 January 17, 2018

82 Morningstar that is correlated with either XT or the index. Nevertheless, because XT tracks the index, we are disclosing this potential conflict of interest. Related Person May Invest in the Same Securities (Item 9 / Part 2A Item 11) EFS Advisors may open an EMAP account for themselves and participate in the EFS 401(k) Plan that includes EMAP. In that regard, Advisors buy and sell the same underlying securities as clients and will therefore have interest in the same securities owned by or recommended to our clients. Economic Benefit from Third Parties (Item 6 / Part 2A Item 12) From time to time, EFS and/or Ric Edelman may enter into discussions with any third party, including existing vendors or other service providers (including without limitation BlackRock, Dimensional Fund Advisors, Morningstar, Orion, State Street Global Advisors and TD Ameritrade) regarding joint ventures, partnerships, marketing initiatives or other such forms of cooperation. EFS may also use third parties, including existing vendors or service providers in a consultative manner, sounding them out for advice or insight, at no or a reduced cost to EFS, which the Firm could use for its proprietary purposes and/or for the potential benefit of our clients. This activity could create a conflict of interest to the extent that it benefits the Firm and such benefits are not passed on to the client, or EFS otherwise makes decisions with respect to that third party which may adversely affect the client. In addition, to the extent EFS has an arrangement or relationship with a third-party separate and apart from that third party s provision of services to EFS clients, EFS judgment with regard to those services could be affected by its arrangement or relationship. Institutional Alliance Related Conflicts (Item 9 / Part 2A Items 12 and 14) Orion and Salentica, (two vendors EFS uses) along with other companies have formed an Institutional Alliance with TD Ameritrade. EFS uses Orion as its portfolio accounting system and Salentica as its Client Relationship Management (CRM) system, and may from time to time use other vendors which are part of the Institutional Alliance. Generally speaking, new client accounts are established with TD Ameritrade as the custodian, unless the client directs otherwise. EFS has a tiered fee schedule in the contract with Orion, whereby the fee is calculated based on the number of accounts it maintains with Orion. Orion charges EFS a flat dollar amount up to a fixed number of accounts, and a fixed dollar amount per account over that threshold. The fee schedule does not vary depending on the custodian selected by EFS, in part to address the potential conflict of interest. Orion may directly or indirectly receive an economic benefit due to its Institutional Alliance relationship. The tiered fee schedule in the contract with Orion will remain in force, regardless of which custodian EFS directs business to, or whether Orion receives economic benefit from third parties. The Institutional Alliance makes it less likely for EFS to move away from TD Ameritrade, which creates a potential conflict of interest as a custodian other than TD Ameritrade may be able to provide better quality service or provide services at a lower cost to the client. However, because the cost to the client of these custodial services is included in the wrap fee, lower costs to EFS will not be reflected in the client s costs. Salentica may also directly or indirectly receive an economic benefit due to its Institutional Alliance relationship and there could be other such arrangements in the future. Wrap Fee Brochure 29 January 17, 2018

83 In addition, EFS has had discussions with Orion about receiving an economic benefit, based on payments Orion receives from TD Ameritrade for EFS client accounts where TD Ameritrade acts as custodian. If EFS and Orion agree to any amendment that provides economic benefits to EFS, EFS will further amend this ADV to disclose the economic benefits EFS will receive and the related conflicts of interest. Some of the products or services provided by TD Ameritrade may benefit EFS, but may not benefit client accounts. Receiving these economic benefits creates a conflict of interest and could directly or indirectly influence EFS to recommend TD Ameritrade to clients for custody and brokerage services. EFS employees may serve on TD Ameritrade Advisory Panels and be reimbursed for travel and meal expenses, as well as Orion or Salentica Advisory Panels and be reimbursed for meals. EFS participation in the AdvisorDirect program could lead to increased client referrals. From time to time, TD Ameritrade may sponsor EFS corporate events. TD Ameritrade is the founding sponsor of the Certified Financial Planner Board of Standards, Inc. and is paying for EFS participation in their Financial Planner Reentry Initiative. TD Ameritrade and Orion have bought or have agreed to buy a large number of copies of The Truth About Your Future. EFS may also ask vendors to buy copies of a current or future book or provide financial incentive for doing so. Such vendor purchases may also be a conflict of interest. Dimensional Funds Related Conflicts (Item 9 / Part 2A Item 14) Dimensional Fund Advisors LP ( Dimensional ) sponsors a "Find an Advisor" program, which may provide economic benefit to EFS and creates a conflict of interest that could influence EFS to include or continue to include Dimensional products in EMAP. EFS employees may serve on Dimensional Advisory Panels and Dimensional pays or reimburses EFS for meal expenses incurred. Review of Accounts The Investment Committee, as discussed below, oversees rebalancing and the evaluation of EMAP performance. Generally speaking, client accounts are reviewed daily by the trading system for potential rebalancing opportunities, unless certain restrictions have been placed on the account. Funds in the accounts that have exceeded or fallen below their drift parameters are adjusted to get them back to their original asset target(s). Ongoing monitoring includes an evaluation of EMAP performance for potential changes to add or remove asset classes, reallocate asset classes, as well as add, remove, or replace securities as market or other conditions warrant. Securities we buy or sell for accounts are subject to our limited discretionary authority. EFS Advisors generally meet periodically with clients to review economic, tax, financial, political, social and other relevant issues and to determine whether any changes in strategy are warranted. Wrap Fee Brochure 30 January 17, 2018

84 Based on these meetings, client situations and circumstances are reviewed on a periodic basis and recommendations are made as needed. Changes may also be made based on the client s personal circumstances, including health, employment and family status, time horizon or restrictions that the client may place on the investments in the account. On at least an annual basis, EMAP clients are contacted to update their personal and financial information, including health, employment, marital and family status, time horizon, goals and objectives, and risk tolerance. The information is used to determine if there are any changes that could impact the ongoing suitability of the account. Clients may request a review at any time as well. Investment Committee The Investment Committee ( Committee ) is an independent advisory body to senior management, which conducts ongoing reviews and makes recommendations with respect to the ongoing portfolio management and construction of new and existing EMAP asset allocation models. The Committee makes recommendations to senior management regarding adjustments to the models available through EMAP that it deems necessary and appropriate considering material changes since the model portfolios were originally constructed or previously modified. The Committee also evaluates recommendations from senior management regarding any such proposed material changes to EMAP and/or the models. Nature and Frequency of Client Reports Clients participating in EMAP receive account statements at least quarterly and confirmations from the applicable Custodian and generally have unlimited and continuous access to their account information through websites offered and maintained by the account custodian and EFS. Client Referrals and Other Compensation Turnkey Asset Management Program (TAMP) EFS has established a Turnkey Asset Management Program ( TAMP ), whereby the Firm makes the EMAP asset allocation models available to clients of select unaffiliated investment advisors ( TAMP Advisors ). EFS conducts a due diligence review of each TAMP Advisor and each of their investment advisor representatives (IARs), prior to establishing the relationship and on an ongoing basis thereafter. We provide systems, services, and back-office support to the TAMP advisors. EFS has appointed a Manager to administer the TAMP program, manage the TAMP Advisor relationships and help to ensure proper support of their clients. The TAMP Advisor is responsible for the supervision of its IARs. The TAMP Advisor initiates the relationship with the client and is the ongoing client relationship manager. The TAMP Advisor, through its IARs, compiles personal and financial information about the client, maintains the appropriate books and records, makes an asset allocation model recommendation that will meet the client s goals and objectives, maintains the ongoing client relationship, and meets with the client on a periodic basis to discuss suitability and any reasonable restrictions the client would like to impose on his/her account. The EMAP fee is shared between the two entities on a negotiated basis. The client does not pay an increased fee for EMAP as a result of this arrangement. Wrap Fee Brochure 31 January 17, 2018

85 Client Referrals From time to time, EFS will enter into agreements to pay other investment advisers ( Solicitors ) for client referrals in accordance with the requirements of the Cash Solicitation Rule of the Investment Advisers Act, the respective federal and state laws governing the same, and ERISA, if applicable. In such cases, the Solicitors will be paid a percentage of the wrap fees EFS receives relating to the client s account with EFS. EMAP wrap fees are based on a percentage of client assets invested in the wrap fee program. Any such referral fee will be paid solely from the investment advisory fee. The client does not pay an increased fee as a result of these arrangements. Compensation paid to a Solicitor is negotiated between the Solicitor and EFS. The client is provided with a copy of the EFS ADV and a copy of the EFS written disclosure document, which describes the arrangement between EFS and the Solicitor, including the terms, conditions and compensation. Relationship with TD Ameritrade and Others Most EMAP accounts are established with TD Ameritrade, which provides custody of securities, trade execution, clearance and settlement of transactions. EFS has a number of other business relationships with TD Ameritrade and receives indirect benefits from TD Ameritrade. TD Ameritrade Advisory Panels EFS employees may serve on TD Ameritrade Institutional Advisory Panels from time to time. The panels are sponsored by TD Ameritrade and consist of independent advisors who advise TD Ameritrade on issues relevant to its service, technology and products provided. In-person meetings are held one to four times a year. Panel members are not compensated for their participation; however, TD Ameritrade may pay or reimburse EFS for the travel, lodging and meal expenses incurred when EFS employees attend panel meetings. The benefits received by EFS and its employees by serving on a panel do not depend on the amount of brokerage transactions directed to TD Ameritrade. Clients should be aware, however, that the receipt of economic benefit by EFS and its employees in and of itself creates a conflict of interest and could indirectly influence EFS s recommendation of TD Ameritrade for custody of assets and brokerage services. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. Panel members are selected by TD Ameritrade and appointed to serve for a three-year term. Longer service is permitted at the discretion of TD Ameritrade Institutional sales, service and senior management. At times, panel members are provided with confidential information about TD Ameritrade initiatives. Therefore, panel members are required to sign a confidentiality agreement. Orion and Salentica Advisory Panels EFS employees may serve on Orion or Salentica Advisory Panels from time to time. The panels are sponsored by these vendors and consist of independent advisors who advise the vendors on issues relevant to their products provided. Panel members are not compensated for their participation, however Orion or Salentica pay or reimburse EFS for the travel, lodging and meal expenses incurred when EFS employees attend panel meetings. Clients should be aware that the receipt of these economic benefits by EFS and its employees in and of itself creates a conflict of interest. In addition, Wrap Fee Brochure 32 January 17, 2018

86 as Orion and Salentica are part of the Institutional Alliance, this could indirectly influence EFS to recommend TD Ameritrade to clients for custody and brokerage services. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. Dimensional Fund Advisory Panels EFS employees may serve on Dimensional Fund Advisors LP ( Dimensional ) Advisory Panels from time to time. The panels are sponsored by Dimensional and consist of independent advisors who advise Dimensional on issues relevant to its products provided. Panel members are not compensated for their participation and EFS pays for the travel and lodging expenses incurred when EFS employees attend panel meetings, however Dimensional pays or reimburses EFS for meal expenses. Clients should be aware that the receipt of these economic benefits by EFS and its employees in and of itself creates a conflict of interest and could influence EFS to include or continue to include Dimensional managed mutual funds in the EMAP portfolios or recommend other Dimensional products or services. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. TDA AdvisorDirect Program EFS participates in the TD Ameritrade Institutional program known as AdvisorDirect. TD Ameritrade Institutional is a division of TD Ameritrade, member FINRA/SIPC. TD Ameritrade is an independent and unaffiliated SEC registered broker-dealer and FINRA member. There is no employee or agency relationship between TD Ameritrade and EFS. The AdvisorDirect program allows TD Ameritrade to refer its brokerage customers and other investors seeking fee-based personal investment management or financial planning services to other advisors such as EFS. TD Ameritrade has established the referral program as a means of retaining brokerage customers. TD Ameritrade does not supervise EFS and has no responsibility for our management of client asset allocation models or other advice or services. To participate in AdvisorDirect, an advisor must meet certain minimum eligibility criteria; fee-based compensation, education and investment experience, AUM and licensing and registration. However, AdvisorDirect is not open to all advisors who meet these minimum criteria. TDA limits the number of advisors based on the services provided and investment style of the advisor. We receive client referrals from TD Ameritrade through participation in the AdvisorDirect program that result in economic benefit to EFS. We pay TD Ameritrade an ongoing referral fee for each successful client referral. This fee is usually a percentage (not to exceed 25%) of the annual advisory fee that the client pays us. We will also pay TD Ameritrade the referral fee on any advisory fees we receive from any of a referred client s family members, including a spouse, child, or any other immediate family member who resides with the referred client and also becomes an EFS client. Clients who are referred through this program do not pay higher fees or costs than other EFS clients. For more information regarding additional or other fees paid directly or indirectly to TD Ameritrade, please refer to the TD Ameritrade AdvisorDirect Disclosure and Acknowledgment Form. EFS participation in the AdvisorDirect program poses conflicts of interest. TD Ameritrade will most likely refer clients through AdvisorDirect to EFS to encourage clients to custody their assets at TD Wrap Fee Brochure 33 January 17, 2018

87 Ameritrade and maintain client accounts that are profitable to TD Ameritrade. Consequently, in order to obtain client referrals from TD Ameritrade, we have an incentive both to recommend to clients that assets under management be held in custody with TD Ameritrade and to place transactions for client accounts with TD Ameritrade. We have agreed not to solicit clients referred through AdvisorDirect to transfer their accounts from TD Ameritrade nor to establish brokerage or custody accounts at other custodians, except when our fiduciary duties require doing so. EFS participation in AdvisorDirect does not diminish our duty to seek best execution of trades for client accounts. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. TD Ameritrade Institutional Program EFS participates in the TD Ameritrade Institutional Program. We receive services that include custody of client securities, trade execution and clearance and settlement of transactions. The Institutional Program provides additional economic benefits to EFS that are not typically available to TD Ameritrade retail investors. There is no direct link between EFS s participation in the program and the investment advice it gives to its clients. The economic benefits include the following products and services, which are provided at no cost or at a reduced cost to EFS: Receipt of duplicate client statements and confirmations Research-related products and tools Consulting services Access to a trading desk serving EFS Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts) The ability to have advisory fees deducted directly from client accounts Access to an electronic communications network for client order entry and account information Access to mutual funds with no transaction fees and to certain institutional money managers Discounts on compliance, marketing, research, technology and/or other services Practice management products or services provided to EFS by third-party vendors Business consulting and professional services received by EFS-related persons (may be paid for by TD Ameritrade) Some of the products and services made available by TD Ameritrade through the Institutional Program may benefit EFS but may not benefit client accounts. These products or services may assist us in managing and administering client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help EFS manage and further develop our business enterprise. The benefits received by EFS or its personnel through Wrap Fee Brochure 34 January 17, 2018

88 participation in the program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As disclosed above, EFS participates in TD Ameritrade s institutional program and EFS will recommend TD Ameritrade to clients for custody and brokerage services. Therefore, receiving these economic benefits creates a conflict of interest and could directly or indirectly influence EFS to recommend TD Ameritrade to clients for custody and brokerage services. TDA Sponsorship of EFS Corporate Events From time to time, TD Ameritrade may sponsor EFS corporate events. The decision to act as a sponsor of EFS corporate events is at their sole discretion and expense. The sponsorship of EFS corporate events by TD Ameritrade provides indirect economic benefits to EFS and creates a potential conflict of interest that could indirectly influence EFS to recommend TD Ameritrade to clients for custody of assets and brokerage services. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. Sponsorship of The Truth About Money Television Program Ric Edelman is the host of a syndicated television program, The Truth About Money with Ric Edelman, airing on public television stations. The program covers many aspects of financial education. A portion of the television show is filmed before a studio audience where participants can ask questions. An audience participant may discuss a specific mutual fund, ETF, or insurance product that may be held in the accounts of certain EMAP clients or under consideration at the time of the question. Mr. Edelman does not give specific legal, tax or investment advice, and he may give advice that is the same as or different from the advice EFS has given or may give to its clients. The Truth About Money with Ric Edelman is no longer producing new episodes, but previously produced episodes air on PBS affiliate stations such as WETA in the DC Metro area; episodes are also available on In the past, TD Ameritrade sponsored the television show. The decision of TD Ameritrade to act as a sponsor of the television program was made at its sole discretion and expense. As part of our fiduciary duties to clients, we endeavor at all times to put the interests of our clients first. Participation by EFS employees in the TD Ameritrade Institutional Operations Panel, EFS participation in the AdvisorDirect program, and TD Ameritrade s agreement to sponsor the television program in the past create conflicts of interest and could influence our choice of TD Ameritrade for client account custody and brokerage services. In selecting custodial and brokerage firms, we evaluate all the services offered, the quality of those services and the cost indirectly borne by clients to determine if a clearing firm provides overall quality of services for the price. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. In the past, ishares, the exchange-traded fund business of BlackRock, Inc., and one of the industry s leading exchange-traded funds platforms, also acted as a sponsor of the aforementioned television show. The decision of BlackRock to act as a sponsor of the television program was made at its sole discretion and its own expense. As part of our fiduciary duties to clients, we endeavor at all times to put the interests of our clients first. BlackRock s agreement to sponsor the television program in the past creates a conflict of interest and could influence our decision to use BlackRock or ishares to Wrap Fee Brochure 35 January 17, 2018

89 provide exchange-traded funds (ETFs) in the EMAP portfolios. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. Evaluation of NANR, XT and Other ETFs Certain models available through EMAP include positions in the SPDR S&P North American Natural Resources ETF (NANR) and the ishares Exponential Technologies ETF (XT). Ric Edelman became interested in how new economy innovation and technology disruption would change investing and initially articulated the principles that BlackRock later used in creating XT. EFS played a similar role with respect to NANR. XT and NANR are sponsored and managed by BlackRock and State Street Global Advisors, respectively. Neither Ric Edelman nor EFS receives any direct or indirect compensation from either of the funds or their respective affiliates based on the sale or investment in either fund. For each of these funds, a very high percentage of each ETF s total assets is held by EMAP clients. There is a conflict of interest regarding the initial role that EFS and/or Ric Edelman played in the suggestion for or the creation of these two ETFs, as well as any promotion of NANR or XT by EFS and/or Ric Edelman, in that EFS may receive indirect economic and other benefits from the association of its name with that ETF. That conflict could influence our decision to use either State Street Global Advisors SPDRs or BlackRock s ishares to provide ETFs in EMAP. There could potentially also be such a conflict in the future, if EFS and/or Ric Edelman were to play a role in the creation of a third party s index or other product. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. In addition, EFS has a joint marketing arrangement with Morningstar, an unaffiliated third party that created and maintains the Morningstar Exponential Technologies Index. Under the joint marketing arrangement, EFS receives an economic benefit from Morningstar. However, neither Ric Edelman nor EFS receive any direct or indirect economic benefit from Morningstar that is correlated with either XT or the index. Nevertheless, because XT tracks the index, we are disclosing this potential conflict of interest. In selecting new ETFs for our portfolios or evaluating those currently used, the Portfolio Manager presents the results of any pertinent analysis to the Investment Committee and a decision is reached after consideration of the quantitative results as well as other, more qualitative factors. Please refer to Item 6 above for further discussion on the firm s investment selection methodology. The EFS Chief Compliance Officer periodically attends Investment Committee meetings and provides Conflicts of Interest training to the Investment Committee. EFS Participation in the Financial Planner Reentry Initiative The Certified Financial Planner Board of Standards, Inc. (CFP Board) is a non-profit organization that promotes the value of professional, competent and ethical financial planning services, as represented by those who have attained CFP certification. The CFP Board sponsors an initiative called the Financial Planner Reentry Initiative, to support financial services firms in establishing reentry programs for experienced professionals seeking to return to the workforce. Payment for EFS participation in this program is not required, as a result of the lead founding sponsorship of the CFP Board s Center for Financial Planning by TD Ameritrade Institutional. This arrangement provides indirect economic benefits to EFS and creates a potential conflict of interest that could indirectly Wrap Fee Brochure 36 January 17, 2018

90 influence EFS to recommend TD Ameritrade to clients for custody of assets and brokerage services. Please refer to the Conflicts of Interest section above for further information on this conflict. Evaluation of Dimensional Funds Products Dimensional Fund Advisors LP ( Dimensional ) is an SEC registered investment adviser that manages securities and other assets (which are used in EMAP accounts) for mutual funds, institutional investors and clients of independent financial advisers. Dimensional has developed an internet-based tool called "Find an Advisor" to assist investors trying to locate financial advisors through whom they may purchase Dimensional Funds. This program provides direct or indirect economic benefits to EFS and creates a conflict of interest that could influence EFS to include or continue to include Dimensional managed mutual funds in the EMAP portfolios or recommend other Dimensional products or services. Please refer to the Conflicts of Interest and Other Disclosures section above for further information on this conflict. As part of our fiduciary duty to clients, we endeavor at all times to put the interests of our clients first. In selecting new mutual funds or ETF s for our portfolios and evaluating those currently used, the Portfolio Manager presents the results of any pertinent analysis to the Investment Committee and a decision is reached after consideration of the quantitative results as well as other, more qualitative factors. Please refer to Item 6 above for further discussion on the firm s investment selection methodology. The EFS Chief Compliance Officer periodically attends Investment Committee meetings and provides Conflicts of Interest training to the Investment Committee. Financial Information Registered investment advisers are required to provide clients with financial information or disclosures about their financial condition under certain circumstances. We are not aware of any financial condition that would impair our ability to meet contractual or fiduciary commitments to clients. We have not been the subject of any bankruptcy proceeding. Wrap Fee Brochure 37 January 17, 2018

91 Edelman Financial Services, LLC Investment Committee This brochure provides information about the members of the Edelman Financial Services, LLC Investment Committee and is a supplement to the Edelman Financial Services, LLC brochure which is attached. If you have any questions about the contents of either brochure, please contact us at 888- PLAN-RIC ( ) or you may us at info@ricedelman.com or write us at the address below. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority, nor does registration with the SEC imply a certain level of skill or training. Additional information about each member of the Investment Committee is also available on the SEC s website at Legato Road, 9 th Floor Fairfax, VA EdelmanFinancial.com RicEdelman.com 888-PLAN-RIC ( ) (fax) info@ricedelman.com Form ADV Part 2B 1 March 31, 2017

92 EFS Investment Committee Summary EFS has an Investment Committee which consists of twelve (12) voting members, one (1) ex-officio member, and seven (7) non-voting members. The committee meets regularly and conducts ongoing evaluation of EMAP performance and makes recommendations to senior management regarding material changes to the asset allocation models, including, but not limited to, adding or removing asset allocation models, changing the target percentages of the asset classes (i.e. reallocation), and adding, removing, or replacing securities as deemed appropriate. Each Advisor then has the fiduciary duty to determine which model or combination of models (if any) is in the best interest of each client. Andrew Massaro, Executive Director, Financial Planning, serves as the Chairman of the Investment Committee, which is responsible for the investment management of EMAP assets and establishing the EMAP Investment Policy. Mitchell York, EMAP Portfolio Manager, is responsible for implementing and monitoring that policy. Voting members of the committee consist of EFS Investment Advisors and senior staff members who are appointed by the President of EFS. Non-voting members, with the exception of Mitchell York, provide no investment advice to the committee and consist of managers from the operations, information technology, trading, legal and compliance areas. They provide operational, legal and compliance guidance to the committee s voting members and assist with the implementation of decisions. Ex-Officio Committee Members: Ed Moore President Voting Committee Members: Robert Bowman Associate Director, Financial Planning Scott Butera Director, Financial Planning Ann Crehan Director, Financial Planning Mary Davis Executive Director, Financial Planning Doug Keegan Regional Director, Financial Planning J.B. Liebstein Director, Financial Planning Brian Lipps Regional Director, Financial Planning Andrew Massaro Executive Director, Financial Planning Michelle Muhammed Associate Director, Financial Planning R.J. Reibel Manager, Retirement Plans Division Dave Sheehan Director, Financial Planning Anderson Wozny Executive Director, Financial Planning Non-Voting Members: Mike Attiliis Bill Hayes Darren Norwood Eric Olsen Aaron Rowe Ed Schweitzer Mitch York Vice-President, Business Systems Group Corporate General Counsel Manager, Compliance Review & Surveillance EMAP Trading & Risk Management Analyst Vice-President, Operations Manager, TAMP Division EMAP Portfolio Manager Form ADV Part 2B 2 March 31, 2017

93 Edward (Ed) Philip Moore President Member of Investment Committee, Ex Officio 4000 Legato Road 9 th Floor Fairfax, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1960 Formal Education: Bachelor of Science in Industrial Engineering and Operations Research, Virginia Polytechnic Institute and State University Business Background: Ed Moore has been an investment advisor since 1986, and has been with Edelman Financial Services since Employment History: Present; President of Edelman Financial Services Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Ed has no legal or disciplinary events to report. Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client s best interests, we may deposit, transfer, purchase or liquidate securities in the client s account that is maintained with our firm. Ed can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm s policy, Ed generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

94 Ed also holds insurance licenses. As such, he may recommend the purchase of life, health, long-term care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Ed does not receive any additional compensation from non-clients for providing advisory services. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Ed s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) * Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. Ed Moore Updated March 31, 2017

95 Robert Scott Bowman Associate Director, Financial Planning Voting Member of Investment Committee 200 Westgate Parkway Suite 202 Henrico, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1968 Formal Education: Bachelor of Business Administration Finance and Insurance, Radford University College of Business and Economics Business Background: Robert Bowman has been in investment management for 27 years, and has been with Edelman Financial Services since Employment History: 2012 Present; Associate Director of Financial Planning for Edelman Financial Services. Provides financial advice to clients ; Portfolio Manager for Edelman Financial Services. Directed portfolio and risk management for EMAP ; Managing Director at Trusco Capital Management. Directed portfolio and risk management ; Portfolio Manager at Crestar Asset Management. Directed portfolio and risk management ; Equity Trader at Capitoline Investment Advisory. Professional Designation(s):* Chartered Financial Analyst Chartered Alternative Investment Analyst Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Robert has no legal or disciplinary events to report. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

96 Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client s best interests, we may deposit, transfer, purchase or liquidate securities in the client s account that is maintained with our firm. Robert can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm s policy, Robert generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Robert also holds insurance licenses. As such, he may recommend the purchase of life, health, long-term care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Robert may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Robert s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) * Important Information About the Chartered Financial Analyst (CFA) Designation: The CFA designation is highly revered in investment management field and those who have the credential are expected to have an in-depth knowledge of the investment industry, with many going on to careers as portfolio managers or research analysts at hedge funds and private equity firms. Obtaining the qualification requires; a selfstudy program which takes several years to complete and participants must pass three six-hour exams, as well as agree to abide by a strict code of ethics and standards of conduct. Candidate must also meet one of the following requirements: Undergraduate degree and four years of professional experience involving investment decision-making, or Four years qualified work experience (full time, but not necessarily investment related). Important Information About the Chartered Alternative Investment Analyst (CAIA) Designation: The Chartered Alternative Investment Analyst program provides individuals with the core competencies required to create, manage, and monitor an institutional-quality portfolio consisting of both traditional and alternative investments. Candidates must hold a U.S. bachelor's degree or the equivalent, and have more than one year of professional experience, or alternatively have at least four years of professional experience. The candidate must pass a Level I and Level II exam, pay an annual membership fee and agree on an annual basis to abide by the Member Agreement which includes adhering to a Professional Conduct Standard. Robert Bowman Updated March 31, 2017

97 Scott Christopher Butera Executive Director, Financial Planning Voting Member of Investment Committee 6550 Rock Spring Drive Suite 510 Bethesda, MD This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1975 Formal Education: Bachelor of Arts in Economics, University of Maryland Business Background: Scott Butera has been an investment advisor for 20 years, and has been with Edelman Financial Services since Employment History: 2006 Present; Executive Director of Financial Planning for Edelman Financial Services. Provides financial advice to clients ; Vice President/Senior Account Executive at Fidelity Investments. Provided financial advice to clients ; Investment Advisor at Charles Schwab. Provided financial advice to clients ; Financial Advisor for American Express. Provided financial advice to clients. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Scott has no legal or disciplinary events to report. Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client s best interests, we may deposit, transfer, purchase or liquidate securities in the client s account that is maintained with our firm. Scott can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

98 In accordance with our firm s policy, Scott generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Scott also holds insurance licenses. As such, he may recommend the purchase of life, health, long-term care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Scott may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Scott s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. Scott Butera Updated March 31, 2017

99 Ann Mary Crehan Director, Financial Planning Voting Member of Investment Committee 1750 Tysons Boulevard Suite 910 Tysons Corner, VA This is a supplement to the Edelman Financial Services LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1974 Formal Education: Bachelor of Science in Business and Finance, Mount Saint Mary's University Master of Business Administration with a concentration in Finance, Loyola University Business Background: Ann Crehan has been an investment advisor for 21 years, and has been with Edelman Financial Services since Employment History: Present; Director of Financial Planning for Edelman Financial Services. Provides financial advice to clients ; Financial Advisor at Merrill Lynch. Provided financial advice for clients ; Branch Manager at M&T Bank. Operated retail branch and provided investments for clients. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Chartered Retirement Planning Counselor Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Ann has no legal or disciplinary events to report. Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client s best interests, we may deposit, transfer, purchase or liquidate securities in the client s account that is maintained with our firm. Ann can accommodate her clients because she holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

100 In accordance with our firm s policy, Ann generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Ann also holds insurance licenses. As such, she may recommend the purchase of life, health, long-term care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Ann may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Ann s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. Important Information About the Chartered Retirement Planning Counselor (CRPC ) Designation: The Chartered Retirement Planning Counselor (CRPC ) program is issued by the College for Financial Planning and focuses on a course of study encompassing pre- and postretirement needs and issues related to asset management and estate planning. Although the CRPC program requires no prerequisites, Candidates must complete a final designation exam that is online, closed-book and proctored. Additionally, Candidates must complete 16 hours of continuing education every two years. Ann Crehan Updated March 31, 2017

101 Mary Stone Davis Executive Director, Financial Planning Voting Member of Investment Committee 4000 Legato Road 9th Floor Fairfax, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1959 Formal Education: Bachelor of Business Administration, Southern Methodist University Business Background: Mary Davis has been an investment advisor for 36 years, and has been with Edelman Financial Services since Employment History: 1994 Present; Executive Director of Financial Planning for Edelman Financial Services. Provides financial advice for clients. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Mary has no legal or disciplinary events to report. Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client s best interests, we may deposit, transfer, purchase or liquidate securities in the client s account that is maintained with our firm. Mary can accommodate her clients because she holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm s policy, Mary generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

102 Mary also holds insurance licenses. As such, she may recommend the purchase of life, health, long-term care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Mary may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Mary s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. Mary Davis Updated March 31, 2017

103 Douglas (Doug) Arthur Keegan Regional Director, Financial Planning Voting Member of Investment Committee 4000 Legato Road 9 th Floor Fairfax, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1967 Formal Education: Master of Business Administration in Finance, The University of Calgary Master of Arts in Music, Chopin Academy of Music, Warsaw, Poland Bachelor of Arts in Music, Chopin Academy of Music, Warsaw, Poland Business Background: Doug Keegan has been an investment advisor for 17 years, and has been with Edelman Financial Services since Employment History: 2010 Present; Regional Director of Financial Planning for Edelman Financial Services. Manages the firm s financial planners ; Manager of Financial Planning for Sullivan, Bruyette, Speros & Blayney, Inc. Managed the firm s financial planners and provided financial advice to clients ; Financial Advisor for Jacqueline L. Powell & Associates, Inc. Provided financial advice to clients ; Financial Advisor for Sovereign Bank. Provided financial advice to clients ; Financial Advisor for AXA Advisors, LLC. Provided financial advice to clients ; Financial Advisor for New England Securities. Provided financial advice to clients. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Doug has no legal or disciplinary events to report. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

104 Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client's best interests, we may deposit, transfer, purchase or liquidate securities in the client's account that is maintained with our firm. Doug can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm's policy, Doug generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Doug also holds insurance licenses. As such, he may recommend the purchase of life, health, longterm care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Doug does not receive any additional compensation from non-clients for providing advisory services. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Doug s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. Douglas (Doug) Keegan Updated March 31, 2017

105 Jerome Bruce (JB) Liebstein Executive Director, Financial Planning Voting Member of Investment Committee 6550 Rock Spring Drive Suite 510 Bethesda, MD This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1961 Formal Education: University of Maryland, College Park, MD, Tel Aviv University, Israel, West Virginia University, Morgantown, West Virginia, Business Background: JB Liebstein has been an investment advisor for 21 years, and has been with Edelman Financial Services since Employment History: 2006 Present; Executive Director of Financial Planning for Edelman Financial Services. Provides financial advice to clients ; Registered Representative for Next Financial Group. Provided financial planning to clients ; Registered Representative at Lincoln Financial Group. Provided financial planning to clients ; Registered Representative at Cigna Financial Group. Provided financial planning to clients. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Chartered Financial Consultant Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. JB has no legal or disciplinary events to report. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

106 Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client s best interests, we may deposit, transfer, purchase or liquidate securities in the client s account that is maintained with our firm. JB can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm s policy, JB generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. JB also holds insurance licenses. As such, he may recommend the purchase of life, health, long-term care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation JB may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. JB s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisoryrelated activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. Important Information About the Chartered Financial Consultant (ChFC ) Designation: The Chartered Financial Consultant (ChFC ) program prepares candidates to meet the advanced financial planning needs of individuals, professionals and small business owners. Candidates gain a sustainable advantage in this competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income taxation, retirement planning, investments and estate planning. Candidates are required to have three years of full-time business experience within the five years preceding the awarding of the designation and pass a final proctored exam for each course. In addition, the Chartered Financial Consultant must complete 30 hours of continuing education every two years. Jerome (JB) Liebstein Updated March 31, 2017

107 Brian Christopher Lipps Regional Director, Financial Planning Voting Member of Investment Committee 4000 Legato Road 9 th Floor Fairfax, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1974 Formal Education: Bachelor of Science in English, Radford University Master of Business Administration in Finance, University of Southern California Business Background: Brian Lipps has been an investment advisor for 18 years, and has been with Edelman Financial Services since Recent Employment History: 2013 Present; Regional Director of Financial Planning for Edelman Financial Services. Manages the firm s financial planners ; Vice President and Branch Manager at Charles Schwab & Co. Inc. Managed investment advisors and financial planners ; Financial Consultant at Wells Fargo Securities Inc. Provided financial advice to clients ; Financial Consultant at Merrill Lynch, Pierce, Fenner & Smith Inc. Provided financial advice to clients. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Chartered Financial Analyst Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Brian has no legal or disciplinary events to report. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

108 Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client's best interests, we may deposit, transfer, purchase or liquidate securities in the client's account that is maintained with our firm. Brian can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm's policy, Brian generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Brian also holds insurance licenses. As such, he may recommend the purchase of life, health, longterm care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Brian does not receive any additional compensation from non-clients for providing advisory services. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Brian s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. Important Information About the Chartered Financial Analyst (CFA) Designation: The CFA designation is highly revered in investment management field and those who have the credential are expected to have an in-depth knowledge of the investment industry, with many going on to careers as portfolio managers or research analysts at hedge funds and private equity firms. Obtaining the qualification requires; a self-study program which takes several years to complete and participants must pass three six-hour exams, as well as agree to abide by a strict code of ethics and standards of conduct. Candidate must also meet one of the following requirements: Undergraduate degree and four years of professional experience involving investment decision-making, or Four years qualified work experience (full time, but not necessarily investment related). Brian Lipps Updated March 31, 2017

109 Andrew Charles Massaro Executive Director, Financial Planning Chairman of Investment Committee 4000 Legato Road 9 th Floor Fairfax, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1967 Formal Education: Bachelor of Science in Business Administration, Georgetown University Business Background: Andrew Massaro has been an investment advisor for 28 years, and has been with Edelman Financial Services since Employment History: 1994 Present; Executive Director of Financial Planning for Edelman Financial Services. Provides financial advice to clients ; Senior New Business Specialist at Schoenke & Associates. Provided executive benefits consulting to corporations ; Registered Representative at Capital Analysts Inc. Provided estate planning and investment management to business owners. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Certified Fund Specialist Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Andrew has no legal or disciplinary events to report. Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client s best interests, we may deposit, transfer, purchase or liquidate securities in the client s account that is maintained with our firm. Andrew can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

110 In accordance with our firm s policy, Andrew generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Andrew also holds insurance licenses. As such, he may recommend the purchase of life, health, longterm care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Andrew may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Andrew s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) * Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. Important Information About the Certified Fund Specialist (CFS ) Designation: A Certified Funds Specialist learns criteria such as alpha, beta, correlation coefficient, first-auto correlation, R-squared, and standard deviation that should be incorporated in the selection process. With mutual funds training, a Certified Fund Specialist is able to evaluate and compare financial measurements and benchmarks when constructing a portfolio. Candidates of the CFS must meet one of the following requirements: (1) a bachelor's degree or (2) one year of financial services work experience. In addition, CFS candidates must complete 30 hours of continuing education every two years. Andrew Massaro Updated March 31, 2017

111 Michelle Vincent Muhammed Associate Director, Financial Planning Voting Member of Investment Committee 1010 Wayne Avenue Suite 1200 Silver Spring, MD This is a supplement to the Edelman Financial Services LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1978 Formal Education: Bachelor of Science in Chemistry, Seton Hall University Business Background: Michelle Muhammed has been an investment advisor for 16 years and has been with Edelman Financial Services since Employment History: Present; Associate Director of Financial Planning for Edelman Financial Services. Provides financial advice to clients ; Vice President, Senior Account Executive at Fidelity Investments. Provided financial advice to clients ; Financial Consultant at AXA Advisors LLC. Provided financial advice to clients ; Divisional Vice President at AXA Advisors LLC. Managed and trained a team of financial representatives. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Chartered Financial Consultant Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Michelle has no legal or disciplinary events to report. Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client's best interests, we may deposit, transfer, purchase or liquidate securities in the client's account that is maintained with our firm. Michelle can accommodate her clients because she holds the appropriate securities licenses as a CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

112 Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm's policy, Michelle generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Michelle also holds insurance licenses. As such, she may recommend the purchase of life, health, longterm care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Michelle may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Michelle s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) * Important Information About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, CFP candidates must complete 30 hours of continuing education every two years. Important Information About the Chartered Financial Consultant (ChFC ) Designation: The Chartered Financial Consultant (ChFC ) program prepares candidates to meet the advanced financial planning needs of individuals, professionals and small business owners. Candidates gain a sustainable advantage in this competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income taxation, retirement planning, investments and estate planning. Candidates are required to have three years of full-time business experience within the five years preceding the awarding of the designation and pass a final proctored exam for each course. In addition, the Charter Financial Consultant must complete 30 hours of continuing education every two years. Michelle Muhammed Updated March 31, 2017

113 Raymond James (R.J.) Reibel, II Manager, Retirement Plans Division Voting Member of Investment Committee 200 Westgate Parkway Suite 202 Henrico, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1977 Formal Education: Bachelor of Arts in Public Policy, College of William & Mary Master of Science in Business Finance, Virginia Commonwealth University Business Background: R.J. Reibel has been an investment advisor for 13 years, and has been with Edelman Financial Services since Employment History: Present; Manager of Retirement Plans Division for Edelman Financial Services. Investment Advisor to corporate retirement plans ; Planning Specialist at Financeware Inc. Designed and reviewed financial plans for advisors and retirement plans for companies ; Financial Analyst at Marsh USA. Provided budgeting and forecasting analysis to office manager. 2000; Registered Representative at Mass Mutual. Sold life Insurance and mutual funds. Professional Designation(s):* Chartered Retirement Plans Specialist Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. R.J. has no legal or disciplinary events to report. Other Business Related Activities R.J. is not involved in any other business related activities. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

114 Additional Compensation R.J. may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. R.J. s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information about the Chartered Retirement Plans Specialist (CRPS ) designation: The Chartered Retirement Plans Specialist designation provides the advisor with the unique skills needed to implement and oversee internal retirement plans. As retirement plan options evolve and tax complexities increase, many companies seek professional plan administrators to design, install, and maintain their company retirement plans. There is no prerequisite/experience required to obtain the CRPS designation. Candidates must pass a final designation exam which is online, closed-book and proctored. In addition, the candidate must complete 16 hours of continuing education every two years. Raymond (R.J.) Reibel Updated March 31, 2017

115 David Thomas Sheehan Director, Financial Planning Voting Member of Investment Committee 4000 Legato Road 9 th Floor Fairfax, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1978 Formal Education: Bachelor of Science, focus in Family Financial Management, Virginia Polytechnic Institute and State University Masters of Business Administration; Concentration in Finance, Keller Graduate School of Management Business Background: David Sheehan has been an investment advisor for 10 years and has been with Edelman Financial Services since Employment History: 2011 Present; Director of Financial Planning at Edelman Financial Services. Provides financial advice to clients ; Operations Manager at Edelman Financial Services. Managed back office operations ; Edelman Direct Advisor at Edelman Financial Services. Provided financial advice to clients nationwide ; Financial Analyst at Edelman Financial Services. Worked with financial advisors providing research and analysis to create financial plans for clients. Professional Designation(s):* CERTIFIED FINANCIAL PLANNER Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. David has no legal or disciplinary events to report. CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

116 Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client's best interests, we may deposit, transfer, purchase or liquidate securities in the client's account that is maintained with our firm. David can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm's policy, David generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. David also holds insurance licenses. As such, he may recommend the purchase of life, health, long-term care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation David may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. David s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important About the CERTIFIED FINANCIAL PLANNER (CFP ) Designation: The CERTIFIED FINANCIAL PLANNER (CFP ) certification represents proven expertise within the financial planning profession. Those with the CFP designation have demonstrated competency in all areas of finance related to financial planning. Candidates for the CFP designation must pass a certification exam administered by the Certified Financial Planner Board of Standards Inc. that focuses on over 100 topics of concern to the financial planning field, such as retirement, estate, and investment planning. In addition to passing the CFP certification exam, candidates must also complete qualifying work experience (three years full-time or equivalent part-time experience in the financial planning field) and agree to adhere to the CFP Board's code of ethics and professional responsibility and financial planning standards. In addition, a CFP must complete 30 hours of continuing education every two years. David Sheehan Updated March 31, 2017

117 Eugene Anderson Wozny Executive Director, Financial Planning Voting Member of Investment Committee 4000 Legato Road 9 th Floor Fairfax, VA This is a supplement to the Edelman Financial Services LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1970 Formal Education: Bachelor of Science in Business Administration, East Carolina University Master of Science in Financial Services, Institute of Business and Finance Business Background: Anderson Wozny has been an investment advisor for 24 years, and has been with Edelman Financial Services since Employment History: Present; Executive Director of Financial Planning for Edelman Financial Services. Provides financial advice to clients ; Investment Representative at SunTrust Securities. Provided investment advice to bank clients ; Financial Planning Analyst at Bennett Financial Advisors. Prepared financial plans and investment recommendations for financial planners. Professional Designation(s):* Accredited Asset Management Specialist,Accredited Wealth Management Advisor,Certified Fund Specialist,Chartered Mutual Fund Counselor,Registered Financial Consultant, Certified Annuity Specialist, Certified Income Specialist, Certified Estate and Trust Specialist Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Anderson has no legal or disciplinary events to report. Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client s best interests, we may deposit, transfer, purchase or liquidate securities in the client s account that is maintained with our firm. Anderson can accommodate his clients because he holds the appropriate securities licenses as a Registered Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm s policy, Anderson generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

118 appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Anderson also holds insurance licenses. As such, he may recommend the purchase of life, health, longterm care and disability insurance products, as well as fixed and variable annuities. There could be a conflict of interest if such recommendation were to generate a commission. Additional Compensation Anderson may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Anderson s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information About the Accredited Asset Management Specialist (AAMS ) Designation: The Accredited Asset Management Specialist or AAMS provides the advisor with a logical progression of topics, enabling them to think in terms of clients total financial situations, not just their investments. At the conclusion of the studies, the candidate s ability to identify opportunities and employ strategies is enhanced not only with regard to investments, but also related to planning for insurance, tax, retirement, and estate issues. There is no prerequisite. The candidate must complete a self-study course consisting of 12 modules, requiring hours. The candidate must also pass a final exam (online, closed-book, proctored). The candidate is required to complete 16 hours of continuing education every 2 years. Important Information About the Accredited Wealth Management Advisor (AWMA ) Designation: Candidates of the Accredited Wealth Management Advisor designation must pass a final designation exam that is online, closed-book and proctored. There is no prerequisites/experience required to obtain the AWMA designation. In addition, Accredited Wealth Management Advisor must complete 16 hours of continuing education every two years. Important Information About the Certified Fund Specialist (CFS ) Designation: A Certified Funds Specialist learns criteria such as alpha, beta, correlation coefficient, first-auto correlation, R- squared, and standard deviation that should be incorporated in the selection process. With mutual funds training, a Certified Fund Specialist is able to evaluate and compare financial measurements and benchmarks when constructing a portfolio. Candidates of the CFS must meet one of the following requirements: (1) a bachelor's degree or (2) one year of financial services work experience. In addition, CFS candidates must complete 30 hours of continuing education every two years. Important Information About the Chartered Mutual Fund Counselor (CMFC ) Designation: The Chartered Mutual Fund Counselor provides candidates with a thorough knowledge of mutual funds and their various uses as investment vehicles. The case studies used throughout the course presenting client scenarios and pointing out opportunities for candidates to make the most of these popular investments provide insight into effective use of these investment vehicles. There is no prerequisites/experience required for this designation. Candidates must pass a final designation exam which is online, closed-book and proctored. In addition, a Chartered Mutual Fund Counselor must complete 16 hours of continuing education every two years. Important Information About the Registered Financial Consultant (RFC) Designation: Registered Financial Consultant is a professional designation awarded by the International Association of Registered Financial Consultants (IARFC) to those financial advisors who meet high standards of education, experience and integrity. Candidates must meet all of the following requirements: (1) undergraduate or graduate financial planning degree, or have earned one of the following designations: AAMS, AEP, CEP, CFA, CFP, ChFC, CLU, CPA, EA, LUTC, MS, MBA, JD, Ph.D, or completed a CFP equivalent, IARFC-approved college curriculum, (2) if operating on a commission basis, must meet licensing requirements for securities and life and health insurance; if operating strictly as fee-only and not licensed, then must be registered as an investment adviser, and (3) four years full-time experience as a financial planning practitioner. Candidates are required to pass the IARFC self-study course: final certification exam. In addition, candidates must complete 40 hours of continuing education per year. Important Information About the Certified Annuity Specialist (CAS ) Designation: The Certified Annuity Specialist program covers all the traditional aspects of fixed-rate and variable products; a detailed part of the materials also covers the different titling options and the estate and income tax ramifications of each. CAS candidates must meet one of the following requirements: (1) a bachelor's degree or (2) one year of financial services work experience. In addition, CAS candidates must complete 30 hours of continuing education every two years. Important Information About the Certified Income Specialist (CIS ) Designation: The Certified Income Specialist program is an intermediate-to-advanced course on investment concepts, cash reserves, FDIC coverage, utilities, preferreds, bonds, and other income-oriented options. Candidates must have at least 2,000 hours of work experience in the financial services industry or a bachelor's degree from an accredited college or university. The candidate must pass three exams, complete one open-book case study and sign a code of ethics. The candidate must report 30 hours of CE credit every two years. Important Information About the Certified Estate and Trust Specialist (CES ) Designation: The Certified Estate and Trust Specialist program is designed to provide individuals with a solid foundation in estate planning and asset repositioning implementation. Candidates must have at least 2,000 hours of work experience in the financial services industry or a bachelor's degree from an accredited college or university. The candidate must complete a self-study course consisting of three modules, pass three exams, and complete a case study. Additionally, the candidate must sign a code of ethics and complete 30 hours of continuing education every two years. Eugene Anderson Wozny Updated March 31, 2017

119 Mitchell (Mitch) Paul York EMAP Portfolio Manager Member of Investment Committee 200 Westgate Parkway Suite 202 Henrico, VA This is a supplement to the Edelman Financial Services, LLC brochure. Please contact us at if you have any questions about our brochure or this supplement. Educational Background and Business Experience Year of Birth: 1968 Formal Education: Bachelor of Business Administration, Eastern Kentucky University Master of Arts in Economics, University of South Florida Business Background: Mitch York has been has been in investment management for 20 years, and has been with Edelman Financial Services since Employment History: 2013 Present; EMAP Portfolio Manager for Edelman Financial Services. Manager of the Edelman Managed Asset Program (EMAP) ; Portfolio Manager at Wertz York Capital Management. Portfolio manager for a government bond fund and a State of Florida fixed income trust ; Financial Advisor at Securities America Inc. Provided investment and financial advice for individuals and families. Professional Designation(s):* Chartered Financial Analyst Disciplinary Information Like all Registered Investment Advisors, we are required to disclose all material facts regarding any legal or disciplinary events that could materially influence your evaluation of your advisor. Mitch has no legal or disciplinary events to report. Other Business Related Activities Sometimes, when an appropriate situation arises and is in the client's best interests, we may deposit, transfer, purchase or liquidate securities in the client's account that is maintained with our firm. Mitch can accommodate his clients because he holds the appropriate securities licenses as a Registered CORPORATE HEADQUARTERS 4000 Legato Rd., 9 th Fl., Fairfax, VA RicEdelman.com Updated March 31, 2017

120 Representative with EF Legacy Securities, LLC, a broker-dealer and affiliate of Edelman Financial Services. In accordance with our firm's policy, Mitch generally does not recommend the purchase of securities products that generate brokerage commissions. However, purchasing or selling securities may be appropriate at times, and in such cases the firm might charge the client a transaction fee. When this occurs, the firm may offer discount brokerage rates as an accommodation to our clients. Additional Compensation Mitch may receive additional compensation for referring clients to Edelman Financial Services, under the firm s referral program. Supervision Edelman Financial Services has adopted a formal compliance program designed to prevent, detect and correct any actual or potential violations by the firm or its supervised persons of the Investment Advisers Act of 1940, and other federal securities laws and rules adopted under the Advisers Act. Mitch s investment advisory activity is supervised by the firm s Compliance Supervisory Review Team, which is located at the firm s Corporate Headquarters in Fairfax, Virginia. The team supervises all advisory-related activities using both technological and physical analysis to review and approve new accounts, transactions and other advisory-related activities. The team is a division of the firm s Compliance Department, which is managed by Rainey Gray, Interim Chief Compliance Officer. He can be reached at rainey.gray@ricedelman.com or by calling (703) *Important Information About the Chartered Financial Analyst (CFA) Designation: The CFA designation is highly revered in investment management field and those who have the credential are expected to have an in-depth knowledge of the investment industry, with many going on to careers as portfolio managers or research analysts at hedge funds and private equity firms. Obtaining the qualification requires; a self-study program which takes several years to complete and participants must pass three six-hour exams, as well as agree to abide by a strict code of ethics and standards of conduct. Candidate must also meet one of the following requirements: Undergraduate degree and four years of professional experience involving investment decision-making, or Four years qualified work experience (full time, but not necessarily investment related). Mitchell (Mitch) York Updated March 31, 2017

121 Rev. 02/2016 FACTS Why? WHAT DO EDELMAN FINANCIAL SERVICES, LLC AND EF LEGACY SECURITIES, LLC DO WITH YOUR PERSONAL INFORMATION? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. This information can include: What? Social Security number and income Assets and investment experience Account transactions and risk tolerance, and Employment information When you are no longer our client, we continue to share your information as described in this notice. How? All financial companies need to share clients personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients personal information; the reasons Edelman Financial Services, LLC and EF Legacy Securities, LLC choose to share; and whether you can limit this sharing. Reasons we can share your personal information For our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus For our marketing purposes to offer our products and services to you Do Edelman Financial Services, LLC and EF Legacy Securities, LLC share? Yes Yes Can you limit this sharing? No No For joint marketing with other financial companies No We do not share For our affiliates everyday business purposes information about your transactions and experiences For our affiliates everyday business purposes information about your creditworthiness Yes No No We do not share For our affiliates to market to you No We do not share For nonaffiliates to market to you No We do not share Questions? Contact us through Edelmanfinancial.com or call us at or (804)