Luke Costa

OUR COMMITMENT TO YOU AS CFP® PROFESSIONALS As CERTIFIED FINANCIAL PLANNERSTM, our extensive training and financial planning experience will help to assess your current needs and develop a plan to achieve your financial goals. As CFP® professionals, we are held to strict ethical standards to ensure that any financial advice and financial planning recommendations we make are in your best interest. As part of our commitment to you as CFP® professionals, we will be transparent with you regarding material conflicts of interest as defined by the CFP Board, which simply put are business relationships or compensation structures that could influence our relationship with you if not properly managed and that a typical client would want to know about in making a decision (hereafter, “conflicts of interest” or “conflicts”). While most, if not all, financial services business structures contain conflicts of interest of one kind or another, all CFP® professionals must disclose these conflicts so that prospective clients can make an informed decision as to whom they turn to for financial planning and advice. We provide below a description of our relationship with The Northwestern Mutual Life Insurance Company (“NM”) and its relevant affiliates with respect to insurance products (collectively, “Northwestern Mutual”), a summary of our and Northwestern Mutual’s approach to managing conflicts of interest, an explanation of how we and Northwestern Mutual are compensated for sales of insurance products, and the conflicts of interest that arise because of the manner in which we are each compensated. The compensation arrangements and conflicts that we describe below are not necessarily unique to Northwestern Mutual—many of them are common in the marketplace for insurance products. For information regarding compensation and conflicts of interest relating to sales of investment products and advisory services, please see Northwestern Mutual Investment Services, LLC’s (“NMIS”) Client Relationship Summary and Guide to Brokerage Services and Northwestern Mutual Wealth Management Company’s Client Relationship Summary and its Investment Advisory Program Disclosure Brochures available at https://www.northwesternmutual.com/investing-disclosure/. For more information regarding what it means to be a CFP® professional and the standards that we are required to adhere to by the CFP Board, please visit www.cfp.net. Our Relationship with Northwestern Mutual with respect to Insurance Products As of December 31st, 2024, less than 5% of Alinity Wealth Management’s revenue was derived from insurance compensation. Yet, this is where most of the conflicts of interest are derived. Insurance products contain commissions which present an inherent conflict of interest for clients. However, for many of our clients, this conflict doesn’t even exist because they have no need for insurance therefore, we do not recommend they purchase any at all. However, to minimize the conflict of interest that insurance compensation creates, we review the best available options with as many insurance carriers as is reasonable to ensure we provide the best insurance choices for client recommendations. As part of that process, we do recommend, sell and service a variety of insurance products from Northwestern Mutual insurance products (e.g., life, annuities, disability income and/or long-term care, the latter through NM’s wholly-owned subsidiary Northwestern Long Term Care Insurance Company (“NLTC”)) but only when NM’s insurance is the best option for your family or business. Per our contract with Northwestern Mutual, we are obligated to primarily recommend, sell and service Northwestern Mutual insurance products. This obligation forms an obvious conflict of interest. However, we will only choose NM insurance when it is the best policy for you; often it is in your best interest to choose a policy from a different carrier. Here are many examples when a different carrier is a better option: • When Northwestern Mutual insurance is more expensive for the same benefit amount. • When Northwestern Mutual is unable to offer coverage; • When Northwestern Mutual’s underwriting criteria are materially unfavorable; • When Northwestern Mutual does not offer an insurance product or type of insurance product that meets your (or your business’s) needs or objectives; or • When a Northwestern Mutual insurance product that otherwise meets your (or your business’s) needs or objectives does not offer a unique product feature appropriate for your specific situation; • When Northwestern Mutual insurance product is not acceptable to you. We are also required to meet annual minimum insurance production requirements established by Northwestern Mutual, regardless of firm revenue or compensation provided to NM from investment management or financial planning fees. If we are not able to meet the insurance minimum of NM, we may be forced to terminate our contract with Northwestern Mutual to continue serving you in your financial and investment planning in the future. How I and Northwestern Mutual Manage Conflicts of Interest To develop life-long relationships with our clients and help ensure we provide financial advice or planning recommendations in their best interests, we engage in a discovery process using various tools to ensure we have a clear understanding of our clients’ needs and aspirations. In making recommendations to you to meet your needs and achieve your goals, we gather various relevant information about you, which can include your age, other investment or insurance holdings, financial situation and needs, tax status, financial objectives, financial experience, time horizon, liquidity needs, risk tolerance, and any other information that you may disclose to me. We use this information to match your needs, aspirations and attributes with the right product or service irrespective of the compensation that we will receive if you purchase those products or services. Lastly, we strive to maintain life-long relationships with our clients to help ensure they stay on track. The rigor of these processes supports our ability to make recommendations that are in your best interest notwithstanding our conflicts of interest. In addition, although Northwestern Mutual and its affiliates are not responsible for supervising us to ensure that we meet the standards set by the CFP Board, we are subject to written policies and procedures and supervisory systems established by NM and its affiliates that have been designed to ensure that insurance and investment products are appropriately sold by its financial representatives, irrespective of whether the representative is a CFP® professional. With respect to non-cash compensation, we do not receive any. There are regulations at both the state and federal level that impose certain limits on non-cash compensation with respect to insurance and investment products. We at Alinity Wealth Management do not receive “sales trips” or other non-cash incentive compensation from Northwestern Mutual. On rare occasions, we are invited to partially paid educational conferences which we qualify for since we are among the top 3% of wealth managers by investment revenue at Northwestern Mutual Wealth Management as of December 31, 2024. Compensation, Revenue and Related Conflicts Unless we are working with you in a fee-based arrangement for a specific scope of financial planning, we are compensated through various forms of commissions, fees, bonuses and benefits only when you “take action” by purchasing products and services. This is a conflict of interest because unless you purchase a product or service, we will not be compensated for the time we spend with you and the expertise that we provide to you. Below we describe the types of compensation we receive and Northwestern Mutual’s related revenue. Our Compensation for Northwestern Mutual Insurance Product Sales We are compensated by Northwestern Mutual for sales of its insurance products (including life insurance policies, annuity contracts, disability income policies and long-term care policies) through commissions, which are typically calculated as a percentage of the insurance premium/annuity considerations you pay. These commissions are typically paid in the form of first-year commissions (a percentage of the first-year premium/considerations paid by you), renewal commissions (a percentage of annual premiums paid in the second to tenth policy years by you and/or a percentage of contract fund value in the second to tenth policy year), persistency fees (a percentage of annual premiums paid in the eleventh policy year onward by you and/or a percentage of contract fund value in the eleventh policy year onward) and for variable annuities and some variable life policies (in lieu of renewal commissions and persistency fees) service fees (a percentage of considerations paid by you in the second contract year onward). Most of the commissions we receive upon the sale of a Northwestern Mutual policy or contract are paid in the first year. The rate of commissions we receive can vary by insurance product and other factors such as age of insured, health, et cetera. This transaction-based commission structure, which is a typical compensation structure in the insurance industry, is a conflict of interest because it rewards us for selling products to clients often and for selling insurance products that pay the highest rates of commission and that have relatively higher initial and ongoing premium payments associated with them. As described above, we take steps to manage this conflict (and similar conflicts) to ensure that our recommendations to you are aligned to your needs and in your best interest. We only recommend insurance when you absolutely need it and structure it to align with your need alone, regardless of compensation we receive. Finally, if we were to ever have meaningful Northwestern Mutual insurance sales (unlikely due to the very high level of insurance sales required), our compensation on investment products and advisory services increases. NM’s compensation structure incentivizes us to recommend and sell Northwestern Mutual insurance products to increase our investment compensation and is also a conflict of interest. If you have any questions regarding any aspect of the compensation and benefits, we receive in connection with the sale of Northwestern Mutual insurance products, or any other insurance carrier’s products, please ask us for more information. Revenue to Northwestern Mutual and its Affiliates As a manufacturer of insurance products, NM, and in some cases, its affiliates (e.g., Northwestern Mutual Series Fund, Inc., NM’s proprietary mutual fund) receive revenue on every NM insurance product we sell. Northwestern Mutual is therefore incented to ensure we sell primarily NM insurance products. Northwestern Mutual and its affiliates also receive revenue from certain third-party funds offered under its variable insurance products. For additional details on payments made to NM and its affiliates, you should review the prospectus for any NM variable product that you are purchasing, if applicable. We are happy to discuss further with you at your request any questions you may have about any information in this document. __________________________________________________ Life and disability insurance, annuities, and life insurance with long-term care benefits are issued by The Northwestern Mutual Life Insurance Company, Milwaukee WI (NM). Long-term care insurance is issued by Northwestern Long Term Care Insurance Company, Milwaukee, WI, a subsidiary of NM. Investment products are offered through Northwestern Mutual Investment Services, LLC, 1-866-664-7737, a dually registered broker-dealer and investment adviser and a wholly-owned company of NM, member FINRA and SIPC. NM Variable annuities and variable insurance are underwritten by NMIS. Fiduciary and fee-based planning services are offered through Northwestern Mutual Wealth Management Company, a limited purpose federal savings bank and a wholly owned company of NM. Investment products and trust services are not insured by the FDIC, and are not deposits or other obligations of, or guaranteed by NMWMC, NMIS or NM. All investments are subject to risk including the possible loss of principal invested.