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Item 2A Material Changes

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NCA Financial Planners Form CRS & ADV Part 2A

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Kevin Myeroff

Securities offered through Royal Alliance Associates, Inc. (RAA), Member FINRA/SIPC. RAA is separately owned and other entities and/or marketing names, products or services referenced here are independent of RAA. RAA does not provide tax or legal advice. Sequoia Financial Group is not affiliated with RAA.

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NCA Financial Planners - Awards 

1Barron’s “Top 100” Financial Advisors List, “Top 100 Independent Advisors” List and Barron’s “Top 1,200” Advisors by State

Source: Barron’s “Top 100 Financial Advisors in the U.S.”, April 17, 2020, “America’s Top 100 Independent Financial Advisors”, September 20, 2021 and Barron’s “America’s Top 1,200 Financial Advisors,” March 11, 2022 respectively. Barron’s is a registered trademark of Dow Jones & Company, L.P. All rights reserved. Barron’s “Top 100 Financial Advisors in the U.S.”, “America’s Top 100 Independent Financial Advisors” and “America’s Top 1,200 Financial Advisors” base their rankings upon data provided by individual advisers and their firms, including submissions by Financial Planners of Cleveland, Inc. dba NCA Financial Planners (“NCA”). Barron’s confirms that data via regulatory databases, cross-checks with securities firms and conversations with individual advisers. The rankings reflect “the volume of assets overseen by the advisors and their teams, revenues generated for the firms and the quality of the advisors’ practices.” The scoring system assigns a top score of 100 and rates the rest by comparing them with the winner. A ranking of “N” denotes “not ranked that year”. The formula Barron’s uses to rank advisers is proprietary. Its major components are: assets under management, revenue produced for the firm, regulatory record, quality of practice and philanthropic work. Investment performance isn’t an explicit component because not all advisors have audited results and because performance figures often are influenced more by clients’ risk tolerance than by an advisor’s investment-picking abilities. Neither NCA nor any other participating advisers paid a fee to be eligible for the “Top 100 Financial Advisors in the U.S.”, “America’s Top 100 Independent Financial Advisors” or “America’s Top 1,200 Financial Advisors” rankings. NCA is unaware of any undisclosed facts that could potentially invalidate the appropriateness of the rankings. By virtue of disclosing these rankings, NCA is disclosing favorable ratings (to the extent that NCA is ranked above other advisors) and unfavorable ratings (to the extent that NCA is ranked below other advisors). Barron’s does not publish, nor is NCA aware of the percentage of other advisers that received the applicable rankings. The rankings may not be representative of any one client’s experience because of the way in which it is calculated. The rankings are independently granted. The rankings are absolutely not indicative of NCA’s future performance, or any future performance pertaining to its clients’ investments. These rankings or any other rankings and/or recognition by unaffiliated rating services and/or publications should not be construed as a guarantee that a client will experience a certain level of results or satisfaction if NCA is engaged, nor should it be construed as a current or past endorsement by any of its clients. A copy of NCA’s current written disclosure statement discussing its advisory services and fees remains available upon request.

Additional information about Barron’s “Top 100 Financial Advisors in the U.S.” is available at the following link: https://www.barrons.com/articles/barrons-top-100-financial-advisors-in-the-u-s-51587167582 and the ranking list itself is available at the following link: https://www.barrons.com/report/top-financial-advisors/100/2020?mod=faranking_subnav

Additional information about Barron’s “America’s Top 100 Independent Financial Advisors” is available at the following link: ; https://www.barrons.com/advisor/articles/top-100-independent-advisors-top-100-ria-firms-51631641094? and the ranking list itself is available at the following link: https://www.barrons.com/advisor/report/top-financial-advisors/independen...

Additional information about Barron’s “America’s Top 1,200 Financial Advisors” is available at the following link: https://www.barrons.com/articles/top-1200-financial-advisors-america-516... the ranking list itself is available at the following link:  https://www.barrons.com/advisor/report/top-financial-advisors/1000. The methodology can be found here: https://www.barrons.com/articles/barrons-methodology-for-ranking-financi...

2Forbes Top 250 Wealth Advisors" and Forbes “Best-In-State Wealth Advisors”

“Forbes” is a registered mark of Forbes LLC. Data for the “Forbes Top 250 Wealth Advisors” list and the “Forbes Best-In-State Wealth Advisors” list are compiled by Forbes’ partners at “SHOOK™ Research, LLC.”, and are based on an algorithm of qualitative criteria, mostly gained through telephone and in- person due diligence interviews, and quantitative data. SHOOK scours the financial services industry— banks, brokerages, custodians, insurance companies, clearinghouses and others for nominations. SHOOK accepts advisors who meet pre-determined minimum thresholds and acceptable compliance records. SHOOK invites a limited number of nominees to complete an online survey. Basic Requirements for both the “Forbes Top 250 Wealth Advisors” list and the “Forbes Best-In-State Wealth Advisors” list include (1) 7 years as an advisor (2) Minimum 1 year at the current firm, with exceptions (acquisitions, etc.). (2) The advisor must be recommended, and nominated, by Firm. (3) Completion of an online survey. (4) Over 50% of revenue/production must be with individuals. (5) Acceptable compliance record.

Additional quantitative requirements are the following: (1) Revenue/production; weightings assigned for each. (2) Assets under management—and quality of those assets—both custodied and a scrutinized look at assets held away. (Although individual numbers are used for ranking purposes, we publish the entire team's assets.) (3) Client-related data, such as retention. (4) Portfolio performance is not a factor; audited returns among advisors are rare, and differing client objectives provide varying returns. Additional qualitative requirements are as follows: (1) Telephone and in-person meetings with advisors (if an in- person meeting cannot be accomplished, exceptions are considered in which the interview will occur after a ranking has been published). (2) Advisors that exhibit "best practices" within their practices and approach to working with clients. (only explicitly listed in 2017, 2018, 2019, 2020, 2021 and 2022 criteria) (3) Compliance records & u4s. Some “dings” can be overlooked (e.g., firm or product failure beyond the scope of an advisor's due diligence; the older a ding, the less we look). Since there are many gray areas, the SHOOK team is willing to listen to a Firm that is willing to stand behind the advisor with written support from leadership. (4) Advisors that provide a full client experience of service model, investing process, fee structure (higher % of fee-based assets earns more points), and breadth of services, including extensive use of Firm’s platform and resources (e.g., liabilities) (5) Credentials (years of service can serve as proxy). (6) Use of team & team dynamics (7) Community involvement (8) Discussions with management, peers, competing peers (9) Telephone and in-person meetings. When using compliance issues to categorize, the following conditions will be considered in order to lessen weightings infractions: (1) Infractions that are denied or closed with no action. (2) Complaint arose from a product, service or advice initiated by a previous advisor or another member or former member of team. (3) Length of time since complaint. (4) Complaints related to product failure not related to investment advice (some limited partnerships, adjusted-rate securities, etc.). (5) Complaints that have been settled (must be proven) to appease a client who remained with the advisor for at least one year following settlement date. (6) Complaints that are proven to be meritless. (7) Actions taken as a result of administrative error or failure by firm. Once an advisor's compliance rating falls into a tenable category, an advisor's rating must be among SHOOK's highest qualitative measures including in-person interview and must consider letters of recommendation from firm. The ranking algorithm is designed to fairly compare the business practices of a large group of advisors based on quantitative and qualitative elements. Data are weighted to ensure priorities are given to dynamics such as preferred “best practices”, business models, recent business activity, etc. Each variable is graded and represents a certain value for each measured component. These data are fed into an algorithm that measures thousands of advisors against each other. Neither NCA nor any other participating advisers paid a fee to be eligible for the “Forbes Top 250 Wealth Advisors” or the “Forbes Best-In-State Wealth Advisors” rankings. NCA is unaware of any undisclosed facts that could potentially invalidate the appropriateness of the rankings. By virtue of disclosing these rankings, NCA is disclosing favorable ratings (to the extent that NCA is ranked above other advisors) and unfavorable ratings (to the extent that NCA is ranked below other advisors). The rankings may not be representative of any one client’s experience because of the way in which they are calculated. The rankings are independently granted. The rankings are absolutely not indicative of NCA’s and its advisors’ future performance, or any future performance pertaining to its clients’ investments. These rankings or any other rankings and/or recognition by unaffiliated rating services and/or publications should not be construed as a guarantee that a client will experience a certain level of results or satisfaction if NCA is engaged, nor should it be construed as a current or past endorsement by any of its clients. A copy of NCA’s current written disclosure statement discussing its advisory services and fees remains available upon request. 

Additional information about the methodology behind the “2022 Forbes Best-In-State Wealth Advisors” methodology is available at the following link:  https://www.forbes.com/best-in-state-wealth-advisors/#252f940c291d and the ranking is available at the following link: https://www.forbes.com/sites/rjshook/2022/04/07/methodology-forbes-best-....

Additional information about the methodology behind the “2021 Forbes Top 250 Wealth Advisors” methodology is available at the following link: https://www.forbes.com/sites/rjshook/2021/08/24/methodology-americas-top... the ranking list itself is available at the following link: https://www.forbes.com/top-wealth-advisors/#50804b8d1a14

SHOOK is completely independent and objective and does not receive compensation from the advisors, Firms, the media, or any other source in exchange for placement on a ranking. SHOOK is funded through conferences, publications and research partners. Since every investor has unique needs, investors must carefully choose the right advisor for their own situation and perform their own due diligence. SHOOK’s research and rankings provide opinions for how to choose the right financial advisor and not indicative of future performance or representative of any one client’s experience. Portfolio performance is not a criteria due to varying client objectives and lack of audited data. Remember, past performance is not an indication of future results.  For more information, please see www.SHOOKresearch.com.

3Financial Times Top 400 and Financial Times Top 300 Registered RIAs

Research for the award was conducted on behalf of the Financial Times by Ignites Research, a Financial Times sister publication (collectively, “FT”). The FT contacts the largest US brokerages to ask for practice information and data for their top advisers across the US. In doing so, they can obtain verified data on assets under management instead of relying on self-reporting by the advisers themselves. They asked for information on advisers with more than 10 years’ experience and that have more than $300m in assets under management. Such minimum criteria filters out most advisers. The FT then invite qualifying advisers out of this group to complete a short questionnaire that gives more information about their practices. They combine that information to their own research on the candidates, including data from regulatory filings. The formula the FT uses to grade advisers is based on six broad factors and calculates a numeric score for each adviser (1) Assets under management: can signal experience managing money and client trust (2) AUM growth rate (looking at one-year, two-year, or three-year growth rates as specified below): can be taken as a proxy for performance, asset retention and ability to generate new business. (3) Years of experience: indicates experience managing assets in different economic and interest-rate environments. (4) Compliance record: provides evidence of past client disputes. A string of complaints could signal problems. (5) Industry certifications (CFA, CFP, etc.): demonstrate technical and industry knowledge and obtaining these designations shows a professional commitment to investment skills. (6) Online accessibility: illustrates commitment to providing investors with easy access and transparent contact information. Assets under management accounted for an average of 72% of each adviser’s score. Additionally, the FT places a cap on the number of advisers from any one state that roughly corresponds to the distribution of millionaires across the US. The FT 400 and FT 300 is presented as an elite group, not a competitive ranking. FT acknowledges that ranking the industry’s top advisers from 1 to 400/300 would be a futile exercise, since each takes different approaches to their practice and has different specializations. The following are the subtle changes to the above criteria to the Financial Times Top 400 Financial Advisers across the 2013 to 2020 span:

 

In 2019, the period analyzed for the latest 300 list, data was collated in April and May.

Neither NCA nor any other participating advisers paid a fee to be eligible for the Financial Times Top 400 or Financial Times Top 300 ranking. NCA is unaware of any undisclosed facts that could potentially invalidate the appropriateness of the ranking. By virtue of disclosing this ranking, NCA is disclosing favorable ratings (to the extent that NCA is ranked above other advisors) and unfavorable ratings (to the extent that NCA is ranked below other advisors). The ranking may not be representative of any one client’s experience because of the way in which it is calculated. The ranking is independently granted. The ranking is absolutely not indicative of NCA’s and its advisors’ future performance, or any future performance pertaining to its clients’ investments. This ranking or any other rankings and/or recognition by unaffiliated rating services and/or publications should not be construed as a guarantee that a client will experience a certain level of results or satisfaction if NCA is engaged, nor should it be construed as a current or past endorsement by any of its clients.  A copy of NCA’s current written disclosure statement discussing its advisory services and fees remains available upon request. Additional information about the methodology behind the Financial Times Top 400 ranking and the ranking list itself is available at the following link: https://www.ft.com/content/bad0ff38-5605-11e9-a3db-1fe89bedc16e  Addit... information about the methodology behind the Financial Times Top 300 RIAs ranking and the ranking list itself is available at the following link: https://www.ft.com/content/6a45556e-6c21-4770-bc94-468fee0de563

4InvestmentNews Best Places to Work For Financial Advisers

With to respect to InvestmentNews’ “Best Places to Work for Financial Advisers” award, NCA provides the following information to the best of its knowledge: Source: InvestmentNews’ “Best Places to Work for Financial Advisers,” March 2018 and March 2019. InvestmentNews is a multi-media news outlet that provides news, analysis, and information directed towards the financial advisory community through its publication of a weekly newspaper, website, newsletters, research, events, videos, and webcasts. InvestmentNews is part of Bonhill Group (Formerly part of Crain Communications, Inc. In connection to the “Best Places to Work for Financial Advisers” award, InvestmentNews has partnered with Best Companies Group (“BCG”) to research and evaluate nominees on InvestmentNews’ behalf. BCG is a division of Bridge Tower Media (a multi-title publishing and events company) that identifies and recognizes best employers at the city, state, regional and industry level. NCA is not affiliated with InvestmentNews, Crain Communications, Inc., Bonhill Group, BCG, or BridgeTower Media. NCA’s receipt of this award should not be viewed as an endorsement of NCA by any of these unaffiliated entities. To be eligible for consideration, companies must be a registered investment adviser (RIA), affiliated with an independent broker-dealer (BD), or a hybrid doing business through an RIA, be in the business for a minimum of one year and have a firm-wide minimum of 15 full-time/part-time employees based in the U.S. (across all divisions and departments). The assessment process is a two-part process designed to gather detailed data about each participating company. In part one, the employer completes an employer questionnaire detailing information about the company’s policies, practices, benefits, and demographics. Part two of the assessment process requires that a certain number of employees from each nominated company complete an “Employee Engagement & Satisfaction Survey” consisting of approximately 78 statements that employees respond to on a 1 to 5 point Likert scale of agreement ranging from “Strongly Disagree” to “Strongly Agree.” In addition to these statements, the employee survey also includes 2 open ended questions and 7 demographic questions. Each company’s employees are surveyed at random. The total number of employees surveyed from each company is contingent upon the respective company’s size in accordance with the following criterion: For 2018(i) companies with 15-99 will have all employees surveyed, (ii) companies with 100-199 employees will have no more than 250 employees surveyed; (iii) companies with 200-499 employees will have no more than 350 employees surveyed, (iv) companies with 500-2499 employees will have no more than 400 surveyed; (v) companies with 2,500 or more employees will have no more than 350 employees surveyed. To ensure the credibility of the information, companies with 15-24 employees must have an 80% or better response rate to be considered for the list. For 2019: (i) companies with 15-250 employees will have all employees surveyed, (ii) Companies with 251-499 employees will have 250 employees surveyed, (iii) companies with 500-2,499 employees will have 350 employees surveyed (iv) companies with 2,500 or more employees will have 400 employees surveyed. In 2018, the results of the employee surveys are analyzed and categorized according to 9 Core Focus Areas: Leadership and Planning, Corporate Culture and Communications, Role Satisfaction, Work Environment, Relationship with Supervisor, Training, Development and Resources, Pay and Benefits and Overall Engagement. In 2019, the results are categorized into 5 Core Focus Areas: Leadership, Corporate Communications, Training and Development, Pay and Benefits and Overall Engagement. Each company is ranked based on this data. For quality control, BCG will conduct random quality checks. If BCG selects your company for a quality check, the survey coordinator will receive a written request for information upon program completion. After this two-part process is completed, the two respective data sets derived from this process are combined and analyzed to determine the rankings. As of 2018 60 out of the 100-plus firms that applied for consideration met the award designation’s qualifying criterion. Subsequently, 50 companies were ultimately selected to receive the award designation. Out of these 50 companies, NCA was selected to be recognized on the 2018 “Best Places to Work for Financial Advisers” ranking. As of 2019, 75 out of more than 100 firms that applied were ultimately selected to receive the award designation. InvestmentNews does not require membership or payment to be considered for the award. Neither NCA, nor any other participating advisers, paid a fee to be considered for the Investment News’ “Best Places to Work for Financial Advisers” ranking. NCA applied for consideration, and the result was independently granted. NCA is unaware of any undisclosed facts that could potentially invalidate the appropriateness of the ranking. By virtue of disclosing this ranking, NCA is disclosing favorable ratings (to the extent that NCA is ranked above other advisors) and unfavorable ratings (to the extent that NCA is ranked below other advisors). This ranking or any other rankings and/or recognition by unaffiliated rating services and/or publications should not be construed as a guarantee that a client will experience a certain level of results or satisfaction if NCA is engaged, nor is the ranking indicative of NCA’s and its advisors’ future performance, or any future performance pertaining to its clients’ investments. A copy of NCA’s current written disclosure statement discussing its advisory services and fees remains available upon request. Additional information about the assessment process behind the Investment News Best Places to Work for Financial Advisers ranking is available at the following link: https://www.inbestplacestowork.com/images/PDFs/FA-handout-19.pdf The ranking list is available at the following link: https://www.investmentnews.com/section/best-places-to-work-for-financial...

5Crain’s 2021 Notable Wealth Managers

The following is with respect to Kevin Myeroff and Les Globits from NCA Financial Planners (“NCA”) being named to “Crain’s 2021 Notable Wealth Managers for 2021,” (the “Crain’s 2021 List”) which NCA is providing to the best of its knowledge: Crain's Cleveland Business is a print and online newspaper delivering local business news and information to Cleveland's business executives, which is published by Crain Communications Inc. NCA is not affiliated with Crain Communications Inc. Candidate profiles were drawn from the nomination materials submitted by third parties, and the ultimate list presented does not reflect all nominees. Crain’s 2021 List only includes those individuals for whom nominations were submitted and accepted after editor review. To qualify for Crain’s 2021 List, nominees must be: based in Northeast Ohio; currently employed full time at a financial institution or company offering wealth management services; showcase professional achievements; have a minimum of three years’ experience; oversee at least $10 million in assets under advisement; and demonstrate activity in the community and/or philanthropic activities, mentoring programs and/or diversity and inclusion initiatives. The Crain’s 2021 List may employed have different methodology than described above for similar designations granted in other years.  Kevin Myeroff and Les Globits were nominated for consideration, and the result was independently granted. Crain’s 2021 List was originally published on November 8, 2021. NCA is not aware of the number of nominees, or the percentage of nominees that were ultimately published to Crain’s 2021 List. However, based on its representations, NCA believes that the methodology used to evaluate inclusion on Crain’s 2021 List is quantifiable and objective, and that participating candidates do not appear to have subjective input in the analysis. Crain’s 2021 List does not appear to include candidates on the Crain’s 2021 List if the ratings are not statistically valid with respect to any candidate; and NCA is not aware of any facts that would call into question the validity of the inclusion on the Crain’s 2021 List or the appropriateness of NCA’s advertising its inclusion. NCA has reviewed the surveys used in the preparation of these ratings and has determined that they are structured to make it equally easy for a participant to provide favorable and unfavorable responses, and they are not designed or prepared to produce any predetermined result. Neither the participating candidates nor their employees pay a fee in exchange for inclusion on Crain’s 2021 List. However, NCA or its representatives may pay a fee to Crain, an affiliate, or an unaffiliated third party in exchange for plaques or article reprints commemorating the designation. While NCA or its representatives would pay this fee after receiving the designation and not as a condition precedent to receiving it, the fact that any fee is paid with respect to receipt of the designation should be considered if the designation is a factor in a current or prospective client’s evaluation of whether to initially engage or continue to engage NCA for advisory services. This publication may not be representative of any one client’s experience because of the way in which it is calculated. The publication does not guarantee NCA’s and its advisors’ future performance, or any future performance pertaining to its clients’ investments. The publication should not be construed by a client or prospective client as a guarantee that they will experience a certain level of results if NCA is engaged, or continues to be engaged, to provide investment advisory services; and should not be construed as a current or past endorsement of NCA by any of its clients. 

METHODOLOGY: The honorees do not pay to be included. Their profiles were drawn from the nomination materials submitted. This list is not comprehensive. It includes only individuals for whom nominations were submitted and accepted after a review by editors. To qualify for the list, nominees must be based in Northeast Ohio. They must be currently employed full time at a financial institution or company offering wealth management services and showcase professional achievements. They must have a minimum of three years’ experience and oversee at least $10 million in assets under advisement. They must be active in the community and/or philanthropic activities, mentoring programs and/or diversity and inclusion initiatives. Article link: https://www.crainscleveland.com/awards/crains-2021-notable-wealth-manage... Link to Kevin Myeroff: https://www.crainscleveland.com/awards/kevin-myeroff-notable-wealth-mana... Link to Les Globits: https://www.crainscleveland.com/awards/les-globits-notable-wealth-manage...

 

Please Note: Limitations: Neither rankings and/or recognition by unaffiliated rating services, publications, media, or other organizations, should be construed by a client or prospective client as a guarantee that he/she will experience a certain level of results if NCA is engaged, or continues to be engaged, to provide investment advisory services. Rankings published by magazines, and others, generally base their selections exclusively on information prepared and/or submitted by the recognized adviser. Rankings are generally limited to participating advisers. No ranking or recognition should be construed as a current or past endorsement of NCA by any of its clients. NCA Financial Planners did not pay to be eligible for or participate in any of these listed recognitions or awards.

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