Brookstone Capital Management LLC

• A percentage of assets under your management
• Hourly charges
• Fixed fees (other than subscription fees)

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

See the firm's brochure (dated March 11, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$12,750,129,748 as of October 2026, filing dated September 29, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Financial planning services
• Portfolio management for individuals and/or small businesses
• Selection of other advisers (including private fund managers)
• Educational seminars/workshops

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2007 (19 years)

Employees

Total: 405. Performing investment advisory functions: 320.

Wrap fee program participation

Yes.

Other offices (Schedule D, Section 1.F)

25 other offices, as of the October 2026 filing

Atlanta, GABartonsville, PABrentwood, TNBuffalo Grove, ILConcord, NHDurham, NCFairfax, VAFlower Mound, TXFort Wayne, INFrankfort, ILGrand Rapids, MIGray, TNHorsham, PAIndiana, PALas Vegas, NVMurfreesboro, TNNorthbrook, ILPalm Harbor, FLPittsburgh, PAShreveport, LASidney, OHSnellville, GASouthern Pines, NCWheaton, ILWorthington, OH

States registered or notice-filed

51 states or jurisdictions

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SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

3 Reports 3 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
• 11.D(4) In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.D(5) Has another federal regulator, a state regulator, or a foreign financial regulator ever denied, suspended, or revoked the registration or license of the firm or an advisory affiliate, prevented either by order from associating with an investment-related business, or restricted either one's activity?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $3,548,000,000 in the October 2021 data and $12,750,129,748 in the October 2026 data, up 259%.

Total employees: 350 in October 2021 and 405 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. October 2026
   • Updated its list of owners and control persons (Schedule A).
2. April 2026
   • Employees performing advisory functions went from 319 to 320.
   • Regulatory assets under management went from $10,409,137,908 to $12,750,129,748 (+22%).
   • Changed its office addresses in Brentwood, TN.
   • Changed its office addresses in Buffalo Grove, IL.
   • Changed its office addresses in Murfreesboro, TN.
   • Changed its office addresses in Pittsburgh, PA.
   • Changed its office addresses in Sidney, OH.
   • Added an office in Fairfax, VA.
   • Added an office in Flower Mound, TX.
   • Added an office in Fort Wayne, IN.
   • Added an office in Frankfort, IL.
   • Added an office in Gray, TN.
   • Added an office in Horsham, PA.
   • Added an office in Indiana, PA.
   • Added an office in Las Vegas, NV.
   • Added an office in Northbrook, IL.
   • Added an office in Palm Harbor, FL.
   • Added an office in Shreveport, LA.
   • Added an office in Southern Pines, NC.
   • Added an office in Wheaton, IL.
   • No longer lists an office in Castle Rock, CO.
   • No longer lists an office in Deerfield, IL.
   • No longer lists an office in Edwardsville, IL.
   • No longer lists an office in Englewood, CO.
   • No longer lists an office in Germantown, MD.
   • No longer lists an office in Kokomo, IN.
   • No longer lists an office in Lewisville, TX.
   • No longer lists an office in Maitland, FL.
   • No longer lists an office in Muskegon, MI.
   • No longer lists an office in Palos Park, IL.
   • No longer lists an office in Stevens Point, WI.
   • No longer lists an office in Westlake, OH.
   • No longer lists an office in Willow Grove, PA.

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.