Overview

Assets Under Management: $782 million
Headquarters: CLAYTON, MO
High-Net-Worth Clients: 64
Average Client Assets: $6 million

Services Offered

Services: Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Clients

Number of High-Net-Worth Clients: 64
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 45.85
Average High-Net-Worth Client Assets: $6 million
Total Client Accounts: 21
Discretionary Accounts: 13
Non-Discretionary Accounts: 8

Regulatory Filings

CRD Number: 107574
Last Filing Date: 2024-03-29 00:00:00
Website: https://acgnet.com

Form ADV Documents

Additional Brochure: ASSET CONSULTING GROUP, LLC (2025-07-14)

View Document Text
Item 1 - Cover Page Asset Consulting Group, LLC 231 S. Bemiston Ave., Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 World Wide Web Address: www.acgnet.com July 14, 2025 This brochure provides information about the qualifications and business practices of Asset Consulting Group, LLC (“ACG”). If you have any questions about the contents of this brochure, please contact us at 314-862- 4848 or jason.pulos@acgnet.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional Information about Asset Consulting Group, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2 - Material Changes This brochure, revised as of July 14, 2025, contains the following material change from the prior version, dated March 28, 2025. Item 15 – Custody: The description has been updated to reflect that ACG may be deemed to have custody of client assets under SEC rules. ACG does not physically hold assets or take custody directly. Clients continue to receive regular statements from their qualified custodians and should carefully review them. Currently, our brochure may be requested by contacting Jason Pulos, Chief Compliance Officer at jason.pulos@acgnet.com. Additional Information about Asset Consulting Group, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Item 3 - Table of Contents ITEM 4 - ADVISORY BUSINESS ....................................................................................................................................... 4 ITEM 5 - FEES AND COMPENSATION ............................................................................................................................ 5 ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................. 6 ITEM 7 - TYPES OF CLIENTS............................................................................................................................................ 6 ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................................................... 6 ITEM 9 - DISCIPLINARY INFORMATION ........................................................................................................................ 6 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ..................................................................... 6 ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING .. 7 ITEM 12 - BROKERAGE PRACTICES ............................................................................................................................... 7 ITEM 13 - REVIEW OF ACCOUNTS ................................................................................................................................ 7 ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ....................................................................................... 8 ITEM 15 - CUSTODY ....................................................................................................................................................... 8 ITEM 16 - INVESTMENT DISCRETION ............................................................................................................................. 8 ITEM 17 - VOTING CLIENT SECURITIES .......................................................................................................................... 8 ITEM 18 - FINANCIAL INFORMATION ........................................................................................................................... 8 3 Item 4 - Advisory Business A. Description of Firm Asset Consulting Group, LLC, a Delaware limited liability company, is a wholly-owned subsidiary of GWM Holdco, LLC. GWM Holdco, LLC is controlled by its managing member, Guggenheim Manager, Inc. Guggenheim Manager, Inc. is a wholly-owned subsidiary of Guggenheim Capital, LLC. GWM Holdco, LLC is a majority-owned subsidiary of Guggenheim Partners, LLC. Guggenheim Partners, LLC is a wholly- owned subsidiary of Guggenheim Capital, LLC. ACG provides general consulting services to taxable and tax-exempt investors such as trusts, endowments, foundations and other non-profit corporations, insurance company reserves, and corporate, public, Taft-Hartley employee benefit plans and high net worth individuals and family offices. In addition, ACG also provides outsourced research services to 3rd Party intermediaries and other advisers. ACG has provided investment consulting and investment research services since 1989. B. Description of Services General Consulting Services • Creation/Review of Investment Policies and Objectives: Assisting the client in defining appropriate investment objectives and investment policies by which to achieve those objectives based upon that client’s unique situation. • Asset Allocation and Review: Assisting the client in allocating its assets in a strategic manner among different investment vehicles, such as common stocks, debt instruments, foreign securities, temporary cash and alternative investments, so as to achieve the stated investment objectives. • Investment Manager Due Diligence and Monitoring: Assisting the client in evaluating and monitoring investment managers appropriate to make specific security level investments for the client’s portfolio in accordance with the objectives of the client. • Performance Measurement and Evaluation: Providing the client with customized quarterly written performance reports, which measure, compare and evaluate the investment managers selected by the client. We can also prepare other customized written reports based on client needs. All reports are part of fee-based rather than subscription-based services and are specifically designed for that client’s reporting needs. • Efficiency Reports: Assisting the client with regular review of investment manager and custodian fees and providing guidance for a systematic funding of investment managers from cash inflows. • Best Practices Reviews: From time to time we are engaged to perform an assessment of a client’s processes, systems and resources for the purpose of providing perspective with regard to potential improvements. • Financial Modeling: We have developed a proprietary tool for analyzing the effect of various asset allocation strategies. While we do not provide forecasting services, we can use this tool with client provided data to assist in developing various financial analyses. This tool is utilized when clients request that the structure of their related investment portfolio be stress-tested along with an integration of the client provided underlying forecasted business results. 4 C. Customization ACG tailors its advisory services to the individual needs of each client. ACG provides advice on asset allocation, portfolio structuring and manager or fund selection that is customized for each client based on each client’s unique tolerance for risk, legal or regulatory requirements, nature of liabilities and other unique circumstances of each client. ACG acts primarily as an Investment Consultant rather than as a conventional investment advisor or “money manager.” As an Investment Consultant, ACG generally does not have discretion over client assets, however ACG does have 14 client relationships as of 4/30/2025 with clients who have granted ACG authority to select, retain, and terminate investment managers and/or pooled investment vehicles and to allocate assets among them subject to written guidelines provided by the client. These 14 discretionary relationships represented $589.5 million in client assets as of 4/30/2025. In addition ACG has 8 clients that have granted ACG authority to arrange and effect the purchase or sale of mutual funds at Client’s custodian upon Client’s direction, representing approximately $192.2 million in client assets. As of 12/31/2024 ACG had 133 client relationships where we served exclusively as a traditional Investment Consultant. In these relationships ACG provides its Client with alternatives and various courses of action; however, all decisions regarding the investment of Client’s assets, including the establishment of an investment policy and the selection and retention of investment managers and the arranging and effecting of the purchase or sale of investments remain with Client. As of 12/31/2024 these 133 traditional consulting relationships include clients whose assets were valued at approximately $199.4 Billion. Item 5 - Fees and Compensation A. Description of Fees ACG charges retainer fees that are based on estimates of time, complexity and scope of services to be provided, necessity and frequency of travel and personal meetings, asset size and number of client portfolios being evaluated. Retainer fees may increase as a result of the types of assets included in client portfolios, the number of portfolios being analyzed, their complexity, and estimates of extraordinary time requirements for client servicing. Retainer fees may be structured as a percentage of assets under consultation or on a fixed fee basis. Fees are negotiable. ACG may also be employed on a project basis. Fees for specialized consulting projects, or any singular above-described service, such as asset allocation or investment manager searches, are based upon estimates of time, project complexity, necessity and frequency of travel and personal meetings. B. Method of Billing ACG bills clients directly for services rendered. Fees are billed quarterly in arrears. However, project basis fees are billed after services have been provided. ACG’s services may be terminated by either party upon thirty (30) days written notice. Fees for the quarter in which termination of service occurs will be prorated from the date of termination. C. Other Fees and Expenses ACG’s retainer fee only covers the cost of our consulting services. Each client will bear all of its own investment expenses, both as incurred directly and indirectly through investing in funds or with investment managers, including interest, custody and brokerage fees and the fees, expenses and profit participations of custodian, investment managers, investment funds and any other service providers that the client may utilize. 100% of ACG’s revenues are earned from investment consulting fees and paid directly by the client to ACG. Neither ACG nor any of its employees derive any revenue or receive any compensation as a result of arrangements with investment managers, investment funds or broker-dealers. 5 Item 6 - Performance-Based Fees and Side-by-Side Management On a limited basis, in accordance with the exceptions to the prohibition on performance based fees contained in Section 205(b) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and Rule 205-3 under the Advisers Act, Clients will pay ACG an incentive fee that is tied to the performance of the portfolio relative to a predefined benchmark. Item 7 - Types of Clients ACG provides general consulting services to taxable and tax-exempt investors such as trusts, endowments, foundations and other non-profit corporations, insurance company reserves, and corporate, public, Taft- Hartley employee benefit plans, high net worth individuals, single and multi-family offices and other advisors. Our Clients range in size from approximately $50 million to several billion dollars, with the average client having investable assets in the $500 million to $600 million range. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ACG provides clients with a structured and disciplined investment program diversified across multiple asset classes and multiple investment managers. ACG utilizes a multi-manager approach to meet the investment goals and objectives of each client. Portfolios are constructed with a focus on the style and approach of investment managers as well as correlations between managers and security and sector concentrations. ACG performs both qualitative and quantitative analyses in evaluating investment strategies, investment managers and investment vehicles. Qualitative analysis includes, among other things, review and assessment of a portfolio manager’s investment process, sources of investment ideas, research methodology, valuation methodology, risk management techniques, method of operation, background, integrity, talent, dedication, assets under management, personal investment, organization and staff, and liquidity. Quantitative analysis includes, among other things, assessment and review of rates of return, standard deviation of return, Sharpe Ratio, correlation with various market indices and with other portfolio managers, performance compared to other portfolio managers employing the same strategy, worst loss period and fees. Investment managers recommended by ACG and selected by clients will employ investment strategies that have inherent risk. Client's assets managed by one or more investment managers may be lost in whole or in part and past results are not necessarily indicative of future performance. The value of client’s assets may go down as well as up, and will be subject to various market, economic or business risks, as well as the risk that the investment recommendations and decisions made may not always be profitable or prove to have been wise. ACG does not guarantee (i) that client's assets will not decline in value, (ii) any specific level of performance of client's assets or any specific investment manager or investment, (iii) the success of any investment strategy employed or investment decision made by investment managers or (iv) the success of the overall portfolio of client’s assets. Item 9 - Disciplinary Information Neither ACG nor any employees of the firm have any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of ACG’s advisory business or the integrity of ACG’s management. Item 10 - Other Financial Industry Activities and Affiliations A. If you or any of your management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer, disclose this fact. Neither ACG nor any management person are registered or have an application pending as a broker- dealer or registered representative of a broker-dealer. 6 B. If you or any of your management persons are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities, disclose this fact. Neither ACG nor any management person are registered or have an application pending as a futures commission merchant, commodity pool operator, commodity trading advisor or an associated person of any of the foregoing entities. C. Related Entity Services ACG has related entities that include other SEC registered investment advisors. However, ACG does not recommend or refer clients to any affiliated entities, with the limited exception of the occurrence that a Client of ACG specifically requests that an affiliated entity be included as a candidate for evaluation. In the event that a client of ACG requests ACG to include an affiliated entity as a candidate for evaluation, ACG would have a conflict between its obligation to act in the best interests of its clients and any interest that ACG’s affiliates may have in generating revenue for themselves or promoting themselves. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ACG has adopted a Code of Ethics (“Code of Ethics”) pursuant to the Advisors Act Rule 204A-1. The Code of Ethics applies to all employees and is designed to address conflicts of interest arising among ACG, its employees and client transactions that may arise during the course of business. It is also designed to detect and prevent the misuse of material, nonpublic information. The Code of Ethics is based upon the principle that ACG’s employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid: (i) serving their own personal interests ahead of clients: (ii) taking inappropriate advantage of their position with ACG; and (iii) any actual or potential conflicts of interest or any abuse of the position of responsibility. The Code of Ethics establishes policies and procedures that are reasonably designed to (a) prevent improper trading, (b) identify circumstances that may result in an actual or potential conflict of interest or the appearance thereof, and each employee of ACG must receive pre-approval from the Chief Compliance Officer or the Deputy Chief Compliance Officer. ACG does not provide investment advice or recommendations regarding the purchase or sale of publicly tradable securities. Related persons may invest with managers, mutual funds or other pooled private investment funds, which the firm may also recommend to clients. ACG is required to collect and maintain certain records of securities holdings and securities transactions effected on behalf of its employees. These records are reviewed to identify and resolve any potential conflicts of interest that may arise from employee trading activity. A copy of ACG’s Code of Ethics is available upon request from Jason Pulos at 314-862-4848. Item 12 - Brokerage Practices ACG is not a broker-dealer, ACG does not have any soft-dollar arrangements to utilize research, research- related products or services or any other services obtained from broker-dealers, or third parties, on a soft dollar commission basis. Further, ACG does not charge investment managers to be in our database nor does ACG receive any selling compensation from any third parties. 100% of our revenues are derived from providing objective investment consulting advice to our clients. Any transactions that we direct on behalf of a discretionary client are executed by the client’s independent custodian. Item 13 - Review of Accounts On a monthly basis, ACG reviews the performance of each client’s assets as a whole and each investment manager retained by clients individually. If appropriate, based on qualitative and quantitative analysis ACG may recommend replacement of an existing investment manager, and/or allocation of client’s assets among other portfolio managers. Such reviews are performed by the individual consultant assigned the 7 primary responsibility for the particular client. ACG reports to clients, in a format reasonably requested by each client, the performance of client’s assets no less frequently than quarterly. Reporting is completed at the portfolio level, the asset class level and the manager level. Item 14 - Client Referrals and Other Compensation ACG does not pay referral fees. Item 15 - Custody Each client is responsible for the selection of its own custodial institution. ACG does not physically hold client funds or securities. As required by SEC rules, clients with funds or securities over which ACG is deemed to have custody will receive at least quarterly statements directly from their qualified custodians. ACG urges clients to carefully review and compare the custodian statements with statements or reports ACG may provide. ACG’s statements or reports may vary from custodial statements based on methodologies of certain securities and should not be relied upon by the client for audit and valuation confirmation. For the accounts which ACG is deemed to have custody, ACG is required to obtain an annual surprise custody examination of the assets. Item 16 - Investment Discretion Clients may grant ACG authority or discretion to select, retain and terminate investment managers and/or pooled investment vehicles and allocate assets among them subject to written guidelines provided by the client. Client’s grant ACG authority or discretion by executing a discretionary investment advisory agreement. As such ACG may be deemed to provide portfolio management or supervisory services or have discretionary authority to determine securities to be bought or sold or the amount of securities to be bought or sold for a client’s account as the definition of securities includes mutual funds and other private investment funds, even though in all cases it is the fund manager or advisor that determines which securities are bought and sold within the underlying funds. Item 17 - Voting Client Securities ACG does not exercise proxy voting authority over client accounts. Item 18 - Financial Information ACG does not require or solicit prepayment of fees. All client fees are billed and payable quarterly in arrears. As a registered investment adviser, ACG is required in this Item to provide you with certain financial information or disclosures about its financial condition. ACG has no financial condition that impairs its ability to meet contractual and fiduciary commitments to clients, and ACG has not been the subject of a bankruptcy proceeding. 8 Asset Consulting Group, LLC 231 S. Bemiston Ave., Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 World Wide Web Address: www.acgnet.com Part 2B of Form ADV: Brochure Supplement This brochure provides information about the qualifications and business practices of Asset Consulting Group, LLC (“ACG”). If you have any questions about the contents of this brochure, please contact us at 314-862- 4848 or jason.pulos@acgnet.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional Information about Asset Consulting Group, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. 9 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Mitchell H. Boraz, Managing Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Mitchell H. Boraz that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Mitchell H. Boraz is available on the SEC’s website at www.adviserinfo.sec.gov. 10 Item 2 - Educational Background and Business Experience Name: Mitchell H. Boraz Title: Managing Director Year of Birth: 1957 Education: University of Missouri-St. Louis B.S. Accounting – 1979 Professional Designations: Certified Investment Management Analyst* Business Background: Asset Consulting Group, LLC 3/02 – Present *The Certified Investment Management Analyst (CIMA) certification signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. Prerequisites for the CIMA certification are three years of financial services experience and an acceptable regulatory history. To obtain the CIMA certification, candidates must pass an online Qualification Examination, successfully complete a one-week classroom education program provided by a Registered Education Provider at an AACSB accredited university business school and pass an online Certification Examination. CIMA designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). Item 3 - Disciplinary Information Mr. Boraz has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Boraz is not actively engaged in any other invested related business or occupation. Mr. Boraz is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Boraz is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Boraz does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 11 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 12 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Elizabeth A. Bowen, Vice President Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Elizabeth A. Bowen that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. information about Elizabeth A. Bowen is available on the SEC’s website at Additional www.adviserinfo.sec.gov. 13 Item 2 - Educational Background and Business Experience Name: Elizabeth Bowen Title: Vice President Year of Birth: 1974 Education: Truman State University B.A. Finance – 1995 Webster University M.B.A. Finance – 2001 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 3/16 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Ms. Bowen has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Ms. Bowen is not actively engaged in any other invested related business or occupation. Ms. Bowen is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Ms. Bowen is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Ms. Bowen does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 14 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 15 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Nathan R. Burk, Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Nathan R. Burk that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Nathan R. Burk is available on the SEC’s website at www.adviserinfo.sec.gov. 16 Item 2 - Educational Background and Business Experience Name: Nathan R. Burk Title: Director Year of Birth: 1978 Education: University of Missouri B.S. Finance and Real Estate – 2000 University of Missouri St. Louis M.B.A. – 2005 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC, 07/14 – Present Wells Fargo Securities, Equity Analyst 03/07-06/14 *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Burk has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Burk is not actively engaged in any other invested related business or occupation. Mr. Burk is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Burk is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Burk does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 18 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Craig M. Coleman, II, Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Craig M. Coleman, II that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. information about Craig M. Coleman, II is available on the SEC’s website at Additional www.adviserinfo.sec.gov. 19 Item 2 - Educational Background and Business Experience Name: Craig M. Coleman, II Title: Director Year of Birth: 1981 Education: Southeast Missouri State University B.S. Finance – 2002 Professional Designations: Certified Investment Management Analyst* Business Background: Asset Consulting Group, LLC 7/21 – Present *The Certified Investment Management Analyst (CIMA) certification signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. Prerequisites for the CIMA certification are three years of financial services experience and an acceptable regulatory history. To obtain the CIMA certification, candidates must pass an online Qualification Examination, successfully complete a one-week classroom education program provided by a Registered Education Provider at an AACSB accredited university business school and pass an online Certification Examination. CIMA designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). Item 3 - Disciplinary Information Mr. Coleman has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Coleman is not actively engaged in any other invested related business or occupation. Mr. Coleman is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Coleman is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Coleman does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 20 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 21 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Daniel E. Flynn, Consultant Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Daniel E. Flynn that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Daniel E. Flynn is available on the SEC’s website at www.adviserinfo.sec.gov. 22 Item 2 - Educational Background and Business Experience Name: Daniel E. Flynn Title: Consultant Year of Birth: 1987 Education: University of Missouri B.S. Finance and Real Estate– 2009 M.B.A. – 2011 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC, 11/14 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Flynn has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Flynn is not actively engaged in any other invested related business or occupation. Mr. Flynn is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Flynn is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Flynn does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 23 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 24 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Michael P. Hotz, Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Michael P. Hotz that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Michael P. Hotz is available on the SEC’s website at www.adviserinfo.sec.gov. 25 Item 2 - Educational Background and Business Experience Name: Michael P. Hotz Title: Director Year of Birth: 1983 Education: Indiana University B.S. Accounting – 2006 Indiana University M.B.A. Finance – 2006 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 12/10 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Hotz has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Hotz is not actively engaged in any other invested related business or occupation. Mr. Hotz is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Hotz is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Hotz does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 26 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 27 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Thomas J. Janisch, Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Thomas J. Janisch that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Thomas J. Janisch is available on the SEC’s website at www.adviserinfo.sec.gov. 28 Item 2 - Educational Background and Business Experience Name: Thomas J. Janisch Title: Director Year of Birth: 1962 Education: Washington University M.B.A – 1987 St. Louis University B.A. American Studies – 1984 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 8/01 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Janisch has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Janisch is not actively engaged in any other invested related business or occupation. Mr. Janisch is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Janisch is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Janisch does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 29 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 30 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Patricia J. Karolczak, Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Patricia J. Karolczak that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Patricia J. Karolczak is available on the SEC’s website at www.adviserinfo.sec.gov. 31 Item 2 - Educational Background and Business Experience Name: Patricia J. Karolczak Title: Director Year of Birth: 1974 Education: University of Missouri-St. Louis B.S. Business and Administration - 1997 Business Background: Asset Consulting Group, LLC October 1997 – Present Item 3 - Disciplinary Information Ms. Karolczak has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Ms. Karolczak is not actively engaged in any other invested related business or occupation. Ms. Karolczak is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Ms. Karolczak is not actively engaged in any other non-investment related business activities. Ms. Karolczak is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA Item 5 - Additional Compensation Ms. Karolczak does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 32 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 33 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Christopher A. Lowry, Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Christopher A. Lowry that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. information about Christopher A. Lowry is available on the SEC’s website at Additional www.adviserinfo.sec.gov. 34 Item 2 - Educational Background and Business Experience Name: Christopher A. Lowry Title: Director Year of Birth: 1965 Education: University of Colorado M.S. Finance – 1995 Georgetown University B.S. Business Administration – 1988 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 01/06 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Lowry has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Lowry is not actively engaged in any other invested related business or occupation. Mr. Lowry is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Lowry is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Lowry does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 35 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 36 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page William K. Melvin, Portfolio Analyst Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about William K. Melvin that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about William K. Melvin is available on the SEC’s website at www.adviserinfo.sec.gov. 37 Item 2 - Educational Background and Business Experience Name: William K. Melvin Title: Portfolio Analyst Year of Birth: 1993 Education: University of Missouri B.S. Finance and Banking – 2015 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC, 06/2015 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Melvin has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Melvin is not actively engaged in any other invested related business or occupation. Mr. Melvin is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Melvin is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Melvin does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 38 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 39 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Donald J. Mueth, Managing Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Donald J. Mueth that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Donald J. Mueth is available on the SEC’s website at www.adviserinfo.sec.gov. 40 Item 2 - Educational Background and Business Experience Name: Donald J. Mueth Title: Managing Director Year of Birth: 1962 Education: University of Missouri – St. Louis B.S. Business Administration – 1984 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 2/01 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Mueth has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Mueth is not actively engaged in any other invested related business or occupation. Mr. Mueth is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Mueth is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Mueth does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 41 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 42 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Alexander M. Nixon, Vice President Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Alexander M. Nixon that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. information about Alexander M. Nixon is available on the SEC’s website at Additional www.adviserinfo.sec.gov. 43 Item 2 - Educational Background and Business Experience Name: Alexander M. Nixon Title: Vice President Year of Birth: 1990 Education: Drury University Bachelor of Business Administration in Finance – 2012 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC, 04/14 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Nixon has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Nixon is not actively engaged in any other invested related business or occupation. Mr. Nixon is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Nixon is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Nixon does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 44 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 45 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Joseph F. Nugent, Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Joseph F. Nugent that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Joseph F. Nugent is available on the SEC’s website at www.adviserinfo.sec.gov. 46 Item 2 - Educational Background and Business Experience Name: Joseph F. Nugent Title: Director Year of Birth: 1968 Education: Avila University B.S. Accounting - 2004 Business Background: Asset Consulting Group, LLC November 2005 – Present Item 3 - Disciplinary Information Mr. Nugent has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Nugent is not actively engaged in any other invested related business or occupation. Mr. Nugent is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Nugent is not actively engaged in any other non-investment related business activities. Mr. Nugent is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. Item 5 - Additional Compensation Mr. Nugent does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 47 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 48 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Jason C. Pulos, Managing Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Jason C. Pulos that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Jason C. Pulos is available on the SEC’s website at www.adviserinfo.sec.gov. 49 Item 2 - Educational Background and Business Experience Name: Jason C. Pulos Title: Managing Director Year of Birth: 1967 Education: St. Louis University J.D. Law – 1992 University of Missouri B.A. Political Science – 1989 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 11/2000 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Pulos has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Pulos is not actively engaged in any other invested related business or occupation. Mr. Pulos is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Pulos is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Pulos does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 50 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 51 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Haley M. Rives, Managing Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Haley M. Rives that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Haley M. Rives is available on the SEC’s website at www.adviserinfo.sec.gov. 52 Item 2 - Educational Background and Business Experience Name: Haley M. Rives Title: Managing Director Year of Birth: 1979 Education: Washington University M.B.A. – 2006 University of Illinois B.S. Finance – 2001 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 4/07 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Ms. Rives has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Ms. Rives is not actively engaged in any other invested related business or occupation. Ms. Rives is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Ms. Rives is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Ms. Rives does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 53 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 54 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Daniel C. Tarlas, Senior Managing Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Daniel C. Tarlas that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Daniel C. Tarlas is available on the SEC’s website at www.adviserinfo.sec.gov. 55 Item 2 - Educational Background and Business Experience Name: Daniel C. Tarlas Title: Senior Managing Director Year of Birth: 1957 Education: University of Tulsa B.S. Communication – 1979 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 4/92 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Tarlas has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Tarlas is not actively engaged in any other invested related business or occupation. Mr. Tarlas is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Tarlas is not actively engaged in any other substantial non-investment related business activities. Item 5 - Additional Compensation Mr. Tarlas does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 56 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 57 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page George A. Tarlas, Senior Managing Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about George A. Tarlas that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about George A. Tarlas is available on the SEC’s website at www.adviserinfo.sec.gov. 58 Item 2 - Educational Background and Business Experience Name: George A. Tarlas Title: Senior Managing Director Year of Birth: 1966 Education: University of Colorado B.S. Finance – 1988 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 1/97 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Tarlas has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Tarlas is not actively engaged in any other invested related business or occupation. Mr. Tarlas is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Tarlas is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Tarlas does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 59 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 60 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Phineas W. Troy, Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Phineas W. Troy that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Phineas W. Troy is available on the SEC’s website at www.adviserinfo.sec.gov. 61 Item 2 - Educational Background and Business Experience Name: Phineas W. Troy Title: Director Year of Birth: 1985 Education: University of Missouri B.S. Finance and Banking – 2006 University of Missouri St. Louis M.B.A. – 2008 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC, 12/20 – Present Mercer, Principal and Sr. Consultant, 11/18 – 12/20 Summit Strategies Group, Vice President and Sr. Consultant – 4/12 – 11/18 *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Troy has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Troy is not actively engaged in any other invested related business or occupation. Mr. Troy is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non-Investment Related Business Activities Mr. Troy is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Troy does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 62 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 63 Part 2B of Form ADV: Brochure Supplement Item 1 - Cover Page Roger J. Willis, Managing Director Asset Consulting Group, LLC 231 S. Bemiston, Suite 1400 St. Louis, MO 63105 Phone: 314-862-4848 Date of Supplement: July 14, 2025 This brochure supplement provides information about Roger J. Willis that supplements the Asset Consulting Group, LLC brochure. You should have received a copy of that brochure. Please contact Jason Pulos, Managing Director at 314-862-4848 or jason.pulos@acgnet.com if you did not receive Asset Consulting Group, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Roger J. Willis is available on the SEC’s website at www.adviserinfo.sec.gov. 64 Item 2 - Educational Background and Business Experience Name: Roger J. Willis Title: Managing Director Year of Birth: 1971 Education: University of Natal, South Africa Bachelor of Commerce (Finance) – 1991 Honors Degree (Economics) – 1992 Professional Designations: Chartered Financial Analyst* Business Background: Asset Consulting Group, LLC 8/10 – Present *The Chartered Financial Analyst (CFA) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 - Disciplinary Information Mr. Willis has no criminal, civil or regulatory disciplinary information to report. Item 4 - Other Business Activities A. Other Investment Related Business Activities Mr. Willis is not actively engaged in any other invested related business or occupation. Mr. Willis is not registered and has no applications pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of an FCM, CPO or CTA. B. Other Non- Investment Related Business Activities Mr. Willis is not actively engaged in any other non-investment related business activities. Item 5 - Additional Compensation Mr. Willis does not receive any additional compensation or receive an economic benefit for advisory services provided to non-clients of ACG. Each employee of ACG’s compensation includes a base salary and an incentive bonus. Base compensation is determined by an individual’s level of responsibility, skill, experience and education. Incentive compensation is discretionary in nature and is based on overall firm success as well as each individual’s contribution. 65 Item 6 - Supervision ACG’s Investment Committee is responsible for establishing the firm’s overall investment philosophy and investment process and insuring a consistent, disciplined and ethical process is adhered to by all members of the firm. ACG’s Investment Adviser Representatives are supervised by senior members of the Firm, as outlined below: Don Mueth, CFA – Managing Director-Chief Operating Officer Jason Pulos, CFA – Managing Director-Chief Compliance Officer Daniel Tarlas, CFA – Senior Managing Director-Co Head of ACG George Tarlas, CFA – Senior Managing Director-Co Head of ACG 66