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Item 1 – Cover Page
ADV Part 2A
Firm Brochure
Barron Financial Group, LLP
103 Albert St.
Torrington, CT 06790
(860) 489-0432
financial.questions@barronfinancialgroup.com
www.barronfinancialgroup.com
February 3, 2026
This Brochure provides information about the qualifications and business practices of
Barron Financial Group, LLP (“BFG”). If you have any questions about the contents of this
Brochure, please contact BFG using the information listed above. The information in this
Brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority.
Barron Financial Group, LLP is a registered investment advisor with the SEC. Registration of
an investment advisor does not imply any certain level of skill or training.
Additional information about Barron Financial Group, LLP is also available on the SEC’s
website at www.adviserinfo.sec.gov.
Item 2 – Material Changes
The last update of our brochure was March 2025.
We have updated Item 8 to more clearly explain out Method of Analysis and we have updated Item 13 to
clarify that rebalancing is done on a quarterly basis. These are not material changes.
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Item 3 – Table of Contents
Item 1 – Cover Page ......................................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................................. 2
Item 3 – Table of Contents ............................................................................................................................................. 3
Item 4 – Advisory Business ........................................................................................................................................... 4
Item 5 – Fees and Compensation ................................................................................................................................ 7
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................ 10
Item 7 – Types of Clients ............................................................................................................................................. 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 11
Item 9 – Disciplinary Information ........................................................................................................................... 15
Item 10 – Other Financial Industry Activities and Affiliations ..................................................................... 15
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading . 15
Item 12 – Brokerage Practices .................................................................................................................................. 16
Item 13 – Review of Accounts ................................................................................................................................... 16
Item 14 – Client Referrals and Other Compensation ........................................................................................ 17
Item 15 – Custody .......................................................................................................................................................... 18
Item 16 – Investment Discretion ............................................................................................................................. 18
Item 17 – Voting Client Securities ........................................................................................................................... 18
Item 18 – Financial Information............................................................................................................................... 19
ADV Part 2B Brochure Supplement ........................................................................................................................ 20
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Item 4 – Advisory Business
Barron Financial Group, LLP (“BFG” or “Firm”) is owned by James A. Thibault and has been providing
advisory services since 2006.
As of December 31, 2025, Barron Financial Group, LLP had a total of $199,126,279.99 in assets under
management. $194,949,923.93 of those assets were managed on a discretionary basis, and
$ 4,176,356.06 were managed on a non-discretionary basis.
PORTFOLIO MANAGEMENT SERVICES:
BFG provides continuous advice to a client and investment management based on the individual
needs of the client. Through personal discussions in which goals and objectives based on a client’s
particular circumstances are established, BFG develops a client’s personal investment policy and
creates and manages a portfolio based on that policy. The Portfolio Management Service, BFG will
manage advisory accounts on a discretionary basis only. Account supervision is guided by the stated
objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income).
PORTFOLIO ADVISORY SERVICES:
In some cases, BFG’s Portfolio Management Services are not suitable for a client. In these cases, BFG
offers Portfolio Advisory Services to clients and manages their accounts on a non-discretionary basis.
Recommendations will be based on a client’s individual circumstances and needs, BFG will help
determine investments, or managers, which are appropriate for the client. Factors considered in this
determination are account size, risk tolerance and the opinion of the client. Clients should refer to
the specific investment prospectuses for a full description of the investments chosen. BFG will meet
with the client on a regular basis, or as determined by the client, to review the account(s).
Under the Portfolio Advisory Service, BFG will assist the client in selecting new investments, and then
monitor the performance accordingly. However, all investment decisions are solely at the discretion
of the client.
RETIREMENT PLAN ADVISORY SERVICES:
BFG offers service to qualified and non-qualified retirement plans including 401(k) plans, 403(b)
plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans.
BFG acts as a limited scope ERISA 3(21) fiduciary that can advise, help, and assist plan sponsors with
their investment decisions. As an investment advisor BFG has a fiduciary duty to act in the best
interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their
plan, though using BFG can help the plan sponsor delegate liability by following a diligent process.
1. Figures:
• Provide investment advice to the Client about asset classes and investment
alternatives available for the Plan in accordance with the Plan’s investment policies
and objectives. Clients will make the final decision regarding the initial selection,
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retention, removal, and addition of investment options. BFG acknowledges that it is a
fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections. The
Client retains the sole responsibility to provide all notices to the Plan participants
required under ERISA Section 404(c)(5) and 404(a)-5.
investment performance, consistency of
• Assist in monitoring investment options by preparing periodic investment reports that
fund management and
document
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
• Meet with the Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. Client understands BFG’s
assistance in education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, BFG is not providing fiduciary advice as
defined by ERISA 3(21)(A)(ii) to the Plan participants. BFG will not provide
investment advice concerning the prudence of any investment option or combination
of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
BFG can provide these services or, alternatively, can arrange for the Plan’s other providers
to offer these services, as agreed upon between BFG and Client.
3. BFG has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
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• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in t h e calculation of Fees paid to BFG on the
ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
FINANCIAL PLANNING SERVICES:
BFG also provides advice in the form of a Financial Plan. Clients purchasing this service will receive a
written report, providing the client with a detailed financial plan designed to achieve his or her stated
financial goals and objectives. Generally, BFG only offers financial planning services to existing
Portfolio Management clients, although exceptions to this can be made at BFG’s discretion.
In general, the financial plan will address any or all of the following areas of concern:
PERSONAL: Family records, budgeting, personal liability, estate information and financial
goals.
TAX & CASH FLOW: Income tax and spending analysis and planning for past, current, and
future years. BFG will illustrate the impact of various investments on a client’s current income
tax and future tax liability.
DEATH & DISABILITY: Cash needs at death, income needs of surviving dependents, estate
planning and disability income analysis.
RETIREMENT: Analysis of current strategies and investment plans to help the client achieve
his or her retirement goals.
INVESTMENTS: Analysis of investment alternatives and their effect on a client’s portfolio.
BFG gathers required information through in-depth personal interviews. Information gathered
includes a client’s current financial status, future goals, and attitudes towards risk. Related documents
supplied by the client are carefully reviewed, including a questionnaire completed by the client, and
a written report is prepared. Should a client choose to implement the recommendations contained in
the plan, BFG suggests the client work closely with his/her attorney, accountant, insurance agent,
and/or stockbroker.
Implementation of financial plan recommendations is entirely at the client’s discretion.
If a conflict of interest exists between the interests of BFG and the interests of the Client, the Client is
under no obligation to act upon BFG’s recommendation. If the Client elects to act on any of the
recommendations, the Client is under no obligation to affect the transaction through BFG. Financial
plans will be completed and delivered within ninety (90) days contingent upon timely delivery of all
required documentation.
BFG tailors all services to meet the individual needs of our clients. The goals and objectives for each
Client are documented in our Client files. Investment strategies are created that reflect the stated
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goals and objectives. Clients can impose restrictions on investing in certain securities or types of
securities. These restrictions can, in some cases prohibit engagement with BFG.
Item 5 – Fees and Compensation
PORTFOLIO MANAGEMENT SERVICES:
The annual fee for Portfolio Management services will be charged as a percentage of assets under
management, according to the following tiered schedule:
Assets Under Management
Annual Fee
$0 - $250,000
1.50%
$250,001 - $1,000,000
1.25%
Over $1,000,000
1.00%
This is a tiered or breakpoint fee schedule, meaning the entire account is charged the same
management fee. The annual fee is negotiable based upon certain criteria (e.g., historical relationship,
type of assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with Clients,
etc.). Fees are billed quarterly in advance based on the closing portfolio balance at the end of the
previous quarter.
For example:
A client that invests $100,000 will pay an annual fee of $1500 per year or $375 per quarter.
A client that invests $300,000 will pay an annual fee of $3750 per year or $937.50 per quarter.
A client that invests $1,000,000 will pay an annual fee of $10,000 per year of $2500 per
quarter.
BFG will not make fee adjustments for contributions to and withdrawals from client accounts below
$25,000. All fees paid to BFG for investment advisory services are separate and distinct from the fees
and expenses charged by mutual funds to their shareholders.
Held Away Account Management
BFG uses a third-party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of Client funds since BFG does not have direct access to Client log-in
credentials to affect trades. BFG is not affiliated with the platform in any way and receives no
compensation from them for using their platform. A link will be provided to the Client allowing them
to connect an account(s) to the platform. Once Client account(s) is connected to the platform, BFG
will review the current account allocations. When deemed necessary, BFG will rebalance the account
considering client investment goals and risk tolerance, and any change in allocations will consider
current economic and market trends. The goal is to improve account performance over time,
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minimize loss during difficult markets and manage internal fees that harm account performance.
Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed
necessary.
PORTFOLIO ADVISORY SERVICES:
The annual fee for Portfolio Advisory Services will be charged as a percentage of assets under
management, according to the following schedule:
Assets Under Management
Annual Fee
$0 - $100,000
1.50%
$100,001 - $1,000,000
1.25%
Over $1,000,000
1.00%
This is a tiered or breakpoint fee schedule, meaning the entire account is charged the same
management fee. The annual fee is negotiable based upon certain criteria (e.g., historical relationship,
type of assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with Clients,
etc.). Fees are billed quarterly in arrears based on the daily average balance of the advised accounts.
For example:
A client that invests $100,000 will pay an annual fee of $1500 per year or $375 per quarter.
A client that invests $300,000 will pay an annual fee of $3750 per year or $937.50 per quarter.
A client that invests $1,000,000 will pay an annual fee of $10,000 per year of $2500 per
quarter.
In 2021 and prior years BFG followed a separate fee schedule, which remains in effect with clients
who signed agreements with BFG during such period and who have not agreed to an amended
advisory fee schedule.
These fees will generally include a management fee, other fund expenses, and a possible distribution
fee.
RETIREMENT PLAN ADVISORY SERVICES:
The annual fee for Retirement Plan Advisory Services will be charged as a percentage of the plan
assets under advisements, based on the following schedule:
Assets Under Management
Annual Fee
$0 - $1,000,000
1.00%
$1,000,001 - $3,000,000
0.75%
$3,000,001 - $5,000,000
0.50%
Over $5,000,000
0.25%
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The annual fees are based on the market value of the Included Assets and shall not exceed 1%. Fees
are charged quarterly or monthly in arrears or in advance based on the assets as calculated by the
custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals
by Plan participants or other anticipated or scheduled transfers or distribution of assets) on the last
business day of the previous quarter. If the services to be provided start any time other than the first
day of a quarter, the fee will be prorated based on the number of days remaining in the quarter. If the
agreement is terminated prior to the end of the fee period, BFG shall be entitled to a prorated fee
based on the number of days during the fee period services were provided.
The fee schedule, which includes compensation of BFG for the services is described in detail in the
ERISA Plan Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor can elect to
pay the fees. Each Client can elect to be billed directly or have fees deducted from Plan Assets. BFG
does not reasonably expect to receive any additional compensation, directly or indirectly, for its
services. If additional compensation is received, BFG will disclose this compensation, the services
rendered, and the payer of compensation.
FINANCIAL PLANNING/CONSULTING SERVICES:
BFG charges an hourly or a fixed fee for financial planning and consulting. Prior to the planning
process the Client will be provided an estimated plan fee. For hourly and fixed fee arrangements,
services will be completed and delivered within ninety (90) days contingent upon timely delivery of
all required documentation. BFG reserves the right to waive the fee should the Client implement the
plan through BFG.
HOURLY FEES
Hourly Fee Services are offered based on an hourly fee of $200 per hour. If appropriate, an
estimate for total hours is determined at the start of the advisory relationship.
FIXED FEES
Fixed Fee Services are offered based on a range of $400 - $3,200 depending on the complexity
of the engagement. Up to 50% of the estimated fee is due upon signing the advisory
agreement, with the balance (based on actual hours) due upon presentation of the plan or
completion of the consulting work to the client.
GENERAL INFORMATION ON FEES AND SERVICES
Payment of Fees:
Portfolio Management Fees are deducted directly from the Client’s Account.
Portfolio Advisory Fees are deducted directly from the Client’s Account.
Financial Planning Fees are invoiced directly to the Client.
Retirement Plan Advisory Fees are determined by the Plan Client between directly invoiced or
deducted directly from the Plan Account.
Negotiability of Fees and Account Minimums: In certain circumstances, all of BFG’s fees and
account minimums can be negotiable on a case-by-case basis. Fees will not be adjusted for additions
or withdrawals of less than $25,000.
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Termination of Advisory Relationship: A client agreement can be cancelled at any time, by either
party, for any reason upon receipt of 30 day written notice. Upon termination of any account, any
prepaid, unearned fees will be promptly refunded. Also, any unpaid earned fees will be due and
payable. The client has the right to terminate an agreement without penalty within five business days
after entering into the agreement.
Mutual Fund Fees: All fees paid to BFG for investment advisory services are separate and distinct
from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses
are described in each fund’s prospectus. These fees will generally include a management fee, other
fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client will pay
an initial or deferred sales charge depending on the specific fund. A client could invest in mutual funds
directly, without the services of BFG. In that case, the client would not receive the services provided
by BFG which are designed, among other things, to assist the client in determining which mutual fund
or funds are most appropriate to each client’s financial condition and objectives.
Accordingly, the client should review both the fees charged by the funds and the fees charged by BFG
to fully understand the total amount of fees to be paid by the client, and to thereby evaluate the
advisory services being provided.
Advisory Fees in General: Clients should note that similar advisory services are available from other
registered investment advisers for similar or lower fees.
Other Fees: BFG’s fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by the client. Clients will incur certain charges imposed
by custodians, brokers, third-party investment and other third-parties such as fees charged by
managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer
and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual funds and exchange traded funds also charge internal management fees, which are disclosed
in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to BFG’s
fee, and BFG does not receive any portion of these commissions, fees, and costs.
Item 6 – Performance-Based Fees and Side-By-Side Management
BFG does not charge any performance-based fees (fees based on a share of capital gains on or capital
appreciation of the assets of a client).
Item 7 – Types of Clients
BFG provides advisory services to individuals, high net worth individuals, pension and profit-sharing
plans, trusts, estates, charitable organizations and corporations or other business entities.
Generally, BFG requires a minimum of $250,000 of assets under management for this Portfolio
Management services, and $100,000 for Portfolio Advisory services. These minimum portfolio sizes
are negotiable under certain circumstances. BFG on a case-by-case basis can group certain related
client accounts for the purposes of achieving the minimum account size and determining the
annualized fee.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis:
Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance
is not a guarantee of future returns. Security analysis methods include:
Fundamental analysis concentrates on factors that determine a company’s value and expected future
earnings. This strategy would normally encourage equity purchases in stocks that are undervalued
or priced below their perceived value. The risk assumed is that the market will fail to reach
expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market trends. The
assumption is that the market follows discernible patterns and if these patterns can be identified then
a prediction can be made. The risk is that markets do not always follow patterns and relying solely
on this method does not take into account new patterns that emerge over time.
Charting analysis strategy involves using and comparing various charts to predict long and short-
term performance or market trends. The risk involved in using this method is that only past
performance data is considered without using other methods to crosscheck data. Using charting
analysis without other methods of analysis would be making the assumption that past performance
will be indicative of future performance, which is not always the case.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be
leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not
always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it
changes the very cycles these investors are trying to exploit.
Quantitative analysis deals with measurable factors as distinguished from qualitative considerations
such as the character of management or the state of employee morale, such as the value of assets, the
cost of capital, historical projections of sales, and so on.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return
for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return,
each by carefully choosing the proportions of various assets.
In developing a financial plan for a Client, BFG’s analysis can include cash flow analysis, investment
planning, risk management, tax planning and estate planning. Based on the information gathered, a
detailed strategy is tailored to the Client’s specific situation.
The main sources of information include financial newspapers and magazines, annual reports,
prospectuses, and filings with the SEC.
Investment Strategy:
The investment strategy for a specific Client is based upon the goals and objectives stated by the
Client during consultations. The Client can change these objectives at any time by providing written
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notice to BFG or documented discussion with BFG. Each Client executes a Client profile form or
similar form that documents their objectives and their desired investment strategy.
Risks of Investments and Strategies Utilized:
Investing in securities involves risk of loss that Clients should be prepared to bear. BFG’s investment
approach constantly keeps the risk of loss in mind. Investors can face the following investment risks:
General Investment and Trading Risks. Clients can invest in securities and other financial
instruments using strategies and investment techniques with significant risk characteristics. The
investment program utilizes such investment techniques as option transactions, margin transactions,
short sales, leverage, and derivatives trading, the use of which can, in certain circumstances,
maximize the adverse impact to which a Client is subject.
Interest-rate Risk. Fluctuations in interest rates can cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next
year, because purchasing power is eroding at the rate of inflation.
Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk. This is the risk that future proceeds from investments have to be reinvested at
a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.
Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets
are more liquid if many traders are interested in a standardized product. For example, Treasury Bills
are highly liquid, while real estate properties are not.
Management Risk. The advisor’s investment approach can fail to produce the intended results. If
the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized
in the expected time frame, the overall performance of the Client’s portfolio can suffer.
Options Trading. The risks involved with trading options are that they are very time-sensitive
investments. An options contract is generally for a few months. The buyer of an option could lose his
or her entire investment even with a correct prediction about the direction and magnitude of a
particular price change if the price change does not occur in the relevant time period (i.e., before the
option expires). Additionally, options are less tangible than some other investments. An option is a
“book-entry” only investment without a paper certificate of ownership.
Trading on Margin. In a cash account, the risk is limited to the amount of money that has been
invested. In a margin account, risk includes the amount of money invested plus the amount that has
been loaned. As market conditions fluctuate, the value of marginable securities will also fluctuate,
causing a change in the overall account balance and debt ratio. As a result, if the value of the securities
held in a margin account depreciates, the Client will be required to deposit additional cash or make
full payment of the margin loan to bring the account back up to maintenance levels. Clients who
cannot comply with such a margin call will be sold out or bought in by the brokerage firm.
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Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange.
The risks of owning an ETF generally reflect the risks of owning the underlying securities they are
designed to track, although lack of liquidity in an ETF could result in it being more volatile and ETFs
have management fees that increase their costs. ETFs are also subject to other risks, including: (i) the
risk that their prices do not correlate perfectly with changes in the underlying reference units; and(ii)
the risk of possible trading halts due to market conditions or other reasons that, in the view of the
exchange upon which an ETF trades, would make trading in the ETF inadvisable.
Mutual Fund Risks. An investment in mutual funds could lose money over short or even long
periods. A mutual fund’s share price and total return are expected to fluctuate within a wide range,
like the fluctuations of the overall stock market.
Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock.
Prices of common stock react to the economic condition of the company that issued the security,
industry and market conditions, and other factors which can fluctuate widely. Investments related to
the value of stocks can rise and fall based on an issuer’s actual and anticipated earnings, changes in
management, the potential for takeovers and acquisitions, and other economic factors. Similarly, the
value of other equity-related securities, including preferred stock, warrants, and options can vary
widely.
Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap
issuers. Securities of small-cap issuers present greater risks than those of large-cap issuers. For
example, some small- and mid-cap issuers often have limited product lines, markets, or financial
resources. They can be subject to high volatility in revenues, expenses, and earnings. Their securities
can be thinly traded, and be followed by fewer investment research analysts, and can be subject to
wider price swings and thus can create a greater chance of loss than when investing in securities of
larger-cap issuers. The market prices of securities of small- and mid-cap issuers generally are more
sensitive to changes in earnings expectations, to corporate developments, and to market rumors than
are the market prices of large-cap issuers.
Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold
commodities, commodities contracts, and/or derivative instruments, including futures, options, and
swap agreements. The prices of commodities contracts and derivative instruments, including futures
and options, are highly volatile. Payments made pursuant to swap agreements can also be highly
volatile. Price movements of commodities, futures and options contracts, and payments pursuant to
swap agreements are influenced by, among other things, interest rates, changing supply and demand
relationships, trade, fiscal, monetary and exchange control programs and policies of governments,
and national and international political and economic events and policies. The value of futures,
options, and swap agreements also depends upon the price of the commodities underlying them. In
addition, Client assets are subject to the risk of the failure of any of the exchanges on which its
positions trade or of its clearinghouses or counterparties.
Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements
of forward and other derivative contracts are influenced by, among other things, interest rates,
changing supply and demand relationships, trade, fiscal, monetary and exchange control programs
and policies of governments, and national and international political and economic events and
policies. Clients are also subject to the risk of failure of any of the exchanges on which their positions
trade or of its clearinghouses.
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Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers. Investments
in securities of non-U.S. issuers pose a range of potential risks which could include expropriation,
confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains
or other income, political or social instability, illiquidity, price volatility, and market manipulation. In
addition, less information can be available regarding securities of non-U.S. issuers, and non-U.S.
issuers are not always subject to accounting, auditing and financial reporting standards, and
requirements comparable to or as uniform as those of U.S. issuers.
Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets issuers. In
addition to the risks associated with investments outside of the United States, investments in
emerging markets (i.e., the developing countries) can involve additional risks. Emerging markets
generally are not as efficient as those in developed countries. In some cases, a market for the security
does not exist locally, and transactions will need to be made on a neighboring exchange. Volume and
liquidity levels in emerging markets are lower than in developed countries. When seeking to sell
emerging market securities, little or no market can exist for the securities. In addition, issuers based
in emerging markets are not generally subject to uniform accounting and financial reporting
standards, practices, and requirements comparable to those applicable to issuers based in developed
countries, thereby potentially increasing the risk of fraud or other deceptive practices.
Capitalization Risks. Investing in Companies within the same market capitalization category carries
the risk that the category can be out of favor due to current market conditions or investor sentiment.
Market Risks. Turbulence in the financial markets and reduced liquidity can negatively affect the
Companies, which could have an adverse effect on each of them. If the securities of the Companies
experience poor liquidity, investors will be unable to transact at advantageous times or prices, which
can decrease the Company’s returns. In addition, there is a risk that policy changes by central
governments and governmental agencies, including the Federal Reserve or the European Central
Bank, which could include increasing interest rates, could cause increased volatility in financial
markets, which could have a negative impact on the Companies. Furthermore, local, regional, or
global events such as war, acts of terrorism, the spread of infectious illness or other public health
issues, recessions, or other events could have a significant impact on the Companies. For example,
the rapid and global spread of a highly contagious novel coronavirus respiratory disease, designated
COVID-19, resulted in extreme volatility in the financial markets and severe losses; reduced liquidity
of many Companies’ securities; restrictions on international and, in some cases, local travel;
significant disruptions to business operations (including business closures); strained healthcare
systems; disruptions to supply chains, consumer demand and employee availability; and widespread
uncertainty regarding the duration and long-term effects of this pandemic. Some sectors of the
economy and individual issuers have experienced particularly large losses. In addition, the COVID-
19 pandemic did result in an economic downturn. The Companies’ values could decline over short
periods due to short-term market movements and over longer periods during market downturns.
The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the
risks involved in an investment with BFG.
BFG’s strategies do not utilize securities that BFG believes would be classified as having any unusual
risks, and BFG does not recommend frequent trading, which can increase brokerage and other costs
and taxes.
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BFG utilizes several investment strategies for client use. Those strategies include Tactical, Strategic,
Active Asset Allocation and Capital Preservation. The Tactical strategy is one based on the idea of
diversified asset allocation. The tactical component is where BFG overweight’s and underweights
various asset classes based on what they feel the future economy will deliver. The Strategic strategy
is also based on diversified asset allocation but does not include tactical overweight’s or
underweights. The strategy also uses only index mutual funds to represent the various asset classes.
The Active Asset Allocation strategy is one fully conceived and designed by BFG and follows a
momentum system using mathematical signals designed by BFG. The Capital Preservation portfolio
is also based on diversified asset allocation but targets a lower risk profile of about 2 on a scale of 1
to 10. It has very limited equity exposure and a much broader fixed income representation.
Item 9 – Disciplinary Information
BFG and its management have not been involved in any criminal or civil actions, administrative or
self-regulatory enforcement proceedings, nor any legal or disciplinary events that are material to a
Client’s or prospective Client’s evaluation of BFG or the integrity of its management.
Item 10 – Other Financial Industry Activities and Affiliations
Neither BFG nor its representatives are registered, and do not have an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer. Further, neither BFG
nor its representatives 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.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
BFG has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. BFG's Code
of Ethics describes the firm's fiduciary duties and responsibilities to clients and sets forth BFG's
practice of supervising the personal securities transactions of employees with access to client
information. Individuals associated with BFG can buy or sell securities for their personal accounts
identical or different than those recommended to clients. It is the expressed policy of BFG that no
person employed by the firm shall prefer his or her own interest to that of an advisory client or make
personal investment decisions based on investment decisions of advisory clients. Neither BFG nor its
related persons recommend to Clients, or buys or sells for Client accounts, securities in which BFG or
a related person has a material financial interest.
To supervise compliance with its Code of Ethics, BFG requires that anyone associated with this
advisory practice with access to advisory recommendations provide annual securities holding
reports and quarterly transaction reports to the firm's principal. BFG also requires such access
persons to receive approval from the Chief Compliance Officer prior to investing in any IPO's or
private placements (limited offerings).
BFG's Code of Ethics further includes the firm's policy prohibiting the use of material non- public
information and protecting the confidentiality of client information. BFG requires that all individuals
must act in accordance with all applicable Federal and State regulations governing registered
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investment advisory practices. Any individual not in observance of the above can be subject to
discipline.
BFG will provide a complete copy of its Code of Ethics to any client or prospective upon request.
Item 12 – Brokerage Practices
BFG requires the use of a specific broker-dealers. BFG selected their broker based on a number of
factors including but not limited to their relatively low transaction fees, quality of customer service,
and reporting ability. BFG relies on the broker-dealer to provide its execution services at the best
prices available. Lower fees for comparable services can be available from other sources. Clients pay
for any and all custodial fees in addition to the advisory fee charged by BGF. Not all advisers require
clients to direct the use of a particular broker dealer.
Research and Other Soft Dollar Benefits
BFG does not receive soft dollar benefits. However, BFG participates in the Fidelity Institutional
Wealth Services (FIWS) program, sponsored by Fidelity Brokerage Services LLC (“Fidelity”), a FINRA
member broker dealer. Clients in need of brokerage and custodial services will have either Fidelity
and/or National Financial Services, LLC (“National Financial”), an affiliate of Fidelity, recommended
to them. BFG does not receive any Soft Dollar Benefits; however, as part of the FIWS program, BFG
receives other benefits that it would not receive if it did not offer investment advice (See the
disclosure under Item 14 of this Brochure). These benefits include technology and research.
Brokerage for Client Referrals
BFG does not receive Client referrals from any custodian or third-party in exchange for using that
broker-dealer or third party.
Directed Brokerage
BFG does not allow Client directed brokerage.
Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best
execution. The determination of what can constitute best execution and price in the execution of a
securities transaction by a broker involves a number of considerations and is subjective. Factors
affecting brokerage selection include the overall direct net economic result to the portfolios, the
efficiency with which the transaction is effected, the ability to affect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship
with such broker and the financial strength and stability of the broker. The firm does not receive any
portion of the trading fees.
Aggregating Trading for Multiple Client Accounts
BFG does not aggregate trades.
Item 13 – Review of Accounts
PORTFOLIO MANAGEMENT SERVICES:
While the underlying securities within the Portfolio Management Services accounts are continuously
monitored, James Thibault, Managing Partner and John Seagrave, Partner of BFG, reviews all portfolio
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allocations every quarter Accounts are reviewed in the context of each client’s stated investment
objectives and guidelines.
Changes in variables such as market, political or economic circumstances, or changes in a client’s
individual financial objectives or circumstances can trigger more frequent reviews.
PORTFOLIO ADVISORY SERVICES:
Depending on the circumstance, the underlying investment securities, or the independent
investment adviser(s) will be continuously monitored. In addition, James Thibault, Managing Partner
of BFG, reviews these accounts on at least an annual basis, or more often as requested by the client.
Changes in variables such as market, political or economic circumstances, or changes in a client’s
individual financial objectives or circumstances can trigger more frequent reviews.
RETIREMENT PLAN ADVISORY SERVICES:
Plan assets are reviewed as necessary, and according to the standards and situations described above
for investment management accounts.
NATURE AND FREQUENCY OF REPORTS
PORTFOLIO MANAGEMENT SERVICES:
BFG will provide a quarterly inventory of holding by asset class to its clients.
PORTFOLIO ADVISORY SERVICES:
The account custodian will send quarterly statements directly to the client.
RETIREMENT PLAN ADVISORY SERVICES:
Clients utilizing BFG's employee benefit retirement plan services receive reporting services through
their respective plan administrator.
FINANCIAL PLANNING/CONSULTING SERVICES:
Financial Planning clients will receive a completed financial plan. Additional reports will not typically
be provided unless otherwise contracted for. Consulting Services clients will not typically receive
reports due to the nature of the service.
Item 14 – Client Referrals and Other Compensation
As indicated under the disclosure for Item 12, the FIWS program provides BFG with access to services
designed to assist investment advisers that are not available to retail investors. These services are
generally available to investment advisers at no charge.
The services provided by FIWS benefit BFG but do not always benefit its clients' accounts. Many of
the products and services assist BFG in managing and administering clients' accounts. These include
software and other technology that provide access to client account data (such as trade confirmations
17
and account statements), facilitate trade execution (and allocation of aggregated trade orders for
multiple client accounts), provide research, pricing information and other market data, facilitate
payment of BFG's fees from its clients' accounts, and assist with back-office functions, recordkeeping,
and client reporting. Many of these services generally are used to service all or a substantial number
of BFG's accounts.
Recommended brokers also make available to BFG other services intended to help BFG manage and
further develop its business enterprise. These services can include consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance, and marketing. BFG does not, however, enter into any commitments with the brokers for
transaction levels in exchange for any services or products from brokers. While as a fiduciary, BFG
endeavors to act in its clients' best interests, BFG's requirement that clients maintain their assets in
accounts at Schwab or Fidelity is based in part on the benefit to BFG of the availability of some of the
foregoing products and services and not solely on the nature, cost or quality of custody and brokerage
services provided by the brokers.
BFG does not compensate for Client referrals.
Item 15 – Custody
BFG can be deemed to have limited custody solely because advisory fees are directly deducted from
Client’s accounts by the custodian on behalf of BFG.
Clients should receive at least quarterly statements from the broker dealer, bank or other qualified
custodian that holds and maintains client’s investment assets. BFG urges clients to carefully review
such statements and compare such official custodial records to the account statements that we
provide to you. Our statements can vary from custodial statements based on accounting procedures,
reporting dates, or valuation methodologies of certain securities.
BFG is not affiliated with the custodian. The custodian does not supervise BFG, its employees or its
activities.
Item 16 – Investment Discretion
For Portfolio Management Services, BFG requires discretionary authority to determine which
securities and the amounts of securities that are bought or sold. Any limitations on this discretionary
authority shall be included in this written authority statement. Clients can change/amend these
limitations as required. Such amendments shall be submitted in writing.
Item 17 – Voting Client Securities
As a matter of firm policy and practice, BFG does not have any authority to and does not vote proxies
on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any
and all securities maintained in client portfolios. Nevertheless, BFG can provide advice to clients
regarding the clients’ voting of proxies, upon request
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Item 18 – Financial Information
BFG does not require nor solicit prepayment of more than $1,200 (SEC) in fees per Client, six months
or more in advance.
BFG has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients and has not been the subject of a bankruptcy proceeding.
19
ADV Part 2B Brochure Supplement
James A. Thibault
Barron Financial Group, LLP
103 Albert St.
Torrington, CT 06790
(860) 489-0432
www.barronfinancialgroup.com
February 3, 2026
This Brochure Supplement provides information about James A. Thibault that supplements the
Barron Financial Group, LLP Brochure. You should have received a copy of that Brochure. Please
contact Sandra Thibault, Chief Compliance Officer if you did not receive Barron Financial Group,
LLP’s Brochure or if you have any questions about the contents of this supplement.
Additional information about James A. Thibault is available on the SEC’s website at
www.adviserinfo.sec.gov.
20
James A. Thibault, AWMA®, CFP®
Born: 1966
Item 2 – Educational Background and Business Experience
EDUCATION:
University of Hartford, B.S. in Mechanical Engineering, 1984.
Rensselaer Polytechnic Institute, Master of Business Administration - Finance concentration, 2003
BUSINESS BACKGROUND:
Barron Financial Group, LLP, Managing Partner, 03/2006 - present.
Purshe Kaplan Sterling Investments, Registered Representative, 03/2006 - 10/2017.
Accredited Wealth Management Advisor (AWMA®):
To earn the AWMA® designation, follow these steps:
1. Complete an eight-module education program provided by CFFP. There are no
prerequisites for this program, and you have 120 days to complete it (including testing
and passing the Final Exam). The modules cover getting to know your high-net-worth
client; considerations for business owners; income tax strategies for high-net-worth
clients; executive benefits planning for high-net-worth clients; estate planning for high-
net-worth clients; and fiduciary, regulatory, and ethical issues for financial services
providers.
2. Take and pass the AWMA® exam. You must take the test for the first time within six months
of enrolling for the program, and you have a year to pass it. There are 80 questions on the
exam, and the passing score is 70 percent. According to Analyst Forum, you should plan
on studying for about 150 hours.
3. Agree to abide by a code of ethics.
Certified Financial Planner™ (CFP®): The CERTIFIED FINANCIAL PLANNER™ and CFP® marks
(are professional certification marks granted in the United States by Certified Financial Planner
Board of Standards, Inc. The CFP® certification is recognized for its (1) high standard of
professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services and attain a bachelor’s
degree from an accredited college or university. CFP Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning,
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investment planning, income tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination.
Experience – Complete at least three years of full-time financial planning-related
experience and Ethics – Agree to be bound by CFP Board’s Standards of Professional
Conduct, a set of documents outlining the ethical and practice standards for CFP®
professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two
years; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
Item 3- Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice. No information is applicable to this item.
Item 4- Other Business Activities
James Thibault is not currently engaged in any other business activities.
Item 5- Additional Compensation
James Thibault does not receive additional compensation, performance-based fees, nor receives
any additional compensation for performing advisory services other than what is disclosed in
Item 5 of Part 2A.
Item 6 - Supervision
The Chief Compliance Officer of BFG supervises and monitors the advisory services of Luke
Pergola. The Chief Compliance Officer, Sandra Thibault, can reached at 860-489-0432 or
sthibault@barronfinancialgroup.com.
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ADV Part 2B
Brochure Supplement
John E. Seagrave Jr
Barron Financial Group, LLP
103 Albert St.
Torrington, CT 06790
(860) 489-0432
www.barronfinancialgroup.com
February 3, 2026
This Brochure Supplement provides information about John E. Seagrave Jr that supplements the
Barron Financial Group, LLP Brochure. You should have received a copy of that Brochure. Please
contact Sandra Thibault, Chief Compliance Officer if you did not receive Barron Financial Group,
LLP’s Brochure or if you have any questions about the contents of this supplement.
Additional information about John E. Seagrave Jr is available on the SEC’s website at
www.adviserinfo.sec.gov.
23
John E. Seagrave Jr, CFP®, CRPC®
Born: 1988
Item 2 – Educational Background and Business Experience
EDUCATION:
University of Connecticut, M.S. in Sports Management, 2012
University of Connecticut, B.S. in Resource Economics and Marketing. 2010
BUSINESS BACKGROUND:
Barron Financial Group, LLP, Investment Adviser Representative, 03/2017 - present.
UConn Athletics, Director of Sales, 08/2014 - 02/2017.
UConn Athletics, Assistant Director of Marketing, 05/2012 - 08/2014.
UConn Athletics, Marketing Assistant, 05/2009 - 05/2012.
Certified Financial Planner™ (CFP®): The CERTIFIED FINANCIAL PLANNER™ and CFP® marks
(are professional certification marks granted in the United States by Certified Financial Planner
Board of Standards, Inc. The CFP® certification is recognized for its (1) high standard of
professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services and attain a bachelor’s
degree from an accredited college or university. CFP Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning,
investment planning, income tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination.
Experience – Complete at least three years of full-time financial planning-related
experience and Ethics – Agree to be bound by CFP Board’s Standards of Professional
Conduct, a set of documents outlining the ethical and practice standards for CFP®
professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two
years; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
Chartered Retirement Planning CounselorSM - CRPC®: The Chartered Retirement Planning
Counselor (CRPC) designation distinguishes
financial advisors and other retirement
professionals as experts in helping clients prepare for retirement. To become a CRPC, these
individuals must meet several qualifications, undergo hours of training, and take an examination.
Once a CRPC has their certification in hand, there are continuing education requirements that
help keep their knowledge up to date.
Item 3- Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice. No information is applicable to this item.
Item 4- Other Business Activities
John E. Seagrave Jr is currently engaged in any other business activities, but none of them have a
conflict of interest with his role as an investment advisors with Barron Financial. The activities are as
follows:
Burlington Chamber of Commerce- President/Board Member
Central Connecticut Chamber of Commerce- Board Member
Prime Time House- Board Member/Treasurer/Finance Committee, Philanthropic/Community Service
Northwest Community Bank- Foundation Board of Directors
Tavern Day Group- Board Member, Community Relations
Item 5- Additional Compensation
John E. Seagrave Jr does not receive additional compensation, performance-based fees, nor
receives any additional compensation for performing advisory services other than what is
disclosed in Item 5 of Part 2A.
Item 6 - Supervision
The Chief Compliance Officer of BFG supervises and monitors the advisory services of Luke
Pergola. The Chief Compliance Officer, Sandra Thibault, can reached at 860-489-0432 or
sthibault@barronfinancialgroup.com.