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GARRETT WEALTH ADVISORY GROUP - WRAP FEE BROCHURE
Bentoak Capital (CRD 173563), brochure dated September 2, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Wrap Disclosure Brochure
a Registered Investment Adviser
DISCLOSURE BROCHURE
08/31/2026
201 Ft. Worth Hwy.,
Weatherford, TX 76086
CHIEF COMPLIANCE OFFICER
Kimberly Cushman
(817) 550-6750
ITEM 1. COVER PAGE
www.BentOakCapital.com
This brochure provides information about the qualifications and business practices
of Garrett Wealth Advisory Group, LLC (hereinafter “GWAG” or the “Firm”). If you
have any questions about the contents of this brochure, please contact the Firm at
the telephone number 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. Additional information about the Firm is
available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered
investment adviser. Registration does not imply any level of skill or training.
ITEM 2. MATERIAL CHANGES
Material changes relate to Garrett Wealth Advisory Group, LLC policies, practices, or conflicts of interests only. Since
our last annual filing, dated March 23, 2026, material changes have been made to Items 4, 6 and 9
of this Brochure. These updates reflect GWAG’s change in recommended custodian from
LPL Financial to Pershing Advisor Solutions. In addition, GWAG now has a conflict of interest related to an economic
transition arrangement payable to GWAG by Pershing.
ITEM 3. TABLE OF CONTENTS
ITEM 1. COVER PAGE _____________________________________________________________________________________ 1
ITEM 2. MATERIAL CHANGES _____________________________________________________________________________ 2
ITEM 3. TABLE OF CONTENTS _____________________________________________________________________________ 2
ITEM 4. SERVICES, FEES, AND COMPENSATION __________________________________________________________ 3
ITEM 5. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS _______________________________________________ 5
ITEM 6. PORTFOLIO MANAGER SELECTION AND EVALUATION ____________________________________________ 5
ITEM 7. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ____________________________________ 9
ITEM 8. CLIENT CONTACT WITH PORTFOLIO MANAGERS _________________________________________________ 9
ITEM 9. ADDITIONAL INFORMATION ______________________________________________________________________ 9
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ITEM 4. SERVICES, FEES, AND COMPENSATION
The Garrett Wealth Advisory Group Wrap Fee Program (the “Program”) is an investment advisory program
sponsored by GWAG.
While this brochure generally describes the business of GWAG as it relates to clients receiving services through
the Program, certain sections also describe the activities of the Firm’s Supervised Persons, which refer to any
officers, partners, directors (or other person occupying a similar status or performing similar functions),
employees, or other persons who provide investment advice on GWAG’s behalf and are subject to the Firm’s
supervision or control.
In addition to the Program, the Firm also provides investment management and financial planning services
under different arrangements than those described herein. Information about these services is contained in
GWAG’s Disclosure Brochure.
DESCRIPTION OF THE PROGRAM
The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain
investment products without incurring separate brokerage commissions or transaction charges. A
wrap fee program is considered any arrangement under which clients receive investment advisory
services (which may include portfolio management or advice concerning the selection of other
investment advisers) and the execution of client transactions for a specified fee or fees not based upon
transactions in their accounts.
Prior to receiving services through the Program, clients are required to enter into a written agreement
with GWAG setting forth the relevant terms and conditions of the advisory relationship (the
“Agreement”). Clients must also open a new securities account and complete a new account agreement
with Pershing Advisor Solutions (“Pershing”) or another broker-dealer GWAG approves under the Program
(collectively “Financial Institutions”).
As of January 2026, the firm has $969,768,698 in discretionary assets under management and $62,576,543
in assets under advisement. Clients’ investment portfolios are generally managed on a discretionary basis
by either GWAG’s investment adviser representatives or an independent investment manager
(“Independent Managers”), as recommended or selected by GWAG. GWAG and/or the Independent
Managers primarily allocate clients’ assets among the various investment products available under the
Program, as described further in Item 6 (below).
GWAG manages client investment portfolios on a fully discretionary basis. In addition, GWAG may provide
clients with wealth management services which generally includes a broad range of comprehensive
financial planning and consulting services as well as discretionary management of investment
portfolios.
GWAG primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”),
individual debt and equity securities, and independent investment managers (“Independent Managers”)
or Sub-Advisors in accordance with their stated investment objectives.
Where appropriate, the Firm may also provide advice about any type of legacy position or other
investment held in client portfolios. Clients may engage GWAG to manage and/or advise on certain
investment products that are not maintained at their primary custodian, such as variable life insurance
and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans
(i.e., 529 plans). In these situations, GWAG directs or recommends the allocation of client assets
among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s
provider.
GWAG tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. GWAG consults with clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints and other related factors relevant to the management of
their portfolios. Clients are advised to promptly notify GWAG if there are changes in their financial
situation or if they wish to place any limitations on the management of their portfolios. Clients may
impose reasonable restrictions or mandates on the management of their accounts if GWAG
determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm’s management efforts.
FEES FOR THE PROGRAM
Clients in the Program pay a single annualized fee for participation in the Program (the “Program Fee”).
The Program Fee is prorated and charged quarterly, in advance, based upon the market value of the
assets being managed by GWAG under Program. The Program Fee varies depending upon the market
value of the assets under management of the client and the type of investment management services, as
follows:
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PORTFOLIO VALUE
ADVISORY FEE
Less than $500,000
1.35%
$500,001 - $1,000,000
1.25%
$1,000,001 - $2,000,000
1.15%
$2,000,001 - $3,000,000
1.00%
$3,000,001 - $5,000,000
0.85%
$5,000,001 - $7,000,000
0.75%
Over $7,000,001
Negotiable
GWAG, in its sole discretion, may negotiate to charge a lesser Program Fee based upon certain criteria
(i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing client, account retention, pro bono
activities, etc.).
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), GWAG may negotiate a fee
rate that differs from the range set forth above. Where applicable for fee-based annuities or insurance
products, each carrier calculates and debits the advisory fee on a monthly basis in arrears depending on their
method of fee calculation.
FEE COMPARISON
The Program Fee may also include the management and transaction fees charged by the Independent
Managers. Participation in the Program may cost the client more or less than purchasing such services
separately. The number of transactions made in the client’s accounts, as well as the transaction fees,
determines the relative cost of the Program versus paying for execution on a per transaction basis and
paying a separate fee for advisory services. The Program Fee may be higher or lower than fees charged
by other sponsors of comparable investment advisory programs.
INSURANCE AND ANNUITY SERVICES
GWAG has entered into an investment advisory engagement with Halo Securities, LLC (“Halo”) to offer
investment advisory services on insurance and annuity products. Halo facilitates new insurance and annuity
sales and broker of record services on behalf of GWAG and its Clients. Halo employs FINRA and insurance-
licensed sales representatives who are contracted with all carriers they represent. Halo offers variable,
indexed linked, indexed, and fixed insurance and annuity products from certain insurance companies.
Halo can receive commission or compensation on insurance or annuity products. The commission paid
varies by product type and may vary based on the insurance carrier. When providing this guidance,
GWAG’s investment advice shall be limited to those investments provided by the insurance carrier. While
certain GWAG representatives are also licensed agents, the GWAG representatives do not receive any new or
legacy compensation or commission in this capacity.
For contracts held on the Halo platform, GWAG may charge an advisory fee for certain insurance or
annuities sold or receive an advisory fee for insurance or annuities. This practice represents a conflict of
interest in recommending Clients engage Halo for insurance or annuity services.
In the event that the client owns an insurance or annuity product, the client can engage GWAG to
provide investment management services relative to the investment subdivisions that comprise the
insurance or annuity product. GWAG’s investment selection shall be limited to those provided by the
insurance or annuity carrier. If so engaged, GWAG shall charge an ongoing advisory fee based upon the
market value of the assets per its fee schedule at Item 5. Please Note: Neither GWAG, nor any of its
employees, receives commissions or transaction compensation in relation to the sale of any insurance or
annuity products to its clients.
Situationally, GWAG may refer clients directly to Halo for specific annuity or insurance services for a
product that is only available on commission basis (i.e. Long term care, term insurance). In such situations,
Halo can receive a commission from the insurance carrier. GWAG does not receive any portion of said
commission and only offers this service to clients as a courtesy.
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Clients are under no obligation to implement any recommendation from a GWAG representative to engage
Halo.
OTHER CHARGES
In addition to the advisory fees paid to GWAG clients may also incur certain charges imposed by other
third parties, such as, custodians, trust companies, banks and other financial institutions (collectively
“Financial Institutions”). Clients may incur certain charges imposed by other third parties and can
include, transaction fees, custodial fees, fees charged by independent managers as disclosed in the
fund’s prospectus (e.g., fund management fees and other fund expenses), charges imposed directly
by a mutual fund or ETF in a client’s account, deferred sales charges, odd-lot differentials, transfer taxes,
wire transfer fees, electronic transfer fees, redemption fees, overnight check fees, account closing fees
and other charges imposed by the administrator, custodian, or other service provider.
You will pay fees and incur costs whether you make or lose money on your investments. Fees and costs
will reduce any amount of money you make on your investments over time.
ITEM 5. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
The Program participant includes individuals, high net worth individuals, pension and profit- sharing
plans, trusts, estates, charitable organizations, corporations and business entities.
MINIMUMS ACCOUNT REQUIREMENTS
GWAG does not impose a stated minimum fee or minimum portfolio value for starting and maintaining
an investment management relationship. GWAG typically engages with clients with a minimum
$1,000,000 of investable assets or a minimum of $350,000 gross household income. GWAG has the
authority to make exceptions to these minimums under appropriate circumstances. Certain
Independent Managers may impose more restrictive account requirements and billing practices from
the Firm. In these instances, GWAG may alter its corresponding account requirements and/or billing
practices to accommodate those of the Independent Managers.
ITEM 6. PORTFOLIO MANAGER SELECTION AND EVALUATION
ADVISORY BUSINESS
Clients’ investment portfolios are managed either directly by GWAG or through the use of certain
Independent Managers on a fully discretionary basis.
GWAG primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”),
individual debt and equity securities, and Independent Managers, in accordance with their stated
investment objectives.
Where appropriate, the Firm may also provide advice about any type of legacy position or other
investment held in client portfolios. Clients may engage GWAG to manage and/or advise on certain
investment products that are not maintained at their primary custodian, such as variable life insurance
and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans
(i.e., 529 plans). In these situations, GWAG directs or recommends the allocation of client assets
among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s
provider.
GWAG tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. GWAG consults with clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints and other related factors relevant to the management of
their portfolios. Clients are advised to promptly notify GWAG if there are changes in their financial
situation or if they wish to place any limitations on the management of their portfolios. Clients may
impose reasonable restrictions or mandates on the management of their accounts if GWAG
determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm’s management efforts.
USE OF INDEPENDENT MANAGERS
As mentioned above, GWAG may select certain Independent Managers to actively manage a portion of
its clients’ assets. The specific terms and conditions under which a client engages an Independent
Manager may be set for them in a separate written agreement with the designated Independent
Manager. In addition to this brochure, clients may also receive the written disclosure documents of the
respective Independent Managers engaged to manage their assets.
GWAG evaluates a variety of information about Independent Managers, which may include the
Independent Managers’ public disclosure documents, materials supplied by the Independent
Managers themselves and other third-party analyses it believes are reputable. To the extent possible,
the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk
results in relation to its clients’ individual portfolio allocations and risk exposure. GWAG also takes into
consideration each Independent Manager’s management style, returns, reputation, financial strength,
reporting, pricing and research capabilities, among other factors.
GWAG continues to provide services relative to the discretionary selection of the Independent Managers.
On an ongoing basis, the Firm monitors the performance of those accounts being managed by
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Independent Managers. GWAG seeks to ensure the Independent Managers’ strategies and target
allocations remain aligned with its clients’ investment objectives and overall best interests.
USE OF SUB-ADVISORS
GWAG may elect sub-advisors to trade client accounts based upon GWAG instructions.
GWAG may engage one or more unaffiliated third-party service providers to provide trading, trade-order
management, trade-operations, reconciliation, reporting, portfolio-accounting, or related operational
support (collectively, “Outsourced Trading Providers”). Depending on the arrangement, an Outsourced
Trading Provider may assist GWAG with communicating trade instructions to custodians or broker-dealers,
aggregating or allocating trades, monitoring order status, addressing trade errors, maintaining trade
records, or performing other ministerial or operational functions. Except as otherwise expressly authorized
in writing by GWAG and the client, Outsourced Trading Providers do not have discretionary authority to
determine whether a client should purchase or sell a security, to select securities for a client account, or to
modify GWAG’s investment decisions. GWAG remains responsible for its investment recommendations
and portfolio-management decisions and retains oversight of any Outsourced Trading Provider used in
connection with client accounts.
Where GWAG or an Outsourced Trading Provider is responsible for selecting broker-dealers or otherwise
arranging securities transactions, GWAG seeks to evaluate execution quality consistent with its fiduciary
duty and applicable law. In evaluating execution, GWAG may consider the full range and quality of a
broker-dealer’s services, including execution capability, commission rates and other transaction costs,
financial responsibility, responsiveness, market access, ability to handle the order, settlement capability,
research or other services where permitted, and the overall value of the brokerage and execution
services provided. Best execution does not necessarily mean execution at the lowest available
commission rate or transaction cost.
GWAG generally pays the compensation of an Outsourced Trading Provider from its own resources unless
otherwise disclosed in the applicable advisory agreement, fee schedule, account statement, or other
written disclosure. If an Outsourced Trading Provider’s compensation is paid directly or indirectly from
client assets, is embedded in transaction costs, is paid by a broker-dealer, or creates an incentive
affecting broker selection or trade execution, GWAG will disclose the applicable arrangement and
related conflict of interest. Clients should also refer to Item 12 of this Brochure for additional information
regarding brokerage practices and trade execution.
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
GWAG does not provide any services for a performance-based fee (i.e., a fee based on a share of capital
gains or capital appreciation of a client’s assets).
METHODS OF ANALYSIS
GWAG utilizes a combination of fundamental, technical, and cyclical methods of analysis.
Fundamental analysis involves an evaluation of the fundamental financial condition and competitive
position of a particular fund or issuer.
For GWAG, this process typically involves an analysis of an issuer’s management team, investment
strategies, style drift, past performance, reputation and financial strength in relation to the asset class
concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in relying
upon fundamental analysis is that while the overall health and position of a company may be good,
evolving market conditions may negatively impact the security.
Technical analysis involves the examination of past market data rather than specific issuer information
in determining the recommendations made to clients. Technical analysis may involve the use of
mathematical based indicators and charts, such as moving averages and price correlations, to identify
market patterns and trends which may be based on investor sentiment rather than the fundamentals
of the company. A substantial risk in relying upon technical analysis is that spotting historical trends
may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no
guarantee that GWAG will be able to accurately predict such a reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the assessment of market conditions at a
macro (entire market or economy) or micro (company specific) level, rather than focusing on the overall
fundamental analysis of the health of the particular company that GWAG is recommending. The risks with
cyclical analysis are similar to those of technical analysis.
INVESTMENT STRATEGIES
Prior to developing an investment strategy tailored to each client, GWAG gathers and analyzes detailed
information about the client, including goals, existing investments, insurance coverage, sources of income
and other assets and liabilities. The Firm then seeks to define the client’s investment objectives and
risk profile, which together form the basis for the selection and diversification of investments.
Once an initial investment strategy is established, GWAG’s portfolio managers continually monitor its
clients’ portfolios, making changes as needed.
Based on client suitability, risk tolerance, and investment objectives, their assets may be placed in any one
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or a combination of the following models:
Conservative (Income with Capital Preservation Objective)
Our most conservative investment objective. Emphasis is placed on generation of current income and
long-term preservation of capital. A lower risk level generally means lower overall return expectations. The
portfolio is constructed using a blend of open-end mutual funds and exchange-traded funds (ETF’s) with
special consideration given to each client’s portfolio size and tax situation.
Moderately Conservative (Income with Moderate Growth Objective)
Emphasis is placed on generation of current income with a secondary focus on moderate capital growth.
The portfolio is constructed using a blend of open-end mutual funds and exchange-traded funds
(ETF’s) with special consideration given to each client’s portfolio size and tax situation.
Moderate (Growth with Income Objective)
Emphasis is placed on modest capital growth with some focus on generation of current income. The
portfolio is constructed using a blend of open-end mutual funds and exchange-traded funds (ETF’s)
with special consideration given to each client’s portfolio size and tax situation.
Moderately Aggressive (Growth Objective)
Designed to achieve high long-term growth and capital appreciation. There is little focus on generation of
current income resulting in a higher risk portfolio. The portfolio is constructed using a blend of open-
end mutual funds and exchange-traded funds (ETF’s) with special consideration given to each client’s
portfolio size. Tax sensitivity is generally not a factor.
Aggressive (Aggressive Growth Objective)
Designed to achieve high long-term growth and capital appreciation. There is no focus on generation
of current income resulting in our highest risk portfolio. The portfolio is constructed using a blend of
open-end mutual funds and exchange-traded funds (ETF’s) with special consideration given to each
client’s portfolio size. Tax sensitivity is generally not a factor.
MARKET RISKS
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of GWAG’s recommendations and/or investment
decisions may depend to a great extent upon correctly assessing the future course of price
movements of stocks, bonds and other asset classes. There can be no assurance that GWAG will be able
to predict those price movements accurately or capitalize on any such assumptions.
MUTUAL FUNDS AND ETFS
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities
for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated
daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees,
redemption fees).
The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a
mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which
may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual
NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There
is also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or
more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder
may have no way to dispose of such shares.
REAL ESTATE INVESTMENT TRUSTS (REITS)
GWAG may recommend an investment in, or allocate assets among, various real estate investment trusts
(“REITs”), the shares of which exist in the form of either publicly traded or privately placed securities.
REITs are collective investment vehicles with portfolios comprised primarily of real estate and mortgage
related holdings. Many REITs hold heavy concentrations of investments tied to commercial and/or
residential developments, which inherently subject REIT investors to the risks associated with a
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downturn in the real estate market. Investments linked to certain regions that experience greater
volatility in the local real estate market may give rise to large fluctuations in the value of the vehicle’s
shares. Mortgage related holdings may give rise to additional concerns pertaining to interest rates,
inflation, liquidity and counterparty risk.
BUSINESS DEVELOPMENT COMPANIES (BDCS)
GWAG may recommend an investment in, or allocate assets among, various business development
companies (“BDCs”), the shares of which exist in the form of publicly traded securities. BDCs make
equity and debt investments in small companies that are in the “start up” phase of development.
Many BDCs invest in debt and equity securities of smaller companies that are privately held and lack
publicly available information, which inherently subject BDC investors to the risks associated with a
speculative market. BDC investors are subject to the risk that a company may default when unable to
meet its obligations. The market price of securities issued by a BDC may fluctuate significantly, and
BDCs investments may give rise to additional concerns pertaining to interest rates, inflation, and
liquidity.
VARIABLE ANNUITIES
GWAG may recommend an investment in various fee based annuities. Variable annuities are contracts
between an insurer and the insured under which the insurer agrees to make periodic payments to the
insured after a specified period of time. The payments are variable based upon the performance of a
subaccount in the insured’s policy. Variable annuities are long-term retirement investments and are tax-
deferred until money is withdrawn from the annuity account. Since variable annuities offer a range of
investment options in the subaccounts, including stocks, bonds, and money market instruments, they
subject variable annuity investors to the risks associated with market volatility.
USE OF INDEPENDENT MANAGERS
As stated above, GWAG may select certain Independent Managers to manage a portion of its clients’
assets. In these situations, GWAG continues to conduct ongoing due diligence of such managers, but
such recommendations rely to a great extent on the Independent Managers’ ability to successfully
implement their investment strategies. In addition, GWAG generally may not have the ability to
supervise the Independent Managers on a day-to-day basis.
VOTING OF CLIENT SECURITIES
GWAG generally does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf.
We may vote client securities only upon request. Clients receive proxies directly from the Financial
Institutions where their assets are custodied and may contact the Firm at the contact
information on the cover of this brochure with questions about any such issuer solicitations.
ITEM 7. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
In this Item, GWAG is required to describe the type and frequency of the information it communicates
to the Independent Managers, if any, managing its clients’ investment portfolios. Clients participating in
the Program generally grant GWAG the authority to discuss certain non-public information with the
Independent Managers engaged to manage their accounts. Depending upon the specific arrangement,
the Firm may be authorized to disclose various personal information including, without limitation:
names, phone numbers, addresses, social security numbers, tax identification numbers and account
numbers. GWAG may also share certain information related to its clients’ financial positions and
investment objectives in an effort to ensure that the Independent Managers’ investment decisions
remain aligned with its clients’ best interests. This information is communicated on an initial and
ongoing basis, or as otherwise necessary to the management of its clients’ portfolios.
ITEM 8. CLIENT CONTACT WITH PORTFOLIO MANAGERS
There are no restrictions on a clients’ ability to contact and consult with GWAG. Clients may contact
Independent Managers through GWAG by providing GWAG with written request and identification of the
questions or issues to be discussed with the Independent Managers. After receiving the client’s written
request GWAG, at its sole discretion, contacts the Independent Managers for the client or arranges for the
Independent Managers and the client to communicate directly.
ITEM 9. ADDITIONAL INFORMATION
DISCIPLINARY INFORMATION
GWAG is required to disclose the facts of any legal or disciplinary events that are material to a client’s
evaluation of its advisory business or the integrity of management. GWAG does not have any required
disclosures to this Item.
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OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATION
LEGAL SERVICES
Some of GWAG’s investment adviser representatives (“IARs”) are also licensed attorneys and provide
legal services through an independent, unaffiliated law firm. This creates a conflict of interest because
GWAG or other IARs may refer clients to these individuals for legal services, which could result in the
attorney IAR receiving outside compensation or other indirect economic benefit, in relation to the legal
fee payments. Any legal services are provided entirely outside GWAG under a separate agreement and
fee arrangement between the client and the law firm. Any compensation to the attorney may include
hourly legal fees, flat fees, or other arrangements paid directly by the referred client to the law firm.
GWAG does not receive any direct benefit in relation to this referral. GWAG may also refer clients to other
unaffiliated third-party estate planning attorneys. GWAG does not receive compensation for such
referrals and has no formal referral arrangement with these unaffiliated attorneys. Clients are under no
obligation to use any referred attorney.
GWAG supervises these individuals only in their capacity as IARs and does not supervise or assume
responsibility for the legal services they provide. Clients are not required to engage these attorneys and
may choose any legal professional. Additional details regarding each IAR’s outside business activities and
related conflicts are provided in the respective IAR’s Form ADV Part 2B brochure.
CODE OF ETHICS
GWAG has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that
sets forth the standards of conduct expected of its Supervised Persons. GWAG’s Code of Ethics
contains written policies reasonably designed to prevent certain unlawful practices such as the use of
material non-public information by the Firm or any of its Supervised Persons and the trading by the
same of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of GWAG’s personnel to report their personal securities holdings
and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited
offerings).
However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends
to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and
procedures. This Code of Ethics has been established recognizing that some securities trade in
sufficiently broad markets to permit transactions by certain personnel to be completed without any
appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions
may be made to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly affect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in
that security unless:
The transaction has been completed;
The transaction for the Supervised Person is completed as part of a batch trade with clients; or A
decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United
States;
(ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial
paper, repurchase agreements and other high quality short-term debt instruments, including
repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv)
shares issued by unit investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact GWAG to request a copy of its Code of Ethics.
REVIEW OF ACCOUNTS AND GENERAL REPORTS
GWAG monitors client portfolios and accounts on a continuous and ongoing basis Such reviews are
conducted by the Firm’s investment adviser representatives. All investment advisory clients are
encouraged to discuss their needs, goals and objectives with GWAG and to keep the Firm informed of
any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to
review its previous services and/or recommendations.
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. From time-to-time or as
otherwise requested, clients may also receive written or electronic reports from GWAG and/or an
outside service provider, which contain certain account and/or market-related information, such as an
inventory of account holdings or account performance. Clients should compare the account statements
they receive from their custodian with any documents or reports they receive from GWAG or an outside
service provider.
CLIENT REFERRALS
The Firm does not currently provide compensation to any third-party solicitors for client referrals.
WRAP FEE BROCHURE | Garrett Wealth Advisory Group, LLC | Last Updated – 08.31.2026
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OTHER COMPENSATION
GWAG is currently engaged in a loyalty program with its reporting software (Orion) to credit back a
portion of subscription costs dependent upon agreed on terms. GWAG participates in a loyalty, incentive,
or credit program offered by Orion Advisor Solutions, Inc. (“Orion”), a provider of portfolio-accounting,
reporting, technology, and related services to GWAG. Under this program, Orion may provide GWAG with
credits, discounts, reimbursements, or reductions in the subscription fees and other amounts GWAG
otherwise pays for Orion products or services. The availability and amount of these benefits may depend
on agreed-upon terms, which may include GWAG’s use of Orion products and services, the number of
accounts or amount of assets serviced through Orion, use of certain Orion-affiliated or third-party service
providers, or other program criteria. GWAG retains these benefits and does not credit them directly to
client accounts. This arrangement creates a conflict of interest because it provides GWAG with an
economic incentive to continue using Orion and, where applicable, to recommend or maintain client
accounts, investment programs, service providers, or other arrangements that may increase GWAG’s
eligibility for or amount of Orion-related benefits. GWAG addresses this conflict by evaluating its
technology, platform, custody, and service-provider relationships based on the quality, cost, capabilities,
service, security, and appropriateness of the services for clients and GWAG’s business, and not solely on
the availability of Orion credits or discounts. GWAG does not believe that its participation in the program
materially compromises its duty to act in clients’ best interests; however, clients should be aware of this
incentive when evaluating GWAG’s recommendations
In making a transition to Pershing, an economic transition arrangement will be payable to GWAG. This
economic transition arrangement is contingent upon GWAG moving assets to the Pershing platform and
maintaining a certain dollar amount of assets on the Pershing platform for a specified period of time. This
economic transition arrangement includes reimbursements for transition related costs, including but not
limited to transfer fees charged to clients during transfer process, software subscription fees, transition
team, etc.
FINANCIAL INFORMATION
GWAG is not required to disclose any financial information due to the following:
The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or
more in advance of services rendered;
The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
The Firm has not been the subject of a bankruptcy petition at any time during the past ten
years.
WRAP FEE BROCHURE | Garrett Wealth Advisory Group, LLC | Last Updated – 08.31.2026
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