Overview

Headquarters
Apex, NC
Total Firm Assets
$135 million
Average High-Net-Worth Client Portfolio Size
$1.4 million
Minimum Account Size
$10,000

Fee Structure

Primary Fee Schedule (BSG ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $1,000,000 2.00%
$1,000,001 and above 1.25%

Minimum Annual Fee: $50

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $70,000 1.40%
$10 million $132,500 1.32%
$50 million $632,500 1.26%
$100 million $1,257,500 1.26%

Clients

High-Net-Worth Share of Firm Assets
63.46%
Number of High-Net-Worth Clients
63
Total Client Accounts
676
Discretionary Accounts
676

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection, Educational Seminars

Regulatory Filings

SEC CRD Number
297243

Primary Brochure: BSG ADV PART 2A (2026-07-01)

View Document Text
Business-owner Strategies Group, LLC d/b/a BSG Advisers CRD 297243 56 Hunter Street, Suite 230 Apex, NC 27502 (919) 267-4753 www.bsgadvisers.com FORM ADV PART 2A BROCHURE Updated July 1, 2026 This brochure provides information about the qualifications and business practices of Business-owner Strategies Group, LLC. If you have any questions about the contents of this brochure, contact us at compliance@bsgadvisers.com or call 919-267-4753 and ask to speak with the Chief Compliance Officer (“CCO”). The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Business-owner Strategies Group, LLC is available on the SEC's website at www.adviserinfo.sec.gov. Business-owner Strategies Group, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Item 2 Summary of Material Changes Form ADV Part 2 requires Registered Investment Advisers to amend their brochure annually or when information becomes materially inaccurate. If there are any material changes to our disclosure brochure, we are required to notify you and provide you with a description of the material changes. Since our last brochure update dated January 12, 2026, we have made the following material changes, effective July 1, 2026: Item 4 – We have updated the description of our advisory business to better describe how we provide investment management services through third-party managed account platforms, sub- advisers, model providers, and related technology. Item 5 – We have updated the methodology for billing investment management fees from quarterly in advance, based on quarter-end account values, to monthly in arrears, based on the average daily balance of billable assets. Item 8 – We have updated the description of our investment philosophy, portfolio construction approach, methods of analysis, investment strategies, and related risks. Item 10 – We have updated our disclosures regarding the conflicts of interest associated with our use of third-party managed account platforms, sub-advisers, model providers, and related technology providers. Item 12 – We have updated our brokerage practices disclosure to better describe how client accounts may be traded, administered, and supported through custodians, third-party managed account platforms, sub-advisers, and related technology providers. Item 13 – We have updated our account review disclosure to better describe our review of client portfolios, investment models, sub-advisers, third-party managed account platforms, and related services. Item 15 – We have updated our custody disclosure to better describe the process by which advisory fees are calculated, submitted, and deducted from client accounts. 2 Item 3 Table of Contents Item 2 Summary of Material Changes ................................................................................. 2 Item 3 Table of Contents..................................................................................................... 3 Item 4 Advisory Business .................................................................................................... 4 Item 5 Fees and Compensation .......................................................................................... 9 Item 6 Performance-Based Fees & Side-By-Side Management .........................................14 Item 7 Types of Clients ......................................................................................................14 Item 8 Analysis Methods, Investment Strategies & Risk of Loss ........................................14 Item 9 Disciplinary Information ...........................................................................................17 Item 10 Other Financial Industry Activities & Affiliations .....................................................17 Item 11 Code of Ethics, Interest in Client Transactions, & Personal Trading ......................18 Item 12 Brokerage Practices ..............................................................................................19 Item 13 Account Reviews ..................................................................................................20 Item 14 Client Referrals & Other Compensation ................................................................20 Item 15 Custody ................................................................................................................20 Item 16 Investment Discretion ...........................................................................................21 Item 17 Voting Client Securities .........................................................................................21 Item 18 Financial Information .............................................................................................21 3 Item 4 Advisory Business Firm Description Business-owner Strategies Group, LLC (d/b/a/ BSG Advisers) is a Registered Investment Adviser (RIA) based in Apex, NC. The company is organized as a limited liability company (LLC) under the laws of the State of North Carolina. We have been providing investment advisory services since September 2018. The firm is owned by Intelligent Insights, Inc. (wholly owned by Robert Picha), TLA Group, Inc. (wholly owned by Laird Hepburn), and Wealth CAPS, Inc. (wholly owned by Justin Struble), each holding a minority ownership interest. Robert Picha, Laird Hepburn, and Justin Struble are also managers of BSG Advisers and are actively involved in the firm’s day-to-day operations. The following paragraphs describe our services. Refer to the description of each investment advisory service listed below for information on how we tailor our services to your individual needs. As used in this brochure, the words "BSG", "BSG Advisers", "we," "our," and "us" refer to Business-owner Strategies Group, LLC, and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. We offer a broad range of services including the following: • Financial Education • Educational Seminars Insurance Planning • • Financial Planning & Consulting • Investment Management • Pension Consulting • Retirement Plan Services Clients who enter into agreements with us do so with the understanding that, under the Investment Advisers Act of 1940, BSG Advisers is engaged in the business of providing investment advice and does so for compensation and therefore is subject to a fiduciary standard of care. BSG Advisers acts in its clients’ best interest and provides full and fair disclosure of all material conflicts of interest. Financial Planning & Consulting Services We provide a wide range of financial planning and consulting services that are broadly broken into either personal planning services or business planning services. These are further broken down into the following discrete services which we describe in subsequent sections: • Comprehensive Financial Planning • Continuous Financial Planning • Business-oriented Financial Planning • Business or Personal Financial Consulting Comprehensive Financial Planning involves helping clients manage their financial resources to move toward their stated goals. When you engage us for financial planning, we use a systematic process to understand your needs, wants and wishes as well as your resources, time horizons, and constraints. Our process largely parallels the 7-Step CFP® Financial Planning Process: 5. Present clear, written recommendations. 6. Implement agreed-upon recommendations. 7. Monitor progress and regularly update. 1. Understand your financial situation. 2. Help you identify, quantify, and set goals. 3. Analyze possible courses of action. 4. Develop recommendations and rationales. 4 Planning is usually broad-based and comprehensive with a focus on helping you achieve your financial goals over multiple years. If you engage our firm for this service, we will complete an agreement to specify the scope of services we will provide, the price for such services, the term of the agreement, and our refund policy. Some of the topics we cover include: • Financial Position • Protection / Insurance Analysis • Cash Flow Analysis • Education Funding • Funding Retirement • Non-retirement Goals • Investment Analysis • Tax and Estate Planning Considerations The output of our collaborative planning process is a financial plan deliverable that you can use to implement actions on your own, in collaboration with us, or with an entirely different service provider. During the planning process, we integrate clients into our Triangular Review System© where we request to meet three times per year to discuss changes in goals, plans, investments, insurance, taxes, and estate plans. Continuous Planning is an optional service that is only available to clients who have already completed Comprehensive Financial Planning. The goal of Continuous Planning is to ensure your plan stays on track and that necessary changes are identified early on so proper action can be taken. If you engage our firm for this service, we will complete an agreement to specify the scope of services we will provide, the price for such services, the term of the agreement, and our refund policy. Continuous Planning agreements are open-ended, month-to-month, and do not expire. Either party may terminate these services with proper notice as defined in the agreement. Business-oriented Financial Planning typically involves helping business-owner clients in getting good answers to important questions related to: • Business Succession Planning • Buy / Sell Design and Funding • Executive / Deferred Compensation • Key Person Protection • Tax and Estate Planning • Business Value Estimation Such services are often single-topic engagements. If you engage our firm for this service, we will complete an agreement to specify the scope of services we will provide, the price for such services, the term of the agreement, and our refund policy. The output of our collaborative planning process is a deliverable that you can use to implement actions on your own, in collaboration with us, or with an entirely different service provider. Business Planning agreements expire the earliest of completion of the scope of work, six (6) months from the effective agreement date, or upon termination in writing by either party. Business or Personal Financial Consulting is appropriate when a financial plan isn’t called for, such as when a client needs specific information about a narrow topic that can be addressed during a single meeting. For example, you may want our opinion on your existing investment portfolio, or our perspective on a pending business decision. In such cases, our services are restricted to the specific topic under consideration. Topics may include any financial planning topic, or related topics about which we have expertise. 5 Consulting services are not suitable for complex topics involving ongoing analysis. If you engage our firm for this service, we will complete an agreement to specify the scope of services we will provide, the price for such services, the term of the agreement, and our refund policy. There is no deliverable associated with these services and the engagement generally concludes with a single meeting, although this is negotiable with your adviser. Investment Management Services We provide investment management services to individuals, families, trusts, corporations, and other business entities on a discretionary basis. Our investment advice is tailored to meet your needs and investment objectives. If you engage our firm for investment management services, we will complete an agreement to specify the scope of services we will provide, the price for such services, the term of the agreement and our refund policy. Investment management agreements generally continue until terminated in writing by either party, death of an account owner, or upon your closure of accounts. When we provide investment advice to you regarding retirement plan accounts or Individual Retirement Accounts (IRAs), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code (IRC), as applicable. These laws govern retirement accounts, and we are required to disclose conflicts of interest and abide by impartial conduct standards. Prior to making a recommendation regarding moving (or not moving) an account, we will provide you with a clear explanation as to why we deem our recommendation to be in your best interest. Our internal policies and procedures are designed to ensure we deliver on this requirement. If you wish to have us manage your assets, we require you to grant our firm discretionary authority to manage your account(s). Discretionary authority allows us to determine the specific securities, quantity of securities, and timing of purchase or sale for your account(s) without your approval prior to each transaction. Discretionary authority is granted by the agreement you sign with our firm along with trading authorization forms that a custodian may require. You may limit our discretionary authority by providing our firm with your restrictions and guidelines in writing. As part of our investment management services, we may select one or more sub-advisers, third-party money managers, model providers, investment strategists, platform providers, technology providers, and related service providers to help manage all or a portion of your account(s). We refer to these providers collectively in this brochure as “Managed Account Providers.” Managed Account Providers may support or perform functions including portfolio administration, managed account implementation, model delivery, sleeve accounting, trading, rebalancing, performance reporting, fee calculation, billing support, and other operational or investment-related services. After gathering information about your financial situation, objectives, restrictions, risk tolerance, time horizon, liquidity needs, tax considerations, and other relevant circumstances, we may recommend that your account(s) be managed through one or more Managed Account Providers. These arrangements may be used for all or a portion of your account(s) and may include separately managed account, unified managed account, model-based, or sleeve-based portfolio structures. You authorize us, or a Managed Account Provider selected by us, to provide instructions to the custodian of your account(s) in furtherance of our discretionary authority. We may allocate all or a portion of your assets among various individual debt or equity securities, mutual funds, exchange- 6 traded funds, cash or cash equivalents, model portfolios, separately managed account sleeves, or other securities consistent with our investment process, your investment objectives, and our disclosures. Factors we consider when selecting, recommending, or using Managed Account Providers include, but are not limited to, the provider’s investment process, services, technology, trading capabilities, operational capabilities, price, performance, methods of analysis, investment strategies, available investment vehicles, reporting, custody compatibility, and ability to support our investment management process and your financial needs, time horizon, risk tolerance, investment objectives, and restrictions. We remain responsible for providing advisory services under our agreement with you. We monitor the services, performance, investment approach, operational support, and continued appropriateness of Managed Account Providers we use or recommend. We may add, remove, or replace any such provider, model, strategy, or service arrangement without obtaining your prior approval, unless otherwise required by your agreement with us or applicable law. Pension Consulting & Retirement Plan Services We assist employers considering sponsoring a retirement plan as well as those who already have a plan. We provide a range of ongoing fiduciary (as defined by ERISA) and non-fiduciary (as defined by ERISA) services to existing plans. If you engage our firm for pension consulting services, we will complete an agreement to specify the scope of services we will provide, the price for such services, the term of the agreement and our refund policy. Pension consulting agreements generally continue for the lesser of six months, completion of the scope of services, or termination in writing by either party. Pension consulting services include but are not limited to: • Plan Design • Vendor Selection • Price Negotiation • Plan Implementation We offer ongoing retirement plan services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the Plan Sponsor or named fiduciary. If you engage our firm to provide retirement plan services, we will complete an agreement to specify the scope of services we will provide, the price for such services, the term of the agreement, and our refund policy. Retirement plan agreements generally continue until terminated in writing by either party, or upon closure of all plans you have with us. Our services include: Investment Monitoring • Plan Benchmarking • Non-discretionary Investment Advice • • Performance Reporting Investment Committee Support • • Vendor Management Assistance When providing Retirement Plan Services, we act as a fiduciary under ERISA Section 3(21) with respect to the investment advice we provide. We do not act as an ERISA Section 3(38) investment manager and do not exercise discretionary authority over the Plan’s assets. Pension Consulting and Retirement Plan Services are non-discretionary and advisory in nature. These services are not portfolio or investment management services. The ultimate decision to act remains with the client. 7 We may assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as diversification, asset allocation, and risk tolerance. Such educational seminars may include other investment-related topics specific to the plan. Financial Education & Educational Seminars We offer two types of financial education events: one-time speaking or training events, generally referred to as seminars, and ongoing, systematic financial education, generally referred to as a “Financial Wellness” program. We offer the latter to companies, clubs, civic groups, and similar entities as a workplace benefit. We have designed our Financial Wellness program to be delivered systematically with the objective of helping employees increase their general knowledge about a variety of personal finance topics including asset allocation, budgeting, making use of retirement investment accounts, uses of personal insurance, and college planning. These services may be at no charge or for a fee depending on the specific scope of services. If you engage our firm for financial education or seminar services, we will work with you to define a clear engagement letter that specifies the scope of services we will provide, the price for such services, the term of the agreement, and our refund policy. Insurance Planning Investment Adviser Representatives (IARs) who provide advice on behalf of our firm may be licensed insurance agents and may assist you in identifying insurance products for personal or business planning purposes. If you engage the assistance of our advisers in obtaining such insurance, the adviser may earn commission-based compensation. This creates a conflict of interest as IARs might be incentivized to recommend insurance products based on commission rather than solely considering your needs. You are under no obligation, contractual or otherwise, to purchase insurance products through any person affiliated with our firm. Insurance commissions earned by advisers are separate from our advisory fees. Other Items Regarding our Advisory Business Assets Under Management – As of December 31, 2025, BSG Advisers had $134,763,000 in regulatory discretionary assets under management and $13,000,000 in other non-regulatory non- discretionary assets under advisement. Disclosure Regarding Department of Labor Prohibited Transaction Exemption 2020-02 – When we provide you investment advice regarding retirement plans or individual retirement accounts, we are fiduciaries within the meaning of ERISA and/or the IRC, as applicable, which are laws governing retirement accounts. The way we are compensated creates some conflicts with your interests. We operate under this exemption’s conditions which require us to: • Meet a professional standard of care when making investment recommendations; • Never put our financial interests ahead of yours when making recommendations; • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. 8 Wrap Fee Programs – We do not participate in any wrap fee program. Types of Investments – We offer advice on equity securities, corporate debt securities (other than commercial paper), municipal securities, mutual fund shares, United States government securities, money market funds, REITs, and ETFs. We may advise you on multiple types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Item 5 Fees and Compensation We do not require or solicit prepayment of more than $1,200 per client, six months or more in advance, for any service. Where appropriate, we have listed our standard minimum and maximum fees. All fees discussed below are negotiable. Financial Planning & Consulting Services Comprehensive Financial Planning and Continuous Planning are fixed-fee offerings with the cost based upon the scope and complexity of your financial situation. Our agreements for these services disclose our fee, payment terms, and refund policy. Comprehensive planning fees are generally between $3,000 and $6,000, and our standard minimum fee is $1,500. We do not have a maximum fee. Continuous Planning fees are based upon your Comprehensive Financial Planning fee and generally start at $50 per month up to a maximum of one twelfth (1/12) of your Comprehensive Financial Planning fee. You may pay for Comprehensive Financial Planning with full or partial up-front payment and up to 50% upon delivery, or by monthly installment at no additional cost. Continuous Planning is charged monthly, in advance. We will not begin working on your plan until we have received initial payment. Business-oriented Financial Planning Services are only provided on an hourly basis. Based upon the complexity of the proposed scope of work, we will provide an estimate of the hours of effort required to deliver our services and the hourly rate we will charge for such services. Our standard minimum hourly fee is $150, and our maximum hourly fee is $450. The rate is based upon the IAR’s expertise and experience. Our standard minimum fee for these services is $750. When working on an hourly basis, you agree we may bill you for an additional number of hours if our initial estimate is insufficient to complete the agreed-upon work. This additional number of hours will be specified in the agreement. If we are unable to complete the services within the total hours, we will advise you promptly and discuss options to modify the scope of the agreement or increase the fee estimate. All changes in the scope of services or estimated fee will be documented in an amendment signed by all parties. You may request a copy of a blank agreement to review by emailing us. We may require you to pay at least 25% of the estimated cost of Business planning up front before we begin work. You are welcome to pay the entire estimated cost. We will invoice you monthly for any remaining costs on an as-earned basis. Upon termination of an agreement, we will refund any unearned fee as may be applicable. 9 Business or Personal Financial Consulting Services are only provided on an hourly basis. Our standard minimum hourly fee is $150, and our maximum hourly fee is $450 with a standard one (1) hour minimum. We will bill you for our time upon the completion of the engagement. Investment Management Services We charge an asset-based fee for investment management services. Our agreement discloses our fee, payment terms, and refund policy. Our investment management fee is negotiable and applies only to Billable Assets. Our standard minimum account size is $10,000. We may waive our account minimum on a case-by- case basis depending on a client’s specific circumstances. Our standard minimum annual investment management fee is the greater of 0.35% per year or $50, subject to the maximum fee described below. Our maximum annual investment management fee is 2.00% per year for account balances less than or equal to $1,000,000 and 1.25% per year for the portion of an account that is over $1,000,000, as shown in the following table. Unless otherwise disclosed in writing, compensation for Managed Account Providers is paid from the investment management fee charged under the agreement and does not result in an additional advisory fee to you. Annual Investment Management Fee Schedule Maximum Annual Fee Billable Assets in Each Account 2.00% The first $1,000,000 1.25% The amount over $1,000,000 For purposes of our investment management agreement, “Billable Assets” generally means all assets in the account(s) we manage other than funds held in the primary cash position. We charge investment management fees monthly, in arrears, based on the number of days in the preceding calendar month. We calculate the fee using the Average Daily Balance (“ADB”) of Billable Assets in each account during the billing period. We calculate ADB by summing the daily ending value of Billable Assets in the account and dividing by the number of days in the month. Monthly Fee = (ADB × Applicable Annual Rate ÷ Days in the Year) × Days in Month For purposes of this formula, “Applicable Annual Rate” means the annual fee rate stated in your investment management agreement. Your agreement may state a single annual fee rate or a tiered fee schedule that applies different annual fee rates to different levels of Billable Assets. For partial months, we will pro-rate your fee for the portion of the month during which we provided investment management services. Because investment management fees are billed monthly in arrears, there will generally be no unearned investment management fees to refund upon termination. Upon termination, we will calculate any final fee earned from the beginning of the current billing month through the effective date of termination. We may deduct this final fee from your account(s) before liquidation or transfer. If your account(s) are closed, transferred, or otherwise unavailable before we can deduct the final fee, we may invoice you directly, and such invoice is payable upon receipt. 10 If we accept management of an account where our standard minimum fee based on the account size would exceed 2.00%, we will reduce our fee to comply with the 2.00% limit. We calculate fees at the individual account level unless otherwise agreed in writing. We may charge less than the fee specified in the agreement, and we may apply temporary or permanent fee reductions without requiring a signed amendment. Any such reduction does not waive our right to charge the agreed fee in a later billing period. We will not increase your annual fee rate or tiered fee schedule without your written consent. This brochure and our investment management agreement authorize us to charge your account(s), or a related account if so authorized, for our investment management fee in accordance with applicable regulatory procedures. You instruct and authorize the qualified custodian to deduct our fee from your account(s), generally within the first ten business days of each calendar month for the preceding month, and to pay the fee to us, our designated billing agent, or another advisory program provider, as applicable. This authorization is intended to permit fee deduction from your account(s) in accordance with applicable custody rule requirements. Your qualified custodian will send account statements, at least quarterly, showing all account activity, including advisory fee deductions. You should carefully review your custodian statements and compare them with any fee information we provide. If you wish to hold unmanaged positions, you must hold such assets in a separate, non-managed account not subject to the investment management agreement. Selection of Other Advisers As discussed in Item 4, we may use Managed Account Providers to help us provide investment management services. Unless otherwise disclosed in writing, compensation for Managed Account Providers is paid from the investment management fee charged under our agreement and does not result in an additional advisory fee to you. Managed Account Provider costs vary based on the provider, strategy, platform, services, and investment arrangement. When these costs are paid from our investment management fee, they reduce the net compensation retained by BSG Advisers. Because Managed Account Provider costs, services, technology, and operational arrangements vary, we have a conflict of interest when selecting or recommending Managed Account Providers. We address this conflict by disclosing it, considering whether the arrangement is appropriate for the client, monitoring the services provided, and retaining responsibility for the advisory services provided under our agreement with you. If we use a Managed Account Provider for all or a portion of your account, that provider, a qualified custodian, our designated billing agent, or another advisory program provider may assist with fee calculation, fee deduction, trading, reporting, portfolio administration, or other services. You should carefully review your custodian statements and any fee information we provide. Additional Fees and Expenses Our investment management fee does not include expenses charged by mutual funds, exchange- traded funds, similar investment products, custodians, broker-dealers, or other service providers. These expenses may include fund management fees and expenses, account fees, wire fees, transfer fees, 11 termination fees, margin interest, transaction charges, ticket charges, custodial charges, brokerage charges, or similar fees. These charges are separate from our fee and are your responsibility. We do not share in any portion of custodian, brokerage, transaction, or fund expenses charged to your account. To fully understand your total investment management costs, you should review all fees and expenses charged by your custodian, funds, our firm, Managed Account Providers, and others. For information on our brokerage practices, refer to Item 12. Pension Consulting & Retirement Plan Services Pension Consulting Services are offered on an hourly- or fixed-fee basis depending upon the complexity and scope of services. If you engage us for Pension Consulting, our agreement with you will disclose our fee, payment terms, and refund policy. Our maximum hourly fee is $450 and is negotiable. Fixed-fee consulting generally costs between $2,000 and $10,000. We have neither a specified minimum nor maximum fixed fee. For fixed-fee engagements, we will provide a fixed price for the consulting engagement. For hourly engagements, we will provide an estimate of the hours of effort required to deliver our services and the hourly rate we will charge for such services. When working on an hourly basis, you agree we may bill you for an additional number of hours if our initial estimate is insufficient to complete the agreed-upon work. This additional number of hours will be specified in the Agreement. If we are unable to complete the scope of services within the total hours, we will advise you promptly and discuss options to modify the scope of the Agreement or increase the fee estimate. All changes in the scope of services or estimated fee will be documented in an amendment signed by all parties. You may pay for fixed-fee consulting engagements by monthly or quarterly invoice with substantially- equal invoices. We will issue an initial invoice upon acceptance of the consulting agreement by all parties. Upon termination of an agreement, we will refund any unearned fee. You may pay for hourly-fee consulting engagements by monthly or quarterly invoice as earned. We will issue an initial invoice upon acceptance of the consulting agreement by all parties. This payment will be credited to the total cost estimate, and subsequent invoices will be as earned. Upon termination of an agreement, we will refund any unearned fee. If we are unable to deliver the agreed-upon consulting services within six months of agreement acceptance, we will refund any unearned fee. We charge asset-based fees and flat fees for Retirement Plan Services. The agreement discloses our fee, payment terms, and refund policy. If we agree to asset-based compensation, your fee will not exceed 1.00% per year on Plan assets. We will calculate the fee based upon the closing value of Plan assets (less any excluded assets) on the last business day of the preceding calendar quarter using this formula: Quarterly Fee = (The Prior Quarter’s End Plan Assets Value x Annual Fee Rate) / 4 Participants’ separate brokerage accounts and non-publicly-traded securities or property (other than collective trusts and similar vehicles) are excluded assets for the purpose of calculating this fee. 12 An agreement established at any time other than the first day of a calendar quarter is subject to a pro- rated fee. The fee is payable for the proportion of days in the calendar quarter for which we provide retirement plan services. You may pay asset-based fees either directly from Plan assets, by invoice to the Plan Sponsor, or a combination of these. When paying by invoice to the Plan Sponsor, we charge our fee in advance, at the beginning of each calendar quarter calculating the fee as described in the preceding section. Each calendar quarter, we will send you an invoice detailing the fee and the way we calculated it. When fees are paid directly from Plan assets, your Recordkeeper, meaning the entity that maintains participant account balances, transactions, and retirement plan records, will calculate the fee. The exact timing and manner of calculation will be disclosed in your recordkeeping agreement, which requires the signature of both a Plan trustee and a Member of BSG Advisers. Some Recordkeepers deduct fees monthly or quarterly in advance while others deduct fees in arrears. BSG Advisers will abide by your Recordkeeper’s protocols for calculating and paying our fee. Upon termination of an agreement, we will work with your Recordkeeper to credit unearned fees back to your Plan or, if invoiced to the Plan Sponsor, we will refund any unearned fee. If we agree to flat-fee compensation, we will base our fee on the size and complexity of the Plan. Our standard minimum annual charge for flat-fee retirement plan services is $750 and may include an annual fee increase on each anniversary of the agreement not to exceed 5% compounded annually. We have no specified maximum fee. For flat fees totaling less than $1,200 per year, we may bill you annually. For higher fees, we bill quarterly in advance using this formula: Quarterly Fee = Annual Fee / 4 An agreement established at any time other than the first day of a calendar quarter is subject to a pro- rated fee. The fee is payable for the proportion of days in the calendar quarter for which we provide retirement plan services. You may pay flat fees either directly from Plan assets or by invoice to the Plan Sponsor. When you elect to have fees paid by invoice, we will send you an invoice detailing the fee and the way we calculated it. If you elect to have fees deducted from Plan assets, you grant BSG Advisers the authority to have fees automatically deducted from the Plan’s accounts and remitted to us upon your Recordkeeper’s receipt of our invoice. Upon termination of an agreement, we will work with your Recordkeeper to credit unearned fees back to your Plan or, if invoiced to the Plan Sponsor, we will refund any unearned fee. Financial Education & Educational Seminars We charge hourly and fixed fees for education and seminar services. Fees for educational seminars can range from $0 to $5,000 per session and are based on the size and complexity of the expected work. The fee for our Financial Wellness program is determined on a case-by-case basis starting at $50 per employee per year. Factors we consider in terms of pricing include the total annual number of sessions, the degree of content customization, and the direct cost of delivering the service. For example, a single-site company where we deliver six standard sessions in a single year will be priced differently than a multi-site 13 company where we deliver the same content but must do so multiple times to achieve the employer’s intended purpose. Similarly, two nearly-identical companies may have different per-employee pricing if one company desires content customization beyond our typical offerings. In all cases, our fee is negotiable. If you engage us for these services, the engagement agreement will disclose our fee, payment terms, and refund policy. Upon termination of an agreement, we will refund any unearned fee. Insurance Planning Advisers providing investment advice on behalf of our firm may be licensed insurance agents. These advisers may earn commission-based compensation for selling insurance products. Insurance commissions earned by these advisers are separate and distinct from our advisory fees. This practice presents a conflict of interest as discussed in Item 10. Item 6 Performance-Based Fees & Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. We calculate our fees as described in Item 5. Item 7 Types of Clients We offer investment advisory services to individuals (other than high net worth individuals), high net worth individuals, families, trusts, pension, and profit-sharing plans (but not the plan participants), charitable organizations, corporations, and small businesses. Our typical client has at least $250,000 in investable assets. Item 8 Analysis Methods, Investment Strategies & Risk of Loss Investment Philosophy Our investment philosophy generally begins with the view that long-term investment portfolios should be growth-oriented unless a client’s needs support a different approach. We believe ownership of productive securities, including equity and other growth-oriented investments, is generally essential to long-term growth, purchasing power preservation, and wealth accumulation. We tailor portfolios based on each client’s financial plan, objectives, risk tolerance, risk capacity, time horizon, income needs, liquidity needs, tax sensitivity, restrictions, and other relevant factors. This does not mean every account will be fully invested in growth assets. It means we begin with a preference for long-term exposure to productive assets and then adjust when a client’s needs call for more liquidity, income, stability, diversification, tax sensitivity, or risk reduction. Investment Strategies Our primary approach generally emphasizes diversified portfolios using mutual funds, exchange-traded funds, model portfolios, separately managed account sleeves, individual securities where appropriate, cash or cash equivalents, and Managed Account Providers. Our investment strategies may include 14 long-term purchases, asset allocation, strategic allocation, tactical adjustments, dollar-cost averaging, rebalancing, model-based investing, separately managed account sleeves, and unified managed account structures. We may design, select, or use investment models for different purposes, including growth, income, liquidity, risk reduction, tax sensitivity, or other client objectives. We may use different models or portfolio sleeves within a single account or household. We may adjust allocations, replace investments, replace models, or change Managed Account Providers when we believe doing so is appropriate. Client accounts may hold individual stocks, bonds, mutual funds, exchange-traded funds, cash or cash equivalents, separately managed account sleeves, model portfolios, or other securities consistent with our investment process and disclosures. We typically do not rely on individual security selection as the primary driver of portfolio construction. Upon client request, and where appropriate, we may use or recommend covered-call or other options strategies. Options strategies involve additional risks and are not suitable for all clients. Methods of Analysis Our analysis focuses primarily on asset allocation, portfolio construction, investment strategy selection, model design, fund and ETF analysis, Managed Account Provider review, and implementation. We evaluate investments, models, and providers using information we believe to be relevant, which may include market conditions, asset-class characteristics, valuation, expenses, liquidity, tax characteristics, diversification, concentration, benchmark fit, factor exposure, historical performance, downside risk, manager process, provider process, and the role of investments or strategies within portfolios. We maintain an Investment Committee process to evaluate investment philosophy, model construction, investment options, third-party models, Managed Account Providers, and other investment-related matters. As part of this process, we may review absolute returns, relative returns, risk-adjusted returns, volatility, drawdowns, benchmark comparisons, correlation among positions or asset classes, costs, tax characteristics, liquidity, and other quantitative or qualitative factors. We generally favor investments, models, and strategies that we believe offer a favorable relationship between expected risk and expected return, but no metric or analysis guarantees future results. Our analysis is based on information we believe to be reliable, but that information may be incomplete, inaccurate, or subject to change. Historical performance, risk statistics, correlation data, and other analytical measures are backward-looking and may not predict future performance or future risk. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. We do not guarantee future performance of any account, investment strategy, investment product, model portfolio, Managed Account Provider, or financial plan. Although we seek to manage accounts consistent with documented objectives, restrictions, and investment profiles, there is no guarantee that our efforts will be successful. 15 Our growth-oriented investment philosophy may result in higher exposure to equity, equity-like, or other growth assets than a more conservative approach. These assets can experience significant short-term and long-term declines. Portfolios designed for long-term growth may underperform more defensive strategies during market declines, recessions, rising-rate environments, or periods when growth- oriented investments are out of favor. Common investment risks include market risk, equity risk, interest-rate risk, credit risk, inflation risk, and liquidity risk. These risks may affect security prices, fund values, account values, income, purchasing power, and the ability to sell investments at an acceptable price or within an acceptable time. Asset allocation and diversification do not guarantee a profit or protect against loss. Different asset classes, sectors, factors, models, and strategies may perform differently than expected. Rebalancing and tactical adjustments may cause accounts to sell assets that later outperform or buy assets that later underperform. Concentration risk may arise when portfolios, models, funds, or strategies have meaningful exposure to a particular asset class, sector, factor, issuer, manager, investment theme, or economic trend. Concentrated exposure can help portfolios when the area of concentration performs well, but it can also increase losses or volatility when that area performs poorly. Model-based strategies and Managed Account Providers involve additional risks. A model, strategy, manager, platform, technology provider, or sub-adviser may perform poorly, deviate from expectations, experience operational failures, use incorrect data, implement trades differently than expected, or fail to achieve its intended objective. We monitor Managed Account Providers we use or recommend, but monitoring does not eliminate these risks. Conflicts related to Managed Account Providers are discussed in Items 5 and 10. Technology and operational risk may arise from trading, reporting, billing, data, rebalancing, model delivery, platform systems, cybersecurity incidents, or other operational processes. Errors, outages, delays, interruptions, unauthorized access, or inaccurate data may affect account management, reporting, billing, trading, or the timing and accuracy of portfolio changes. Options strategies, including covered calls, involve additional complexity and are not suitable for all clients. Covered-call strategies may generate income but can limit upside participation and may not protect against losses in underlying investments. Tax Considerations Our strategies and investments may have tax implications. Unless we specifically agree otherwise in writing, tax efficiency is not our primary consideration in managing your assets. We recommend that clients consult with a qualified tax professional regarding the tax consequences of investments, transactions, withdrawals, and other financial decisions. 16 Item 9 Disciplinary Information Neither Business-owner Strategies Group, LLC (BSG Advisers) nor any of its management persons has any legal or disciplinary events to disclose that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Item 10 Other Financial Industry Activities & Affiliations Insurance Planning Our IARs may be licensed insurance agents holding appointments with multiple insurance companies. As such, they can receive separate, yet customary, commission compensation resulting from the sale of insurance products from those companies. Examples of these products include life insurance, disability insurance, long-term care insurance, and annuities. This presents a conflict of interest because insurance-licensed advisers providing investment advice on behalf of our firm may have an incentive to recommend insurance products to you. You are under no obligation, contractual or otherwise, to purchase insurance products through any person affiliated with our firm. We take the following steps to address this conflict: • We disclose the existence of all material conflicts of interest, including the potential for our firm or our advisers to earn compensation from clients in addition to our advisory fees. • We explain that clients have no obligation to purchase recommended products from our advisers. • We conduct regular reviews of adviser recommendations to ensure they are suitable for our client’s needs. • We require our advisers to disclose and obtain approval for all outside business activities so we can properly address conflicts of interest. • We monitor outside business activities to verify conflicts of interest continue to be properly addressed by our firm. • We educate our advisers regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for the advice provided to clients. Recommendation of Other Advisers Unless otherwise disclosed in writing, compensation for Managed Account Providers (discussed in Items 4 and 5) is paid from our investment management fee and does not result in an additional advisory fee to you. Provider costs, services, technology, investment options, and operational arrangements vary, which creates a conflict of interest because we may have an incentive to recommend or use one provider over another. We address this conflict by disclosing it, considering whether the arrangement is appropriate for the client, conducting due diligence, monitoring services provided, and retaining responsibility for advisory services under our agreement with you. You are not obligated to use a Managed Account Provider we recommend unless that provider is required for a program, strategy, model, account structure, or service arrangement you choose. 17 Other Activities and Affiliations We do not have any relationship or arrangement with any reportable entity that is material to our advisory business or to our clients. None of our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. None of our management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Item 11 Code of Ethics, Interest in Client Transactions, & Personal Trading Our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Under the Investment Advisers Act of 1940, BSG Advisers is subject to a fiduciary standard of care. Our goal is to always protect your interests. All persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm are also required to report any violations of our Code of Ethics. We maintain and enforce written policies designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients, or prospective clients, may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions Neither our firm nor any person associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. Personal Trading Practices Our firm, or persons associated with our firm, may buy, sell, or hold the same securities, funds, exchange-traded funds, or other investments that we recommend to you or that are held in client accounts. A conflict of interest may exist because we or persons associated with our firm could have an incentive to trade for personal accounts in a way that benefits us or them rather than our clients. To mitigate this conflict, it is our policy that neither our firm nor persons associated with our firm shall have priority over client accounts in the purchase or sale of securities. Our Code of Ethics requires persons with trading authority to disclose all accounts in which they have a beneficial interest and to provide quarterly transaction statements. Our compliance team reviews quarterly statements to monitor adherence to our Code of Ethics. Persons associated with BSG Advisers are prohibited from participating in an initial public offering without first seeking written approval from the CCO. Any person wishing to purchase or sell a security obtained through a private placement must first seek written approval from the CCO. Participation in investment clubs must be approved in writing by the CCO before any such participation. Each of these policies is intended to protect the interests of our clients. 18 Item 12 Brokerage Practices Your assets must be maintained in an account at a “qualified custodian” (a broker-dealer or bank). We seek to recommend a custodian that will hold your assets and execute transactions on terms that are favorable compared to other available providers and their services. We recommend the brokerage and custodial services of Fidelity Brokerage Services (Fidelity) or Charles Schwab & Co., Inc (Schwab), both of which are unaffiliated SEC-registered broker-dealers. In recognition of the value of the services these custodians provide, you may pay higher trading costs than those that may be available elsewhere. When recommending a custodian, we consider a range of factors, including: • Capability to buy and sell securities for your account itself or to facilitate such services; • The likelihood that your trades will be promptly executed; • Availability of investment research and tools; • Overall quality of services; • Price competitiveness; • Reputation, financial strength, and stability; and • Existing relationship with our firm and our other clients. In limited circumstances, and at our discretion, some clients may instruct our firm to use a different custodian for transactions in their accounts. If you choose to direct our firm to use a particular custodian, you should understand that this might prevent our firm from effectively negotiating trading costs on your behalf. This practice may also prevent our firm from obtaining favorable net price and execution. We encourage you to consider whether the expenses, execution, clearance, and settlement capabilities that you may obtain through your directed custodian are favorable in comparison to those that we would otherwise obtain for you. Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements with any custodian, broker-dealer, or Managed Account Provider. Brokerage for Client Referrals We do not receive client referrals from any custodian, broker-dealer, sub-adviser, or Managed Account Provider in exchange for cash or any other form of compensation. Nor do we receive any benefits for client referrals to any party. Block Trades When BSG Advisers trades directly, we do not combine multiple orders for shares of the same securities purchased or sold for advisory accounts we manage. Accordingly, clients may pay different prices for the same securities transactions than other clients pay, and we may not be able to buy or sell the same quantities of securities for all clients. Managed Account Providers, sub-advisers, custodians, broker-dealers, trading platforms, or other service providers may aggregate, batch, block, rotate, allocate, or otherwise process trades for multiple accounts according to their own trading and allocation procedures. Clients should review the applicable 19 Form ADV brochures, program disclosures, custodial documents, and other materials provided by those parties for more information about their trading practices. Item 13 Account Reviews We conduct periodic reviews of client accounts to help maintain alignment with client investment objectives, risk tolerance, financial goals, and other relevant circumstances. For clients receiving investment management services, we review accounts at least annually and more frequently as needed based on market conditions, significant life events, client requests, changes in client circumstances, or other relevant events. Account reviews may include performance evaluation, asset allocation review, rebalancing, portfolio- sleeve review, monitoring of applicable Managed Account Providers, and consideration of whether accounts remain consistent with the client’s documented objectives, restrictions, and investment profile. The Investment Committee reviews investment philosophy, model construction, investment options, third-party models, Managed Account Providers, and other investment-related matters as part of our firm-level investment oversight process. Client account reviews are conducted as described above. Clients receiving financial planning services are integrated into our Triangular Review System©, which involves three scheduled annual meetings to discuss updates to goals and plans, investments and insurance accounts, and tax and estate matters. Clients not receiving financial planning services may be invited to participate in additional review meetings, but our standard review obligation for investment management clients is an annual review. Employer retirement plan sponsor clients receive ongoing monitoring, including investment performance reviews, benchmarking, and reporting as outlined in the applicable agreement. Client reviews may also be triggered by client requests, material changes in the client’s situation, or other relevant events. Item 14 Client Referrals & Other Compensation We do not receive any compensation from any third party in connection with providing investment advice to you nor do we compensate any individual or firm for client referrals. We do not solicit funds for any other firms. Refer to Item 12 for information about our brokerage practices and custodial relationships. Advisers providing investment advice on behalf of our firm may be licensed insurance agents. Refer to Item 10 for information on the conflicts of interest this presents, and how we address these conflicts. Item 15 Custody If we provide you investment management services, your qualified custodian will debit your account(s) for payment of our advisory fees. We do not have custody of client funds or securities, except for this 20 limited authority to deduct our advisory fees directly from client accounts. Clients provide written authorization for these deductions in their advisory agreement. We or our designated billing agent may submit fee information to the custodian, which then deducts and pays the fee from account assets as authorized by the client. The custodian sends clients account statements at least quarterly, detailing all activity, including fee deductions. We do not send separate invoices to clients when advisory fees are deducted directly from investment accounts, as this is not required under SEC rules. We encourage clients to review statements carefully and contact us with any questions. This process ensures transparency and protection in line with regulatory standards. Item 16 Investment Discretion Before we can buy or sell securities on your behalf, you must first sign our discretionary investment management agreement and any necessary trading authorization forms. This agreement grants us, or our agents, exercise discretion over the selection and quantity of securities to be bought or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives and impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in a specific security or industry should not exceed specified percentages of your portfolio value. Similarly, you may restrict transactions in the securities of a specific industry or security. Refer to Item 4 for more information. Item 17 Voting Client Securities We will not vote proxies on behalf of our advisory accounts. At your request, we may offer you advice about corporate actions and the exercise of your proxy voting rights. In most cases, you will receive proxy materials directly from the custodian. In the event we receive any written proxy materials, we will send them directly to you by mail. If you have authorized our firm to contact you by electronic mail, we will forward any electronic solicitations to vote proxies. Certain Managed Account Providers may require that you allow the provider to vote proxies. If you have any question about a particular solicitation, you should contact your Adviser directly or contact the Chief Compliance Officer at compliance@bsgadvisers.com. Item 18 Financial Information Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities or serve as trustee or signatory for client accounts. We do not require prepayment of more than $1,200 per client, six (6) months or more in advance, for any service. We are not required to include a financial statement with this brochure. We have not filed a bankruptcy petition at any time in the past ten years. 21

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