Overview

Headquarters
Greenville, SC
Total Firm Assets
$147 million
Average High-Net-Worth Client Portfolio Size
$0.8 million

Fee Structure

Primary Fee Schedule (ADV PART 2A- BURGESS INVESTMENT GROUP, LLC)

MinMaxMarginal Fee Rate
$0 $500,000 1.40%
$500,001 $1,000,000 1.25%
$1,000,001 $3,000,000 1.00%
$3,000,001 $5,000,000 0.75%
$5,000,001 and above 0.60%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,250 1.32%
$5 million $48,250 0.96%
$10 million $78,250 0.78%
$50 million $318,250 0.64%
$100 million $618,250 0.62%

Clients

High-Net-Worth Share of Firm Assets
41.73%
Number of High-Net-Worth Clients
78
Total Client Accounts
864
Discretionary Accounts
862
Non-Discretionary Accounts
2

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

SEC CRD Number
318698

Primary Brochure: ADV PART 2A- BURGESS INVESTMENT GROUP, LLC (2026-06-09)

View Document Text
Burgess Investment Group, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Burgess Investment Group, LLC If you have any questions about the contents of this brochure, please contact us at 864-987-8522 or by email at: johnathanburgess12@gmail.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Burgess Investment Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov . Burgess Investment Group, LLC’s CRD number is: 318698 . 632 S. Main Street Greenville, SC 29601 864-920-3155  info@bigmoneyretirement.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 06/02/2026 1 Item 2: Material Changes Burgess Investment Group, LLC has the following material changes to report. Material changes relate to Burgess Investment Group, LLC’s policies, practices or conflicts of interests. ● ● ● ● ● The firm will be opening up a new office location in Charlotte North Carolina The firm has made Tom Osman their new Head of Finance The firm has made Jeremy Shory their new Head of Operations The firm has made John Obeck their new Chief Compliance Officer. The firm is now SEC registered. ii Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ii Item 3: Table of Contents iii Item 4: Advisory Business 2 Item 5: Fees and Compensation 4 Item 6: Performance-Based Fees and Side-By-Side Management 6 Item 7: Types of Clients 6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss 7 Item 9: Disciplinary Information 12 Item 10: Other Financial Industry Activities and Affiliations 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 14 Item 12: Brokerage Practices 15 Item 13: Review of Accounts 16 Item 14: Client Referrals and Other Compensation 17 Item 15: Custody 18 Item 16: Investment Discretion 18 Item 17: Voting Client Securities (Proxy Voting) 19 Item 18: Financial Information 19 Item 19: Requirements For State Registered Advisers 19 iii Item 4: Advisory Business A. Description of the Advisory Firm Burgess Investment Group, LLC (hereinafter “BIGL”) is a Limited Liability Company organized in the State of South Carolina. The firm was formed in December 2021 and began providing advisory services in April 2022. Burgess Investment Group, LLC may do business under the following names: BIG Money Retirement Solutions, BIG Money Retirement, BIG Retirement, and BIG Money Management, LLC. The firm is located in Greenville South Carolina but will soon open a branch office in Charlotte NC beginning in August 2026. The principal owner is Johnathan Burgess. B. Types of Advisory Services Portfolio Management Services BIGL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. BIGL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy Asset allocation Risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring BIGL evaluates the current investments of each client with respect to their risk tolerance and time horizon. BIGL will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is prepared for each client. BIGL makes investment decisions in accordance with the fiduciary duties owed to its clients and without consideration of BIGL’s economic, investment or other financial interests. To meet its fiduciary obligations, BIGL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, BIGL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is BIGL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 2 Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. We offer this service as part of portfolio management or a stand alone service. Services Limited to Specific Types of Investments sectors), treasury inflation protected/inflation BIGL does not limit the range of securities offered. Our investment advice may include mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. BIGL may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: ● ● ● ● ● ● Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions BIGL will tailor an investment program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by BIGL on behalf of the client. BIGL may use model allocations together with a specific set of recommendations for each client based on their personal resources, needs, and goals. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent BIGL from properly servicing the client account, or 3 if the restrictions would require BIGL to deviate from its standard suite of services, BIGL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. BIGL does not participate in wrap fee programs. E. Assets Under Management BIGL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $146,274,367 $861,259 December 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $500,000 1.40% $500,000 - $1,000,000 1.25% $1,000,001 - $3,000,000 1.00% $3,000,001 - $5,000,000 0.75% $5,000,001 - AND UP 0.60% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of BIGL's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Financial Planning Fees Fixed Fees 4 The negotiated fixed rate for creating client financial plans is between $100 and $10,000. Clients may terminate the agreement without penalty, for full refund of BIGL’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in arrears on a monthly basis. Payment of Financial Planning Fees Financial planning fees may be paid via check and wire. Fixed financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by BIGL. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Outside Compensation For the Sale of Securities to Clients Neither BIGL nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management BIGL does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients 5 BIGL generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals $750k+ under management or $1.5m net worth There is no account minimum for any of BIGL’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss BIGL employs a disciplined, multi-method approach to investment analysis and portfolio management. The strategies and methods described below are applied across client accounts based on individual goals, risk tolerance, and time horizon. All investment activity carries inherent risk, and clients should carefully review this disclosure prior to engaging our advisory services. A. Methods of Analysis and Investment Strategies Methods of Analysis BIGL’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis - We study historical price patterns on performance charts to identify potential buying and selling opportunities. Key risk : Past patterns do not guarantee future performance. Relying solely on charts assumes history will repeat — which it may not. Cyclical analysis - We analyze economic and market cycles to time investment decisions. Key risk : Markets do not always repeat prior cycles, and widespread adoption of this strategy can distort the very cycles it seeks to exploit. Fundamental analysis - We evaluate a company's financial health, management quality, and competitive position to identify undervalued securities. Key risk : The market may not recognize or price in a company's intrinsic value within a client's expected time frame. Modern portfolio theory - We construct portfolios designed to achieve the optimal return for a given level of risk. Key risk : Higher expected returns require accepting 6 higher risk. Each client's tolerance for that trade-off is unique and must be evaluated individually. Quantitative analysis - We apply mathematical models using measurable data — including asset values, historical sales projections, and cost of capital — to guide investment decisions. Key risk : Models may underperform when real-world conditions diverge from historical patterns or the assumptions built into those models. Technical analysis - We examine historical price and trading volume data to forecast future market movements. Key risk: Markets do not always adhere to historical patterns, and new trends can emerge that fall outside what prior data would predict. B. Material Risks Involved employs the following investment strategies. Those involving Investment Strategies BIGL leverage, derivatives, or short positions carry materially greater risk than long-only approaches and are fully disclosed below. Clients should be prepared for the possibility of loss in any of these strategies. Long term trading - We hold investments over extended periods to capture long-run market returns. Clients are exposed over time to inflation (purchasing power) risk, interest rate risk, economic cycle risk, broad market volatility, and political or regulatory change. Margin transactions - We may borrow from a brokerage firm to amplify purchasing power. If account values decline below the firm's required threshold, a margin call may force the liquidation of assets at an inopportune time or require an immediate infusion of additional capital. Options transactions - We use contracts that convey the right — but not the obligation — to buy or sell a security at a set price. Options can expire worthless, resulting in total loss of premium paid. Uncovered ("naked") call options carry theoretically unlimited loss potential. Spread strategies pair offsetting positions to limit — but not eliminate — risk. Short sales - We may sell borrowed securities with the intent to repurchase them at a lower price. Because a security's price can theoretically rise without limit, short sales carry the potential for unlimited loss. Historically, equity markets trend upward over time, which works against short positions held for extended periods. Short term trading - We buy and sell securities over shorter time horizons to capitalize on near-term opportunities. In addition to long-term risks, short-term trading introduces liquidity risk and economic instability risk. Frequent trading also increases transaction costs and potential tax liabilities — both of which can materially reduce net returns. 7 Clients should be prepared for the possibility of loss in any of these strategies. C. Risks of Specific Securities Utilized BIGL's use of short sales, margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Risk of capital loss; all funds carry costs that reduce returns. Fixed income funds carry lower risk; equity funds carry higher volatility and loss potential. (Stocks): Value may fluctuate based on company-specific developments, Equity industry conditions, and the broader economic environment. Fixed income (Bonds): Subject to interest rate risk (prices fall when rates rise), inflation risk, liquidity risk, call risk, and credit/default risk. Foreign bonds add currency and political risk. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Subject to market volatility, tracking error, liquidity risk, and shutdown risk. Leveraged, inverse, or narrow-sector ETFs carry amplified risk. Each ETF has a unique risk profile detailed in its prospectus. Real estate / REITs: Revenues and valuations may be impacted by local market conditions, interest rates, capital improvement requirements, tax changes, zoning laws, and environmental regulations. Annuities: Are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are long-term insurance contracts designed for retirement. By paying a premium now, you secure guaranteed future income or investment returns. While distinct from life insurance, variable annuities carry market risks and are unsuitable for short-term goals, as early withdrawals incur substantial fees and tax penalties. Private Placements: An unregistered offering to a select group of accredited investors that is exempt from standard registration requirements. Resale is often restricted by securities laws, and liquidation may occur at a significant discount — or result in total loss of principal. Capital: Investments in Venture early-stage companies carry high risk due to uncertainty surrounding the company's development, viability, and ultimate realization event. 8 Commodities: Prices are influenced by supply, demand, weather, disease, storage capacity, and delivery constraints. Even diversified commodity exposure carries significant uncertainty. Options: Are contracts to purchase a security at a given price. May expire worthless, resulting in total loss of premium. Uncovered calls carry unlimited loss potential. Spread strategies limit but do not eliminate risk. Non-U.S. Securities: present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Cryptocurrency: Highly volatile, unregulated, and not backed by any government or central bank. Risks include price crashes, market manipulation, cybersecurity threats, technical failures, and blockchain forks. Prices can drop to zero. Past performance is not indicative of future results. Clients should be prepared for the possibility of loss in any of these strategies. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations as a Broker/Dealer or Broker/Dealer A. Registration Representative Neither BIGL nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor 9 either a Futures Neither BIGL nor its representatives are registered as or have pending applications to become Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Advisors at BIGL are also independent licensed insurance agents. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of BIGL are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. BIGL addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. BIGL periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. BIGL will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by BIGL’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Johnathan Brett Burgess is a minority equity partner in Corbin Burgess & Co, LLP, an insurance-related firm. He holds no role in operations, personnel, compliance, financial management, or supervision. His involvement is limited to consulting and educational coaching on sales methodology and practice development, contributing about 1% of annual compensation and roughly 1 hour monthly outside trading hours. of Other Advisers or Managers and How This D. Selection Adviser is Compensated for Those Selections BIGL does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics 10 Procedures and Reporting, Certification of Compliance, BIGL has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Reporting Regulations, Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. BIGL's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests BIGL does not recommend that clients buy or sell any security in which BIGL or a related person has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of BIGL may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of BIGL to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. BIGL will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Securities At/Around the Same Time as Clients’ D. Trading Securities From time to time, representatives of BIGL may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of BIGL to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, BIGL will never engage in trading that operates to the client’s disadvantage if representatives of BIGL buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on BIGL’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and BIGL may also 11 the market expertise and research access provided by the consider broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in BIGL's research efforts. BIGL will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. BIGL recommends Charles Schwab & Co., Inc. Member FINRA/SIPC, and Signal Securities Inc. 1. Research and Other Soft-Dollar Benefits While BIGL has no formal soft dollars program in which soft dollars are used to pay for third party services, BIGL may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). BIGL may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and BIGL does not seek to allocate benefits to client accounts proportional to any soft dollar credits generated by the accounts. BIGL benefits by not having to produce or pay for the research, products or services, and BIGL will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that BIGL’s acceptance of soft dollar benefits may result in higher commissions charged to the client. BIGL currently has a minority ownership interest in the Signal broker-dealer. Signal provides marketing to BIGL. 2. Brokerage for Client Referrals BIGL receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use BIGL may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to BIGL to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. The custodian may allow the client to execute transactions within their portfolio which would be independent and without permission. 12 B. Aggregating (Block) Trading for Multiple Client Accounts BIGL does not aggregate (Block Trade) or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts for BIGL's advisory services and provided on an ongoing basis are reviewed periodically by John Obeck, Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at BIGL are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, BIGL’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of BIGL's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. BIGL does not provide reports relating to its subscription services. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) 13 BIGL participates in the institutional advisor program (the "Program") offered by Charles Schwab & Co., Inc. Charles Schwab & Co., Inc. offers independent investment advisor services which include custody of securities, trade execution, clearance and settlement of transactions. BIGL receives some benefits from Charles Schwab & Co., Inc. through its participation in the Program. As disclosed above, BIGL participates in Charles Schwab & Co., Inc. institutional advisor program and BIGL may recommend Charles Schwab & Co., Inc. to clients for custody and brokerage services. There is no direct link between BIGL's participation in the Program and the investment advice it gives to its clients, although BIGL receives economic benefits through its participation in the Program that are typically not available to Charles Schwab & Co., Inc. retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving BIGL participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have BIGL's fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to BIGL by third party vendors. Charles Schwab & Co., Inc. may also pay for business consulting and professional services received by BIGL's related persons. Some of the products and services made available by Charles Schwab & Co., Inc. through the Program may benefit BIGL but may not benefit its client accounts. These products or services may assist BIGL in managing and administering client accounts, including accounts not maintained at Charles Schwab & Co., Inc.. Other services made available by Charles Schwab & Co., Inc. are intended to help BIGL manage and further develop its business enterprise. The benefits received by BIGL or its personnel through participation in the Program do not depend on the amount of brokerage transactions directed to Charles Schwab & Co., Inc.. As part of its fiduciary duties to clients, BIGL endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by BIGL or its related persons in and of itself creates a conflict of interest and may indirectly influence the BIGL's choice of Charles Schwab & Co., Inc. for custody and brokerage services. B. Compensation to Non – Advisory Personnel for Client Referrals BIGL does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, BIGL will be deemed to have limited custody of client's assets and must have written authorization from 14 the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion BIGL offers discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, BIGL generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, BIGL’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to BIGL. Item 17: Voting Client Securities (Proxy Voting) BIGL will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet BIGL neither requires nor solicits prepayment of more than $500 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither BIGL nor its management has any financial condition that is likely to reasonably impair BIGL’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years BIGL has not been the subject of a bankruptcy petition in the last ten years. Item 19: Requirements For State Registered Advisers 15 A. Principal Executive Officer and Management Person; Their Formal Education and Business Background BIGL’s current management is Johnathan Brett Burgess. Education and business background can be found on the individual's Form ADV Part 2B brochure supplement. B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any) Other business activities for each relevant individual can be found on the Form ADV Part 2B brochure supplement for each such individual. C. Calculation of Performance-Based Fees and Degree of Risk to Clients BIGL does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. D. Material Disciplinary Disclosures for Management Persons of this Firm There are no civil, self-regulatory organization, or arbitration proceedings to report under this section. E. Material Relationships That Management Has With Issuers of Securities (If Any) See Item 10.C and 11.B. 16

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