BUTTONWOOD FINANCIAL GROUP, LLC

Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure BUTTONWOOD FINANCIAL GROUP, LLC 3013 Main Street Kansas City, MO 64108 (816) 285-9000 w ww.ButtonwoodFG.com April 30, 2025 This Brochure provides information about the qualifications and business practices of Buttonwood Financial Group, LLC. If you have any questions about the contents of this Brochure, you may contact us at (816) 285- 9000 or jon@buttonwoodfg.com to obtain answers and additional information. Buttonwood Financial Group, LLC is a registered investment adviser with the United States Securities and Exchange Commission (“SEC”). Registration as an investment adviser does not imply any level of skill or training. The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Buttonwood Financial Group, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Part 2A - i  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Item 2 Material Changes This Brochure dated April 30, 2025, updates and replaces the previously published Brochure for Buttonwood Financial Group, LLC dated March 31, 2025. These changes below are reflected in this April 30, 2025 version: Extensive updates were made to Items 4, 5, 6, 7, 8, 10, 12, 13, and 16 mainly due to changes in our business services and fees. We urge you to read this document in its entirety and call us at 816-285- 9000, should you have any questions. The changes below were reflected in the March 31, 2025 version: Item 4 – Advisory Business – updated to: (i) reflect our assets under management as of February 28, 2025, and (ii) remove information on our Wrap Program, which is no longer offered to clients. Item 5 – Fees and Compensation – updated to reflect our new fee schedule for investment management fees and enhance disclosures regarding our billing practices pertaining to those fees. Item 14 - Client Referrals and Other Compensation – updated to reflect that beginning in 2025, Buttonwood representatives no longer receive compensation for bringing in new clients and no longer shares in the advisory fees paid by the clients they service. Item 16 – Investment Discretion – updated to clarify when Buttonwood has discretionary authority of clients’ managed assets. Item 17 – Voting Client Securities – updated to add disclosures that Buttonwood has will have voting authority for certain ERISA Plans when the firm serves as Section 3(38) fiduciary and such authority has been delegated via the Plan documents. Please note we also removed reference to our Wrap Program in other sections of this Brochure. The changes below were reflected in the December 18, 2024 version: Item 7 – Types of Clients – updated to clarify that the firm does not require a minimum account size and does not charge a minimum advisory fee. Item 10 – Other Financial Industry Activities and Affiliations – removed disclosures regarding an arrangement with 55 International Partners, LLC through Black Rock, as Buttonwood no longer has such an arrangement in place Item 12 – Brokerage Practices – updated to include details regarding prime brokerage arrangements, including the additional associated costs. Also added disclosures regarding the firm’s soft dollar and best execution practices. Part 2A - ii  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Item 14 – Client Referrals and Other Compensation – updated to: (i) clarify that Buttonwood does not provide direct or indirect compensation to any clients or unaffiliated third parties for referring prospective clients to the firm, and (ii) reflect that Buttonwood’s investment adviser representatives do receive compensation for client referrals and share in the advisory fees paid by the clients they service. We made additional non-material updates to other sections in this Brochure, so we encourage each client to review the complete Brochure carefully and to contact us with any questions you may have. Pursuant to SEC rules, we will provide you with a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. All such information will be provided to you free of charge. Currently, our Brochure may be requested by contacting Jon McGraw, President and Chief Compliance Officer of Buttonwood Financial Group, LLC at (816) 285-9000 or jon@buttonwoodfg.com. Part 2A - iii  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Item 3 Table of Contents P age Item 1 Cover Page ................................................................................................................................. A - i Item 2 Material Changes ............................................................................................................................. ii Item 3 Table of Contents .......................................................................................................................... iii Item 4 Advisory Business ................................................................................................................. 2A - 5 Item 5 Fees and Compensation ............................................................................................................... 11 Item 6 Performance-based Fees and Side-by-Side Management ....................................................... 15 Item 7 Types of Clients ............................................................................................................................ 15 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .............................................. 16 Item 9 Disciplinary Information ............................................................................................................. 22 Item 10 Other Financial Industry Activities and Affiliations ............................................................... 22 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 24 Item 12 Brokerage Practices ....................................................................................................................... 25 Item 13 Review of Accounts ...................................................................................................................... 29 Item 14 Client Referrals and Other Compensation ............................................................................... 30 Item 15 Custody ........................................................................................................................................... 30 Item 16 Investment Discretion .................................................................................................................. 31 Item 17 Voting Client Securities ................................................................................................................ 31 Item 18 Financial Information ................................................................................................................... 32 Part 2A - iv  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Item 4 Advisory Business Buttonwood Financial Group, LLC (“Buttonwood” “we”, “us”, or “the firm”) is an independent SEC registered investment advisory firm located in Kansas City, Missouri. The firm has been in business since 2002 and has been registered with the SEC as an independent investment advisory firm since 2009. Jon McGraw is the primary owner and President of the firm. A. Buttonwood’s Wealth Management Services Buttonwood offers comprehensive Wealth Management Services designed to assist clients with coordination and simplification of their financial lives by serving in the role of primary financial advisor and administrator. We strive to organize, formalize, implement and monitor financial strategies in a manner consistent with our clients’ multi-generational life goals and objectives. As each client’s individual situation and needs can vary, we tailor each engagement to meet the needs of the individual client. Below are the services Buttonwood can perform on a client’s behalf as mutually discussed and agreed to: 1. Family CFO Planning Services • Financial Planning – includes a review of the client’s current and future financial needs and outlook. • Financial Independence/Retirement Planning – includes consideration of senior issues, assisted living and savings for retirement, and cash flow needs. • Business Strategy – The firm can provide business strategy related general consulting in areas such as entity structure, startup funding, operations workflows, employee benefits, business valuation. • Tax Strategy – The firm can provide tax strategy related services which include tax return • coordination, , tax loss harvesting, and general tax reduction tactics. Insurance Planning – The firm can provide insurance planning services including review of life insurance, disability insurance, long term care insurance, health insurance, employer insurance coordination, and home, auto, and business insurance coordination. • Multigenerational Wealth and Education Planning - including gifting, funding, estate planning, transfer strategies, family governance, family meeting coordination and mentoring. • Lifecycle Roadmaps – The firm can provide lifecycle consulting services related to education, generational planning, retirement, senior issues, and assisted living, among others. • Estate & Legacy – The firm can provide estate and legacy consulting services related to plan implementation, philanthropic and foundation management, estate settlement and transfer, asset titling. Part 2A - 5  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure 2. Investment Management Services We offer discretionary or non-discretionary investment management1 which includes: • Development of client specific strategic asset allocation plans • Selection and transaction of securities on a fully discretionary basis (unless otherwise noted) Investment allocation reviews Integrated tax management with investment selection • Due diligence of investment opportunities • • • Monitoring and portfolio rebalancing activities • Ongoing supervision of investments • Regular client investment and performance reporting Please refer to Item 4.C.2 below for information on the types of securities we recommend/utilize in clients’ investment portfolios. For accounts we manage, clients may impose reasonable restrictions on investing in certain securities or types of securities. Clients may also request that we hold specific non- recommended securities on their behalf. We feel that client input and involvement are critical parts of not only the financial planning process, but also the implementation of investment decisions. 3. Simplicity360 Services: In addition to our Family CFO Planning and Investment Management Services outlined above, our Simplicty360 Services are available to our clients. Simplicity360 Services can include the below: • Bill pay services • Business payroll and benefits coordination • Business marketing review • Business strategic planning with output of a strategic plan, which includes mission/vision/values/goals for the business for the year • Concierge assistance for personal and business financial, insurance, legal, and tax needs • Consultation regarding business sales and exit strategies • Coordination of annual business filings with relevant states • Customized investment strategies to accompany model investments including private real estate, bond portfolios, private debt and equity • Family legacy planning 1 Please refer to Item 16 of this Disclosure Brochure for descriptions of discretionary and non-discretionary investment management. Part 2A - 6  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure • Family meeting coordination • Multigenerational strategy planning • Philanthropic consultation and strategy • Private aircraft and watercraft coordination and consulting • Private family foundation management • Professional employer organization consultation • Property management services • QuickBooks: online set up, monthly reconciliation, and/or accounting coordination • Tax: quarterly estimated tax payment services • Tax: payment of Federal and State taxes • Tax: proactive coordination of the entire tax process with client’s preferred CPA • Trust: corporate trustee services • Trust: interface with or serving as corporate trustee Buttonwood works with each client in selecting the Simplicity360 services that best meet their specific needs. B. ERISA Plan Section 3(38) Services Buttonwood offers investment management services as a Section 3(38) investment manager to ERISA plans, which can include 401K retirement plans, defined contribution plans, and defined benefit plans. As a Section 3(38) investment manager, Buttonwood will have full discretionary authority to manage, acquire, or dispose of ERISA plan assets, which shall include the selection, monitoring, and changing of investments. As an Investment Manager and Fiduciary to an ERISA Plan, Buttonwood will: • Evaluate, monitor, change, and select plan investment options • Not vote proxies on behalf of a client’s account(s), unless the Plan directs Adviser to vote proxies • Complete all necessary compliance filings (such as Forms 13) with the U.S. Securities and Exchange Commission In addition, Buttonwood will provide the following non-discretionary advisory services to an ERISA Plan client, and we will not have any decision-making authority when providing such service(s) on behalf of the Plan: • Assistance with development and implementation of an Investment Policy Statement • Assistance with oversight of the Plan • Limited assistance with administration of the Plan and development of Plan terms • Assistance with evaluation and selection of the Plan’s investment platform and plan administrator Part 2A - 7  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Buttonwood also will assist in other non-advisory, non-fiduciary functions, including: • Enrollment and educational meetings with Plan participants • General market and retirement plan industry updates Buttonwood will not be responsible for functions not detailed above, such as: • Monitoring or evaluating any self-directed participant brokerage accounts within the Plan • Monitoring or evaluating an ERISA Plan client’s company stock • Plan recordkeeping and reporting to participants • DOL or IRS required document compliance or form filings C. Additional Important Information About Buttonwood’s Services 1. Gathering Specific Client Information The advice and services provided by us are tailored to each client’s individual needs and stated objectives. At the beginning of an engagement, we discuss with each client in detail critically important information such as the client’s risk tolerance, time horizon, projected future liquidity needs, current balance sheet items, tax considerations, personal views and other factors in order to formulate a comprehensive multigenerational financial strategy. This information is gathered and put into a customized Investment Policy Statement for each client and then discussed during ongoing meetings to help us adapt strategy to each client’s changing life. Through our Family CFO Planning Services, we will create a comprehensive financial strategy, which we will review with our clients on an ongoing basis. Because each client is unique, we require that they be involved in the initial planning and ongoing review processes. Such involvement does not need to be time-consuming, but we want our clients to remain informed and have a sense of awareness about their investments. Our clients are encouraged to review their goals, situation, and plans regularly and to communicate with us regarding any changes in their circumstances, goals and objectives. Buttonwood relies upon the information provided by clients, so it is very important for clients to not only initially provide accurate and complete information, but to also promptly notify Buttonwood of any material changes in their financial circumstances, including investment needs, investment guidelines, risk tolerances, and any other applicable information that becomes inaccurate or changes due to various circumstances. 2. Types of Investments As part of our Investment Management services, Buttonwood creates a portfolio for each client, which is based on the client’s Investment Policy Statement and can consist of various types of securities. We generally provide advice regarding the following securities: (i) fixed income securities, (ii) open- end mutual funds, (iii) exchange traded funds (“ETFs”), (iv) fixed and variable annuities, and (v) private investment funds (“Private Funds”).2 2 Private Funds can include, but not be limited to hedge funds, real estate funds, private equity funds, and venture capital funds, and Part 2A - 8  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Please refer to Item 8 below for further information on the types of investments we recommend and/or utilize in clients’ accounts, along with the associated material risks. 3. Buttonwood’s Fiduciary Responsibility Because Buttonwood is a registered investment adviser, we have a fiduciary duty to our clients, which includes a duty of care and a duty of loyalty. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered 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. As a fiduciary, we are required to act in the best interests of our clients and we must always put their interest ahead of our own. Buttonwood cannot waive, limit, or otherwise put restrictions on our fiduciary duty. Please refer to Items 7 and 11 for further information regarding our fiduciary duty. 4. Implementation of Buttonwood Recommendations We view our clients as the Family “CEO”, and we serve in the role of Family “CFO”. After our initial review, clients will direct us whether to implement the Plan(s) for the commencement of our Investment Management and optional Simplicity 360 Services. Also, upon client direction, Buttonwood will work with a client’s outside professional advisors (such as accountants, lawyers and third-party managers) to assist with strategy development and/or implementation. Clients should note that they always retain the right to decide whether to act upon any of our recommendations and are free to select any advisory firm to implement the recommendations (i.e., provide investment management services and/or family office services). Clients also are not obligated in any way to invest in any Private Fund recommended by Buttonwood. Should a client decide to invest in a recommended Private Fund, the client will be required by the issuer of the Private Fund to complete and execute the subscription agreement and other Offering Documents. We will work with the client to help facilitate the completion and the delivery of the documents and implementation of the transaction, and then once invested we will provide ongoing monitoring and oversight of the investment. Buttonwood has conflicts of interest when making certain recommendations since we will receive advisory fees and other benefits should the client implement investment and other recommendations through Buttonwood. Importantly, as part of Buttonwood’s fiduciary duty to clients, both the firm and our representatives endeavor at all times to put the interests of the clients first; therefore, recommendations will only be made to the extent that we believe them to be in the best interests of our clients. Further details regarding conflicts of interest associated with the services provided by Buttonwood are outlined in various sections of this Disclosure Brochure. We encourage both prospective and current clients to read this document in its entirety. will only be discussed with Buttonwood clients that meet the applicable regulatory qualification definition (i.e., accredited investor, qualified client, and/or qualified investor) and such potential investment is suitable for the qualified client and in line with their Investment Policy Statement. Part 2A - 9  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure 5. Margin Accounts and Other Types of Securities Backed Loans A client’s managed account(s) can either be a cash account or a margin account. Unlike a cash account, a margin account allows the client to borrow money against the portfolio assets. While we do not encourage clients to borrow money via their margin account, there have been times in the past, and can be in the future, where we recommend use of a margin account for a client’s short- term borrowing needs. However, in accordance with our fiduciary duty to our clients, we only suggest the use of margin in cases where we believe it is in the client’s best interest. Also, depending on the needs of a client or upon a client’s request, the Firm will recommend that a client consider obtaining a securities-backed loan or line of credit with an unaffiliated third-party bank or brokerage firm. These types of loans are generally referred to as SBLs and SBLOCs and are not suitable for all investors and carry a number of risks. Clients should not obtain such a loan or line of credit without fully understanding the benefits and risks. Please refer to Item 8 below for details on applicable risks. There also is a conflict of interest surrounding the Firm’s recommendation to obtain such a loan, mainly due to the fact that the loan proceeds may be used in place of a client having to withdraw assets from their account managed by the Firm. Therefore, the Firm continues to receive fees on the securities in the account even though they are used as collateral. To address this conflict, the Firm has processes in place to help ensure that all recommendations being provided to clients are suitable and the clients are aware of all material risks and conflicts. Buying securities on margin or utilizing a securities-backed loan or line of credit subjects clients to additional costs and risks that should be carefully considered before opening a margin account or obtaining a securities backed loan or line of credit. For further details on the risks, please refer to Item 8 of this Disclosure Brochure. 6. Wealth Management Services Agreement New clients are required to enter into a written agreement with Buttonwood (“Client Agreement”), which will outline the services to be provided, the fees to be charged and the terms and conditions under which we will render our services. Buttonwood will provide a copy of this Disclosure Brochure and the applicable Brochure Supplements (Form ADV Part 2B) to each new client prior to or upon execution of our written Client Agreement. Our advisory relationship with a client will continue until terminated by the client or Buttonwood in accordance with the provisions of the executed Client Agreement. D. Wrap Fee Programs Buttonwood no longer offers a wrap program where the firm serves as sponsor and has not and currently does not participate in a wrap program as a portfolio manager. Part 2A - 10  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure E. Assets Under Management As of February 28, 2025, we managed approximately $696,762,721 in regulatory assets under management, with $551,062,199 being managed on a discretionary basis and $145,700,522 managed on a non- discretionary basis. Item 5 – Fees and Compensation A. Buttonwood Fees As mentioned above, Buttonwood offers Wealth Management Services, which includes Family CFO Planning Services, Investment Management Services, and Simplicity 360 Services. 1. Family CFO Planning Fee Family CFO Planning Fees are negotiable and are quoted as a fixed annual fee ranging from $1,000 to $100,000 based on the scope and complexity of the engagement. We generally bill this fee quarterly in advance. Fees may be paid by us deducting the amount from a client’s checking account or the client directing us to deduct the fee from their managed account(s) upon our submission of an invoice to the applicable custodian. Payment of fees through fee deduction may result in the liquidation of a client's securities if there is insufficient cash in the account. Clients are required to provide us with instructions on or about the 10th day of the month following the close of each calendar quarter. At account opening, Family CFO Planning Services fees are prorated based on the number of days that the Account(s) are open during the quarter, and the first payment is due upon the effective date of the Client Agreement. On rare occasions, we will charge an hourly fee in lieu of a flat rate, depending on the services to be performed. Generally, the billing process is the same, except that hourly fees are charged in arrears. Below are our basic hourly rates: $600 per hour for Firm Principal or senior Advisor $450 per hour for Lead Advisor $300 per hour for Wealth Management Strategist $200 per hour for Operations Staff $125 per hour for Client Services $75 per hour for Admin 2. Investment Management Fee Buttonwood charges an annualized management fee (“Investment Management Fee”) based on multi- generational assets3 under management (“AUM”) based on the value of a client’s managed account(s) 3 For fee billing purposes only, Buttonwood will aggregate all a client’s account(s) and will group those account(s) associated with client (such as Client’s relatives (e.g., grandparents, parents, spouse, children), associated businesses or accounts for which client serves as a Part 2A - 11  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure (inclusive of cash, cash equivalents), as of the close of business on the last business day of the quarter. At account opening, Investment Management Fees are prorated based on the number of days that the Account(s) are open during the quarter. The first payment is due within the first 30 days from the effective date of the client agreement or upon the account’s transference and will be based upon the market value in the account(s) as of 30 days after the effective date. Fees are assessed in accordance with the following tiered fee schedule. Investment Management Fees Based on Client’s Aggregated Assets Under Management (AUM) AUM Tier $0 - $2,500,000 $2,500,001 - $5,000,000 $5,000,001 - $10,000,000 Over $10,000,001 Annualized Fee Rate 0.80% 0.65% 0.50% 0.40% The Investment Management Fee is calculated by taking the Aggregated AUM as reported by each applicable custodian of all client accounts (in effect at the time) and applying the annualized fee rate(s) above. Annual fee rates above are divided by four (4) to arrive at a prorated quarterly rate. Our fees will be paid directly to Buttonwood from each applicable designated account(s) by the custodian upon written authorization by the client or may be billed separately to a client or business. Under these circumstances, Buttonwood will provide the Bank and/or Custodian with the amount to be deducted from each applicable designated account(s). Accounts terminated during a quarter are pro-rated up to the date we discontinue servicing the account (subject to the termination notice provisions of the client agreement), and any unearned fees paid in advance will be promptly refunded. Buttonwood’s Investment Management Fee schedule can be amended from time to time by the firm upon 30-day written notice to clients. Payment of fees could result in the liquidation of a client's securities if there is insufficient cash in the account. Buttonwood also reserves the right to decline accepting a new account or to waive or negotiate advisory fees with clients in our sole discretion. For family and friends of the Firm, Buttonwood will discount its advisory fee for managing their accounts. For employees and spouses/domestic partners of employees, we will waive our advisory fee for managing their accounts. 3. Simplicity360 Services Annual fees for these services range from $1,000 to $100,000 for various terms and conditions, and dependent upon the services selected by a client. Generally, tailored pricing is negotiated with a client Power of Attorney or For the Benefit Of a related client account) for the purpose of determining the aggregated account value/assets under management. Part 2A - 12  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure once the services are selected and will be reflected in the Client Agreement. We bill this fee quarterly in arrears and clients can pay us from any account they choose. For example, a client can instruct us to deduct the fee from their checking account, a business account, or the client can direct us to deduct the fee from their account(s) managed by Buttonwood upon our submission of an invoice to the applicable custodian. Payment of fees through fee deduction from an investment account may result in the liquidation of a client's securities if there is insufficient cash in the account. Clients are required to provide us with payment instructions on or about the 10th day of the month following the close of each calendar quarter. 4. ERISA Plan Section 3(38) Services The annual fee for this service is 0.50% of the ERISA Plan assets and will be calculated and deducted by the plan’s administrator and paid to us, as authorized by the ERISA Plan client in the Client Agreement. 5. Negotiability of Buttonwood Fees Buttonwood has discretion to negotiate alternative fees on a case by case basis. The specific annual fee will be outlined within the Client Agreement. Buttonwood has clients that have different fee schedules/arrangements than the ones reflected in this Disclosure Brochure. In addition, discounts not generally available to our advisory clients are offered to family members and friends of the firm and our supervised persons. Also, we have in the past waived fees for friends and family members, and we reserve the right to do so in the future. 6. Other Fees and Expenses In addition to our fees referenced above, our clients will incur other charges, as applicable, imposed by custodians, brokers, and other third parties. These fees can include but not limited to custodian fees, brokerage fees, retirement plan administration fees, margin interest, debit balance interest, bank service fees, transaction related fees (including markups and markdowns), , odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes. A client’s managed account that is invested in mutual funds and/or ETFs will be subject to certain fees and expenses. Each mutual fund and ETF charge fees to shareholders/investors, which are described in their respective prospectus. For open-end mutual funds, the fees and expenses usually include a management fee, administrative and operational fees, and certain distribution (e.g., 12b-1 fees) and/or redemption fees. These fees are generally referred to as a fund’s “expense ratio” and the fees are deducted at the mutual fund level when calculating the fund’s net asset value (“NAV”) and has a direct bearing on the performance of the mutual fund. Certain open-ended mutual funds also charge an up-front (at time of purchase) or back-end (at time of redemption) sales charge. In addition, some open-end mutual funds offer different share classes of the same fund, and one share-class can have a higher expense ratio than another share class. ETFs generally do not have 12b-1 distribution fees or redemption fees but charge certain administrative and operational expenses. Mutual fund and Part 2A - 13  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure ETF expense ratios vary by mutual fund and ETF, so it is important to read the applicable prospectus to fully understand all the fees charged. Buttonwood continually strives to invest our clients in the most economical mutual fund share class available. However, determining the most economical share class will depend on certain factors, including but not limited to client facts and circumstances, such as the amount of time the shares are held by a client and the amount a client will be investing. In addition, there have been times in the past, and can be in the future, when Buttonwood does not have access to lower-cost share classes for a mutual fund that the firm is investing in for clients. This typically occurs when the client’s custodian (e.g., Schwab) does not offer a lower cost share class for investment, or the total investment amount at time of purchase does not meet the minimum investment requirement for the lower cost share class. Currently, Schwab does not charge a transaction fee on any mutual funds bought and sold through Schwab for Buttonwood clients that have their managed assets custodied at Schwab. Please refer to Item 12 for further details on our custodian and brokerage arrangement with Schwab. Buttonwood monitors clients’ open-end mutual fund investments in their managed accounts on an ongoing basis and performs at least semi-annual reviews of share class availability for lower cost shares. For new clients that hold any mutual funds upon account opening, Buttonwood will first determine whether such mutual fund(s) remains suitable and in line with the client’s Investment Policy Statement. If we believe the client should remain invested, we will check to see if a lower cost share class of the particular mutual fund is available, as applicable, and if allowed by the client’s custodian and believed to be economical for the client, we will implement a transfer into the lower cost share class. Client assets invested in Private Funds are also subject to management fees, performance fees, and other expenses as described in each Private Fund’s offering documents (i.e., private placement memorandum, partnership/operating agreement, and subscription agreement). These fees and expenses are also separate from and in addition to the advisory fees charged by Buttonwood. Clients should carefully review a Private Fund’s offering documents prior to investing to fully understand the total amount of fees that will be paid. Fee based variable annuities also carry fees that are in addition to Buttonwood’s fees. While the fees are outlined in an annuity’s prospectus, they can include, but not be limited to administrative fees, surrender charges, mortality expenses, transfer fees, distribution fees, contract fees, underwriting fees and fees associated with the underlining portfolio investments, such as mutual fund fees. Some of these additional fees are included in the expense ratio and reflected in the per share value of the annuity, while other fees are deducted from the client’s assets invested in the annuity. In addition, Buttonwood’s fees do not include any services provided by outside professionals. Although Buttonwood can, upon client’s direction, participate and liaise with the client’s outside professionals and assist with negotiations for such services, clients are responsible for the negotiation and payment of outside services and fees. For those clients who have selected Schwab as their custodian, trading and other associated transaction costs assessed by Schwab are paid by Buttonwood in our sole discretion. Part 2A - 14  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure For those clients who have selected custodians outside of Schwab, trading and other associated transaction costs will be passed down to client. In all cases, account transition costs, wire fees, overnight delivery fees, reorg fees and other fees and costs assessed by the client’s qualified custodian are passed on to the client. Item 12 describes the factors that we consider in recommending broker-dealers for client transactions and determining the reasonableness of their compensation. It is important for clients to understand that all the fees charged to their managed accounts lowers the overall performance of the accounts. Therefore, clients should review all applicable direct and indirect fees charged, including but not limited to custodian fees, transaction fees, fees associated with investments (e.g., mutual funds, ETFs, Private Funds), and any other third-party fees, along with our advisory fees to fully understand the total amount of fees to be paid. For further information, please refer to the SEC’s Investor Bulletin at https://www.investor.gov/introduction-investing/general- resources/news-alerts/alerts-bulletins/investor-bulletins/updated Item 6 – Performance-Based Fees and Side-By-Side Management We do not charge or participate in any performance-based fees (fees based on a share of capital gains on, or on capital appreciation of, the assets of a client) and consequently do not simultaneously manage performance-based and non-performance-based accounts. However, some of the Private Funds that Buttonwood’s clients invest in do charge performance or incentive-based fees, which are outlined in the respective Private Fund’s offering documents and should be reviewed by investors prior to investing. Buttonwood does not receive any portion of these fees. Item 7 – Types of Clients We offer services to individuals, families, businesses, corporate pension and profit-sharing plans, defined benefit and defined contribution plans, charitable institutions, foundations, endowments and trust programs. We do not currently require a minimum account size but reserve the right to do so in the future. We also reserve the right to decline accepting an account or to waive a fee depending on the circumstances. When Buttonwood and our advisory personnel provide investment advice to a client regarding the client’s retirement plan account or IRA account, Buttonwood and our personnel are fiduciaries within the meaning of Title I of the ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with our clients’ interests, so Buttonwood operates under a special rule that requires us to act in our clients’ best interests and not put our interest ahead of theirs. Under this special rule’s provisions, Buttonwood must: Part 2A - 15  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure • 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); • Adhere to impartial conduct standards, whereby Buttonwood: o Provides advice and follows policies and procedures designed to ensure that we give advice that is in our clients’ best interests; o Charges no more than is reasonable for our services; and o Avoids making any materially misleading statements to our clients regarding our services and recommendations, fees and compensation, conflicts of interest, and any other matters relevant to our clients’ investment decisions. When recommending a rollover of a retirement account to a client, Buttonwood will document the reasons that the rollover recommendation is in the best interest of the client and provide a copy of the documentation to the client. If a client receiving investment management services is a pension or other employee benefit plan governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), Buttonwood will provide certain required disclosures to the “responsible plan fiduciary” (as such term is defined in ERISA) in accordance with Section 408(b)(2), regarding the services we provide and the direct and indirect compensation we receive by such clients. Generally, these disclosures are contained in this Form ADV Part 2A, the client agreement and/or in a separate ERISA disclosure document and are designed to enable the ERISA plan’s fiduciary to: (1) determine the reasonableness of all compensation received by Buttonwood; (2) identify any potential conflicts of interest; and (3) satisfy reporting and disclosure requirements to plan participants. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Method of Analysis Our methods of analysis, sources of information and investment strategies vary substantially by security or product type, asset class, investment risk, and other factors. In addition to traditional methods such as fundamental and technical analysis, our analysis and sourcing may be supported by phone calls, correspondence or other means of direct and indirect communication with investment managers, third party opinions, investment conference materials and continuing education courses. Other sources of information include traditional research materials such as financial newspapers and magazines, annual reports, prospectuses, filings with the SEC, research materials prepared by others, and company press releases. We also subscribe to various professional publications. B. Investment Strategies and Risk of Loss The primary investment strategies used to implement investment advice given to clients include long- term (held at least one year) and short-term (sold within a year) securities purchases and sales. Investment securities and strategies are implemented in consideration of the client’s risk management Part 2A - 16  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure and risk reduction objectives, and tax strategies, rather than for speculation. The firm’s general investment strategy, consistent with the tenets of modern portfolio theory, is to attempt to reduce overall portfolio risk and volatility by building globally diversified portfolios rather than recommending only a particular type of security or specialized strategy. While open-end mutual funds, bonds (fixed income), and ETFs are the primary investment vehicles used in or recommended for client accounts, we also from time to time recommend Private Funds and fee-based Variable Annuities, when deemed suitable and appropriate. In certain circumstances, if requested by a client we can also provide research on investments that were not recommended by us, and/or are not part of a client’s recommended portfolio. Fixed Income: The most common type of fixed-income security is a bond. Bonds are issued by federal governments, local municipalities, and major corporations. Bonds are debt securities, so the primary risk associated with fixed-income investments is the borrower defaulting on making payments. Fixed- income securities are usually recommended for investors seeking a “balanced” type of portfolio; however, the percentage of the portfolio dedicated to fixed income will depend on an investor’s personal investment objectives. Bonds are usually rated by a national rating company (e.g., Moody’s and Fitch Ratings), which assesses the creditworthiness of the bond and the issuer. The interest payment on fixed-income securities is considered regular income and is determined based on the creditworthiness of the borrower and current market rates. In general, bonds with longer-dated maturities pay a higher rate, also referred to as the coupon rate, because they are considered riskier. The longer the security is on the market, the more time it has to lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns the amount borrowed, also referred to as the principal or par value. Exchange Traded Funds: A number of ETFs are designed to track an index, so their performance is close to that of the selected index. There are also actively managed ETFs, which is an ETF that has one or more managers making investment decisions on the ETF’s underlining portfolio holdings. Some benefits of investing in ETFs include: (a) their underlining portfolio is professionally managed by an investment adviser who researches, selects, and monitors the performance of the securities purchased by the ETF; (b) they usually do not have a dollar amount minimum for any purchases or sells; (c) they have continuous pricing since they are traded on an exchange and can be bought and sold on the exchange any time throughout the trading day; and (d) they usually have lower management and expense fees than open-end mutual funds. Some disadvantages and risks include: (a) investors pay transaction costs, management and administrative fees, and/or other expenses regardless of how the ETF performs; (b) investors cannot directly influence which securities the ETF manager buys and sells or the timing of those trades; (c) ETFs can have lower dividend yields than open-end mutual funds and individual stocks, and (d) their trading price is subject to both market volatility and the volatility of the securities in the ETFs underlining portfolio. Part 2A - 17  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Open-End Mutual Funds: An open-end mutual fund is a company that pools money from many investors into a portfolio and invests the money in a variety of differing security types based on the objectives of the mutual fund. The portfolio of the mutual fund consists of the combined holdings it owns. Each mutual fund share purchased represents the investor’s proportionate ownership of the mutual fund’s holdings and the income those holdings generate. The price that investors pay for mutual fund shares is the fund’s per share net asset value (“NAV”) plus any shareholder fees that the fund imposes at the time of purchase (such as sales loads). Some benefits of investing in open-end mutual funds include: (a) their underlining portfolio is professionally managed by an investment adviser who researches, selects, and monitors the performance of the securities purchased by the fund; (b) they typically have a diversified portfolio; (c) some mutual funds accommodate investors who do not have a lot of money to invest by setting relatively low dollar amounts for initial purchases, subsequent monthly purchases, or both; and (d) at any time, mutual fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed on redemption. Some disadvantages and risks include: (a) investors pay sales charges, annual management and administrative fees, and/or other expenses regardless of how the mutual fund performs; (b) investors cannot directly influence which securities the fund manager buys and sells or the timing of those trades; and (c) the price at which an investor purchases or redeem shares of an open-end mutual fund will depend on the fund’s NAV, which is not calculated until the close of the stock market each day. When investors buy and hold an individual stock or bond, the investor must pay income tax each year on the dividends or interest the investor receives. However, the investor will not have to pay any capital gains tax until the investor actually sells and makes a profit. Open-end mutual funds are different. When an investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary dividends and/or capital gains distributed by the mutual fund in a calendar year to investors. Private Fund Investments: As mentioned in Item 4 above, Buttonwood recommends Private Funds to certain qualified clients. Private Funds are unregistered securities that are usually structured as a limited partnership or limited liability company. Similar to mutual funds, Private Funds pool money received from investors into a portfolio and invests the money based on the objectives of the Private Fund. Initially, Buttonwood will review the investment opportunity and relevant documentation and then determine whether the Private Fund is suitable and in line with any of our qualified clients’ Investment Policy Statement. For the Private Funds where we provide ongoing monitoring and oversight, we will perform periodic due diligence and reviews on these investments, which can include but not be limited to, obtaining and reviewing reports and valuation information from the issuer, such as investor reports, audited financials, and certain regulatory filings, as applicable, and performing due diligence/research on the investment manager and certain other key service providers to the fund. Private Fund investments present special risks for clients, including without limitation, liquidity issues, higher fees, volatile performance, heightened risk of loss, limited transparency, special tax considerations, subjective valuations and limited regulatory oversight. In addition, investors in Private Funds are subject to the risks of each Fund’s underlining investments, which depending on the type of investment can be significant. Therefore, Private Funds are usually not suitable for all our clients Part 2A - 18  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure and, as a result, will only be offered to certain qualifying clients for whom an investment therein is determined to be suitable. Fee-Based Variable Annuities: A variable annuity it an insurance product that offers a range of investment options. These types of investment products are exposed to the risks associated with operations of the issuing life insurance company, such as insurance pricing, asset liability management and interest rate risk, and other operational risks, along with the risks applicable to the types of investments in the annuity’s underlining portfolio (“sub-account”). For example, an annuity that has mutual funds in the sub-account is subject to the risks of investing in a mutual fund. In addition, for some annuities, the allowable investments in a sub-account may be limited and, in some cases, certain riders can cause additional restrictions. The investment management process is administered by the firm’s Investment Policy Committee which meets regularly to conduct structured and ongoing evaluation, implementation, monitoring, and adjusting of investment models and strategies. We often allocate client accounts for consistency with Buttonwood “model” portfolios. The development and maintenance of our model portfolios is materially supported by BlackRock Fund Advisors and/or its affiliates, including BlackRock Investments, LLC (collectively, “BlackRock”), which provides us with investment research, model recommendations and marketing support at no cost. Research and recommendations provided by BlackRock to us, however, predominantly favor the use of iShares ETFs, which are distributed by BlackRock. While we are under no obligation to utilize iShares ETFs in the management of our model portfolios, such model portfolios will predominantly and sometimes exclusively utilize iShares ETFs in their construction. This creates a material conflict of interest for us as the receipt of such services from BlackRock reduces our operating costs, which creates an incentive for us to recommend and utilize products sponsored or distributed by BlackRock in the management of all client accounts. Please see the “Item 10 – Other Financial Industry Activities and Affiliations” section for additional information regarding BlackRock. Securities and strategies have varying degrees of risk and will only be recommended when suitable and appropriate for a particular client’s situation. Additional Material Risks As fiduciaries to our clients, we use our best judgment and good faith efforts in rendering services. However, any investment in securities involves a risk of loss that clients should be prepared to bear. Not e very investment decision or recommendation made by us will be profitable. We cannot warrant or guarantee any particular level of account performance, or that an account will be profitable over time. Some additional investment risks applicable to investing in securities a client should be aware of include, but are not limited, to the following: Market Risk: The price of a stock, bond, mutual fund or other security can drop in reaction to tangible Part 2A - 19  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. Equity Risk: Equity securities are subject to the risk that stock prices can fall over short or extended periods of time. Historically, the equity markets have moved in cycles, and the value of equity securities can fluctuate significantly from day-to-day. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies can suffer a decline in response. These factors contribute to price volatility, which is the principal risk of investing in the strategies we offer. Foreign Risk: Investments in overseas markets (international securities) pose special risks, including currency fluctuation and political risks, and such investments can be more volatile than that of a U.S. only investment. The risks are generally intensified for investments in emerging markets. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Political and Legislative Risk: Companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the United States or those companies who conduct a substantial amount of their business outside of the United States. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Concentration Risk: Having too much exposure to one type of investment or sector increases the potential for loss due to various factors, including but not limited to liquidity constraints, company financial issues, and market movement. Variable Annuities: Risks and restrictions are outlined in each respective annuity’s prospectus and statement of additional information and should be read carefully. Also, please refer to the SEC’s Part 2A - 20  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Investor Bulletin, which provides additional risk details at https://www.sec.gov/oiea/investor-alerts- and-bulletins/ib_variableannuities#Annuity_Fees. Private Fund Risk: Private investment funds represent speculative investments and involve a high degree of risk. An investor could lose all or a substantial portion of his/her investment. Investors must have the financial ability, sophistication/experience and willingness to bear the risks of an investment in a private investment fund. Any investment in private investment funds should be discretionary capital set aside strictly for speculative purposes. An investment in a private investment fund is not suitable or desirable for all clients. Only qualified eligible clients can invest in private investment funds. An investment in a private investment fund is usually illiquid and there can be significant restrictions on selling or transferring interests in a private investment fund. information, please to the SEC Investor Bulletin Additionally, private investment funds, including the Private Funds that Buttonwood recommends are usually exempt from registration as a security under Regulation D of the Securities Act of 1933, which means they are not regulated by the U.S. Securities and Exchange Commission, which carries risk. For more at refer https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts- bulletins/investor-bulletins/private. Margin Account Risks: Clients with margin accounts should be aware that there are a number of additional risks that need to be considered. The risks associated with margin accounts include, but are not limited to, the following: • Clients can lose more assets than you deposit in the margin account. A decline in the value of securities in a margin account can require you to provide additional funds to the brokerage firm that has made the loan to avoid the forced sale of securities in a client’s account. • The lending brokerage firm/custodian is allowed to force a sale of securities in a client’s margin account. If the equity in a client’s account falls below the maintenance margin requirements under the law—or the lending brokerage firm’s higher “house” requirements—the brokerage firm/custodian can sell the securities in a client’s account to cover the margin deficiency. A client will also be responsible for any short fall in their account after such a sale. by the SEC at It is important that clients take time to learn about the risks involved with borrowing on margin, and clients should consult with Buttonwood’s advisers regarding any concerns they may have with their margin accounts. For further information about these types of loans, please refer to the Investor Bulletin https://www.sec.gov/oiea/investor-alerts-and- issued bulletins/ib_marginaccount. Securities Backed Loans and Lines of Credit: These types of loans are not suitable for all investors and carry a number of risks, which include: (i) failure to perform by the lender due to financial instability, (ii) tax consequences and loss of appreciation due to premature sale of the securities used as collateral, (iii) lack of funds to repay the loan, and (iv) high cost and high-interest rate charges. For further information about these securities-backed loans and lines of credit, please refer to the Investor Alert Part 2A - 21  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure issued by the SEC at https://www.investor.gov/introduction-investing/general-resources/news- alerts/alerts-bulletins/investor-alerts/investor-28 Clients assume all market risk involved in the investment of account assets. Investments are subject to various market, currency, interest rate, economic, political and business risks. Buttonwood does not represent, guarantee, or imply that the services or methods of analysis employed by us can or will predict future results or insulate any clients from losses due to declining markets. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm or the integrity of our management. On September 23, 2021, following an exam and investigation, the Securities and Exchange Commission ("SEC") initiated a civil action alleging that Buttonwood and its President Jon McGraw violated certain provisions of the Investment Advisers Act of 1940 ("Advisors Act") related to adequacy of disclosures to its clients with respect to mutual fund investments and related conflict of interests with respect to transaction costs. On October 10, 2023, the SEC agreed to and did dismiss with prejudice its claim that Buttonwood and Mr. McGraw acted with scienter, that is, that they committed knowing or reckless misconduct. Also on October 10, 2023, the firm and Mr. McGraw reached a settlement with the SEC of the remaining claims in that civil action without admitting or denying such claims. On November 21, 2023, the U.S. District Court for the Western District of Missouri (Case No. 21-00686-CV-W-BP) approved that settlement in a final judgment. Pursuant to that final judgment approving the settlement: (i) the firm and Mr. McGraw were prospectively and permanently enjoined from violating Sections 206(2) and 206(4) of the Advisers Act; (ii) the firm was required to pay $139,073 in disgorgement and $16,107.13 in interest (of which Mr. McGraw was jointly and severally liable for $79,966.98 and $9,261.60 respectively); (iii) the firm was also required to pay a $100,000 civil penalty; and (iv) Mr. McGraw was also required to pay a $45,000 civil penalty. Item 10 – Other Financial Industry Activities and Affiliations I nsurance Activities From time to time, Buttonwood advisors will recommend that a client purchase one or more types of insurance, depending on the needs of the client. Should a client decide to implement the recommendation and does not have an insurance agent or agency that they work with, Buttonwood will recommend such to the client and at times help facilitate the purchase of the insurance. Buttonwood does not receive any type of compensation for such referrals and/or assistance, and we do not share in any commissions received by the agent or agency should a client purchase the insurance. Clients are free at all times to use any insurance agency or agent they choose. O ther Financial Industry Activities - Arrangement with Mutual Securities, Inc. Our firm has entered into an agreement with Mutual Group (formerly known as Mutual Securities Part 2A - 22  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Inc.), member FINRA/SIPC, whereby Mutual Group will provide operational support services as a platform provider of clients directly held investments. These holdings might include variable annuities, among others. This contractual engagement does not include exercising discretionary authority over Mutual Group brokerage accounts or directly held investments, although we do provide limited monitoring of certain directly held investments. Clients will be solicited to utilize Mutual Group but are under no obligation to move their variable annuities or other securities. For clients of Mutual Group who provide Mutual Group with written consent requesting ongoing investment advisory services, our firm will be engaged to provide ongoing investment-related advisory services on a non- discretionary basis to Mutual Group which may include a general review of client investment holdings, general investment advice, and specific securities recommendations on certain directly held investment holdings. Buttonwood will however consider client directly held investments as part of its Family CFO Services regardless of whether or not client contracts with Mutual Group. For our advisory services provided to Mutual Group, our firm is compensated by Mutual Group through a percentage of the overall assets under advisement not to exceed 0.50%. Clients should be aware that the receipt of these advisory revenues creates a conflict of interest for us as it creates an incentive for us to recommend the use of Mutual Group. Buttonwood addresses these conflicts of interest by (1) providing disclosure of the relationship and the associated conflicts of interest to clients in this Form ADV Part 2A Brochure, and (2) reminding clients that they are under no obligation to use Mutual Group. O ther Financial Industry Activities - Arrangement with BlackRock Fund Advisors Our firm has an arrangement with BlackRock Fund Advisors (“BlackRock”, CRD No. 105247) whereby BlackRock provides our firm ongoing consultation, through their Custom Model Solutions group, around portfolio risk and asset management strategy. BlackRock CMS partially bases their strategy upon data from BlackRock's Aladdin® Platform, a portfolio management and risk analytics operating system. BlackRock also provides our firm with access to various BlackRock software tools as well as both standard BlackRock and custom model portfolios. Through our relationship, they have also provided our firm marketing support at no cost to us. Investment allocations, strategy and models provided by BlackRock are used by us in the development and maintenance of our investment allocations for clients’ managed accounts. Investment models that contain mutual funds and ETFs can predominantly and sometimes exclusively utilize mutual funds and ETFs, which are sponsored, distributed and/or advised by BlackRock. These include iShares ETFs and open-end mutual funds that contain “BlackRock” in the fund name. Buttonwood’s acceptance of investment research, models, trading tools and/or technology paid for or provided by BlackRock creates a conflict of interest for us because the acceptance of these benefits reduces our operating costs, which, in turn, creates an incentive for us to recommend and/or use iShares ETFs and/or other BlackRock products in the investment management of client accounts. BlackRock does not provide and is not responsible for providing investment advice to clients of Buttonwood, does not participate in or make any investment decisions on behalf of Buttonwood or clients of Buttonwood, does not endorse any investment decision or recommendation made by Buttonwood or its representatives, and has no obligation to continue to provide us with its investment models and/or access either to the Aladdin® Platform or trading tools. In addition to the Part 2A - 23  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure aforementioned benefits, from time to time, BlackRock provides Buttonwood personnel discounted or free attendance to conferences, meetings and other educational or social events, which has in the past and may in the future include full coverage of travel expenses to such events. Clients should be aware that the receipt of these benefits creates a conflict of interest for us as it creates another incentive for us to recommend the use of iShares ETFs and/or other BlackRock products in the investment management of client accounts. Buttonwood addresses these conflicts of interest by (1) providing disclosure of the relationship and the associated conflicts of interest to clients in this Form ADV Part 2A Brochure, (2) reminding clients that they have the ability to impose reasonable restrictions on the securities or types of securities to be held in their portfolios, including a restriction on the purchase and/or use of investment products associated with BlackRock, and (3) periodically reviewing (generally on an annual basis) our Investment Policy Committee process, partnerships and providers, which includes assessing the scope of services and resources provided, costs, communications, and other factors of a particular provider, relative to various other similar service providers which may be available. Additional information about either BlackRock can be found in the applicable firm’s Form ADV Part 2 Disclosure Brochure which is available upon request or can be found on the SEC’s website at www.adviserinfo.sec.gov. Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading C ode of Ethics Buttonwood has a Code of Ethics which all employees are required to follow. The Code of Ethics outlines our high standard of business conduct and fiduciary duty to Clients. The Code of Ethics includes provisions relating to the confidentiality of Client information, a prohibition on insider trading, and personal securities trading procedures, among other things. A copy of the Code of Ethics is available to any Client or prospective Client upon request by contacting Jon McGraw at (816) 285- 9000 or jon@buttonwoodfg.com. P ersonal Trading and Conflicts of Interest We do not have any interest in, own, or manage companies that we advise our clients to buy. From time to time, Buttonwood and/or individuals associated with our firm buy and sell many of the same securities for their own account that we buy and sell for our clients. When individuals associated with Buttonwood do own the same securities as our clients, we will purchase or sell securities for Clients before or at the same time as purchasing the same for our account or allowing representatives to purchase or sell the same for their own account. In some cases, Buttonwood or representatives may buy or sell securities for their own account for reasons not related to the strategies adopted for our clients. Our employees are required to follow the Code of Ethics when making trades for their own accounts in securities which are recommended to and/or purchased for Clients. The Code of Ethics is designed to help assure that the personal securities transactions will not interfere with Part 2A - 24  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure decisions made in the best interest of advisory Clients while at the same time, allowing employees to invest their own accounts. Buttonwood will disclose to advisory Clients any material personal trading conflict of interest relating to us, our representatives, or any of our employees which could reasonably be expected to impair the rendering of unbiased and objective advice. Item 12 – Brokerage Practices T he Custodians and Brokers We Use Buttonwood does not maintain possession of client assets. Instead, we require all client assets be maintained in an account at a non-affiliated “qualified custodian,” generally a broker-dealer or bank. The qualified custodian we generally use for clients’ managed accounts is Charles Schwab & Co. (referred to herein as “Schwab” or our “primary custodian”), Inc., a registered broker-dealer and member of the Financial Services Regulatory Authority (FINRA). However, clients ultimately decide what custodian(s) to use and will open an account with the custodian by entering into an account agreement directly with them. We do not actually open accounts for you, although we can assist you in doing so. We also make other custodian recommendations from time to time. H ow We Select Custodians and Brokers In determining whether to recommend a custodian or broker to our advisory clients, we consider many different factors including quality of service, types of services offered, overall capability, execution quality, competitiveness of transaction costs, availability of investment research, reputation and stability of the firm, and their financial resources, and stability, among other things. In determining the reasonableness of a broker’s compensation, we consider the overall cost to you relative to the benefits you receive, both directly and indirectly, from the broker. Although you may direct us to use another broker or custodian, this may result in less favorable execution quality and or may result in greater transaction and other costs. Y our Brokerage and Custody Costs Our clients receive various services directly from our custodians and our brokers. For our clients’ accounts that are custodied at Schwab, Schwab generally does not charge separately for custody services. Schwab is compensated by platform fees, mutual fund and money market fees, transaction fees, and other fees generated from our client assets Transaction fees applicable to our clients’ accounts were negotiated based on the condition that our clients collectively maintain a certain level of assets at Schwab. In addition to transaction fees, Schwab charges a flat dollar amount when serving as a “prime broker” for each trade that Buttonwood has executed by a different broker-dealer but where the securities bought, or the funds from the securities sold, are deposited (settled) into a client’s Schwab account. Please also refer to “Prime Brokerage Arrangements” below for further information on trade execution and costs. Part 2A - 25  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure P roducts and Services Available to Us from Brokers/Custodians Our custodians and our brokers provide us and our clients with access to institutional brokerage services like trading, custody, reporting, and related services, many of which are not typically available to retail customers. Our custodians and brokers also make available various support services, some of which help us manage or administer our clients’ accounts, while others help us manage and grow our business. Our custodians’ and brokers’ institutional brokerage services which benefit you directly may include access to a broad range of investment products, execution of securities transactions, and asset custody. The investment products available through them include some which we might not otherwise have access to or that would require a significantly higher minimum initial investment by our clients. Our primary custodian, Charles Schwab, also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both our custodian’s own and that of third parties. We can use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at our primary custodian. In addition to investment research, our primary custodian also makes available software and other technology that provide access to client account data, facilitates trade execution for multiple client accounts, provides pricing and other market data, facilitates payment of our fees from our clients’ accounts, and assists with back- office functions, recordkeeping, and client reporting. Our primary custodian and brokers also offer other services intended to help us manage and further develop our business. These services include educational conferences and events, consulting on technology, compliance, Cyber Security, legal, and business needs, publications and conferences on practice management and business succession, and access to employee benefits providers, human capital consultants, and insurance providers. The availability of these services from our custodians and brokers benefits us because we do not have to spend as much time researching and in certain situations, purchasing them. This gives us an incentive to recommend that you maintain your account with Schwab based on our interests rather than yours, which is a conflict of interest. We believe, however, that our selection of our custodians and our brokers is in the best interests of our clients, and is primarily supported by the scope, quality, and price of their services that benefit you and not the services that benefit only us. We assess our custodians as part of our normal trading and review process and through periodic testing. Prime Brokerage Arrangements While we mainly place transactions for client accounts with the client’s custodian (e.g., Schwab) for execution, there are times when we use an alternative broker-dealer to provide execution of certain securities transactions. This takes place under a “prime brokerage” or trade away arrangement and usually requires Buttonwood and/or the applicable clients to enter into an agreement (e.g., Prime Brokerage Agreement) with the custodian. Part 2A - 26  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Typically, we use a prime brokerage arrangement for transactions in fixed income securities, such as municipal bonds, when the custodian does not have the ability to obtain the security, or we believe that best execution for such a transaction can be achieved outside the custodian. Clients are under no obligation to enter into a Prime Brokerage Agreement with their custodian and should ensure that they fully read and understand the terms and conditions of such arrangement prior to entering into such an agreement. In addition, in order for a client to participate in a prime brokerage arrangement, the client is required to maintain a minimum net equity of cash and securities in their custodian account, as determined by the custodian. Buttonwood only uses executing brokers that meet our standards with respect to execution and research capabilities. Each of the executing brokers also enters into a Prime Brokerage Agreement with the client’s custodian. An account will be opened with the executing broker in the name of the custodian (e.g., Schwab) as Prime Broker designated for the benefit of the Buttonwood client or Buttonwood on behalf of its clients. This allows the executing broker to execute the trade and then send the trade to the custodian as the Prime Broker for settlement. Buttonwood clients receive confirmations and account statements from their custodian, which include, among other things, a description of each executed transaction, the transaction fees charged (when applicable), including the Prime Broker fee (which is in addition to transaction fees) that is charged by the custodian and the identification of the broker used for execution, along with other required information. Please note that confirmations and statements received by clients with accounts held at Schwab where we pay transaction costs will not reflect the transaction and prime broker fees since they are paid by Buttonwood. Prime brokerage arrangements give Buttonwood more access to fixed income securities beyond the custodian’s inventory and helps us seek better execution by having greater flexibility to, in most cases, negotiate price and transactions costs with the executing broker. Usually, when trading in bonds under the prime brokerage arrangement, the executing broker will add an amount to the execution price of the bond vs. charging a transaction fee or commission. This is referred to as a “markup” and the typical amount charged by the executing broker(s) used by Buttonwood is 0.0025%. That cost is in addition to the fee that the custodian charges for prime brokerage transactions. As referenced above, for clients with accounts custodied at Schwab, any transaction fees charged by the executing broker and the prime brokerage fees charged by Schwab are paid by Buttonwood. However, for fixed income transactions, since the markup amount is embedded into the price of the bond, that cost is borne by the client. Importantly, Buttonwood will only place prime brokerage transactions when the firm believes such transactions will provide overall best execution for the participating clients. Soft Dollar Considerations Section 28(e) of the Exchange Act (“Section 28(e)”) generally allows investment advisers to use client commissions to pay for certain brokerage and research services under certain circumstances without Part 2A - 27  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure breaching their fiduciary duties to clients. Therefore, we do in circumstances in which we feel that execution is comparable, place certain trades with a third-party broker that is providing brokerage and research services to us (“Research Broker”). Brokerage and research services provided by Research Brokers include, among other things, effecting securities transactions and performing services incidental thereto (such as clearance, settlement and custody) and providing research, such as information regarding the economy, industries, securities, sectors of securities, statistical information, and more. Such research services can be received in various forms, including written reports, telephone conversations, and meetings with security analysts and/or individual company management and attending conferences. In addition, the research provided by a Research Broker may be proprietary (i.e., research created by the broker) and/or provided by a third party (i.e. originates from a party independent from the broker providing the execution services, which is commonly referred to as a third-party soft dollar arrangement). In selecting a Research Broker, we make a good faith determination that the amount of the commission charged is reasonable in relation to the value of the brokerage and research services received, viewed in terms of either the specific transactions or our overall responsibility to the accounts for which we exercise investment discretion. Research provided by Research Brokers can be used by us in servicing any or all of our clients, as permitted by Section 28(e). The receipt of brokerage and research services from any broker executing transactions for our clients will not result in a reduction of our customary and normal research activities. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit by us, and although customary, may be deemed to create a conflict of interest between Buttonwood and our clients. Therefore, we believe it is important for clients to be aware of the issues surrounding soft dollars. To address the conflicts inherent in soft dollar arrangements, Buttonwood monitors and reviews transaction results to evaluate the quality of execution provided in order to determine that compensation rates are competitive and otherwise to evaluate the reasonableness of the compensation paid to the executing broker-dealer(s) in light of all the factors described above and that our clients are receiving the best overall deal considering the prevailing facts and circumstances. Currently, Buttonwood does not have any third-party soft dollar arrangements in place. Best Execution To ensure that custodians and brokers recommended by Buttonwood are conducting overall best qualitative execution, we periodically (and no less often than annually) evaluate the trading process and custodians and brokers utilized. Our evaluation considers the full range of brokerage services offered by the custodians and brokers, which will include, as applicable, execution price, transaction fees, research, ability to aggregate trades, capital strength and stability, reliable and accurate communications and settlement processing, use of automation, knowledge of other buyers or sellers, custody, and any services provided to client and/or Buttonwood. Part 2A - 28  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure A ggregation of Transactions While not required, we will aggregate trades for clients in managed accounts, when we have the opportunity, and we believe it is in the best interest of the clients that can participate in an aggregated trade. For aggregated trades that are filled in their entirety, each participating account will receive the average share price. If the aggregated trade is only partially filled, we will allocate the securities traded among participating clients on a pro-rata basis unless we believe the partial fill is not meaningful; then we will allocate in a manner that the Firm considers equitable to all the participating accounts. It is expected that this trade aggregation and allocation policy will be applied consistently. However, if the application of this policy is impractical or results in unfair or inequitable treatment to some or all of our clients, we may deviate from this policy. Item 13 – Review of Accounts R eview of Clients Accounts While the underlying securities within managed accounts are continually monitored by us, managed accounts are reviewed with clients on a regular basis, but no less than annually. Account reviews are performed by registered investment advisory representatives of the firm in the context of each client's stated investment objectives and guidelines. In some instances, however, we may hold certain securities in managed accounts which are held at a client’s direction and are not subject to Buttonwood’s review. More frequent reviews may be triggered by a change in client's investment objectives; tax considerations; and/or changes in the economic climate, or other factors. The type and frequency of review when providing financial planning services will vary depending on client needs. R eports Provided to Clients Investment advisory accounts clients receive account statements from the custodian of their account(s) on a monthly or quarterly basis, as determined by the custodian. We may also provide clients with periodic written reports summarizing account activity and performance. Financial Planning Only clients will generally receive some form of written financial plan. However additional reports will not typically be provided unless otherwise provided for under the terms of the engagement. We strongly recommend that all Clients carefully review statements from the custodian and compare these to reports that we provide. Our reports usually vary from custodial statements based on the type of report provided (e.g., performance report vs. account statement), time period covered in the report, and pricing service used for securities valuations. Part 2A - 29  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Item 14 – Client Referrals and Other Compensation R eferral Arrangements The majority of our new clients come from introductions made by existing clients. However, Buttonwood does not provide any direct or indirect compensation to any client or unaffiliated third party for client referrals. Should Buttonwood decide in the future to provide compensation to a client or unaffiliated third party for client referrals, the firm will only do so in accordance with the requirements of Rule 206(4)- 1 of the Advisers Act and any applicable corresponding state securities laws. Our investment adviser representatives are not directly compensated for bringing in new clients. O ther Economic Benefits Buttonwood receives economic benefits from our custodians in the form of the support products and services that are made available to us and to other independent investment advisors. These products and services, how they benefit us, and the related conflicts of interest are described in Item 12 above. The availability to us of our custodian’s products and services is not based on us giving particular investment advice, such as buying specific securities for our clients. Buttonwood also utilizes the services of various outside service providers and vendors to assist us in managing investment accounts for Clients and providing Family CFO Services to Clients. In determining whether to use an outside service provider or vendor, we consider many different factors including quality of service, types of services offered, overall capability, cost, reputation, stability, etc. In some cases, we bear the full cost of such outsourcing, but in some cases, clients may have fees and costs. Although such service providers and vendors may earn compensation from our clients in addition to what we pay them, we do not share in such additional compensation. We may however receive cost discounts related to volume commitments which would be a conflict of interest in that we could save incremental costs be making larger volume commitments. We feel though that these commitments benefit not just us but also our Clients in that they allow us to provide various services at a lower overall cost. Furthermore, we believe that that our selection of our outside service providers and vendors is in the best interests of our clients, and is primarily supported by the scope, quality, and price of their services that benefit both our clients and us. Item 15 – Custody As mentioned in Item 12 above, we do not hold client assets but instead require that they be held by a third party “qualified custodian.” We do however have limited control in some instances to trade on your behalf, to deduct our advisory fees from your account with your authorization, and/or to request disbursements at your direction (although various types of written authorizations are required depending on the type of account and the type of disbursements). You will receive account statements directly from your custodian, which will be sent to the email or postal mailing address you provide. We strongly recommend that you carefully review these custodial Part 2A - 30  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure statements when you receive them and compare them to reports you receive from us. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion For discretionary Investment Management Services, the client grants Buttonwood limited power-of- attorney with discretionary trading authority to effect investment transactions involving the client’s account(s), including the authority to buy, sell, and execute its investment recommendations for the client in accordance with the client’s investment goals, objectives and risk tolerance, amd without obtaining the client's prior approval of any proposed transaction. Under this authority, Buttonwood can invest, sell, and reinvest proceeds in a client’s account, at our discretion, give instructions in furtherance of such trading authority to brokers, dealers and/or other parties necessary to effect such transactions on behalf of the account, select service providers (including sub-advisers) who are assisting with the service of client’s account, and act on behalf of the client in all matters necessary or incidental to the management of the account(s). For non-discretionary Investment Management Services, Buttonwood can only invest, sell, and reinvest client’s account assets on behalf of the client upon obtaining the client’s prior consent before taking any proposed action. In these circumstances, no transactions will be placed for execution without the client’s prior consent and approval. Clients may impose reasonable restrictions on investing in certain securities or types of securities and may request that non-recommended securities be held at the client’s direction in their account. Item 17 – Voting Client Securities Buttonwood does not accept authority to vote proxies on behalf of clients for securities held in clients’ accounts, with the exception of certain ERISA Plan clients (see below). In addition, Buttonwood will not be responsible for making any elections in regard to any mergers, acquisitions, tender offers, bankruptcy proceedings, class actions, or other corporate accounts. Clients will receive proxies and other solicitations directly from their custodian or transfer agent. If any proxy materials are received by us on behalf of a client, they will be sent directly to the client or a designated representative of the client, who is responsible for voting the proxy. For ERISA Plan clients where Buttonwood serves as a Section 3(38) fiduciary, Buttonwood will vote proxies if the firm has specifically been delegated the responsibility to vote proxies in the ERISA Plan’s documents. A copy of our Proxy Voting Policy is available upon request by contacting us (please see contact information on the cover page of this Brochure). Part 2A - 31  Buttonwood Financial Group, LLC Part 2A of Form ADV – Brochure Item 18 – Financial Information Registered investment advisers are required in some cases to provide certain financial information and/or disclosures about their financial condition. For example, if the firm requires prepayment of fees for six months in advance, has discretionary authority or custody of client funds, or has a condition that is reasonably likely to impair its ability to meet its contractual commitments to its clients, it must provide certain financial information and make certain disclosures. Buttonwood has no financial or operating conditions which trigger such additional reporting requirements. Part 2A - 32