Overview

Assets Under Management: $231 million
Headquarters: SAN JUAN CAPISTRANO, CA
High-Net-Worth Clients: 28
Average Client Assets: $1 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting

Fee Structure

Primary Fee Schedule (CFCG ADV 2A)

MinMaxMarginal Fee Rate
$0 $100,000 1.25%
$100,001 $250,000 0.85%
$250,001 $500,000 0.80%
$500,001 $1,000,000 0.75%
$1,000,001 $2,000,000 0.45%
$2,000,001 $5,000,000 0.25%
$5,000,001 $10,000,000 0.20%
$10,000,001 and above 0.15%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $8,275 0.83%
$5 million $20,275 0.41%
$10 million $30,275 0.30%
$50 million $90,275 0.18%
$100 million $165,275 0.17%

Clients

Number of High-Net-Worth Clients: 28
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 71.35
Average High-Net-Worth Client Assets: $1 million
Total Client Accounts: 1,458
Discretionary Accounts: 1,458

Regulatory Filings

CRD Number: 133657
Last Filing Date: 2024-03-27 00:00:00
Website: https://capitalfin.com

Form ADV Documents

Additional Brochure: CFCG ADV 2A (2025-07-11)

View Document Text
Part 2A of Form ADV: Firm Brochure 31461 Rancho Viejo Road, Suite 104 San Juan Capistrano, CA 92675 949-248-8800 jfisher@capitalfin.com www.capitalfin.com July 11, 2025 This brochure provides information about the qualifications and business practices of Capital Financial Consultants Group, Inc. If you have any questions about the contents of this brochure, please contact Jeff Fisher at 949-248-8800 or jfisher@capitalfin.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 Capital Financial Consultants Group also is available on the SEC's website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 133657. Capital Financial Consultants Group is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1 Item 2 Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual amendment on March 26, 2025, Capital Financial Consultants Group has the following material changes to report: • Our firm is transitioning from an SEC registered firm to a California state registered firm. 2 Item 3 Table Of Contents Item 1 Cover Page Item 2 Material Changes Item 3 Table Of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Item 19 Requirements for State-Registered Advisers Page 1 Page 2 Page 3 Page 4 Page 6 Page 8 Page 8 Page 9 Page 12 Page 12 Page 13 Page 15 Page 17 Page 17 Page 18 Page 18 Page 19 Page 19 Page 20 3 Item 4 Advisory Business Capital Financial Consultants Group, Inc. (formerly Steckler & Wynns Insurance Services, Inc.) is an independent registered investment adviser with its principal place of business located in CA. Capital Financial Consultants Group began conducting business in 2017. The following individuals are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). Jeff Fisher, President and CCO Capital Financial Consultants Group offers the following advisory services to our clients. INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we create and manage a portfolio based on that policy. During our data-gathering process, we determine the client's objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth, and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and will include advice regarding the following securities: Interests in partnerships investing in real estate Interests in partnerships investing in oil and gas interests • Exchange-listed securities • Securities traded over the counter • Foreign issuers • Warrants • Corporate debt securities (other than commercial paper) • Commercial paper • Certificates of deposit • Municipal securities • Variable life insurance • Variable annuities • Mutual fund shares • United States government securities • Options contracts on securities • • Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. 4 FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client to achieve his or her financial goals and objectives. In general, the financial plan can address any or all the following areas: • PERSONAL: We review family records, budgeting, personal liability, estate information, and financial goals. TAX & CASH FLOW: We analyze the client's income tax and spending and planning for past, current, and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. • INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio. INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. • RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. • DEATH & DISABILITY: We review the client's cash needs at death, income needs of surviving dependents, estate planning, and disability income. • ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney and asset protection plans. We gather the required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written financial plan. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. The implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are generic. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through the investment adviser. Pursuant to California Code of Regulations, 10 CCR Section 260.235.2, Capital Financial Consultants Group hereby makes the following statement: a conflict exists between the interest of Capital Financial Consultants Group and the interests of the client. Further, the client is under no obligation to act 5 upon Capital Financial Consultants Group recommendations, and if the client elects to act on any of the recommendations, the client is under no obligation to effect the transactions through Capital Financial Consultants Group. All material conflicts of interest under CCR Section 260.238 (k) are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. While the firm endeavors at all times to offer clients its specialized services at reasonable costs, the fees charged by other advisers for comparable services may be lower than the fees charged by Capital Financial Consultants Group. IRA Rollover Recommendations 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 WRAP FEE PROGRAMS We do not participate in any wrap fee program. AMOUNT OF MANAGED ASSETS As of March 1, 2025, our firm manages approximately $42,045,222 of clients' assets on a discretionary basis and $0 assets on a non-discretionary basis. Item 5 Fees and Compensation INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT The annualized fee for Investment Supervisory Services is charged as a percentage of assets under management, according to the following schedule: Annualized Investment Management Fees Account Value From Account Value To Annual Percentage Fee $0 $99,999.99 1.25% $100,000 $249,999.99 .85% $250,000 $499,999.99 .80% $500,000 $999,999.99 .75% 6 $1,000,000 $1,999,999.99 .45% $2,000,000 $4,999,999.99 .25% $5,000,000 $9,999,999.99 .20% $10,000,000.00 Plus .15% Our fees are billed monthly, in advance, at the beginning of each month based upon the value (market value or fair market value in the absence of market value), of the client's account at the end of the previous billing period. Fees will be debited from the account in accordance with the client authorization in the Client Services Agreement. Limited Negotiability of Advisory Fees: Although Capital Financial Consultants Group has established the aforementioned fee schedules, we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances, and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the contract between the adviser and each client. Discounts, not available to our advisory clients, may be offered to family members and friends of associated persons of our firm. FINANCIAL PLANNING FEES Capital Financial Consultants Group's Financial Planning fee is determined based on the nature of the services being provided and the complexity of each client's circumstances. All fees are agreed upon prior to entering a contract with any client. Our Financial Planning fees are calculated and charged on an hourly basis, ranging from $100 to $200 per hour. Although the length of time it will take to provide a Financial Plan will depend on each client's personal situation, we will provide an estimate for the total hours at the start of the advisory relationship. Our Financial Planning fees are calculated and charged on a fixed fee basis which start at $1,500. We may request a retainer upon completion of our initial fact-finding session with the client; however, advance payment will never exceed $500 for work that will not be completed within six months. The balance is due upon completion of the plan. GENERAL INFORMATION Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. Mutual Fund and ETF Fees: All fees paid to Capital Financial Consultants Group for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and 7 objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any transaction charges imposed by a broker-dealer with which an independent investment manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Registered Representatives and Insurance Agents: Management personnel and other related persons of our firm are licensed as registered representatives of a broker-dealer and/or licensed as insurance agents or brokers. In their separate capacity (ies), these individuals can implement investment recommendations for advisory clients for separate and typical compensation (i.e., commissions, 12b-1 fees, or other sales-related forms of compensation). This presents a conflict of interest to the extent that these individuals recommend that a client invests in a security that results in a commission being paid to the individuals. Clients are not under any obligation to engage these individuals when considering the implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees more than $500 more than six months in advance of services rendered. State of California Required Disclosures While our firm endeavors at all times to offer clients specialized services at reasonable costs, the fees charged by other investments advisers for comparable services may be lower than the fees charged by our firm. Item 6 Performance-Based Fees and Side-By-Side Management Fees are not based on a share of the capital gains or capital appreciation of managed securities.CapitalFinancialConsultantsGroupdoes notuseaperformance-basedfeestructure. Item 7 Types of Clients Capital Financial Consultants Group provides advisory services to the following types of clients: Individuals (other than high net worth individuals) • • High net worth individuals • Charitable organizations • Pension and profit-sharing plans • Corporations We do not have any minimum requirements (no minimum account size or fees) to open or maintain an account with us. 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: Charting: In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend may last and when that trend might reverse. Fundamental Analysis:We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Cyclical Analysis: In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client's investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client's goals. Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is a significant overlap in the underlying investments held in another fund(s) in the client's portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client's portfolio. Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investment Strategies We use the following strategies in managing client accounts, provided that such strategy(ies) is appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: 9 Long-term purchase: We purchase securities with the idea of holding them in the client's account for a year or longer. Typically, we employ this strategy when (1) we believe the securities to be currently undervalued, and/or (2) we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short-term purchases: When utilizing this strategy, we purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short- term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Trading: We purchase securities with the idea of selling them very quickly (typically within 30 days or less). We do this in an attempt to take advantage of our predictions of brief price swings. Short sales: We borrow shares of a stock for your portfolio from someone who owns the stock on a promise to replace the shares on a future date at a certain price. Those borrowed shares are then sold. On the agreed-upon future date, we buy the same stock and return the shares to the original owner. We engage in short selling based on our determination that the stock will go down in price after we have borrowed the shares. If we are correct and the stock price has gone down since the shares were purchased from the original owner, client account realizes the profit. Margin transactions:We will purchase stocks for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase stock without selling other holdings. Option writing: We may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative because it derives its value from an underlying asset. The two types of options are calls and puts: A call gives us the right to buy an asset at a certain price within a specific period. We will buy a call if we have determined that the stock will increase before the option expires. A put gives us the holder the right to sell an asset at a certain price within a specific period. We will buy a put if we have determined that the price of the stock will fall before the option expires. We will use options to speculate on the possibility of a sharp price swing. We will also use options to "hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for your portfolio. 10 We use "covered calls", in which we sell an option on the security you own. In this strategy, you receive a fee for making the option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price. We use a "spreading strategy", in which we purchase two or more option contracts (for example, a call option that you buy and a call option that you sell) for the same underlying security. This effectively puts you on both sides of the market, but with the ability to vary price, time, and other factors. Risk of Loss Different types of investments involve varying degrees of risk. It should not be assumed that future performance of any specific investment or investment strategy (including the investments and or investment strategies recommended or undertaken by Capital Financial Consultants Group) will be profitable or equal to any specific performance level(s). Securities investments are not guaranteed, and you may lose money on your investments. Clients should understand that investing in any securities involves a risk of loss of both income and principal. You should be prepared to bear these risks. We ask that you work with us to help us understand your tolerance for risk. We primarily invest in equity, fixed income, and ETF securities to carry out its investment strategies. The basic risks for each of these securities are discussed below. The fundamental risks of investing in equity securities include the following: market risk (the risk that an investment will decline in value); liquidity risk (the risk that you will be unable to sell an asset); economic risk (the risk of a general downturn in the economy); and tax risk (the risk that the value of investments will be adversely affected by changes in tax laws). The fundamental risks of investing in fixed income securities include the following: market risk (the risk that an investment will decline in value); liquidity risk (limited or no marketability); economic risk (the risk of a general downturn in the economy); tax risk (the risk that the value of investments will be adversely affected by changes in tax laws); and business risk (the risk of inadequate profits or losses due to uncertainties.) Exchange traded funds (ETFs) are investment funds that are traded on stock exchanges. They invest in different securities like stocks, bonds, real estate investment trusts, etc. The prices of ETFs may differ from the underlying value of the securities within the ETF by the fact they are traded on an exchange and thus exposed to the supply and demand forces of market participants. Price premiums and discounts arise, especially for those ETFs that are not traded very frequently. (ETFs) shareholders are subject to the risks stemming from the individual issuers of the fund's underlying portfolio securities such as the equity and fixed income risks discussed above. In addition, shareholders are liable for taxes on any fund-level capital gains, as ETFs are required by law to distribute capital gains in the event, they sell securities for a profit that cannot be offset by a corresponding loss. If an account uses leverage, the account will be subject to heightened risk. Leverage may take the form of borrowing funds, trading on margin, derivative instruments that are inherently leveraged including options. Any such leverage, including leverage that takes the form of instruments and transactions that are inherently leveraged, may result in the account's market value exposure being more than the net asset value of the account. An account may not be able to liquidate assets quickly enough to repay its borrowings, which will increase the losses incurred by the account. In addition to the risks described above that primarily relate to the value of investments, there are various operational, and systems risks involved in investing, including but not limited to "cybersecurity" risk. As the use of technology and frequency of cyber-attacks on financial services targets has become more prevalent, Capital Financial Consultants Group and the client accounts Capital Financial Consultants Group manages have become potentially more susceptible to operational risks through 11 breaches in cybersecurity. A breach in cybersecurity refers to both intentional and unintentional events that may cause Capital Financial Consultants Group to lose proprietary information, suffer data corruption, or lose operational capacity. This, in turn, could cause Capital Financial Consultants Group and/or a client account to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. A cybersecurity breach may also result in a third party obtaining unauthorized access to Capital Financial Consultants Group clients' information, including social security numbers, home addresses, account numbers, account balances, and account holdings. Cybersecurity breaches may involve unauthorized access to digital information systems (e.g., through "hacking" or malicious software coding), and may also result from outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users). In addition, cybersecurity breaches of third-party service providers (e.g., a client's custodian) can subject an account to many of the same risks associated with direct cybersecurity breaches. Although Capital Financial Consultants Group has established risk management systems designed to reduce the risks associated with cybersecurity threats, there is no guarantee that such efforts will succeed, especially since Capital Financial Consultants Group does not directly control the cybersecurity systems third- party service providers. Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. Neither our firm, nor any of our management persons have any reportable arbitration claims, civil, self- regulatory organization proceedings, or administrative proceedings. Capital Financial Consultants Group, Inc. or any management persons have not been subject to any criminal actions. Item 10 Other Financial Industry Activities and Affiliations We have not provided information on other financial industry activities and affiliations because we do not have any relationship or arrangement that is material to our advisory business or to our clients with any of the types of entities listed below. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker; 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund); 3. other investment adviser or financial planner; 4. futures commission merchant, commodity pool operator, or commodity trading adviser; 5. banking or thrift institution; 6. accountant or accounting firm; 7. lawyer or law firm; 8. insurance company or agency; 9. pension consultant; 10.real estate broker or dealer; and/or 11.sponsor or syndicator of limited partnerships. Management personnel of Capital Financial Consultants Group are separately licensed as registered representatives and investment adviser representatives of Independent Financial Group, an unaffiliated broker-dealer and registered investment adviser. These individuals, in their separate 12 capacity as registered representatives, can affect securities transactions for which they will receive separate, yet customary compensation. In their separate capacity as an IFG investment advisory representative, they receive advisory fees distinct from Capital Financial Consultant fees. Management personnel of our firm, in their individual capacities, are agents for various insurance companies. As such, these individuals can receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. Clients, however, are not under any obligation to engage these individuals when considering the implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. Clients should be aware that the receipt of additional compensation by Capital Financial Consultants Group and its management persons or employees creates a conflict of interest that may impair the objectivity of our firm and these individuals when making advisory recommendations. Capital Financial Consultants Group endeavors always to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this conflict: • We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our firm's advisory fees. • We disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies. • We collect, maintain and document accurate, complete, and relevant client background information, including the client's financial goals, objectives, and risk tolerance. • Our firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client's needs and circumstances. • We require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interest in such activities are properly addressed. • We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm. • We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. We do not recommend or select other investment advisers to clients; therefore, we do not receive compensation directly or indirectly from other advisers and present no conflict of interest. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics that sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Capital Financial Consultants Group and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and must adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. 13 Our Code of Ethics includes policies and procedures for the review of quarterly securities transaction reports as well as initial and annual securities holdings reports that must be submitted by the firm's access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement, and recordkeeping provisions. Capital Financial Consultants Group's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to jfisher@capitalfn.com, or by calling us at 949-248-8800 or 858-513- 8445. Capital Financial Consultants Group and individuals associated with our firm are prohibited from engaging in principal transactions. Capital Financial Consultants Group and individuals associated with our firm are prohibited from engaging in agency cross transactions. Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal account's securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security (ies) which may also be recommended to a client. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, thereby preventing such employee(s) from benefiting from transactions placed on behalf of advisory accounts. We may aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro- rata basis. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro- rata, with each account paying the average price. Our employee accounts will be included in the pro- rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm's Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: • No principal or employee of our firm may put his or her own interest above the interest of an advisory client. • No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received because of his or her employment unless the information is also available to the investing public. 14 • It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account. This prevents such employees from benefiting from transactions placed on behalf of advisory accounts. • Our firm requires prior approval for IPO or private placement investments by related persons of the firm. • We maintain a list of all reportable securities holdings for our firm, and anyone associated with this advisory practice that has access to advisory recommendations ("access person"). These holdings are reviewed regularly by our firm's Chief Compliance Officer or his/her designee. • We have established procedures for the maintenance of all required books and records. • All clients are fully informed that related persons may receive separate commission compensation when effecting transactions during the implementation process. • Clients can decline to implement any advice rendered, except in situations where our firm is granted discretionary authority. • All our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. • We require delivery and acknowledgment of the Code of Ethics by each supervised person of our firm. • We have established policies requiring the reporting of Code of Ethics violations to our senior management. • Any individual who violates any of the above restrictions may be subject to termination. As disclosed in the preceding section of this Brochure (Item 10), related persons of our firm are separately registered as registered representatives of a broker-dealer. Please refer to Item 10 for a detailed explanation of these relationships and important conflict of interest disclosures. We do not nor does a related person recommend to clients, or buys or sells for client accounts, securities in which you or a related person has a material financial interest. Item 12 Brokerage Practices Capital Financial Consultants Group may recommend that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc. ("Schwab"), a FINRA registered broker- dealer, member SIPC, to maintain custody of clients' assets and to effect trades for their accounts. Although we recommend that clients establish accounts at Schwab, it is the client's decision to custody assets with Schwab. Capital Financial Consultants Group is independently owned and operated and not affiliated with Schwab. Clients may choose to hold their account assets at other brokerage firms with which we do not maintain relationships. In the event you choose to do so, our advisory services will include advice only. We will not implement our recommendations by instructing these firms to execute securities transactions for you. Capital Financial Consultants Group does not open the account for the client. If the client does not wish to place his or her assets with CS&Co, then Capital Financial Consultants Group cannot manage the client's account through the Institutional Intelligent Portfolios™ Program. Capital Financial Consultants Group considers several factors when recommending a brokerage firm including commission rates, the financial stability and reputation, the quality of the investment research, investment strategies, special execution capabilities, clearance, settlement, custody, record keeping, and other services the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers. 15 Research and Other Benefits Schwab provides Capital Financial Consultants Group with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services are available to independent investment advisers on an unsolicited basis, at no charge to them. These services are not contingent upon our firm committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab's brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Schwab does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Institutional also makes available to our firm other products and services that benefit Capital Financial Consultants Group but may not directly benefit our clients' accounts. Many of these products and services may be used to service all or some substantial number of our client accounts, including accounts not maintained at Schwab. Schwab's products and services that assist us in managing and administering our clients' accounts include software and other technology that: 1. provide access to client account data (such as trade confirmations and account statements). 2. facilitate trade execution and allocate aggregated trade orders for multiple client accounts. 3. provide research, pricing, and other market data. 4. facilitate payment of our fees from clients' accounts; and 5. assist with back-office functions, recordkeeping, and client reporting. Schwab Institutional also offers other services intended to help us manage and further develop our business enterprise. These services may include (1) compliance, legal and business consulting, (2) publications and conferences on practice management and business succession, and (3) access to employee benefits providers, human capital consultants, and insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to Capital Financial Consultants Group. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to our firm. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend or require that clients custody their assets at Schwab, we may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Order Aggregation Capital Financial Consultants Group may, but is not required to, engage in block trading (the bunching or aggregation of transactions) in cases where two (2) or more client accounts are transacting in the same security on the same day. We have adopted trade aggregation policies and procedures to ensure that all accounts are treated fairly when orders are aggregated for execution. Trades, where necessary, are allocated to advisory clients in a manner that fulfills our fiduciary obligations to each client and otherwise allocates securities on a good faith basis that is objective, fair, equitable, consistently applied, and does not unfairly discriminate against any advisory client based upon account 16 performance or other factors. For instance, clients in aggregated transactions each receive the same price per security. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If we are unable to fill an aggregated transaction completely but receive a partial fill of the aggregated transaction, we will allocate the filled portion of the transaction to clients on a pro-rata basis. Capital Financial Consultants Group may choose not to aggregate trades for several reasons, including, but not limited to: (1) an account reaches an investment guideline limit due to unforeseen changes in account assets after an order is placed; (2) a client account is low in cash; (3) a sale transaction is entered to raise cash in an account; or (4) operational considerations. As described in the Institutional Intelligent Portfolios™ Program Disclosure Brochure, SWIA may aggregate purchase and sale orders for ETFs across accounts enrolled in the Program, including both accounts for Capital Financial Consultants Group Clients and accounts for Clients of other independent investment advisory firms using the Institutional Intelligent Portfolios™ Program. Directing Brekerage for Client Referrals Capital Financial Consultants Group and its associated persons do not receive client referrals from broker-dealers or third parties as consideration for selecting or recommending brokers for client accounts. Item 13 Review of Accounts Investment Supervisory Services ("ISS") Individual Portfolio Management REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed at least quarterly. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by Jeff Fisher, President and CCO. REPORTS: In addition to the monthly statements and confirmations of transactions that clients receive from their broker-dealer, we provide upon request quarterly reports summarizing account performance, balances, and holdings. Financial Planning Services REVIEWS:While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for. REPORTS:Financial Planning clients will receive a completed financial plan. Additional reports will not typically be provided unless mutually agreed upon. Item 14 Client Referrals and Other Compensation Referrals We do not provide compensation to other advisers or professionals for referring clients to us. We are not compensated by other advisers or professionals for referring clients to them. Other Compensation Capital Financial Consultants Group receives an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisers that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 - Brokerage Practices). We also 17 receive financial assistance from Schwab in the form of marketing, technology, and transfer of account exit fees reimbursements. Marketing, technology, and transfer of account exit fees reimbursements help Capital Financial Consultants Group grow and service its advisory client base. The level of this support is typical in the industry and very modest relative to the total value of services Capital Financial Consultants Group provides to clients. Item 15 Custody Capital Financial Consultants Group does not have physical custody of Clients' assets, monies, or securities. However, under SEC regulations, we are deemed to have custody of your assets if you authorize us to instruct Schwab to deduct our advisory fees directly from your account. Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least quarterly. Schwab sends account statements to the email or postal mailing address you provided to Schwab. You should carefully review those statements promptly when you receive them to verify the accuracy of the fee calculation, among other things. We also urge you to compare Schwab's account statements to any periodic reports Capital Financial Consultants Group provides to you. Clients should contact us directly if they believe that there may be an error in their statement. We intend to do the following as a result of directly deducting advisory fees under provision California Code of Regulation, Section 260.237(b)(3): A. The investment adviser has custody of the funds and securities solely as a consequence of its authority to make withdrawals from client accounts to pay its advisory fee. B. The investment adviser has written authorization from the client to deduct advisory fees from the account held with the qualified custodian. C. Each time a fee is directly deducted from a client account, the investment adviser concurrently: i. Sends the qualified custodian an invoice or statement of the amount of the fee to be deducted from the client's account; and ii. Sends the client an invoice or statement itemizing the fee. Itemization includes the formula used to calculate the fee, the value of the assets under management on which the fee is based, and the time period covered by the fee. D. The investment adviser notifies the Commissioner in writing that the investment adviser intends to use the safeguards provided in this paragraph (b)(3). Such notification is required to be given on Form ADV. Item 16 Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • Determine the security to buy or sell; and/or • Determine the amount of the security to buy or sell 18 Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. Item 17 Voting Client Securities We vote proxies for all client accounts; however, you always have the right to vote proxies yourself. You can exercise this right by instructing us in writing to not vote proxies in your account. We will vote proxies in the best interests of its clients and per our established policies and procedures. Our firm will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, a copy of any document created by us that was material to making a decision how to vote proxies, and a copy of each written client request for information on how the adviser voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify the client of the conflict and retain an independent third-party to cast a vote. Clients may obtain a copy of our complete proxy voting policies and procedures by contacting Jeff Fisher by telephone, email, or in writing. Clients may request, in writing, information on how proxies for his/her shares were voted. If any client requests a copy of our complete proxy policies and procedures or how we voted proxies for his/her account(s), we will promptly provide such information to the client. We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client's account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. For ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor's right to vote proxies. To direct us to vote a proxy in a particular manner, clients should contact Jeff Fisher by telephone, email, or in writing. You can instruct us to vote proxies according to criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so-called "poison pill" defense against a possible takeover). These requests must be made in writing. You can also instruct us on how to cast your vote in a particular proxy contest by contacting Jeff Fisher. Item 18 Financial Information As an advisory firm that maintains discretionary authority for client accounts, we are also required to disclose any financial condition that is likely to impair our ability to meet our contractual obligations. Capital Financial Consultants Group does not have any financial condition that is reasonably likely to impari our ability to meet contractual commitments to clients. 19 Under no circumstances do we require or solicit payment of fees more than $500 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. Capital Financial Consultants Group has not been the subject of a bankruptcy petition at any time during the past ten years. Item 19 Requirements for State-Registered Advisers Refer to the Part(s) 2B for background information about our principal executive officers, management personnel and those giving advice on behalf of our firm. Our firm is not actively engaged in any business other than giving investment advice that is not already disclosed above. Neither our firm, nor any persons associated with our firm are compensated for advisory services with performance-based fees. Refer to the Performance-Based Fees and Side-By-Side Management section above for additional information on this topic. Neither our firm, nor any of our management persons have any reportable arbitration claims, civil, self- regulatory organization proceedings, or administrative proceedings. Neither our firm, nor any of our management persons have a material relationship or arrangement with any issuer of securities. State of California Required Disclosures All material conflicts of interest under CCR Section 260.238 (k) are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. Our firm maintains a written business continuity plan to ensure that that we may continue to meet out fiduciary obligations to you in the event of an emergency or significant business disruption. 20 Brochure Supplement Part 2B of Form ADV: Jeff Fisher CRD#4950246 31461 Rancho Viejo Rd. #104 San Juan Capistrano, CA 92675 (949) 248-8800 jfisher@capitalfin.com Capital Financial Consultants Group, Inc. San Juan Capistrano, CA 92675 7/11/2025 This brochure supplement provides information about Jeff Fisher that supplements the Capital Financial Consultants Group brochure. You should have received a copy of that brochure. Please contact Jeff Fisher at 949-248-8800 or jfisher@capitalfin.com if you did not receive Capital Financial Consultants Group’s brochure or if you have any questions about the contents of this supplement. Additional information about Jeff Fisher is available on the SEC’s website at www.adviserinfo.sec.gov Jeff Fisher Item 2 Educational, Background and Business Experience Full Legal Name: Jeff Fisher Year of Birth: 1963 Education , , ∗ Business Experience University of Phoenix B.S. Business Administration 2006 ∗ Capital Financial Consultants Group, Inc., Chief Compliance Officer and IAR, 03/2014 to Present ∗ Independent Financial Group, LLC, Registered Representative, 07/2009 to Present ∗ MCL Financial Group, Inc., Chief Compliance Officer, 01/2009 to 07/2009 ∗ MCL Financial Group, Inc., Registered Representative, 12/2005 to 07/2009 ∗ MCL Financial Group, Inc., Administrator Special Projects, 03/2005 to 12/2005 Item 3 Disciplinary Information Form ADV Part 2B requires disclosure of certain criminal or civil actions, administrative proceedings, and self-regulatory organization proceedings, as well as certain other proceedings related to suspension or revocation of a professional attainment, designation, or license. Mr. Jeff Fisher has no required disclosures under this item. Item 4 Other Business Activities Jeff Fisher is also engaged in the following investment-related activities: ∗ Jeff Fisher is separately licensed as an investment adviser representative (“IAR”) of Independent Financial Group (IFG), an unaffiliated investment adviser registered with the SEC. As an IAR with IFG, Mr. Fisher provides investment advice such as investment management and financial planning for a fee separate and distinct from the advisory services offered through Capital Financial Consultants Group. Clients interested in obtaining these services would be required to enter into an agreement with IFG. ∗ Jeff Fisher is separately licensed as a registered representative of Independent Financial Group (IFG), an unaffiliated FINRA member broker dealer. Mr. Fisher in his separate capacity, can effect securities transactions for which he may receive separate, yet customary compensation. In addition, Jeff Fisher may receive additional ongoing 12b-1 distribution Jeff Fisher (sales and marketing) fees from investment companies in connection with mutual fund purchases. ∗ Jeff Fisher is an agent for various insurance companies. As such, he is able to receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. Clients, however, are not under any obligation to engage Mr. Fisher when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. an Mr. Fisher endeavors at all times to put the interest of the clients first as part of his fiduciary duty. However, clients should be aware that the receipt of additional compensation gives Mr. Fisher incentive to recommend investment products based on the compensation received, rather than on the client’s needs, and may affect the judgment of Jeff Fisher when making recommendations. Non-Investment-Related Activities Jeff Fisher is not engaged in other business or occupations that provide substantial compensation or involves a substantial amount of his time. Item 5 Additional Compensation Jeff Fisher may receive cash and non-cash compensation from certain third-party product sponsors as an IAR as permitted by industry rules. For example, product sponsors and other companies may reimburse Mr. Fisher up to 100% of the cost of due diligence, training and education/joint marketing meetings. In addition, sales by IARs may qualify them for additional compensation that may include support for their business activities, attendance at seminars, conferences and entertainment. Item 6 Supervision Capital Financial Consultants Group supervises the activities of its investment adviser representatives (IARs) to ensure that each individual meets his fiduciary obligation to clients. This is accomplished through the review of advisory correspondence, advertising, IAR personal trading, and/or client portfolio transactions, among other reviews. Capital Financial Consultants Group has established a Policies and Procedures manual and Code of Ethics that describes its supervisory procedures. Jeff Fisher Supervisor: Title: Phone Number: Principal 949-248-8800 In addition, Independent Financial Group (IFG) reviews all securities transactions submitted through the broker dealer, reviews RIA trades and conducts annual audits of our office. Item 7 Requirements for State Registered Advisers Jeff Fisher does not have any reportable arbitration claims, has not been found liable in a reportable civil, self-regulatory organization or administrative proceeding, and has not been the subject of a bankruptcy petition. Part 2B of Form ADV: Brochure Supplement Haynes L. Kendall Jr., CFP® 31461 Rancho Viejo Rd. #104 CRD#1274737 San Juan Capistrano, CA 92675 248-8800 (949) hkendall@capitalfin.com , CA 92 Capital Financial Consultants Group, Inc. San Juan Capistrano 675 / /20 6 12 25 This brochure supplement provides information about Haynes Kendall that supplements the Capital Financial Consultants Group brochure. You should have received a copy of that brochure. Please contact Jeff Fisher at 949- 248-8800 or jfisher@capitalfin.com if you did not receive Capital Financial Consultants Group’s brochure or if you have any questions about the contents of this supplement. Additional information about Haynes Kendall is available on the SEC’s website at www.adviserinfo.sec.gov Haynes L. Kendall, Jr., CFP® Item 2 Educational, Background and Business Experience Full Legal Name: Haynes L. Kendall, Jr., CFP® Year of Birth: 1944 Education  University of South Carolina, Bachelor of Arts, Journalism and Business; 1967 Business Experience   ; 0 to Present Independent Financial Group Capital Financial Consultants Group, Inc.; IAR, 02/2014 to Present  , LLC Investment Adviser Representative, 5/2009  Independent Financial Group, LLC; Registered Representative, 12/2004 to Present  Financial Designs Ltd.; Investment Adviser Representative, 04/2001 to 07/2014 Designations QA3 Financial Corp; Registered Representative, 04/2001 to 12/2004 Haynes L. Kendall has earned the following professional designation and is in good standing with the granting authority:  CFP®, 1994: A CERTIFIED FINANCIAL PLANNER™ designation is offered by the Certified Financial Planner Board of Standards, Inc. (CFP Board) to candidates with at least a bachelor’s degree and three years of full-time pertinent experience, and those that complete a CFP Board registered program or hold certain designations, including a CFA. CFP® professionals must agree to be bound by the CFP Board’s Standards of Professional Conduct and complete 30 hours of continuing education every two years. Item 3 Disciplinary Information Form ADV Part 2B requires disclosure of certain criminal or civil actions, administrative proceedings, and self-regulatory organization proceedings, as well as certain other proceedings related to suspension or revocation of a professional attainment, designation, or license. Mr. Haynes L. Kendall has no required Item 4 Other Business Activities disclosures under this item. Investment-Related Activities Haynes L. Kendall is also engaged in the following investment-related activities:  Haynes L. Kendall is separately licensed as an investment adviser representative (“IAR”) of Independent Financial Group (IFG), an unaffiliated investment adviser registered with the SEC. As an IAR with IFG, Mr. Kendall provides investment advice such as investment management and financial planning for a fee separate and distinct from the advisory services offered through Capital Financial Consultants Group. Clients interested in obtaining these services would be required to enter into an agreement with IFG. Haynes L. Kendall, Jr., CFP®  Haynes L. Kendall is separately licensed as a registered representative of Independent Financial Group (IFG), an unaffiliated FINRA member broker dealer. Mr. Kendall in his separate capacity, can effect securities transactions for which he may receive separate, yet customary compensation. In addition, Haynes L. Kendall may receive additional ongoing 12b- 1 distribution (sales and marketing) fees from investment companies in connection with mutual fund purchases.  Haynes L. Kendall is an agent for various insurance companies. As such, he is able to receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. Clients, however, are not under any obligation to engage Mr. Kendall when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. Mr. Kendall endeavors at all times to put the interest of the clients first as part of his fiduciary duty. However, clients should be aware that the receipt of additional compensation gives Mr. Kendall an incentive to recommend investment products based on the compensation received, rather than on the client’s needs, and may affect the judgment of Haynes L. Kendall when making recommendations. Non Investment-Related Activities Haynes L. Kendall is not engaged in other business or occupations that provide substantial compensation or involves a substantial amount of his time. Item 5 Additional Compensation Haynes L. Kendall may receive cash and non-cash compensation from certain third party product sponsors as an IAR as permitted by industry rules. For example, product sponsors and other companies may reimburse Mr. Kendall up to 100% of the cost of due diligence, training and education/joint marketing meetings. In addition, sales by IARs may qualify them for additional compensation that may include support for their business activities, attendance at seminars, conferences and entertainment. Item 6 Supervision Capital Financial Consultants Group supervises the activities of its investment adviser representatives (IARs) to ensure that each individual meets his fiduciary obligation to clients. This is accomplished through the review of advisory correspondence, advertising, IAR personal trading, and/or client portfolio transactions, among other reviews. Capital Financial Consultants Group has established a Policies and Procedures manual and Code of Ethics that describes its supervisory procedures. Supervisor: Jeff Fisher Title: CCO Phone Number: 949-248-8800 In addition, Independent Financial Group (IFG) reviews all securities transactions submitted through the broker dealer and conducts annual audits of our office. Item 7 Requirements for State Registered Advisers L. Haynes Kendall does not have any reportable arbitration claims, has not been found liable in a reportable civil, self-regulatory organization or administrative proceeding, and has not been the subject of a bankruptcy petition.