Cassedy Financial Group, Inc.

FORM ADV | PART 2A BROCHURE March 31, 2026 LOCATION 113 S. Boulevard Suite 200 Tampa, FL 33606 CONTACT INFORMATION (813) 251-0004 (888) 251-0099 www.cassedyfinancialgroup.com This Form ADV Part 2A Brochure provides information about the qualifications and business practices of Cassedy Financial Group, Inc. ("CFG"). If you have any questions about the contents of this Brochure, please contact us at (888)-251-0099. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. Additional information about CFG also is available on the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. References to CFG as being “registered” or a “registered investment adviser” do not imply a certain level of skill or training. 4  ITEM 2 – Material Changes This Brochure provides information on CFG's qualifications and business practices. You will receive a summary of any material changes and an updated Brochure whenever material changes occur. We are also required to update the Brochure annually within 120 days of the close of CFG’s fiscal year, which is December 31st. You may obtain a copy of our most recent Brochure at any time, without charge, by contacting us at (813) 251-0004. The most recent version is also publicly available at the SEC’s Investment Advisor Public Disclosure website at www.adviserinfo.sec.gov. Since our last filing on March 28, 2025, we have made stylistic and editing changes to more thoroughly describe our business practices. Item 4 - We update information and disclosures regarding our advisory and consulting services to issuers of private offerings. We also updated our assets under management. Item 15 - We provide disclosure of the Custody Rule requirements regarding Standing Letters of Authorization for recurring third-party transfers. Future material changes to the information in this Brochure will be noted in this section and provided to clients promptly. Please contact us at the number listed on the cover page to obtain the most recent version of our Brochure 5  ITEM 3 – Table of Contents ITEM 1 – Cover Page ITEM 2 – Material Changes ......................................................................................................................... 2 ITEM 3 – Table of Contents ........................................................................................................................ 3 ITEM 4 – Advisory Business ........................................................................................................................ 4 ITEM 5 – Fees and Compensation .............................................................................................................. 7 ITEM 6 - Performance-Based Fees and Side-By-Side Management ............................................................ 9 ITEM 7 - Types of Clients ............................................................................................................................ 9 ITEM 8 – Methods of Analysis, Investment Strategies and Risk Of Loss ..................................................... 9 ITEM 9 – Disciplinary Information ............................................................................................................ 11 ITEM 10 – Other Financial Industry Activities and Affiliations .................................................................. 11 ITEM 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............ 12 ITEM 12 – Brokerage Practices ................................................................................................................. 13 ITEM 13 – Review of Accounts ................................................................................................................. 15 ITEM 14 – Client Referrals and Other Compensation ............................................................................... 15 ITEM 15 – Custody .................................................................................................................................... 15 ITEM 16 – Investment Discretion ............................................................................................................. 16 ITEM 17 – Voting Client Securities ............................................................................................................ 16 ITEM 18 – Financial Information ............................................................................................................... 16 6  ITEM 4 – Advisory Business Cassedy Financial Group, Inc. (“CFG”) is a Florida corporation with its principal place of business in Tampa, FL. Thomas A. Cassedy is the principal owner of the firm, which has been in existence since 2000, and Mr. Cassedy has been in the investment business for over 38 years. CFG advises high-net-worth families in wealth planning and money management. Consulting and money management services are also provided to corporations and retirement plans. CFG provides clients with discretionary and non-discretionary asset management services and financial consulting services. At this time, CFG does not participate in any wrap fee programs. Asset Management Services CFG reviews each new client’s investment goals, risk tolerance, and objectives. We consider the client’s investment goals and needs when recommending any advisory products or services. We intend to provide each client with bespoke solutions, products, and services that will help to meet their goals and needs. We will gather personal information about each client when helping to choose a product or service. This information may include: • Investment experience • How soon is money needed • Retirement goals • Current financial situation and future needs • Annual income • A client’s ability to withstand losses • A client’s ability to withstand market fluctuations • A client’s instructions on how to invest CFG then manages client assets consistent with the client’s stated objectives or restrictions. As one of its services, CFG can structure mutual fund or Exchange Traded Fund (“ETF”) portfolios for clients. These portfolios will be constructed to meet clients' objectives and sometimes to meet broader diversification needs. In addition to managing various types of securities for clients, such as mutual funds, preferred stocks, warrants, rights, common stocks, bonds, municipal securities, and government bonds, a portion of the client's account may be held in cash or cash equivalents, including money market mutual funds. As of December 31, 2025, CFG had regulatory assets under management of $248,446,484, of which $147,606,752 are assets under discretionary management and $100,839,732 are assets under non-discretionary management. Consulting Services CFG will at times act in a consultant capacity. Consulting services may include but are not limited to reviewing the performance of an investment portfolio and providing asset allocation direction. 7  Fees for these services will be negotiated based on the time and complexity of the task. Prior to engagement, the client will be provided with an agreement that estimates the total fee for services. Fees for Consulting Services range from $400 to $500 per hour, depending on the complexity of the engagement and the services requested. Fees are due after services are rendered. The agreement between CFG and a client for consulting services may be terminated by either party at any time upon 30 days' written notice to the other party. Any fees not yet paid by the client are due promptly upon termination of the agreement. The decision to accept any recommendations or advice provided by CFG as part of its Consulting Services and all decisions regarding implementation thereof are left to the client. Clients are free to implement recommended transactions through broker-dealers and other service providers of their choice. Management of Held Away Assets We use a third-party platform to manage certain held-away assets, such as defined contribution plans, 401(k) accounts, Health Savings Accounts, and similar accounts. When an account is established on the platform, a link is sent to the client allowing them to connect their account(s) to the third-party platform in a secure, compliant manner. Once the client account(s) is connected to the platform, we will have access to periodically review the current account allocations and rebalance the client’s account, as deemed appropriate, considering the client’s investment objectives and risk tolerance. This limited access only allows us to rebalance investment allocations; it does not allow us to transfer funds or securities out of the client’s account. We offer this option as a service to our clients and at no additional cost. We are not affiliated with the platform and do not receive compensation for using or referring clients to their platform. Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries, based on the plan’s needs and the services requested by the plan sponsor or named fiduciary. In general, these services may include existing plan review and analysis, plan-level advice on fund selection and investment options, education services for plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non- discretionary and advisory. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. We may also assist with participant enrollment meetings and provide investment-related educational sessions to plan participants on such topics as diversification, asset allocation, risk tolerance, and time horizon. Our c sessions may include other investment-related topics specific to the particular plan. Additionally, we may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries, shall be detailed in a written agreement and be consistent with the parameters outlined in the plan documents. 8  Retirement Account Rollovers We offer recommendations and advice concerning employer retirement plans or other qualified retirement accounts. Our recommendations may generally include that the client consider withdrawing the assets from his/her employer's retirement plan or other qualified retirement account and rolling the assets over to an Individual Retirement Account (“IRA”) or other qualified investment vehicle. If a client elects to roll the assets into an IRA subject to our management, we will charge an asset-based fee as described in Item 5 below. This poses a conflict of interest because we have an incentive to recommend a rollover to generate compensation rather than solely based on the client’s needs. As a fiduciary, we are required to always act in the client’s best interests. Clients are under no obligation, contractually or otherwise, to rollover their retirement assets, or to have their assets rolled into an IRA managed by us. It is important for clients to understand that many employer retirement plan sponsors permit former employees to keep their retirement assets in their company plan, even after they terminate employment or retire. When deciding whether to roll over employment retirement plan assets into an IRA or another investment vehicle, clients should consider the costs and benefits of each option. Employees will typically have the following options: • Leave the funds in the employer's (or former employer's) plan • Move the funds to the new employer's retirement plan • Withdraw the funds from the plan, which results in a taxable distribution and a taxable event • Rollover the funds into an IRA rollover account Before making any changes to their plan, we encourage clients to carefully consider any tax implications with their accountant or tax advisor. Below are some general 401K Plan features and differences versus an IRA that clients should consider: • Although employer retirement plans may have a more limited investment menu than the options available in an IRA, the plan may also offer unique investment opportunities not available to the public, such as the ability to invest in the employer’s securities if the employer is publicly traded. • The employer retirement plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost, or at a fee which may be lower than our advisory fee. • Clients should understand the various investments available in an IRA, as well as the • associated costs. In some cases, the employer retirement plan may allow participants to hire us as manager and keep the assets titled in the plan’s name. • Clients interested in investing only in mutual funds should understand the cost structures of the share classes available in the employer's retirement plan and how those costs compare with those in an IRA. 9  • • It may be possible to take out a loan on 401k Plan assets. This option is not available for IRAs. It may be possible to delay taking 401k Plan or retirement account minimum distributions beyond age 73. • • A 401k Plan may offer more liability protection than a rollover IRA. Although IRA assets are generally protected from creditors in bankruptcies, it depends on state law and there can be some exceptions to the general rules. IRA distributions are subject to ordinary income tax and may also be subject to a 10% early distribution tax penalty unless they qualify for an exception. There are certain exceptions available based on age, disability, or if the assets are used to pay for higher education expenses or to purchase a home. Clients must understand the differences and options available, as well as the cost and tax implications, to decide whether an IRA rollover is appropriate. Consulting Services to Issuers From time to time, CFG may provide consulting and due diligence to issuers of private offerings. CFG’s receipt of compensation creates a conflict of interest because CFG and its management staff have an incentive to recommend that clients invest in the private offering. We manage this conflict through disclosure, so that clients can make an informed decision, and through policies and procedures that require us to act in our clients’ best interest. ITEM 5 – Fees and Compensation Fees charged by CFG for Asset Management Services are based on the value of the assets being managed. Fees may be negotiated, but generally conform to the following schedule: Equity & Balanced Accounts Account Asset Value First $500,000 Quarterly Fee 0.375% Annual Fee 1.50% Next $3,500,000 0.25% 1.00% Over $4,000,000 0.1875% 0.75% Fixed Income Accounts Account Asset Value First $500,000 Quarterly Fee 0.1875% Annual Fee 0.75% Next $3,500,000 0.125% 0.50% Over $4,000,000 0.09375% 0.375% 10  All fees due to CFG are payable in advance. The fee will be based on the value of the assets on the last day of the previous calendar quarter, as determined by the client’s custodian or another independent third party, and will include cash balances. Fees will be prorated on the number of days remaining in the quarter. If additional cash, securities, or other investments are deposited during a quarter, the applicable fees are prorated for the days remaining in the quarter. An adjustment will be made for any contributions or withdrawals during the quarter exceeding $500,000. Such adjustments are reflected in the fee calculations for the following billing period. Fees are computed at the account level, not at the household level. This method may result in some accounts paying higher or lower fees. To value assets, related accounts may, at CFG's discretion, be combined for fee calculation purposes. Clients provide written authorization for the custodian to deduct CFG’s advisory fees from their accounts and pay them directly to CFG. The custodian is required to issue monthly or quarterly account statements that reflect all activity in the client’s account, including the amount of advisory fees deducted. Clients should verify the accuracy of fees and other information on their account statements and promptly inform CFG of any discrepancies. Fees can also be billed directly to the client. Fees are negotiable depending on the circumstances. CFG may waive, adjust, or rebate fees in certain situations. Clients are advised that other clients with similar assets may pay different fees. If, for any reason, the client decides to terminate the agreement with CFG, the client may do so by written notice to CFG, and a pro-rata refund based on the time services were provided is returned to the client. In addition to CFG's advisory fee, each mutual fund or ETF in which a client's assets may be invested also charges its management fees and other expenses. The specific fees and expenses are described in the respective fund’s prospectus. Depending on the fund, a client may be able to invest directly in the shares of a mutual fund, with or without incurring any sales or advisory management fees. When purchasing directly from fund families, clients may incur a front or back-end sales charge. In that case, the client would not receive the services provided by CFG, 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 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. Please refer to the mutual fund's prospectus for additional information regarding fees and expenses. Mutual fund companies generally offer multiple share classes of the same fund. Share classes are described in the mutual fund's prospectus. Each share class charges different fees and internal expenses. Depending on the share class selected, fees and internal expense charges may be higher or lower. Certain funds do not charge a transaction fee but have higher internal expenses. Selecting funds with higher fees and expenses may adversely affect an account’s long-term performance. CFG’s policy is to recommend that clients invest in the lowest-cost share class available, based on the client’s individual needs. CFG typically recommends advisor- or institutional-share classes, which usually have the lowest expense ratios and are more beneficial than other share classes. Advisor or institutional share classes are generally available to investors 11  in qualified fee-based advisor programs or accounts that meet certain minimum investment requirements. When deemed appropriate for a client’s specific situation, CFG may, at times, recommend selecting or holding a mutual fund share class that charges higher internal expenses than other available share classes for the same family. CFG will conduct periodic testing of accounts to ensure that the appropriate recommended share class has been selected for its clients. For share classes transferred in from other institutions, CFG’s policy is to, as soon as practicable, evaluate whether more beneficial share classes may be available for the client to exchange at no cost and recommend that the client switches to a different lower-cost share class or may recommend liquidating the existing mutual fund holdings, which could result in tax consequences, or the client having to pay contingent deferred sales charges or other redemption fees. ITEM 6 - Performance-Based Fees and Side-By-Side Management CFG does not charge performance-based fees. ITEM 7 - Types of Clients CFG works with high-net-worth individuals and families and offers bespoke portfolios, wealth planning strategies, and money management. The firm also works with individuals, corporations, trusts, pension plans, and other entities in retirement plans and consulting services. The minimum account size is $250,000, although it may be waived at CFG’s discretion. ITEM 8 – Methods of Analysis, Investment Strategies and Risk of Loss CFG uses fundamental analysis to evaluate client securities and make purchases and sales based on that analysis. CFG may also consider technical market factors before deciding the appropriate action to take in a client's account. CFG will also implement various short- and long-term investment strategies and may give advice and act in the performance of duties for a client, which may differ from the advice given or the timing and nature of the action taken for other client accounts. CFG will make a reasonable effort to comply with all investment management restrictions and instructions communicated to the firm by a client. CFG reserves the right to advise clients on any other type of investment that it deems appropriate based on the client’s stated goals and objectives. Investing involves risk of loss, which clients must be prepared to bear. Asset Allocation – The process of dividing an investment portfolio among different asset categories, such as stocks, bonds, and cash, in response to your investment goals, time horizons, liquidity needs, and risk objectives. Diversification – The process of dividing investments within asset categories and subcategories in an effort to reduce certain types of risk. 12  Systematic Rebalancing – The process of periodically rebalancing an investment portfolio back to your strategic asset allocation targets in an intentional effort to maintain an investment mix appropriate for your investment goals, time horizons, liquidity needs, and risk objectives. In addition, there are securities-specific risks: Mutual Funds and ETFs: mutual fund and ETF investments are subject to market and business risk, will fluctuate in value, and carry the risk of owning the underlying securities held in the mutual fund or ETF. Mutual fund investments generally entail additional expenses. Mutual fund and ETF investors should carefully review the respective mutual fund or ETF’s prospectus which contain a description of the investment objectives, risks, fees, and expenses. Fixed Income Market Risk: Fixed-income investments carry inflation, liquidity, and reinvestment risks. Fixed-income securities will fluctuate in value in relation to interest rate changes. In a rising interest-rate environment, the prices of fixed-income securities will decline. In addition, fixed- income securities are subject to financial risk and the risk of issuer default. Bonds that receive a lower credit rating, known as “high yield bonds” or “junk bonds,” carry a greater risk of default, and investors may lose all of their investment. Alternative Investments: Investments in private funds, such as hedge funds or private equity, involve long holding periods, have little liquidity, and carry a significant degree of risk. These types of investments should be assumed only by sophisticated investors capable of bearing the risk of loss on all of their investments. Investors should review the offering documents, which contain a description of the risks, fees, and expenses, before investing. Leverage: Leverage creates an opportunity for greater total returns but also carries a greater risk of loss from adverse price changes. Losses from short selling may be unlimited, whereas losses from a cash investment are limited to the total amount invested. CFG generally will not directly engage in short selling in Client accounts but may invest in funds and other instruments that may engage in short selling. Investing in securities involves a risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot guarantee that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Transactions in a client account, including account reallocations and rebalancing, may trigger a taxable event. Clients are urged to consult with their tax advisor. Other Risks Cybersecurity - CFG utilizes electronic communication networks and electronic media to maintain information regarding its clients and its business. This creates the potential for cybersecurity incidents or cyber-attacks that may result in the inadvertent disclosure of confidential sensitive information to unintended parties, unauthorized access to it, or operational disruptions by 13  malicious hackers. CFG has policies and procedures in place regarding information technology security, maintains technical and physical safeguards, and takes other reasonable precautions to safeguard the confidentiality of sensitive information and internal data. However, despite reasonable precautions, the risk remains that cybersecurity incidents may occur. If such an event were to occur, CFG will promptly notify the affected parties and take all necessary appropriate actions. ITEM 9 – Disciplinary Information found on the There are no legal or disciplinary actions to report for CFG. Thomas A. Cassedy the subject of a FINRA arbitration at his prior broker-dealer. Although both the brokerage firm and Mr. Cassedy disputed the allegations, the matter was settled as a nuisance claim. Publicly available information regarding Mr. Cassedy and the qualifications and backgrounds of our Financial Investment Adviser Public Disclosure website at Advisors can be www.adviserinfo.sec.gov. Please also refer to our advisory team’s Form ADV Part 2B Brochure Supplements for additional information. These documents are provided to you when you establish an account and are available free of charge at any time upon request. ITEM 10 – Other Financial Industry Activities and Affiliations CFG does not have an application pending with the SEC to register as a broker-dealer. CFG does not have any control affiliates or related persons that are broker-dealers, investment advisers or investment companies. Additionally, CFG is not registered and has no application pending to register as a Futures Commission Merchant (FCM), Commodity Pool Operator (CPO), or Commodity Trading Advisor (CTA). Relationship with Charles Schwab CFG will maintain a custodian relationship with Charles Schwab. Through its relationship with Charles Schwab, CFG has access to an institutional platform that provides it with certain benefits, including custody, clearing, and reporting services, as well as online access for clients. Charles Schwab also makes other services available to us, including market and pricing information, marketing support, practice management resources, access to educational conferences, and other benefits that assist CFG in monitoring and/or servicing client accounts that we would otherwise have to pay for. Although CFG believes the custodial and brokerage fees charged by Charles Schwab are competitive, clients may be able to obtain execution and custody services from other service providers at higher or lower costs. Clients are not obligated to use the services of Charles Schwab and may select a different custodian provided it meets the SEC’s Qualified Custodian definition and satisfies CFG’s due diligence. The receipt of economic benefits from Charles Schwab creates a conflict of interest because CFG has an incentive to increase assets at Charles Schwab to reduce its expenses and receive these benefits. CFG believes that the arrangement with Charles Schwab is beneficial to our clients and 14  our business. We manage this potential conflict through disclosure so that clients can make an informed decision and through policies and procedures that require us to act in our clients' best interests. ITEM 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Pursuant to SEC Rule 204A-1, CFG has adopted a Code of Ethics (“COE”) to establish rules of conduct for all Supervised Persons and Access Persons. Supervised Persons are individuals associated with CFG and involved in offering or providing advisory services. Supervised Persons also include our office administrative employees. “Access Persons” are defined as a director, officer, or partner of the firm; an employee who has access to nonpublic information regarding a client’s purchase or sale of securities; or a person designated as such by the Chief Compliance Officer. The COE imposes restrictions and reporting requirements on trading and investments for all Access Persons’ accounts and the accounts of their immediate family members (spouses and children, or other family members residing in the same household). The COE recognizes our Access Person’s fiduciary responsibility to clients. The COE instructs all employees and Access Persons to conduct their affairs in such a manner as to avoid: • Placing their interests ahead of clients’ interests • Taking inappropriate advantage of their position • Engaging in actual or potential conflicts of interest While the COE allows employees and Access Persons to invest in the same securities held in clients’ portfolios, employee trading is monitored to prevent conflicts of interest and ensure that clients’ interests always take precedence. Access Persons are required to file quarterly and annual reports of personal transactions and holdings. The Chief Compliance Officer, or his designee, monitors the reports and activity in the accounts of Access Persons and their immediate family members and seeks to reasonably detect and prevent questionable activity and potential conflicts of interest. Our COE also requires reporting certain gifts and business entertainment, as well as procedures for maintaining the confidentiality of client information. Additionally, our Insider Trading policy prohibits the use of material non-public information. Failure to abide by the COE may subject an employee to sanctions, including termination of employment. A copy of our COE is available to our clients upon request by calling our office at (813) 251-0004. ITEM 12 – Brokerage Practices CFG will generally recommend that clients designate Charles Schwab for custody and execution of securities transactions. We believe that using Charles Schwab is in the best interests of our 15  clients and consistent with our obligation to seek best execution, and that the fees, other charges, and commissions charged are reasonable relative to the value of the services provided. The SEC defines best execution as the “best qualitative execution” not necessarily the lowest possible execution cost. In evaluating the quality of execution, CFG may consider various factors, including but not limited to the institution’s execution capabilities, commission rates, responsiveness, ability to maintain confidentiality, reputation, and financial strength. CFG will periodically evaluate the quality and cost of executions. As part of our evaluation, we will consider, among other factors, the quality and cost of services available from alternative brokers, market makers, and market centers. Charles Schwab may act on an agency or riskless principal basis for a variety of securities and other investments. Although CFG will seek to obtain competitive rates, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. Clients may pay a fee or commissions that are higher than those that another broker may charge to complete the same transaction. CFG or the executing broker may route orders to different brokers or execution venues if we believe that such routing is consistent with best execution. Transactions will not always be placed through the broker that charges the lowest commission. Transactions may involve specialized services provided by the executing brokers, which may justify paying higher commissions or mark-ups. In addition, we may consider the overall quality of assistance or research provided by a broker in evaluating certain investments, industries, or products and making trade routing decisions. In some cases, clients may pay higher commissions or mark-ups/markdowns than if we selected a broker that does not provide research or specialized services. To the extent CFG receives research, it will be used to benefit all clients. Brokerage for Client Referrals CFG does not receive client referrals from external brokers, dealers, or financial intermediaries in exchange for brokerage. Directed Brokerage If a client has a relationship with a broker or financial institution and asks to direct transaction(s) to the particular broker or financial institution for execution, CFG may be unable to achieve the most favorable execution. This can result in additional costs and expenses for the client. Principal and Cross Trades CFG does not engage in principal trades or effect cross transactions for client accounts. Any cross- transactions between client accounts would be handled on an exception basis, only if they are in the best interests of the clients involved and comply with applicable SEC rules. Trade Errors CFG’s trade error policy is to restore the client’s account to its original position through a trade correction, trade cancellation, or adjustment so that the client is not adversely impacted by the error. Trade Aggregation CFG may, when deemed appropriate, aggregate multiple orders at the same custodian or broker 16  into one order. Each client that participates in an aggregated order receives an average price. In case of partial execution of an aggregated order, the executed trades and related commissions will be allocated on a pro-rata basis. Allocation of Investment Opportunities From time to time, two or more accounts may seek to invest in the same securities or pursue a similar strategy. In such cases, CFG seeks to ensure that no account or group of accounts is favored over another. Soft Dollars CFG has no formal soft dollar arrangements. It does not direct client transactions to any particular broker in exchange for soft-dollar benefits. CFG independently purchases research and other related investment tools. CFG also has access to research and receives other benefits from Charles Schwab. The receipt of research from these service providers could be deemed soft dollars. To the extent CFG receives any research, it is used to benefit all clients. ITEM 13 – Review of Accounts Holdings across all client accounts are reviewed on an ongoing basis. Accounts are reviewed at least monthly, or more frequently when market, economic or the client’s personal circumstances warrant a more frequent review. Such reviews are conducted based on each client's financial needs, objectives, and goals. The economy, financial markets, and the client's investment holdings are considered on an ongoing basis. Each client portfolio is reviewed periodically to monitor investment suitability and adherence to any client-imposed investment restrictions. CFG formally reviews client accounts and confirms clients' investment objectives and selected investment profiles at least annually. ITEM 14 – Client Referrals and Other Compensation CFG may compensate other firms and individuals for client introductions or referrals. CFG has not entered into any referral or Promoter arrangements, although it may enter into such arrangements at any time, consistent with the provisions in Advisers Act Rule 206(4)-1. The Rule requires, among other things, providing clients referred by a Promoter with certain disclosures, including a copy of CFG's most recent Form ADV Part 2A Brochure and a disclosure document that sets forth the compensation paid to the Promoter. CFG may not charge clients a higher fee as a result of these types of referral arrangements. ITEM 15 – Custody Your account assets will be custodied by Charles Schwab, a Qualified Custodian, as defined by the SEC. Clients may use a different Qualified Custodian, provided it meets CFG's due diligence and other requirements. The limited ability for CFG to instruct the client’s custodian to deduct our advisory fees results in CFG being deemed to exercise “custody” over client assets. CFG does not 17  maintain physical custody of the client’s funds or securities. The client’s custodian is required to send out monthly account statements unless there has been no activity in the account, in which case statements are sent out quarterly. Clients also have online access to their account(s) to view activity and can access electronic copies of their account statements. The account statements contain all activity during the period, the market value of securities in the account, asset allocation, realized/unrealized gain and losses, dividends and interest paid, deposits and withdrawals, the amount of CFG’s advisory fees, and other pertinent financial reporting information. We are also deemed to have custody of clients’ assets in situations where we have discretion over third-party transfers under Standing Letters of Authorization (SLOA). The SEC has issued a no-action letter providing relief from certain Custody Rule requirements if we comply with the safeguards outlined in the letter. We intend to comply with such safeguards. Most clients receive annual performance reports prepared by CFG that compare the performance in their account against indexes, manager universe, and a risk analysis that addresses account volatility. You should carefully review the account statements detailing the fees being deducted and compare the information on the custodian-prepared statements with the information on the reports and billing invoices CFG sends you. Should you note any errors or discrepancies, please notify us promptly. ITEM 16 – Investment Discretion Advisory clients may provide CFG with limited discretionary authority to determine, without obtaining the client’s specific consent, the securities and amount of securities to buy and sell for their account (subject to any reasonable investment restrictions the client may impose) and when transactions are made. Accounts can also be managed on a non-discretionary basis. In a non-discretionary account, we provide investment advice, formulate strategies, and evaluate account performance. However, we do not implement investment decisions without the client’s prior approval. Clients in non- discretionary arrangements should be aware that they may forego investment opportunities if we are unable to contact them. ITEM 17 – Voting Client Securities CFG does not vote for client securities or vote or provide advice on corporate actions, tender offers, legal proceedings, bankruptcies, and class actions, except as required by law. Clients will receive proxies or other solicitation and correspondence directly from the custodian, or the issuer. Clients may contact CFG to discuss questions about any particular proxy solicitations. Clients may request a copy of our written policies and procedures regarding proxy voting by calling our office at the number listed on the cover page of this Brochure. 18  ITEM 18 – Financial Information CFG is required to inform clients of any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to them. As of the date of this Brochure, CFG has no financial commitments or liabilities that would impair our ability to manage client accounts and meet our contractual commitments to clients. 19