COFG ADVISORS, LLC

Form ADV Part 2A Item 1 – Cover Page COFG Advisors, LLC d/b/a Chicago Oakbrook Financial Group 903 Commerce Drive Suite 300 Oak Brook, IL 60523 (630) 954-5572 http://www.cofgroup.com/ October 1, 2025 This brochure provides information about the qualifications and business practices of Chicago Oakbrook Financial Group. If you have any questions about the contents of this brochure, please contact us at (630) 954-5572 or info@cofgroup.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 Chicago Oakbrook Financial Group also is available on the SEC’s website at www.adviserinfo.sec.gov. Chicago Oakbrook Financial Group is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. 1 10/1/2025  Item 2 – Material Changes The following is a summary of the material changes made to this Brochure since the last update on March 4, 2025: • COFG is no longer affiliated with Commonwealth Financial Network. • COFG has established an institutional relationship with Raymond James Financial Services, Inc. For more information, please see Item 12 and 14. You may request a copy of our current Brochure at any time, without charge, by calling us at (630) 954-5572 or emailing us at info@cofgroup.com. Additional information about Chicago Oakbrook Financial Group is available via the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with Chicago Oakbrook Financial Group who are registered, or are required to be registered, as Investment Adviser Representatives of Chicago Oakbrook Financial Group. 2 10/1/2025  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................................. 1 Item 2 – Material Changes ....................................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................................... 3 Item 4 – Advisory Business ..................................................................................................................................................... 4 Item 5 – Fees and Compensation ............................................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................................................... 12 Item 7 – Types of Clients ....................................................................................................................................................... 12 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................... 13 Item 9 – Disciplinary Information ......................................................................................................................................... 18 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................................. 18 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................ 18 Item 12 – Brokerage Practices ............................................................................................................................................... 19 Item 13 – Review of Accounts .............................................................................................................................................. 20 Item 14 – Client Referrals and Other Compensation ............................................................................................................. 20 Item 15 – Custody .................................................................................................................................................................. 21 Item 16 – Investment Discretion ............................................................................................................................................ 21 Item 17 – Voting Client Securities ........................................................................................................................................ 22 Item 18 – Financial Information ............................................................................................................................................ 22 3 10/1/2025  Item 4 – Advisory Business COFG Advisors, LLC d/b/a Chicago Oakbrook Financial Group (“COFG”) is a registered investment adviser offering financial planning and asset management services to clients. The firm has been in business since 1997. The firm’s principal owner is COFG Brokerage, Inc. COFG Brokerage, Inc. is wholly owned by David Navarro. This Brochure is designed to provide detailed and clear information relating to each item noted in the table of contents. Certain disclosures are repeated in one or more items, and/or other items are referred to in an effort to be as comprehensive as possible on the broad subject matters discussed. Within this Brochure, certain terms in either upper- or lowercase are used as follows: • • • “We,” “us,” and “our” refer to Chicago Oakbrook Financial Group. “Advisory Persons” refers to persons who provide investment recommendations or advice on behalf of Chicago Oakbrook Financial Group. “You,” “yours,” and “client” refer to clients of Chicago Oakbrook Financial Group and its Advisory Persons. Wealth Management Services Chicago Oakbrook Financial Group provides customized wealth management services for its clients. This is achieved through continuous personal client contact and interaction while providing discretionary investment management services and a broad range of comprehensive financial planning. Investment Management Services – Our investment management services are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. COFG will work closely with each client to identify their investment philosophies, goals, needs and investment objectives. COFG will then construct an investment portfolio using a wide range of securities products, including, but not limited to, common and preferred stocks; municipal, corporate, and government fixed income securities; mutual funds; exchange-traded products (“ETPs”); options and derivatives; unit investment trusts (“UITs”); and variable and fixed-indexed insurance products, as well as other products and services, including a variety of asset allocation services, financial planning, consulting services, and other investment managers (See “Independent Managers”). Our Advisory Persons may also offer advice related to direct participation programs, private placements, and other alternative investments, such as alternative energy programs, research and development programs, leasing programs, real estate programs, and pooled commodities futures programs. COFG has also established a relationship with an unaffiliated third-party provider of a platform of insurance consultation (“Insurance Platform”) services to investment advisers with clients who have current or future needs for insurance products. The Insurance Platform is available to SEC- and state-registered investment advisers ("RIAs”). Insurance Platform offers RIAs memberships to its platform for a fixed annual fee. Through its licensed insurance agents, who are also registered representatives of a broker-dealer and FINRA member, Insurance Platform offers members a variety of services relating to commission free insurance products. These services include, among others, providing members with analyses of their current methodology for evaluating client insurance needs, educating and acting as a resource to members regarding insurance products generally and specific insurance products owned by their clients or that their clients are considering purchasing, and providing members access to, and marketing support for, commission free products that insurers have agreed to offer to members’ clients through the Insurance Platform. For providing platform services to RIAs, Insurance Platform receives service fees from the insurers that offer their commission free products through the platform. These service fees are based on the insurance premiums received by the insurers from Insurance Platform’s members’ clients. The Insurance Platform is licensed as an insurance producer in jurisdictions where required to perform the platform services. Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers offering their products through the platform, and registered representatives of a broker-dealer. Use of Independent Managers – COFG may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an 4 10/1/2025  investment advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients’ investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Plan Participant Consulting- COFG offers ongoing advisory services to an individual retirement account (“IRA”) formed under a SIMPLE IRA Plan. Through the Plan Participant Consulting Program, Advisory Persons are able to assist a client with a variety of advisory services such as: • Financial planning and portfolio analysis • Education on the options available through the SIMPLE IRA Plan • Recommended asset allocation Financial Planning Services – COFG provides financial planning services on a wide range of topics as part of its wealth management services. Services include, but are not limited to, comprehensive financial planning, budgeting and cash flow analysis, major purchases, education planning, retirement income/longevity planning, portfolio analysis, estate planning analysis, investment analysis, business succession planning, and fringe benefit analysis. Clients may also elect to enter into financial planning or consulting engagements with Advisory Persons separately from our wealth management services as may be agreed between the client and Advisory Person via a written agreement. Retirement Plan Consulting COFG provides 3(21) retirement plan consulting services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). COFG’s retirement plan consulting services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • Ongoing Investment Recommendation and Assistance These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Investment recommendations and advice offered by Chicago Oakbrook Financial Group and its Advisory Persons do not constitute legal, tax, or accounting advice. Clients should coordinate and discuss the impact of the financial advice they receive from their advisor with their attorney and accountant. Clients should also inform their advisor promptly of any changes in their financial situation, investment goals, needs, or objectives. Failure to notify the advisor of any material changes could result in investment advice not meeting the changing needs of the client. IRA Rollover Considerations As part of our financial planning and advisory services, we may provide you with recommendations and advice concerning your employer retirement plan or other qualified retirement account. When appropriate, we may recommend that you withdraw the assets from your employer’s retirement plan or other qualified retirement account and roll the assets over to an individual retirement account (“IRA”) to be managed by our firm. If you elect to roll the assets to an IRA under our management, we will charge you an asset-based fee as described in Item 5. This practice presents a conflict of interest because our Advisory Representative has an incentive to recommend a rollover to you for the purpose of generating fee- 5 10/1/2025  based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have your IRA assets managed under our program. You have the right to decide whether to complete the rollover and the right to consult with other financial professionals. Some employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer’s (former employer’s) plan. 2. Roll over the funds to a new employer’s retirement plan. 3. Cash out and take a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Before making a change, we encourage you to speak with your financial advisor, CPA and/or tax attorney. Before rolling over your retirement funds to an IRA for us to manage or to a Third-Party Managed Program, carefully consider the following. NOTE: This list is not exhaustive. 1. Determine whether the investment options in your employer’s retirement plan address your needs or whether other types of investments are needed. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Your current plan may have lower fees than our fee and/or the Third-Party Manager’s fee combined. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer’s retirement plan and how the costs of those share classes compare with those available in an IRA. 3. You should understand the various products and services available through an IRA provider and their costs. 4. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. If your plan offers management services, the fee associated with the service may be more or less than our fee and/or the Third-Party Manager’s fee combined. 5. The Third-Party Manager’s or our management strategy may have higher risk than the options provided to you in your plan. 6. Your current plan may offer financial advice, guidance, management and/or portfolio options at no additional 7. cost. If you keep your assets titled in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 8. Your 401(k) may offer more liability protection than a rollover IRA; each state varies. Generally, Federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies; however, there can be exceptions. Consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 9. You may be able to take out a loan on your 401(k), but not from an IRA. 10. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or a home purchase. 11. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 12. Your plan may allow you to hire us or another firm as the manager and keep the assets titled in the plan name. 6 10/1/2025  It is important that you understand your options, their features, and their differences, and decide whether a rollover is best for you. If you have questions, contact us at our main number listed on the cover page of this brochure. In addition to complying with applicable SEC rules, Chicago Oakbrook Financial Group is subject to certain rules and regulations adopted by the U.S. Department of Labor when we provide nondiscretionary investment advice to retirement plan participants and IRA owners. When these DOL rules apply, our Advisory Persons and Chicago Oakbrook Financial Group are “fiduciaries,” for purposes of the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, and the Internal Revenue Code of 1986 (“the Code”), as amended. Therefore, Chicago Oakbrook Financial Group and our Advisory Persons may not receive payments that create conflicts of interest when providing fiduciary investment advice to plan sponsors, plan participants, and IRA owners, unless we comply with a prohibited transaction exemption (“PTE”). Beginning December 20, 2021, Chicago Oakbrook Financial Group and our Advisory Persons will comply with ERISA and the Code by using PTE 2020-02. As fiduciaries under ERISA and the Code, we render advice that is in plan participants’ and IRA customers’ best interest. Chicago Oakbrook Financial Group’s and our Advisory Persons’ status as an ERISA/Code fiduciary is limited to ERISA/Code covered nondiscretionary advice and recommendations regarding rolling over a retirement account and does not extend to all situations. Individualized Services and Client-Imposed Restrictions The investment advisory services provided by our Advisory Persons depend largely on the personal information the client provides to the Advisory Person. In order for our Advisory Persons to provide appropriate investment advice to, or, in the case of discretionary accounts, make tailored investment decisions for, the client, it is very important that clients provide accurate and complete responses to their advisor’s questions about their financial condition, needs, goals, and objectives and notify the advisor of any reasonable restrictions they wish to apply to the securities or types of securities to be bought, sold, or held in their managed account. It is also important that clients promptly inform their advisor of any changes in their financial condition, investment objectives, personal circumstances, or reasonable investment restrictions pertaining to the management of their account, if any, that may affect their overall investment goals and strategies, or the investment advice provided, or investment decisions made by their advisor. In general, the advisor is responsible for delivering investment advisory services to clients, and clients generally deal with matters relating to their accounts by contacting their advisor directly. Of course, clients may contact Chicago Oakbrook Financial Group directly with questions about the advisory services offered by our firm. Wrap Fee Programs Chicago Oakbrook Financial Group does not manage or place client assets into a wrap fee program. Investment management services are provided directly by Chicago Oakbrook Financial Group. Assets Under Management As of December 31, 2024, Chicago Oakbrook Financial Group manages $907,280,235.69 in assets. All assets are managed on a discretionary basis. Program Choice Conflicts of Interest Clients should be aware that the compensation to Chicago Oakbrook Financial Group and your advisor will differ according to the specific advisory programs or services provided. This compensation to Chicago Oakbrook Financial Group and your advisor may be more than the amounts we would otherwise receive if you participated in another program or paid for investment advice, brokerage, or other relevant services separately. Lower fees for comparable services may be available through our firm or from other sources. Chicago Oakbrook Financial Group and your advisor have a financial incentive to recommend advisory programs or services that provide us higher compensation over other comparable programs or services available from our firm or elsewhere that may cost you less. For example, the costs you will incur to have your account managed by our firm may be more than what other similar firms may charge. It’s important to understand all the associated costs and benefits the program and services you select so you can decide which programs and services are best 7 10/1/2025  suited for your unique financial goals, investment objective, and time horizon. We encourage you to review our Form CRS and to discuss your options with your Advisory Person. Item 5 – Fees and Compensation Wealth Management Services Wealth management fees are paid quarterly in advance pursuant to the terms of the client’s written agreement with COFG. Fees are based on the market value of assets under management (“AUM”) on the last business day of the previous calendar quarter. Fees are based on the following schedule and are assessed on a per-account basis: Assets Under Management ($) First $250,000 Next $250,000 Next $500,000 Next $1,500,000 Next $2,500,000 Above $5,000,000 Annual Rate (%) 1.25% 1.00% 0.90% 0.80% 0.75% 0.65% Certain legacy client relationships may be charged according to schedules that differ than described in the tiered schedule above. The initial quarterly fee will be prorated based on the number of billing days in the initial quarter. Fees are based on account value, account type, and nature of the relationship and are negotiable. Other methods of fee calculation exist or are possible, depending on the specific program, the services provided, client circumstances, and the account size. These methods include, but are not limited to, hourly, flat, breakpoint, and blended fee billing. Managed accounts holding strictly cash or cash equivalent positions will be charged a fixed fee of up to 0.40% annually. Clients may make additions to and withdrawals from account[s] at any time. However, reconciliations are performed on a quarterly basis to capture if, at any point, assets in excess of $100,000 are deposited into or withdrawn from an account after the start of the quarterly billing period. An adjustment will be made in the form of a credit or debit the following billing period to reflect the interim change in portfolio value from the date of the deposit/withdrawal until the end of the quarter. As stated above, Chicago Oakbrook Financial Group will generally calculate fees on a per-account basis. In certain circumstances, COFG allows for the aggregation of assets among a client’s “related” managed accounts for purposes of determining the value of AUM and the applicable advisory fee to be paid by a client. Chicago Oakbrook Financial Group reserves the right to determine whether client accounts are “related” for purposes of aggregating a client’s accounts together for a reduction in the percentage fee amount. Wealth management fees are calculated by COFG and deducted from the client’s account[s] at the custodian. COFG will send an invoice to the custodian indicating the amount of the fees to be deducted from the client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with COFG at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by COFG to the brokerage statement from the custodian, as the custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by COFG to be paid directly from their account[s] held by the custodian as part of the investment advisory agreement and separate account forms provided by the custodian. Plan Participant Consulting: The plan participant consulting fees are paid quarterly in arrears pursuant to the terms of the client’s written agreement with COFG. Fees are based on the total value of assets in the entire plan across all SIMPLE IRA participants on the last business day of the calendar quarter. Fees are based on the following schedule: Assets Under Management ($) $0 - $500,000 $500,001 - $1,000,000 Over $1,000,000 Annual Rate (%) 1.00% 0.75% 0.50% 8 10/1/2025  Plan participant consulting fees are calculated by COFG and deducted from the client’s SIMPLE IRA at the custodian. The Advisor shall send an invoice to the custodian indicating the amount of the fees to be deducted from the SIMPLE IRA at the respective quarter end date. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets of the SIMPLE IRA at the end of each quarter. Clients will be provided with a statement, at least quarterly, from the custodian reflecting deduction of the plan participant consulting fee. Clients are urged to also review and compare the statement provided by COFG to the brokerage statement from the custodian, as the custodian does not perform a verification of fees. Clients provide written authorization permitting plan participant consulting fees to be deducted by COFG to be paid directly from their SIMPLE IRA held by the custodian as part of the plan participant consulting agreement and separate account forms provided by the Custodian. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its wealth management fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The Advisor will allocate a portion of the advisory fee collected to the Independent Manager pursuant to the terms of the executed agreement between the Advisor and the Independent Manager. If the Client is required to authorize and enter into an investment advisory agreement with an Independent Manager then the terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.50% annually. For Client accounts implemented through an Independent Manager, the Client’s overall fees may include COFG’s wealth management fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Financial Planning Services COFG offers financial planning services as part of its wealth management services. COFG also offers stand-alone financial planning services either on an hourly basis or a fixed engagement fee. Hourly fees range up to $500 per hour. Fixed fees range up to $40,000. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Retirement Plan Consulting Retirement plan consulting fees are charged an annual asset-based fee of up to 1.00%. Fees may be billed monthly or quarterly (“Billing Period”) in arrears pursuant to the terms of the retirement plan advisory agreement. Retirement plan consulting fees are based on the market value of assets under management at the end of the Billing Period. Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated above. Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan consulting agreement. Other Fees and Costs Clients may incur certain fees or charges imposed by third parties, other than COFG, in connection with investments made on behalf of the client’s account[s]. The client is responsible for all custody and securities execution fees charged by the custodian, as applicable. Our recommended Custodian does not charge securities transaction fees for ETF and equity trades in a client's account, provided that the account meets the terms and conditions of the custodian's brokerage 9 10/1/2025  requirements. However, the custodian typically charges for mutual funds and other types of investments. The fees charged by COFG are separate and distinct from these custody and execution fees. In addition, all fees paid to COFG for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A client may be able to invest in these products directly, without the services of COFG, but would not receive the services provided by COFG which are designed, among other things, to assist the client in determining which products or services are most appropriate for each client’s financial situation and objectives. Accordingly, the client should review both the fees charged by the fund[s] and the fees charged by COFG to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. Clients should be aware that, when assets are invested in shares of mutual funds, variable insurance products, and certain alternative investments within a managed account program, clients will pay investment advisory fees to Chicago Oakbrook Financial Group and to the advisor for their advisory services in connection with the investments. In addition to the payments received by Chicago Oakbrook Financial Group and the advisor, clients will also pay management fees, mutual fund and money market 12b-1 fees, subtransfer agent fees, mutual fund and money market administrative expenses, mutual fund transaction fees, certain deferred sales charges and redemption fees on previously purchased mutual funds, annuity internal expenses and fees, and other fees charged by the investment company, insurance product, or alternative investment sponsor, which are typically charged to clients as an internal expense of the product. These internal expenses are described in the prospectus or offering document for the specific product. Clients may be able to invest directly in the investment company, insurance product, or alternative investment without incurring the investment advisory fees, platform fees, or transaction charges assessed by Chicago Oakbrook Financial Group or their advisor. If a client’s assets are invested in a fee-based annuity, the client will pay both the direct management fee to Chicago Oakbrook Financial Group and their advisor for the advisory services provided by Chicago Oakbrook Financial Group and the advisor in connection with that investment and, indirectly, the management and other fees charged by the underlying annuity investment options, as well as the charges assessed by the insurance company for the product. Of course, clients should also be aware of the tax implications of investing, as well as of the existence of deferred sales charges or redemption fees charged by some product sponsors for positions the client subsequently sells in Chicago Oakbrook Financial Group managed accounts. Mutual Fund Share Classes In most cases, mutual fund companies offer multiple share classes of the same mutual fund. Some share classes of a fund charge higher internal expenses, whereas other share classes of a fund charge lower internal expenses. Institutional and advisory share classes typically have lower expense ratios and are less costly for a client to hold than Class A shares or other share classes that are eligible for purchase in an advisory account. Mutual funds that offer institutional share classes, advisory share classes, and other share classes with lower expense ratios are available to investors who meet specific eligibility requirements that are described in the mutual fund’s prospectus or its statement of additional information. These eligibility requirements include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts that the fund considers qualified fee-based programs. The lowest-cost mutual fund share class for a fund may not be offered through our clearing firm or made available by Chicago Oakbrook Financial Group for purchase within our managed accounts. Clients should never assume that they will be invested in the share class with the lowest possible expense ratio or cost. Chicago Oakbrook Financial Group urges clients to discuss with their advisor whether lower-cost share classes are available in their program account. Clients should also ask their advisor why the funds or other investments that will be purchased or held in their managed account are appropriate for them in consideration of their expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, trading frequency, the amount of the advisory fee charged, whether the client will pay transaction charges for fund purchases and sales, whether clients will pay higher internal fund expenses in lieu of transaction charges that could adversely affect long-term performance, and relevant tax 10 10/1/2025  considerations. Your advisor may recommend, select, or continue to hold a fund share class that charges you higher internal expenses than other available share classes for the same fund. The existence of various fund share classes with lower internal expenses that Chicago Oakbrook Financial Group may not make available for purchase in its managed account programs present a conflict of interest between clients and Chicago Oakbrook Financial Group or its Advisory Persons. A conflict of interest exists because Chicago Oakbrook Financial Group and your advisor have a greater incentive to make available, recommend, or make investment decisions regarding investments that provide additional compensation to Chicago Oakbrook Financial Group that cost clients more than other available share classes in the same fund that cost you less. For those advisory programs that assess transaction charges to clients or to Chicago Oakbrook Financial Group or the advisor, a conflict of interest exists because Chicago Oakbrook Financial Group and your advisor have a financial incentive to recommend or select NTF funds that do not assess transaction charges but cost you more in internal expenses than funds that do assess transaction charges but cost you less in internal expenses. Advance Payment of Fees and Termination Wealth Management Services COFG is compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The client may also terminate the wealth management agreement within five (5) business days of signing the agreement at no cost to the client. After the five-day period, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the client. Upon termination, COFG will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The client’s wealth management agreement with COFG is non-transferable without the client’s prior consent. Plan Participant Consulting: COFG is compensated for its plan participant consulting services at the end of the quarter after services are rendered. Either party may terminate the plan participant consulting agreement, at any time, by providing advance written notice to the other party. The client may also terminate plan participant consulting agreement within five (5) business days of signing COFG’s agreement at no cost to the client. After the five-day period, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The client’s plan participant consulting agreement with COFG is non-transferable without the client’s prior consent. Use of Independent Managers In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager. COFG will assist the Client with the termination and transition as appropriate. Financial Planning Services COFG requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The client may also terminate the financial planning agreement within five (5) business days of signing our agreement at no cost to the Client. After the five-day period, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the client. Upon termination, the client shall be billed for actual hours logged on the planning project times the contractual hourly rate, or in the case of a fixed fee engagement, the percentage of the engagement scope completed by COFG. The client’s financial planning agreement with COFG is non-transferable without the client’ prior consent. Retirement Plan Consulting COFG is compensated for its services at the end of the Billing Period after services are rendered pursuant to the terms of the retirement plan consulting agreement. Either party may request to terminate a retirement plan consulting agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for fees up to and 11 10/1/2025  including the effective date of termination. The Client’s retirement plan advisory agreement with the Advisor is non- transferable without the Client’s prior consent. Other Forms of Compensation COFG does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any client account, other than the investment advisory fees noted above. Special Disclosures for ERISA Plans: In this Brochure, Chicago Oakbrook Financial Group has disclosed conflicts of interest, such as receiving additional compensation from third parties (e.g., 12b-1 fees, subtransfer agent fees, and revenue sharing) for providing marketing, recordkeeping, or other services in connection with certain investments. Chicago Oakbrook Financial Group, however, has adopted policies and procedures that are designed to ensure compliance with the prohibited transaction rules under the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended. For example, Chicago Oakbrook Financial Group has taken several steps to address the conflict of interest associated with Chicago Oakbrook Financial Group’s or Chicago Oakbrook Financial Group’s Advisory Persons’ receipt of compensation for services provided to ERISA plans. First, an advisor negotiates the compensation with ERISA plan sponsors or participants (“ERISA clients”) and the compensation is either an annual fee for ongoing services based on a percentage of assets under advisement, a flat fee, or an hourly rate. Second, to the extent that an advisor receives additional compensation from a third party, the advisor must report it to Chicago Oakbrook Financial Group to enable the additional compensation to be offset against the fees that the ERISA clients would otherwise pay for the advisor’s services. Third, Chicago Oakbrook Financial Group has established a policy not to influence any advisor’s advice or management of assets at any time or for any reason based on any compensation that Chicago Oakbrook Financial Group or the advisor might receive from third parties. In no event will Chicago Oakbrook Financial Group allow Advisory Persons to provide advice or manage assets for ERISA clients if they have conflicts of interest that Chicago Oakbrook Financial Group believes are prohibited by ERISA. As a covered service provider to ERISA plans, Chicago Oakbrook Financial Group will comply with the U.S. Department of Labor regulations on fee disclosures, effective July 16, 2011 (or such other date as provided by the Department). Thus, Chicago Oakbrook Financial Group and its Advisory Persons will disclose (i) direct compensation received from ERISA clients; (ii) indirect compensation (e.g., 12b-1 fees) received from third parties; and (iii) transaction-based compensation (e.g., commissions) or other similar compensation shared with related parties servicing the ERISA plan. These fee disclosures will be made reasonably in advance of entering into, renewing, or extending the advisory service agreement with the ERISA client. Item 6 – Performance-Based Fees and Side-By-Side Management Chicago Oakbrook Financial Group does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients Chicago Oakbrook Financial Group generally provides advisory services to the following types of clients: Individuals (other than high net worth individuals) • • High net worth individuals • Pension and profit-sharing plans • Charitable organizations • Corporations or other businesses not listed above Chicago Oakbrook Financial Group’s managed account programs generally require a minimum investment of $500,000. The firm retains the ability to waive this requirement for any reason in its sole discretion. In some cases, account balances may be combined at the household level to satisfy the account minimum. 12 10/1/2025  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that investors should be sure they understand and should be prepared to bear. Chicago Oakbrook Financial Group primarily serves retail investors. We create and maintain various investment models that may be used by individual Advisory Persons for clients for whom the models are appropriate. However, Chicago Oakbrook Financial Group Advisory Persons have the independence to take the approach they believe is most appropriate when analyzing investment products and strategies for clients. Therefore, Advisory Persons may use the firm’s models in whole, in part, or not at all. There are several sources of information that Chicago Oakbrook Financial Group and the advisor may use as part of the investment analysis process. These sources include, but are not limited to: • Prospectuses and offering materials • Product and sponsor sales materials • Sponsor due diligence meetings and product presentations • Financial publications • Research, software, and materials prepared by third parties • Corporate rating services • SEC filings (annual reports, prospectus, 10-K, etc.) • Company press releases As a firm, Chicago Oakbrook Financial Group does not favor any specific method of analysis over another and, therefore, would not be considered to have one approach deemed to be a “significant strategy.” There are, however, a few common approaches that may be used by Chicago Oakbrook Financial Group or your advisor, individually or collectively, in the course of providing advice to clients. It is important to note that there is no investment strategy that will guarantee a profit or prevent loss. Following are some common strategies employed by Advisory Persons in the management of client accounts: • Dollar Cost Averaging (“DCA”): The technique of buying a fixed dollar amount of a particular investment on a regular schedule, regardless of the share price. More shares are purchased when prices are low, and fewer shares are bought when prices are high. DCA is believed to lessen the risk of investing a large amount in a single investment at higher price. DCA strategies are not effective and do not prevent loss in declining markets. • Asset Allocation: An investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes—equities (stocks), fixed income (bonds), and cash/cash equivalents—each of which has different risk and reward profiles/behaviors. Asset classes are often further divided into domestic and foreign investments, and equities are often divided into small, intermediate, and large capitalization. The general theory behind asset allocation is that each asset class will perform differently from the others in different market conditions. By diversifying a portfolio of investments among a wide range of asset classes, Advisory Persons seek to reduce the overall volatility and risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. Asset allocation does not guarantee a profit or protect against loss. • Technical Analysis (aka “Charting”): A method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that performance of the stock, rather than performance of the company itself, has more to do with the company’s future stock price. It is important to understand that past performance does not guarantee future results. • Fundamental Analysis: A method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts 13 10/1/2025  attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is considered to be the opposite of technical analysis. • Quantitative Analysis: An analysis technique that seeks to understand behavior by using complex mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. • Qualitative Analysis: Securities analysis that uses subjective judgment based on non-quantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. This type of analysis technique is different from quantitative analysis, which focuses on numbers. The two techniques, however, are often used together. Risks of Loss Regardless of what investment strategy or analysis is undertaken, investing in securities involves risk of loss that clients must be prepared to bear; in fact, some investment strategies could result in total loss of your investment. Some risks may be avoided or mitigated, while others are completely unavoidable. Some of the common risks you should consider prior to investing include, but are not limited to: Market risks: The prices of, and the income generated by, the common stocks, bonds, and other securities you own may decline in response to certain events taking place around the world, including those directly involving the issuers; conditions affecting the general economy; overall market changes; local, regional, or global political, social, or economic instability; governmental or governmental agency responses to economic conditions; and currency, interest rate, and commodity price fluctuations. Interest rate risks: The prices of, and the income generated by, most debt and equity securities will most likely be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities generally decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call,” or refinance a security before its stated maturity date, which would typically result in having to reinvest the proceeds in lower-yielding securities. Credit risks: Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Risks of investing outside the U.S.: Investments in securities issued by entities based outside the United States are often subject to the risks described above to a greater extent. Margin transactions: Securities transactions in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan, inherently have more risk than cash purchases. If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a “margin call.” An investor’s overall risk in accounts utilizing margin includes the amount of money invested plus the amount that was loaned to them. Pledging Assets: Pledging assets in an account to secure a loan involves additional risks. The bank holding the loan has the authority to liquidate all or part of the securities at any time without prior notice in order to maintain required maintenance levels, or to call the loan at any time, and this may cause you to sell assets and realize losses in a declining 14 10/1/2025  market. In addition, because of collateral requirements imposed by the bank, investment decisions for the account may be restricted. These restrictions, or a forced liquidation, may interfere with your long-term investment goals and/or result in adverse tax consequences. Tax considerations: Our strategies and investments may have unique and significant tax implications. Unless specifically agreed otherwise, and in writing, however, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, it is strongly recommended that you consult with a tax professional regarding the investing of your assets. Custodians and broker/dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the first in, first out (“FIFO”) accounting method for calculating the cost basis of your equity investments and average-cost for mutual fund positions. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Liquidity risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all. Certain structured products, interval funds, and alternative investments are less liquid than securities traded on an exchange, and you should be aware of the fact that you may not be able sell these products outside of prescribed time periods. You should consult your advisor prior to purchasing products considered illiquid and in instances where changes in your financial situation and objectives may increase your need for liquidity. Inflation risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client’s future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Time horizon and longevity risk: Time horizon risk is the risk that your investment horizon is shortened because of an unforeseen event (e.g., the loss of your job). This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or nearing retirement. Recommendation of particular types of securities: We will recommend various types of securities and do not primarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. In very general terms, however, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Descriptions of the types of securities we may recommend to you and some of their inherent risks are provided below: • Money market funds: A money market fund is technically a security, and, as such, there is a risk of loss of principal, although it is generally rare. In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation (“FDIC”) insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. If it goes down, however, and you earn less than you expected to, you may end up needing more cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns. 15 10/1/2025  • Municipal securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. • Bonds: Also known as corporate debt securities, bonds are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when the bond is set to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. • Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as “equities” or “stocks”). In very broad terms, the value of a stock depends on the financial health of the company issuing it. Stock prices, however, can be affected by many other factors, including, but not limited to, the class of stock (e.g., preferred or common), the health of the market sector of the issuing company, and the overall health of the economy. In general, larger, more well-established companies (i.e., large-caps) tend to be safer than smaller start-up companies (i.e., small-caps), but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. • Mutual funds and ETFs: Mutual funds and ETFs are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund’s investments in accordance with the fund’s investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) 29 rather than balancing the fund with different types of securities. ETFs differ from mutual funds in that they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are “no load,” meaning there’s no fee to buy into or sell out of the fund, other types of mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be “closed-end” or “open-end.” Open-end mutual funds continue to allow new investors indefinitely, whereas closed-end funds have a fixed number of shares to sell, which can limit their availability to new investors. • Variable annuities: A variable annuity is a form of insurance where the seller or issuer (typically an insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump sum (single-payment annuity) or a series of regular payments (regular-payment annuity). The payment stream from the issuer to the annuitant has an unknown duration based principally upon the date of death of the annuitant. At this point, the contract will terminate, and the remainder of the funds accumulated will be forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable annuities pay amounts that vary according to the performance of a specified set of investments, typically bond and equity mutual funds. Many variable annuities typically impose asset-based sales charges or surrender charges for withdrawals within a specified period. Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender charges, such as mortality and expense risk charges, administrative fees, underlying fund expenses, and charges for special features, all of which can reduce the return. • Real estate: Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. In fact, real 16 10/1/2025  estate is known for its ability to serve as a portfolio diversifier and inflation hedge. The asset class still bears a considerable amount of market risk, however. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or by property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. • Limited partnerships: A limited partnership is a financial affiliation that includes at least one general partner and a number of limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner has management authority and unlimited liability. The general partner runs the business and, in the event of bankruptcy, is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks is dependent on the nature of the partnership and disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities; however, like privately placed limited partnerships, their tax treatment is under a different tax regime from equities. You should speak to your tax adviser in regard to their tax treatment. • Options contracts: Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (i.e., the expiration date). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires. A put gives the holder 30 the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires. Selling options is more complicated and can be even riskier. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. • Structured products: A structured product is generally a prepackaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and, to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. In addition to a fixed maturity, they have two components: a note and a derivative. The derivative component is often an option. The note provides for periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell to the investor the security or securities at a predetermined price. Other products use the derivative component to provide for a call option written by the investor that gives the buyer of the call option the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a “principal guarantee” function, which offers protection of principal if held to maturity. These products are not always FDIC insured, however; they may only be insured by the issuer and, thus, have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves a number of risks, including, but not limited to, fluctuations in the price, level, or yield of underlying instruments; interest rates; currency values; and credit quality. They also involve the risk of substantial loss of principal, limits on participation in any appreciation of the underlying 17 10/1/2025  instrument, limited liquidity, credit risk of the issuer, conflicts of interest, and other events that are difficult to predict Investments may also be affected by currency controls; different accounting, auditing, financial reporting, disclosure, and regulatory and legal standards and practices; expropriation (occurs when governments take away a private business from its owners); changes in tax policy; greater market volatility; different securities market structures; higher transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends. These risks may be heightened in connection with investments in developing countries. Investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Any of the common risks described above could adversely affect the value of your portfolio and account performance, and you can lose money. Even though these risks exist, Chicago Oakbrook Financial Group and your advisor will still earn the fees and other compensation described in this Brochure. Clients should carefully consider the risks of investing and the potential that they may lose principal while Chicago Oakbrook Financial Group and your advisor continue to earn fees and other forms of compensation. Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any other governmental agency, entity, or person, unless otherwise noted and explicitly disclosed as such, and as such may lose value. Item 9 – Disciplinary Information Neither Chicago Oakbrook Financial Group, its management personnel nor affiliated Advisory Persons have any disciplinary events requiring reporting in this section. Item 10 – Other Financial Industry Activities and Affiliations The Advisor also serves as a licensed insurance agency, and as such, may offer insurance products on a commission basis. No client shall be under any obligation to purchase any insurance products from the Advisor. The recommendation by an Advisory Person that a Client purchase an insurance product presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than based on a particular Client’s need. Clients are reminded that they remain free to purchase insurance products through other insurance agencies. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. The Advisor does not receive any compensation nor does this present a material conflict of interest. The Advisor will only earn its wealth management fee as described in Item 5.A. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended, Chicago Oakbrook Financial Group has adopted a Code of Ethics that governs conflicts of interest we have when providing our advisory services to you. Our Code of Ethics is designed to ensure that we meet our fiduciary obligations to you and to foster a culture of compliance throughout our firm. Our Code of Ethics is comprehensive and is designed to help us detect and prevent violations of securities laws and to help ensure that we always keep your interests first. We distribute our Code of Ethics to each supervised person at the time of his or her initial affiliation with our firm; we make sure it remains available to each supervised person for as long as he or she remains associated with our firm; and we ensure that updates to our Code of Ethics are communicated to each supervised person as changes are made. 18 10/1/2025  Our Code of Ethics sets forth certain standards of conduct and addresses conflicts of interest between our firm, our employees, our agents, our Advisory Persons, and our advisory clients. Clients and prospective clients of Chicago Oakbrook Financial Group may request a copy of our Code of Ethics at any time. Chicago Oakbrook Financial Group and its Advisory Persons are able to invest in the same securities that we recommend to clients. Chicago Oakbrook Financial Group and its Advisory Persons also recommend securities to, and buy and sell securities for, client accounts at or about the same time that we buy or sell the same securities for our own accounts. These activities create a conflict of interest between us and our clients. Our firm policy prohibits “trading ahead” of clients’ transactions to the detriment of clients. When Chicago Oakbrook Financial Group and its Advisory Persons are purchasing or selling securities for their own accounts, priority will be given to client transactions, or trades will be aggregated together to obtain an average execution price for the benefit of all parties. Item 12 – Brokerage Practices Recommendation of Custodian[s] Chicago Oakbrook Financial Group does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard client assets and authorize us to direct trades to the custodian as agreed upon in the investment advisory agreement. Further, we do not have the discretionary authority to negotiate commissions on behalf of clients on a trade-by-trade basis. Where we do not exercise discretion over the selection of the Custodian, we may recommend the Custodian to clients for custody and execution services. Clients are not obligated to use the Custodian recommended by us and will not incur any extra fee or cost associated with using a custodian not recommended by us. However, we may be limited in the services it can provide if the recommended Custodian is not engaged. How We Select Brokers/Custodians We seek to use a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services • Capability to execute, clear and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], limited partnerships) • Availability of investment research and tools that assist us in making investment decisions. • Quality of services • Competitiveness of the price of those services and willingness to negotiate the prices • Reputation, financial strength, and stability • Prior service to us and our other clients • Availability of other products and services that benefit us Your Brokerage and Custody Costs Chicago Oakbrook Financial Group will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc. (“Raymond James”). Raymond James is a FINRA-registered broker-dealer and New York Stock Exchange/SIPC member. Raymond James will serve as the client’s “qualified custodian”. We maintain an institutional relationships with Raymond James, whereby we receive economic benefits from the Custodian. Please see Item 14 below. 19 10/1/2025  Soft Dollars Chicago Oakbrook Financial Group does not use commissions to pay for research and brokerage services (i.e., soft dollar transactions). Research, along with other products and services other than trade execution, are available to Chicago Oakbrook Financial Group on a cash basis from various vendors. Block Trading Policy Chicago Oakbrook Financial Group may aggregate (“bunch”) transactions in the same security on behalf of more than one client in an effort to strive for best execution and to possibly reduce the price per share. However, aggregated or bunched orders will not reduce the transaction costs to participating clients. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Chicago Oakbrook Financial Group conducts aggregated transactions in a manner designed to ensure that no participating client is favored over another client. Participating clients will obtain the average share price per share for the security executed that day. To the extent the aggregated order is not filled in its entirety and when possible, securities purchased or sold in an aggregated transaction will be allocated pro-rata to the participating client accounts in proportion to the size of the orders placed for each account. The amount of securities maybe increased or decreased to avoid holding odd-lot or a small number of shares for particular clients. It should be noted, Chicago Oakbrook Financial Group does not receive any additional compensation or remuneration as a result of aggregation. Advisory clients purchase funds at net asset value. Item 13 – Review of Accounts All asset management client accounts are reviewed by an Advisory Person no less than quarterly, or when changes in client circumstances or market conditions warrant. Securities within the firm’s model portfolios are regularly reviewed by the firm’s investment committee. Clients will be provided statements at least quarterly directly from account custodian where your assets are maintained. Additionally, you will receive confirmations of all transactions directly from account custodian. All non-retirement accounts and retirement accounts for those clients taking distributions will receive an annual tax reporting statement. In addition, at least once a year, all managed account clients will receive a performance report. You should compare the report with statements received directly from the account custodian(s). Should there be any discrepancy, the account custodian’s report will prevail. Item 14 – Client Referrals and Other Compensation Chicago Oakbrook Financial Group does not compensate, either directly or indirectly, any persons who are not supervised persons, for client referrals. We have established an institutional relationship with Raymond James to assist us in managing Client account[s]. As part of the arrangement, Raymond James makes available to us, certain research and brokerage services, including research services obtained by Raymond James directly from independent research companies. We may also receive additional services and support from Raymond James. We have an incentive to continue to use or expand the use of Raymond James's services. We examined this potential conflict of interest when it chose to enter into the relationship with Raymond James and have determined that the relationship is in the best interests of the our clients and satisfies its client obligations, including its duty to seek best execution. Please see Item 12 above. We receive access to software and related support because we render wealth management services to clients that maintain assets at Raymond James. The software and related systems support may benefit us, but not our clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence our recommendation of this Custodian over one that does not furnish similar software, systems support, or services. 20 10/1/2025  Item 15 – Custody Chicago Oakbrook Financial Group does not accept or maintain custody of any client accounts, except for the authorized deduction of our fees. All clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct us to utilize that Custodian for the client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by us to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the client gives us authority to move money from one account to another account, we may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and Chicago Oakbrook Financial Group have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Chicago Oakbrook Financial Group renders investment advice to the vast majority of its managed account clients on a discretionary basis, pursuant to written authorization granted by the client to the firm. This authorization grants to Chicago Oakbrook Financial Group and your advisor the discretion to buy, sell, exchange, convert, or otherwise trade in securities and/or insurance products, and to execute orders for such securities and/or insurance products with or through any distributor, issuer, or broker/dealer as Chicago Oakbrook Financial Group or your Advisory Person may select. Your Advisory Person may, without obtaining your consent, determine which products to purchase or sell for your managed account, as well as when to purchase or sell such products, and the prices to be paid. All discretionary trades made bt Chicago Oakbrook Financial Group will be made in accordance with each client’s investment objectives and goals. Neither Chicago Oakbrook Financial Group nor your Advisory Person, however, is granted authority to take possession of your assets. You may terminate this discretionary authorization at any time by providing written notice to us. Clients may impose reasonable restrictions on their managed account, including, but not limited to, the type, nature, or specific names of securities to be bought, sold, or held in their managed account, as well as the type, nature, or specific names of securities that may not be bought, sold, or held in their managed account. Clients generally grant Chicago Oakbrook Financial Group and their Advisory Person discretionary trading authority over their managed accounts. If not specifically requested otherwise by the client, discretionary authority will be established at the time the account is first opened. As a matter of firm policy, neither Chicago Oakbrook Financial Group nor its Advisory Persons have or will accept the authority to file class action claims on behalf of clients. This policy reflects Chicago Oakbrook Financial Group’s recognition that it does not have the requisite expertise to advise clients with regard to participating in class actions. Chicago Oakbrook Financial Group and its Advisory Persons have no obligation to determine if securities held by the client are subject to a pending or resolved class action settlement or verdict. Chicago Oakbrook Financial Group and its Advisory Persons also have no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Chicago Oakbrook Financial Group and its Advisory Persons have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. The decision to participate in a class action or to sign a release of claims when submitting a proof of claim may involve the exercise of legal judgment, which is beyond the scope of services provided to clients by Chicago Oakbrook Financial Group or your Advisory Person. In all cases, clients retain the responsibility for evaluating whether it is prudent to join a class action or to opt out. 21 10/1/2025  Item 17 – Voting Client Securities Chicago Oakbrook Financial Group does not accept proxy-voting responsibility for any client. Clients will receive proxy statements directly from the Custodian. Chicago Oakbrook Financial Group will assist in answering questions relating to proxies, however, the client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither COFG, nor its management, have any adverse financial situations that would reasonably impair the ability of COFG to meet all obligations to its clients. Neither COFG, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. COFG is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. 22 10/1/2025