CONWAY FINANCIAL GROUP, LLC

Item 1: Cover Page Conway Financial Group, LLC Form ADV Part 2A Brochure Address: 390 South Woods Mill Rd. Suite 175 Chesterfield, MO 63017 Phone: (314) 579-9157 Email: pconway@conwayfinancialgroup.com Website: https://www.conwayfinancialgroup.com/ This brochure provides information about the qualifications and business practices of Conway Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number or email address listed above. 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. Conway Financial Group, LLC is a registered investment adviser, but registration does not imply a certain level of skill or training. Additional information about Conway Financial Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov and by searching for CRD# 117608. Page 1 of 21 Date of Brochure: January 30, 2026  Item 2: Material Changes In this Item, Conway Financial Group, LLC is required to identify and discuss material changes since filing its last annual amendment. Since filing its last annual amendment on March 25, 2025, no material changes have occurred. Page 2 of 21 Date of Brochure: January 30, 2026  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees & Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities & Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 1 2 3 4 7 8 9 10 12 13 14 15 16 17 18 19 20 21 Page 3 of 21 Date of Brochure: January 30, 2026  Item 4: Advisory Business A. Conway Financial Group, LLC (the “Adviser,” “we,” “us,” or “our”) is an investment adviser founded in 2001, registered with the U.S. Securities and Exchange Commission (“SEC”), and principally owned by Patricia Conway and Dylan Camp. B. Adviser offers the following types of advisory services: i. Annual Financial Planning & Investment Implementation Services. Annual Financial Planning & Investment Implementation Services shall be inclusive of one meeting between the client and Adviser per year during which Adviser shall assess the client’s financial condition, cash flow, goals, risk tolerance, future income needs, liquidity requirements, investment time horizon, and other information that is relevant to the client’s financial life. This information will be used to deliver analyses and recommendations with respect to various topics as mutually agreed between Adviser and the client. Such topics could include, for example, retirement planning, education savings, cash flow management, debt reduction, employee benefits analysis, estate planning, insurance needs, investment allocations, risk mitigation, tax planning, financial goal tracking, etc. After the conclusion of the annual meeting between the client and Adviser described above, the client may instruct Adviser to implement the investment transactions discussed and agreed-to during such annual meeting in the client’s account(s). Pursuant to a limited power of attorney signed by the client, Adviser shall execute such investment transactions in the client’s account(s) at the client’s independent and unaffiliated third-party custodial broker-dealer. Adviser shall not be granted any discretionary trading authority in carrying out such transactions. Except with respect to the client-directed investment transactions described above, Adviser shall not be responsible for the actual implementation of its recommendations. The responsibility to implement Adviser’s recommendations shall rest solely with the client, and the client may accept or reject Adviser’s recommendations in its sole and absolute discretion. If the client elects to act on any such recommendations, the client is under no obligation to effect any transactions through Adviser or any of its investment adviser representatives (“IARs”). Financial planning topics and deliverables may include the following: A Written Statement of Goals and Objectives In the planning process, the client is encouraged to define his/her specific goals and to answer such questions as “What do I hope to achieve with this process?” and “What are my priorities, financially, for myself (spouse, children) and how can I achieve these goals?” A Risk Profile for Both the Client and the Spouse You will be given a questionnaire to fill out independent of one another. This will help you and us to better understand how you approach investment decisions and investment risk. We will prepare your Investment Objectives and your Investment Risk Profile, which will help determine how your investment portfolio should be distributed among various investment asset classes. Cash Flow and Tax Planning You will be asked to provide, in great detail, information about your income and spending habits, your investments, retirement funds, etc. This information will be held in the strictest confidence. We will utilize this data in developing an investment distribution Page 4 of 21 Date of Brochure: January 30, 2026  schedule, estimated taxable income report, and a cash flow projection. An income and cash flow summary statement will help you understand how your funds are being consumed and where you may have a shortfall, if any. Investment Portfolio Allocation Implementation A review of your investment portfolio, in conjunction with your goals and objectives, your cash flow and your federal tax situation, will allow for the development of an investment policy statement. This will summarize our portfolio target asset allocation, which incorporates the client’s risk tolerance. A current investment distribution will be prepared to show the client’s investment allocation mix utilizing fixed income, equities, and real assets. Your investment plan will recommend changes, if any, which need to be made in order to help achieve your stated objectives. Assistance in the implementation of the recommendations will be provided. Adviser generally implements its investments strategy by allocating clients’ investable assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange traded funds (“ETFs”), as well as individual stocks and bonds. The asset allocation may be changed from time to time based on changes to a client’s specific situation. Accounts are held at the client’s Custodian and the Custodian may charge commissions for the purchase or sale of a mutual fund, ETF, stock, or bond. The brokerage firm charges a fee for stock and bond trades. Adviser does not receive any compensation, in any form, from fund companies. Investments may also include: corporate debt securities, certificates of deposit, municipal securities, and investment company securities. Initial public offerings (IPOs) are not available through Adviser. Retirement Planning A retirement needs analysis, based on your financial situation, may be prepared. This will help to answer questions such as “Can I afford to retire?” and “Will I outlive my money?”. Assumptions about income, social security, inflation, expectations, spending, and longevity will all be written down and reviewed over time as needs and expectations change. Risk Management A review of your current insurance coverage will provide assurance that you and your family are adequately covered by financially stable insurance companies. This will provide an opportunity to review your insurance with your agent and to make any changes recommended. Estate Planning A review of your current estate plan, if appropriate, may be provided. An estate tax analysis will show the possible tax implications on your estate with the first to die and the subsequent death of the remaining spouse. This provides the opportunity to review, with your estate planning attorney, your current documents and to make any additions or changes to assure that your estate will pay the minimum in taxes and be distributed according to your wishes. Other Specific Client Needs Other areas of concern such as education funding or disability needs, will be addressed and will be included in your financial plan. Special Project Plans Projects may be undertaken that are not described in other types of agreements, including the development and implementation of Investment Planning recommendations, Page 5 of 21 Date of Brochure: January 30, 2026  periodic investment portfolio review, assistance with tax planning, or other services specifically described in an engagement letter. ii. Ongoing Investment Management. Adviser provides ongoing discretionary or non-discretionary investment management services to its clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s), and inclusive of ongoing financial planning advice and recommendations over the course of the year. This information will then be used to make investment decisions or recommendations that reflect clients’ individual needs and objectives on an initial and ongoing basis. Adviser’s investment decisions and recommendations will allocate portions of clients’ account(s) to various asset classes classified according to historical and projected risks and rates of return. If a client grant’s Adviser discretionary trading authority, Adviser will retain the discretion to buy, sell, or otherwise transact in securities and other investments in a client’s accounts without first receiving the client’s specific approval for each transaction. Such discretionary authority is granted by a client in his or her investment management agreement with Adviser. If a client does not grant Adviser non-discretionary trading authority, clients must first authorize any such trading in their account(s). Clients may impose restrictions on investing in certain securities or types of securities so long as such restrictions may reasonably be implemented by Adviser. C. Adviser generally implements its investments strategy by allocating clients’ investable assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange traded funds (“ETFs”), stocks, and bonds. This portfolio is rebalanced periodically to remain in-line with the client’s agreed-upon asset allocation, though the asset allocation may be changed from time to time based on changes to a client’s specific situation. D. Adviser does not participate in any wrap fee programs. E. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: i. Meet a professional standard of care when making investment recommendations (give ii. iii. iv. prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and v. vi. Give you basic information about conflicts of interest. F. Adviser manages the following amount of discretionary and non-discretionary client assets calculated as of December 31, 2025: Discretionary: Non-Discretionary: Total: $177,721,549 $0 $177,721,549 Page 6 of 21 Date of Brochure: January 30, 2026  Item 5: Fees and Compensation A. Annual Financial Planning & Investment Implementation Fee. In consideration of the Annual Financial Planning & Investment Implementation Services described above, the client shall pay Adviser an annual flat fee that is due and payable by the client upon presentation of an invoice after each annual meeting between the client and Adviser. Such fees will generally range from $3,000 to $15,000, and the specific fee agreed-upon between Adviser and the client shall be set forth in a written agreement and assessed annually. B. Ongoing Investment Management Fee. In consideration of the Ongoing Investment Management Services described above, the client shall pay Adviser an annual flat fee in three incremental installments within 30 days of presentation of an invoice in February, June, and October. Adviser generally imposes a minimum annual fee of $3,500 for Ongoing Investment Management, but annual fees may range up to $50,000. The specific fee agreed-upon between Adviser and the client shall be set forth in a written agreement and assessed annually. C. The considerations taken into account for determining fees include the client’s investable assets, the number of custodians/investment accounts, client’s income, a calculation of the estimated hours to provide the services required, and the complexity of the client’s financial issues. D. Fees may be payable by check, through a third-party payment processor, or deducted from the client’s designated account at the client’s custodian broker-dealer. Adviser reserves the right to stop work on any fee that is more than 60 days overdue. Any unused portion of fees collected in advance will be refunded within 15 days. Any earned, unpaid fees will be due and payable. E. In addition to the fees charged by Adviser, clients will incur brokerage and other transaction costs. Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other transaction-related practices. Clients will also typically incur additional fees and expenses imposed by independent and unaffiliated third-parties, which can include qualified custodian fees, mutual fund or exchange traded fund fees and expenses, mark-ups and mark-downs, spreads paid to market makers, wire transfer fees, check-writing fees, early-redemption charges, certain deferred sales charges on previously-purchased mutual funds, margin fees, charges or interest, IRA and qualified retirement plan fees, and other fees and taxes on brokerage accounts and securities transactions. These additional charges are separate and apart from the fees charged by Adviser. F. Neither Adviser nor any of its supervised persons accepts compensation for the sale of securities or other investment products. Page 7 of 21 Date of Brochure: January 30, 2026  Item 6: Performance-Based Fees & Side-By-Side Management Neither Adviser nor any of its supervised persons accepts performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Page 8 of 21 Date of Brochure: January 30, 2026  Item 7: Types of Clients Adviser generally provides its services to individuals, trusts, and estates. Adviser does not require a minimum account value to open or maintain an account, though we do require a minimum annual fee of $3,500 for Ongoing Investment Management Services. Page 9 of 21 Date of Brochure: January 30, 2026  Item 8: Methods of Analysis, Investment Strategies & Risk of Loss A. The investment strategies used by Adviser when formulating investment advice or managing assets include fundamental analysis and cyclical analysis. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance does not guarantee future returns. The firm’s investment philosophy is built with the objective for long term capital appreciation through the development of a well diversified investment allocation strategy. Our emphasis is focused on capital preservation and minimizing overall portfolio volatility. We consider: no- load mutual funds, ETFs, dividend paying stocks, individual municipal bonds and corporate bonds, to create the portfolio. Portfolios are globally diversified to control the risk associated with traditional markets. A review of your investment portfolio, in conjunction with your goals and objectives, your cash flow and your federal tax situation, will allow for the development of an investment policy statement. This will summarize our portfolio target asset allocation, which incorporates the client’s risk tolerance. A current investment distribution will be prepared to show the client’s solid investment allocation mix utilizing fixed income, equities, and real assets. Your financial plan will recommend changes, if any, which need to be made in order to help achieve your stated goals. Assistance in the implementation of the recommendations will be provided. B. Like any investment strategy, fundamental and cyclical analysis involve material risks. Such material risks are described in further detail below: i. Investing for the long term means that a client’s account will be exposed to short-term fluctuations in the market and the behavioral impulse to make trading decisions based on such short-term market fluctuations. Adviser does not condone short-term trading in an attempt to “time” the market, and instead coaches clients to remain committed to their financial goals. However, investing for the long term can expose clients to risks borne out of changes to interest rates, inflation, general economic conditions, market cycles, geopolitical shifts, and regulatory changes. ii. Inflation risk is the risk that the value of a client’s portfolio will not appreciate at least in an amount equal to inflation over time. General micro- and macro-economic conditions may also affect the value of the securities held in a client’s portfolio, and general economic downturns can trigger corresponding losses across various asset classes and security types. Market cycles may cause overall volatility and fluctuations in a portfolio’s value, and may increase the likelihood that securities are purchased when values are comparatively high and/or that securities are sold when values are comparatively low. Geopolitical shifts may result in market uncertainty, lowered expected returns, and general volatility in both domestic and international securities. Regulatory changes may have a negative impact on capital formation and increase the costs of doing business, and therefore result in decreased corporate profits and corresponding market values of securities. iii. Investing in mutual funds does not guarantee a return on investment, and shareholders of a mutual fund may lose the principal that they’ve invested into a particular mutual fund. Mutual funds invest into underlying securities that comprise the mutual fund, and as such clients are exposed to the risks arising from such underlying securities. Mutual funds charge internal expenses to their shareholders (which can include management fees, administration fees, shareholder servicing fees, sales loads, redemption fees, and other fund fees and expenses, e.g.), and such internal expenses subtract from its potential for market appreciation. Shares of mutual funds may only be traded at their stated net asset Page 10 of 21 Date of Brochure: January 30, 2026  value (“NAV”), calculated at the end of each day upon the market’s close. Investing in ETFs bears similar risks and incurs similar costs to investing in mutual funds as described above. However, shares of an ETF may be traded like stocks on the open market and are not redeemable at an NAV. As such, the value of an ETF may fluctuate throughout the day and investors will be subject to the cost associated with the bid-ask spread (the difference between the price a buyer is willing to pay (bid) for an ETF and the seller's offering (asking) price). Clients are encouraged to carefully read the prospectus of any mutual fund or ETF to be purchased for investment to obtain a full understanding of its respective risks and costs. iv. Investing in common stocks means that a client will be subject to the risks of the overall market as well as risks associated with the particular company or companies whose stock is owned. These risks can include, for example, changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities. Common stocks tend to be more volatile and more risky than certain other forms of investments, especially as compared to fixed income products like bonds. v. Investing in bonds means that a client will be subject to the market prices of such debt securities, which typically fluctuate depending on interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and rise when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bonds are also subject to inflation risk, reinvestment risk, redemption risk, and valuation risk. Page 11 of 21 Date of Brochure: January 30, 2026  Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Adviser’s advisory business or the integrity of Adviser’s management. Page 12 of 21 Date of Brochure: January 30, 2026  Item 10: Other Financial Industry Activities & Affiliations A. Neither Adviser nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. Neither Adviser nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Neither Adviser nor any of its management persons have any relationship or arrangement with any related person below: i. ii. iii. iv. v. vi. vii. viii. ix. x. xi. broker-dealer, municipal securities dealer, or government securities dealer or broker investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) other investment adviser or financial planner futures commission merchant, commodity pool operator, or commodity trading advisor banking or thrift institution accountant or accounting firm lawyer or law firm insurance company or agency pension consultant real estate broker or dealer sponsor or syndicator of limited partnerships Page 13 of 21 Date of Brochure: January 30, 2026  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. Adviser has adopted a code of ethics that will be provided to any client or prospective client upon request. Adviser’s code of ethics describes the standards of business conduct that Adviser requires of its supervised persons, which is reflective of Adviser’s fiduciary obligations to act in the best interests of its clients. The code of ethics also includes sections related to compliance with securities laws, reporting of personal securities transactions and holdings, reporting of violations of the code of ethics to Adviser’s Chief Compliance Officer, pre-approval of certain investments by access persons, and the distribution of the code of ethics and any amendments to all supervised persons followed by a written acknowledgement of their receipt. B. Neither Adviser nor any of its related persons recommends to clients, or buys or sells for client accounts, securities in which Adviser or any of its related persons has a material financial interest. C. From time to time, Adviser or its related persons will invest in the same securities (or related securities such as warrants, options or futures) that Adviser or a related person recommends to clients. This has the potential to create a conflict of interest because it affords Adviser or its related persons the opportunity to profit from the investment recommendations made to clients. Adviser’s policies and procedures and code of ethics address this potential conflict of interest by prohibiting such trading by Adviser or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances Adviser will act in the best interests of its clients. D. From time to time, Adviser or its related persons will buy or sell securities for client accounts at or about the same time that Adviser or a related person buys or sells the same securities for its own (or the related person’s own) account. This has the potential to create a conflict of interest because it affords Adviser or its related persons the opportunity to trade either before or after the trade is made in client accounts, and profit as a result. Adviser’s policies and procedures and code of ethics address this potential conflict of interest by prohibiting such trading by Adviser or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances Adviser will act in the best interests of its clients. Page 14 of 21 Date of Brochure: January 30, 2026  Item 12: Brokerage Practices A. Adviser considers several factors when recommending a custodial broker-dealer for client transactions and determining the reasonableness of such custodial broker-dealer’s compensation. Such factors include the custodial broker-dealer’s industry reputation and financial stability, service quality and responsiveness, execution price, speed and accuracy, reporting abilities, and general expertise. Assessing these factors as a whole allows Adviser to fulfill its duty to seek best execution for its clients’ securities transactions. However, Adviser does not guarantee that the custodial broker-dealer recommended for client transactions will necessarily provide the best possible price, as price is not the sole factor considered when seeking best execution. After considering the factors above, Adviser recommends Charles Schwab & Co, Inc. (“Schwab”) as the custodial broker-dealer for client accounts. i. Adviser does not receive research and other soft dollar benefits in connection with client securities transactions, which are known as “soft dollar benefits”. However, the custodial broker-dealer(s) recommended by Adviser do provide certain products and services that are intended to directly benefit Adviser, clients, or both. Such products and services include (a) an online platform through which Adviser can monitor and review client accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate statements for client accounts and confirmations for client transactions, (d) invitations to the custodial broker-dealer(s)’ educational conferences, (e) practice management consulting, and (f) occasional business meals and entertainment. The receipt of these products and services creates a conflict of interest to the extent it causes Adviser to recommend Schwab as opposed to a comparable custodial broker-dealer. Adviser addresses this conflict of interest by fully disclosing it in this brochure, evaluating Schwab based on the value and quality of its services as realized by clients, and by periodically evaluating alternative broker-dealers to recommend. ii. Adviser does not consider, in selecting or recommending custodial broker-dealers, whether Adviser or a related person receives client referrals from a custodial broker-dealer or third-party. iii. Adviser does not routinely recommend, request, or require that a client direct Adviser to execute transactions through a specified custodial broker-dealer. B. Adviser retains the ability to aggregate the purchase and sale of securities for clients’ accounts with the goal of seeking more efficient execution and more consistent results across accounts. Aggregated trading instructions will not be placed if it would result in increased administrative and other costs, custodial burdens, or other disadvantages. If client trades are aggregated by Adviser, such aggregation will be done so as not to disadvantage any client and to treat all clients as fairly and equally as possible. Page 15 of 21 Date of Brochure: January 30, 2026  Item 13: Review of Accounts A. The CCO of Adviser monitors client accounts on an ongoing basis, and typically reviews client accounts on an annual basis. Such reviews are designed to ensure that the client is still on track to achieve his or her financial goals, and that the investments remain appropriate given the client’s risk tolerance, investment objectives, major life events, and other factors. Clients are encouraged to proactively reach out to Adviser to discuss any changes to their personal or financial situation. B. Other factors that may trigger a review include, but are not limited to, material developments in market conditions, material geopolitical events, and changes to a client’s personal or financial situation (the birth of a child, preparing for a home purchase, plans to attend higher education, a job transition, impending retirement, death or disability among family members, etc.). C. The custodial broker-dealer will send account statements and reports directly to clients no less frequently than quarterly. Such statements and reports will be mailed to clients at their address of record or delivered electronically, depending on the client’s election. If agreed to by Adviser and client, Adviser or a third-party report provider will also send clients reports to assist them in understanding their account positions and performance, as well as the progress toward achieving financial goals. Page 16 of 21 Date of Brochure: January 30, 2026  Item 14: Client Referrals and Other Compensation A. Nobody other than clients provides an economic benefit to Adviser for providing investment advice or other advisory services to clients. However, as described above in Item 12, the custodial broker-dealer(s) recommended for client accounts provides certain products and services that are intended to directly benefit Adviser, clients, or both. B. Neither Adviser nor a related person directly or indirectly compensates a person who is not Adviser’s supervised person for client referrals. Page 17 of 21 Date of Brochure: January 30, 2026  Item 15: Custody For clients that do not have their fees deducted directly from their account(s), and have not provided Adviser with any standing letters of authorization (“SLOAs”) to distribute funds from their account(s) to third parties, Adviser will not have any custody of client funds or securities. For clients that have their fees deducted directly from their account(s), or that have provided Adviser with discretion as to amount and timing of disbursements pursuant to an SLOA to disburse funds from their account(s) to third parties, Adviser will generally be deemed to have custody over such clients’ funds pursuant to applicable custody rules and guidance thereto. At no time will Adviser accept custody of client funds or securities in the capacity of a custodial broker-dealer or other qualified custodian, and at all times client accounts will be held by a third-party qualified custodian as described in Item 12, above. With respect to custody that is triggered by third party SLOAs, Adviser endeavors to comply with the following seven conditions as listed in the 2017 SEC No Action Letter to the Investment Adviser Association: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. If a client receives account statements from both the custodial broker-dealer and Adviser or a third-party report provider, client is urged to compare such account statements and advise Adviser of any discrepancies between them. Page 18 of 21 Date of Brochure: January 30, 2026  Item 16: Investment Discretion Adviser accepts discretionary authority to manage designated accounts on behalf of clients only pursuant to the mutual written agreement of Adviser and the client through a power-of-attorney, which is typically contained in the advisory agreement signed by Adviser and the client. This includes the authority to buy, sell, and otherwise transact in securities and other investment products in client’s account(s) without necessarily consulting with clients in advance. Clients may place reasonable limitations on this discretionary authority so long as it is contained in a written agreement and/or power-of-attorney. Page 19 of 21 Date of Brochure: January 30, 2026  Item 17: Voting Client Securities A. Adviser does not have and will not accept authority to vote client securities. B. Clients will receive their proxies or other solicitations directly from their custodial broker-dealer or a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other solicitations directly to the sender. Page 20 of 21 Date of Brochure: January 30, 2026  Item 18: Financial Information A. Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. Adviser has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. A. Adviser has not been the subject of a bankruptcy petition at any time during the past ten years. Page 21 of 21 Date of Brochure: January 30, 2026