Cosner Financial Group, LLC

Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure February 2026 Cosner Financial Group, LLC 628 Main Street Windsor, CO 80550 (970) 482‐3922 1030 Andrews Hwy Suite 112 Midland, TX 79701 (432) 682‐0326 Firm Website: www.cosnerfinancialgroup.com This brochure provides information about the qualifications and business practices of Cosner Financial Group, LLC (CRD #147942). If you have any questions about the contents of this brochure, please contact our firm by telephone at (970) 482‐3922. 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 Cosner Financial Group, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov . Please note that the use of the term “registered investment adviser” and description of Cosner Financial Group, LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and its employees. 1  Item 2: Material Changes to Our Part 2A of Form ADV: Firm Brochure Cosner Financial Group, LLC is required to advise you of any material changes to our Firm Brochure (“Brochure”) from our last annual update, identify those changes on the cover page of our Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Brochure. We must state clearly that we are discussing only material changes since the last annual update of our Brochure, and we must provide the date of the last annual update of our Brochure. A modification to our proxy voting policy was made in 2025. This only affected Legacy FDM clients who participated in a Wrap Program. 2  Item 3: Table of Contents Section: Page(s): Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure ............................................................................... 1 Item 2: Material Changes to Our Part 2A of Form ADV: Firm Brochure ........................................................... 2 Item 3: Table of Contents ..................................................................................................................................................... 3 Item 4: Advisory Business .................................................................................................................................................... 4 Item 5: Fees & Compensation ............................................................................................................................................. 8 Item 6: Performance-Based Fees & Side-By-Side Management ......................................................................... 11 Item 7: Types of Clients & Account Requirements .................................................................................................. 11 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................. 12 Item 9: Disciplinary Information ..................................................................................................................................... 15 Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 16 Item 12: Brokerage Practices ........................................................................................................................................... 17 Item 13: Review of Accounts or Financial Plans ....................................................................................................... 21 Item 14: Client Referrals & Other Compensation ..................................................................................................... 21 Item 15: Custody .................................................................................................................................................................... 22 Item 16: Investment Discretion ....................................................................................................................................... 23 Item 17: Voting Client Securities ..................................................................................................................................... 23 Item 18: Financial Information ........................................................................................................................................ 24 3  Item 4: Advisory Business We specialize in the following types of services: asset management and financial planning and consulting. A. Description of our advisory firm, including how long we have been in business and our principal owner(s). We are dedicated to providing individuals and other types of clients with an array of investment advisory services. Our firm is a limited liability company formed in the State of Colorado. Our firm has been in business as an investment adviser since 2008. Cosner Financial Group is presently owned by Ryan Cosner. Description of the types of advisory services we offer. (i) (a) Asset Management: We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. We utilize models as a guideline, but each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least annually and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. This service can include portfolio monitoring for clients that want to manage an account or certain funds on their own. This service does not include on-going supervision or discretionary trading with respect to securities transactions. Clients are responsible for determining their own investment ideas, but we can provide a sounding board for the idea and help place and execute the client’s trades at their direction. (b) Gateway Financial Strategies (GFS) The Gateway Financial Strategy is a tactical allocation program open to John Alpers, III clients only. The account, which is part of FD&M Legacy Account is managed on a limited discretionary basis in an attempt to increase returns and/or to reduce risk. Therefore, we will make all trade decisions without first conferring with you. Techniques employed by us include overweighting and underweighting of asset classes, active replacement of underperforming investments or sub accounts and moving up to 100% of each asset type to cash for defensive purposes. This service utilizes models as a guideline but customizes the portfolio taking into consideration your financial situation, goals, objectives and any account limitations or restrictions. If both a transaction fee and no transaction fee (NTF) option is available for the same security, GFS will purchase the lowest cost share class (NTF) if it will reduce the client’s overall cost over the securities anticipated holding period. 4  (ii) Financial Planning and Consulting: We offer a variety of financial planning and consulting services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-advisory related services. For written financial planning engagements, we would generally provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we typically do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. IRA Rollover Considerations As part of our consulting and advisory services, we may provide you recommendations and advice concerning your employer retirement plan or other qualified retirement account. We may recommend you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA") that we manage. If you elect to roll the assets to an IRA that we manage, we will charge you an asset-based fee as described in Item 5. This presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating an asset management fee 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 the assets in an IRA managed by us. Many employers permit former employees to keep their retirement assets in their company plan. 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. Rollover the funds to a new employer's retirement plan. 3. Cash out and taking a taxable distribution from the plan. 5  4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage, you should carefully consider the following: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. 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 fees. 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. c. b. You should understand the various products and services you might take advantage of at an IRA provider and the costs of those products and services. 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. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy may have higher risk than the option(s) provided to you in your current plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets in a 401k or retirement account and you are still working, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401k 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 some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA and you may be able to make penalty free withdrawals from your 401K as early as age 55. 8. 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 home purchase. 9. If you own highly appreciated company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page 6  of this brochure. B. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients, whether clients may impose restrictions on investing in certain securities or types of securities. (i) Individual Tailoring of Advice to Clients: We offer individualized investment advice to clients utilizing the following services offered by our firm: Asset Management. Additionally, we offer general investment advice to clients utilizing the following services offered by our firm: Financial Planning and Consulting. (ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of Securities: We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing their account. In the rare instance that we would allow restrictions, it would be limited to the following services: Asset Management. We do not manage assets through our other services. C. Participation in wrap fee programs. We only offer Wrap Fee Program to clients previously with Financial Design & Management, Inc. (FDM Legacy). The program is designed to assist you in clarifying your investment needs and obtaining professional asset management for a convenient single "wrap" fee on a discretionary or non-discretionary basis. Clients participating in a wrap fee arrangement pay a single fee for advisory, brokerage, clearance custodial, and administrative services. Clients’ portfolio transactions will be executed without a commissions-charge in a wrap fee arrangement. We typically manage wrap fee accounts similarly to non-wrap fee accounts. However, several factors may influence the selection of the account structure, including but not limited to: 1) The client’s preference for a “wrap” vs. transaction charges per trade. 2) Account size. 3) Anticipated trading frequency. 4) Anticipated securities to be traded. 5) Management style. 6) Long term investment goals. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by paying transaction costs separately with another advisor. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies, the brokerage commissions charged by broker-dealers, and the advisory fees charged by investment advisers. We will review with clients any separate program fees that may be charged to clients. As we absorb certain transaction costs in wrap fee accounts, we may have a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. To minimize this conflict, we manage accounts similarly, whether in a wrap 7  program or not, and periodically review the activity and associated costs to assess whether the wrap account is in the clients’ best interest. D. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of client assets we manage on a non-discretionary basis. We manage $359,878,674 on a discretionary basis and $1,796,671 on a non-discretionary basis as of December 31, 2025. Item 5: Fees & Compensation We are required to describe our brokerage, custody, fees and fund expenses so you will know how much you are charged and by whom for our advisory services provided to you. Our fees may be negotiable. Therefore, clients with similar assets under management and investment objectives may pay higher or lower fees than other clients. A. Description of how we are compensated for our advisory services provided to you. (i) (a) Asset Management: Annual Percentage of assets charge*: Assets under management $0-$4,999,999 $5,000,000+ 1.00 % Negotiable *Our firm’s fees are billed on a pro-rata annualized basis quarterly in arrears based on the value of your account on the last day of the quarter. Fees in excess of 2% are in excess of industry standards. Similar advisory services can be obtained for less. (b) FD&M Legacy Account: Advisory fees will be charged in advance of each calendar quarter. The quarterly advisory fee will be based on the value of the account on the last business day of previous quarter. We reserve the right to adjust billing for material interim additions to or withdrawals from the account during the quarter. Fee adjustments for additions and withdrawals made from an account will be reflected on the next billing cycle. The adjustment is calculated based on the number of days the money was under management and your fee schedule. To simplify accounting, your fee each quarter will be rounded up/down to the nearest dollar. Some quarters a client may pay slightly more and some quarters slightly less than the exact formula amount. Over time, such rounding will tend to average out to the exact formula amount. Portfolio Size First $100,000 Next $150,000 Next $250,000 Next $500,000 Next $1,000,000 Next $3,000,000 Quarterly Fee 0.40 - .45% 0.35 - .45% 0.325 - .35% 0.275% 0.2 - .25% 0.1625 - 0.1875% Annual Fee 1.6 - 1.8% 1.4 - 1.8% 1.3 - 1.4% 1.1% 0.8 - 1% 0.65% - 0.75% 8  If the value of your portfolio is less than $150,000, in addition to the advisory fees above, you will pay trading fees for securities transactions executed in your account in accordance with the custodian’s transaction fee schedule. The current fee schedule is included in your Advisory Agreement. (c) Gateway Financial Strategies (GFS) Fees are based on a percentage of assets being managed. This fee is for ongoing account monitoring, for initiating appropriate changes in investments, for quarterly reporting of portfolio results and for personal discussions to ensure your financial objectives are being met. To simplify accounting, your fee each quarter will be rounded up/down to the nearest dollar. Some quarters a client may pay slightly more and some quarters slightly less than the exact formula amount. Over time, such rounding will tend to average out to the exact formula amount. Portfolio Size First $500,000 Next $500,000 Next $1,000,000 Next $3,000,000 Next $5,000,000 Quarterly Fee 0.3375% 0.2750% 0.2500% 0.1875% Negotiable Annual Fee 1.35% 1.10% 1.00% 0.75% Negotiable We do not retain a management fee based on the amount of assets being managed, instead it is reimbursed for operational and compliance costs associated with the GFS. (ii) Financial Planning and Consulting: We charge on an hourly or flat fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. Our hourly fees are $175 for financial advisors. Flat fees generally range from $500 to $10,000. B. Description of whether we deduct fees from clients’ assets or bill clients for fees incurred. (i) (a) Asset Management: Our firm’s fees are billed on a pro-rata annualized basis quarterly in arrears based on the value of your account on the last day of the quarter. Fees will generally be automatically deducted from your managed account. In rare cases, we will agree to directly bill clients. (b) FD&M Legacy Account: Our fees are billed on a pro-rata annualized basis quarterly in advance. The quarterly advisory fee will be based on the value of the account on the last business day of previous quarter. Fees will generally be automatically deducted from your managed account. In rare cases, we will agree to directly bill clients. (c) Gateway Financial Strategies (GFS) Our fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your account on the last day of the quarter. 9  (ii) Financial Planning and Consulting: We require a retainer of fifty-percent (50%) of the ultimate financial planning or consulting fee with the remainder of the fee directly billed to you and due to us within thirty (30) days of your financial plan being delivered or consultation rendered to you. In all cases, we will not require a retainer exceeding $500 when services cannot be rendered within 6 (six) months. (iii) Wrap Fee Program: Details are separately disclosed in our Wrap Brochure. C. Description of any other types of fees or expenses clients may pay in connection with our advisory services, such as custodian fees or mutual fund expenses. The fees described above do not include charges resulting from trades effected with or through broker-dealer(s), markups or markdowns by such other broker-dealers, electronic fund and wire transfer fees, custodial fees, as well as other fees, taxes, and governmental charges imposed. Such fees are the responsibility of the client. See Section 12 for a discussion of our brokerage practices. In addition, these fees do not include the underlying fund expenses, which the client bears as a shareholder of the funds. These fees and expenses are disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). D. Client’s advisory fees are due quarterly. We charge our advisory fees quarterly in arrears. FD&M Legacy/GFS Accounts charge in advance. Upon cancellation, you will be entitled to a prorated refund of prepaid advisory fees. Refunds will be calculated as of the date following the thirty (30) days after receipt of termination notification, or the date we terminate management, if shorter. We will refund a pro-rata portion of the advisory fee for the quarter from the date of termination to the end of the calendar quarter. If you wish to terminate our services, you need to contact us in writing and state that you wish to cancel your asset management agreement. Upon receipt of your letter of termination, we will proceed to close out your account and charge you a pro-rata advisory fee(s) for services rendered up to the point of termination. E. Commissionable securities sales. We may sell securities for a commission in non-advisory accounts. In order to sell securities for a commission, certain supervised persons are registered representatives of Osaic Wealth, Inc. (“Osaic”), member FINRA/SIPC. These supervised persons may accept compensation for the sale of securities or other investment products, including distribution or service (“trail”) fees from the sale of mutual funds. You should be aware that the practice of accepting commissions for the sale of securities: 1) Presents a conflict of interest and gives our firm and/or our supervised persons an incentive to recommend investment products based on the compensation received, rather than on your needs. We generally address commissionable sales conflicts that arise: a) when explaining to clients that commissionable securities sales creates an incentive to recommend products based on the compensation, we and/or our supervised persons may earn and may not necessarily be in the best interests of the client; 10  b) when recommending commissionable mutual funds, explaining that “no-load” funds are available through our firm if the client wishes to become an investment advisory client. 2) In no way prohibits you from purchasing investment products recommended by us through other brokers or agents which are not affiliated with us. Item 6: Performance‐Based Fees & Side‐By‐Side Management We do not offer performance based fees or side-by-side management. Item 7: Types of Clients & Account Requirements We have the following types of clients: Individuals;   High-Net Worth Individuals;  Pension and profit sharing plans;  Corporations or other businesses. We do not require a minimum account balance for our asset management service. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss A. Description of the methods of analysis and investment strategies we use in formulating investment advice or managing assets. We may use one or more of the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the 11  trend may last and when that trend might reverse. We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations. Long‐term purchases. When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short‐term purchases. When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. Short Sales Trading. We purchase securities with the idea of selling them very quickly (typically within 30 days or less). We do this in an attempt to take advantage of our predictions of brief price swings. We borrow shares of a stock for your portfolio from someone who owns the stock on a promise to replace the shares on a future date at a certain price. Those borrowed shares are then sold. On the agreed-upon future date, we buy the same stock and return the shares to the original owner. We engage in short selling based on our determination that the stock will go down in price after we have borrowed the shares. If we are correct and the stock price has gone down since the shares were purchased from the original owner, the client account realizes the profit. Margin transactions. We may purchase stocks for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase stock without selling other holdings. Option writing. We may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative, because it derives its value from an underlying asset. Risks. Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease, and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask us any questions you may have. Examples of risks that may be present in investing include: Capitalization Risk. The risk that mid-capitalization and small-capitalization stocks may be more volatile than the large-capitalization stocks and may at times underperform as compared to large- capitalization stocks. Company Risk. The risk that a particular company’s stock will suffer losses for reasons unique to that company (also known as “unsystematic risk”). Credit Risk. The risk that a bond issuer fails to pay interest and/or principal on their obligations in a timely fashion. 12  Currency Risk. The risk that investments in stocks denominated in other currencies will lose value because of a rise in the value of the dollar relative to those currencies. Foreign Exposure Risk. The risk that investments in foreign markets, including emerging markets may be more volatile than the U.S. markets due to fluctuations in currency exchange rates or political or economic conditions in a particular country. Investing in emerging markets countries may involve risks greater than the risks of investing in more developed foreign countries. Inflation Risk. The risk that in the future, your investments or proceeds from your investments will not be worth what they are today due to the rising costs of goods and services. Said another way, a dollar tomorrow will likely get you less than what it can today. Interest Rate Risk. The risk that the price of bond holdings will decline due to a rise in interest rates. Changes in price will generally be greater for longer-maturity bonds than for bonds with shorter maturities. Legal/Regulatory Risk. The risk that changes in state or federal laws and/or regulations will negatively impact the performance or tax treatment of certain investments. Liquidity Risk. The risk that certain investments may not be readily converted into cash due to the nature of those investments or changes in market conditions. This may negatively impact the ultimate price at which an investment is sold. Management Strategy Risk. The risk that the strategies and techniques utilized by the outside managers who oversee different parts of our clients’ portfolios will not achieve their intended results, leading to underperformance against a conventional index or benchmark and/or other funds with a similar investment objective. Market Risk. The risk that the value of investments can fall, sometimes sharply, in response to economic changes or other events that affect the capital markets as a whole (also known as “systematic risk”). Prepayment Risk. The risk that a bond may be repurchased or redeemed by the issuer before maturity. Depending upon the redemption price, the investor may receive a lower than expected return on the security. Reinvestment Risk. The risk that bond proceeds (principal and/or interest) may have to be reinvested at a lower yield than what the investor received from the original security due to intervening changes in interest rates. ETF and Mutual Funds Risk. ETFs and mutual funds are subject to investment advisory and other expenses, which will be indirectly paid by clients. As a result, the cost of our investment strategies will be higher than the cost of investing directly in ETFs or mutual funds, as there are two levels of fees. ETFs and mutual funds are subject to specific risks, depending on the nature of the fund. ETFs are professionally managed pooled vehicles that invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities or any combination thereof. ETF managers trade fund investments in accordance with fund investment objectives. ETF risk can be significantly increased for funds concentrated in a particular sector of the market, or that 13  primarily invest in small cap or speculative companies, use leverage (i.e., borrow money) to a significant degree, or concentrate in a particular type of security (i.e., equities), rather than balancing the fund with different types of securities. ETFs can be bought and sold throughout the day like stocks, and their price can fluctuate throughout the day. During times of extreme market volatility, ETF pricing may lag versus the actual underlying asset values. This lag usually resolves itself in a short period of time (usually less than one day); however, there is no guarantee this relationship will always occur. Shorting, Margin and Use of Leverage. We, with the client’s consent, may open client accounts as margin accounts and if we elect to use margin, such use can magnify risk to client’s accounts. As these are separately managed accounts, use of margin should be discussed with your IAR. Separately managed accounts wishing to use margin are required to complete a margin agreement. Other forms of leverage which we may use, includes options, short sales, and other inverse or leveraged derivative instruments. We also have the ability to short stocks in the client portfolios, and a high level of risk is associated with this strategy. Shorting securities requires the use of margin. We believe shorting can provide additional opportunities to make money for margin approved clients if we believe a stock is overvalued. In rare circumstances, structured products may be offered to certain clients. These products often involve a significant amount of risk and should only be offered to clients who have carefully read and considered the products’ offering documents, as they are often times based on derivatives. Structured products are intended to be "buy and hold" investments and are not liquid instruments. B. Our practices regarding cash balances in client accounts, including whether we invest cash balances for temporary purposes and, if so, how. We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to asset management services, as applicable. Item 9: Disciplinary Information We are required to disclose whether there are legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. There are a number of specific legal and disciplinary events that we must presume are material for this Item. If our advisory firm or a management person has been involved in one of these events, we must disclose it under this Item for ten years following the date of the event, unless (1) the event was resolved in our or the management person’s favor, or was reversed, suspended or vacated, or (2) the event is not material. For purposes of calculating this ten-year period, the “date” of an event is the date that the final order, judgment, or decree was entered, or the date that any rights of appeal from preliminary orders, judgments or decrees lapsed. The SEC and/or State Regulators have not provided us with an exclusive list of material disciplinary events, which need to be disclosed. If our advisory firm or a management person has been involved in a legal or disciplinary event that is not specifically required to be disclosed, but nonetheless is material to a client's or prospective client's evaluation of our advisory business or the integrity of our 14  management, we must disclose the event. Similarly, even if more than ten years has passed since the date of the event, we must disclose the event if it is so serious that it remains currently material to a client’s or prospective client’s evaluation of our firm or management. We have determined that our firm and management have nothing to disclose under the aforementioned standard. Item 10: Other Financial Industry Activities & Affiliations A. Our firm or our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. The details are as follows: Certain investment adviser representatives of our firm are registered representatives of Osaic as broker-dealer and our firm will be compensated on the normal and customary commission schedule for general securities business. Clients should be aware that these services involve a possible conflict of interest, as commissionable products can influence the recommendations made by our IARs. In their capacities as registered representatives, one may receive distribution or service (“trail”) fees from the sale of certain mutual funds (including money market funds pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services which are distributed from the fund’s total assets). These fee arrangements will be disclosed upon request of a client and are available in the applicable fund’s prospectus. B. If we recommend or select other investment advisers for our clients and we receive compensation directly or indirectly from those advisers, or we have other business relationships with those advisers, we are required to describe these practices and discuss the conflicts of interest these practices create and how we address them. We do not currently recommend other investment advisers to our clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. Brief description of our Code of Ethics adopted and offers to provide a copy of our Code of Ethics to any client or prospective client upon request. We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures with respect to transactions effected by our members, officers and employees for their personal accounts1. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. 15  An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. B. If our firm or a related person invests in the same securities (or related securities, e.g., warrants, options or futures) that our firm or a related person recommends to clients, we are required to describe our practice and discuss the conflicts of interest this presents and generally how we address the conflicts that arise in connection with personal trading. See Item 11.A of this Brochure. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. C. If our firm or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for our firm’s (or the related person's own) account, we are required to describe our practice and discuss the conflicts of interest it presents. We are also required to describe generally how we address conflicts that arise. See Item 11.A of this brochure. Related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Although we rarely submit block trades, if related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. D. Donations to Charities From time to time, we may donate to charitable organizations that are affiliated with clients, are supported by clients, and/or are supported by an individual employed by one of our clients. In general, such donations are made in response to requests from clients, or their personnel. Because our contributions may result in the recommendation of our services, such contributions may raise a potential conflict of interest. As a result, we require that all contributions are made directly to the charitable organization (normally a 501(c)(3) organization). No contribution will be made if the contribution implies that continued or future business with us depends on making such contribution. 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. 16  Item 12: Brokerage Practices A. Description of the factors that we consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). 1) Research and Other Soft Dollar Benefits. If we receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (“soft dollar benefits”), we are required to disclose our practices and discuss the conflicts of interest they create. Please note that we must disclose all soft dollar benefits we receive, including, in the case of research, both proprietary research (created or developed by the broker-dealer) and research created or developed by a third party. Our firm has an arrangement with Fidelity Institutional Wealth Services (“FIWS”) through Fidelity Brokerage Services LLC (CRD # 108476), Member FINRA/SIPC which provides our firm with FIWS’s “platform” services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support our firm in conducting business and in serving the best interests of our clients but that may benefit our firm. a. Explanation of when we use client brokerage commissions (or markups or markdowns) to obtain research or other products or services, and how we receive a benefit because our firm does not have to produce or pay for the research, products or services. As part of the arrangement described in Item 12.A(1), FIWS also makes certain research and brokerage services available at no additional cost to our firm. These services include certain research and brokerage services, including research services obtained by FIWS directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided by FIWS to our firm may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by FIWS to our firm in the performance of our investment decision-making responsibilities. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. b. Incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on our clients’ interest in receiving best execution. As a result of receiving the services discussed in 12.A(1) (a) of this Firm Brochure for no additional cost, we may have an incentive to continue to use or expand the use of FIWS’s services. Our firm examined this potential conflict of interest when we chose to enter into the relationship with FIWS and we have determined that the relationship is in the best interest of our firm’s clients and satisfies our client obligations, including our duty to seek best execution. 17  FIWS charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). FIWS enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. FIWS’s commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by FIWS may be higher or lower than those charged by other custodians and broker-dealers. c. Causing clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as paying-up). Our clients may pay a commission to FIWS that is higher than another qualified broker dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the benefit or all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. d. Disclosure of whether we use soft dollar benefits to service all of our clients’ accounts or only those that paid for the benefits, as well as whether we seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. Although the investment research products and services that may be obtained by our firm will generally be used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. In addition, we do not have any formal soft-dollar agreements in place where we must trade a certain volume in order to receive soft dollar credits or specific research or services. 2) Brokerage for Client Referrals. If we consider, in selecting or recommending broker-dealers, whether our firm or a related person receives client referrals from a broker-dealer or third party, we are required to disclose this practice and discuss the conflicts of interest it creates. Our firm does not consider referrals from a broker-dealer or third party in selecting or recommending broker-dealers. 3) Directed Brokerage. a. If we routinely recommend, request or require that a client directs us to execute transactions through a specified broker-dealer, we are required to describe our practice or policy. Further, we must explain that not all advisers require their clients to direct brokerage. If our firm and the broker-dealer are affiliates or have another economic 18  relationship that creates a material conflict of interest, we are further required to describe the relationship and discuss the conflicts of interest it presents by explaining that through the direction of brokerage we may be unable to achieve best execution of client transactions, and that this practice may cost our clients more money. In certain instances, clients may seek to limit or restrict our discretionary authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Any such client direction must be in writing (often through our asset management agreement) and may contain a representation from the client that the arrangement is permissible under its governing laws and documents if this is relevant. We provide appropriate disclosure in writing to clients who direct trades to particular brokers, that with respect to their directed trades, they will be treated as if they have retained the investment discretion that we otherwise would have in selecting brokers to effect transactions and in negotiating commissions and that such direction may adversely affect our ability to obtain best price and execution. In addition, we will inform you in writing that your trade orders may not be aggregated with other clients’ orders and that direction of brokerage may hinder best execution. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. b. If we permit a client to direct brokerage, we are required to describe our practice. If applicable, we must also explain that we may be unable to achieve best execution of your transactions. Directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices on transactions. See Item 12.A(3) of this Brochure. B. Discussion of whether, and under what conditions, we aggregate the purchase or sale of securities for various client accounts in quantities sufficient to obtain reduced transaction costs (known as bunching). If we do not bunch orders when we have the opportunity to do so, we are required to explain our practice and describe the costs to clients of not bunching. We perform investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are effected only 19  when we believe that to do so will be in the best interest of the affected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non- arbitrary methods of allocation. Item 13: Review of Accounts or Financial Plans A. Review of client accounts or financial plans, along with a description of the frequency and nature of our review, and the titles of our employees who conduct the review. We review accounts at least annually for our Asset Management clients. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. Financial planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. B. Review of client accounts on other than a periodic basis, along with a description of the factors that trigger a review. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. C. Description of the content and indication of the frequency of written or verbal regular reports we provide to clients regarding their accounts. We do not provide written reports to clients, unless asked to do so. Verbal reports to Asset Management clients take place on at least an annual basis. As also mentioned in Item 13.A of this Brochure, financial planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post-financial plan meeting or update to their initial written financial plan. Item 14: Client Referrals & Other Compensation A. If someone who is not a client provides an economic benefit to our firm for providing investment advice or other advisory services to our clients, we must generally describe the arrangement. For purposes of this Item, economic benefits include any sales awards or other prizes. Except for the arrangements outlined in Item 12 of this brochure, we have no additional FIWS arrangements to disclose. 20  Osaic IARs also receive a portion of the compensation that Osaic receives as a member of a selling syndicate. Thus, Osaic IARs have an incentive to recommend certain mutual funds and to recommend purchases of sales in certain offerings because the IAR will receive more compensation in connection with these securities than in connection with other types of securities. Advisory representatives of our firm may receive part of the compensation paid to Osaic in the advisor representative’s capacity as a registered representative of Osaic to the extent permitted by applicable law. Osaic has policies and procedures to address such conflicts of interest. In addition, we offer variable insurance products as registered representatives of Osaic. Therefore, we will receive, as registered representatives of Osaic, compensation for the sale of such products. The client is under no obligation to purchase insurance products through any particular insurance agency or IAR and may effect any such transactions where the client desires. B. If our firm or a related person directly or indirectly compensates any person who is not our employee for client referrals, we are required to describe the arrangement and the compensation. We do not pay referral fees (non-commission based) to independent solicitors (non-registered representatives) for the referral of their clients to our firm. Item 15: Custody We do not have custody of client funds or securities; however, we may be granted authority, by written consent from you, to deduct the advisory fees directly from your account. Client assets are held at a qualified custodian. However, we are deemed to have limited custody of some of our clients’ funds or securities when the clients authorize us to deduct our management fees directly from the client’s account. In addition, we are also deemed to have custody of clients’ funds or securities when clients have standing letters of authorizations (“SLOAs”) with their custodian to move money from a client’s account to a third-party, and under that SLOA it authorizes us to designate the amount or timing of transfers with the custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. The qualified custodian will send to you, at least quarterly, your account statements. The account statements will reveal the funds and securities held with the qualified custodian, any transactions that occurred in your account at the end of period and setting forth all transactions in the account during that period including the amount of advisory fees paid directly to us. We may provide to you reports we prepare regarding your portfolio. You are encouraged to review these reports and compare them against reports received from the independent custodian that services your advisory account. You should immediately inform us of any discrepancy noted between the custodian records and the reports you receive from us. You should notify us if you do not receive the account statements, at least quarterly, from the qualified custodian. 21  Item 16: Investment Discretion If we accept discretionary authority to manage securities accounts on behalf of clients, we are required to disclose this fact and describe any limitations our clients may place on our authority. The following procedures are followed before we assume this authority: Our clients need to sign a discretionary asset management agreement with our firm for the management of their account. This type of agreement only applies to our Asset Management clients. We do not take or exercise discretion with respect to our other clients. If a client chooses to sign a discretionary asset management agreement, our firm will be authorized, without prior consultation, to buy, sell, and trade in stocks, bonds, mutual funds, and other securities and/or contracts to accounts clients authorizes our firm to manage. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. We do not have discretionary authority to determine the broker or dealer to be used for a purchase or sale of securities or the commission rates to be paid to a broker or dealer for a client’s securities transactions. Item 17: Voting Client Securities We do not have the authority to vote client security proxies. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. If a proxy is sent to our firm, we will forward it to you and ask the party who sent it to mail directly to you in the future. Item 18: Financial Information A. If we require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, we must include a balance sheet for our most recent fiscal year. We do not require, nor do we solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we have not included a balance sheet for our recent fiscal year. B. If we have discretionary authority or custody of client funds or securities, or we require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, we must disclose any financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. We are not required to provide financial information to our clients because we do not:    require the prepayment of more than $1,200 in fees six or more months in advance, or take custody of client funds or securities, or currently have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. C. If we have been the subject of a bankruptcy petition at any time during the past ten years, we must disclose this fact, the date the petition was first brought, and the current status. We have nothing to disclose in this regard. 22 

Item 1 ‐ Cover Page ADV: Wrap Brochure February 2026 Cosner Financial Group, LLC 1030 Andrews Hwy Suite 112 Midland, TX 79701 (432) 682‐0326 628 Main Street Windsor, CO 80550 (970) 482‐3922 Firm Website: www.cosnerfinancialgroup.com This wrap fee program brochure provides information about the qualifications and business practices of Cosner Financial Group, LLC. If you have any questions about the contents of this Brochure, please contact us at (970) 482-3922. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Cosner Financial Group, LLC is a registered investment advisor. Additional information about Cosner Financial Group, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm’s CRD number is 147942. Any references to Cosner Financial Group, LLC as a registered investment adviser or its related persons as registered advisory representatives does not imply a certain level of skill or training.  Cosner Financial Group, LLC Item 2 - Material Changes This our updated filing of our Form ADV Part 2A Appendix 1 or “Wrap Brochure”. Each year, we will deliver to you a summary of material changes to our Wrap Brochure, if there are any, with an offer to provide a copy of our updated Wrap Brochure and information on how you may obtain the updated brochure. Furthermore, we will provide you with interim disclosures about material changes if needed. We no longer provide proxy voting services to existing Legacy FDM clients. The most current Wrap Brochure for Cosner Financial Group, LLC may be requested at any time by contacting our office at 970.482.3922. 2 of 15  Cosner Financial Group, LLC Item 3 - Table of Contents Item 1 - Cover Page ................................................................................................................................. 1 Item 2 - Material Changes ....................................................................................................................... 2 Item 3 - Table of Contents ....................................................................................................................... 3 Item 4 - Services, Fees and Compensation .............................................................................................. 4 Management Fees ................................................................................................................................ 6 Item 5 - Account Requirements and Types of Clients ........................................................................... 10 Item 6 - Portfolio Manager Selection and Evaluation ........................................................................... 10 Performance Based Fees .................................................................................................................... 10 Methods of Analysis, Investment Strategies and Risk of Loss.......................................................... 10 Proxy Voting ...................................................................................................................................... 12 Item 7 - Client Information Provided to Portfolio Managers ................................................................ 12 Item 8 - Client Contact with Portfolio Managers .................................................................................. 12 Item 9 - Additional Information............................................................................................................. 12 Disciplinary Information.................................................................................................................... 12 Other Financial Industry Activities and Affiliations ......................................................................... 12 Investment Adviser Relationships ..................................................................................................... 13 Code Of Ethics ................................................................................................................................... 13 Participation or Interest in Client Transactions, Personal Trading, and Privacy Policy .................... 14 Review of Accounts ........................................................................................................................... 14 Client Referrals and Other Compensation ......................................................................................... 14 Financial Information ........................................................................................................................ 15 Additional Disclosures ....................................................................................................................... 15 3 of 15  Cosner Financial Group, LLC Item 4 - Services, Fees and Compensation We provide continuous and ongoing management services based on your individual needs. We will design a portfolio and manage the account taking into consideration your financial goals and objectives, risk tolerance and investment time horizon. You may select from one of two management options. Option One: The account is tactically managed on a limited discretionary basis to increase returns and/or to reduce risk. Therefore, we will make all trade decisions without conferring with you. Techniques employed by us include overweighting and underweighting of asset classes, active replacement of underperforming investments or sub accounts and moving up to 100% of each asset type to cash for defensive purposes. Option Two: Reallocation of assets is generally made gradually and only after discussion with you (i.e., management decisions are made on a non-discretionary basis). We primarily use mutual funds, exchange traded funds (EFTs) and individual stocks and bonds in its managed accounts. Advisory Representatives may use various security types in a client’s account. Many of these are unlikely to be used and would require separate paperwork signed by the client before being purchased or sold. Possible securities that may be held or purchased in an account include but are not limited to: Investment company securities such as mutual funds and variable annuities  Various equity securities (exchange listed, traded over the counter and foreign issues)  Corporate debt securities  U.S. government securities  Commercial paper  Certificates of deposit  Municipal securities   Municipal securities  Exchange traded funds  Interests in partnerships investing in real estate, oil and gas interests, cable TV, equipment leasing, mortgages and other sorts of partnerships  Unit Investment Trusts (UITs) Cosner Financial Group only offers a wrap program to clients previously with Financial Design & Management, Inc (Legacy FDM). When participating in a wrap program you only pay one all-inclusive fee that covers both management fees and trading costs. You maintain every indication of ownership in your managed account and have the authority to instruct us to refrain from purchasing specific securities or to continue to hold specific securities. 4 of 15  Cosner Financial Group, LLC We utilize model portfolios: Aggressive, Moderate, Moderate Aggressive, Conservative, and Very Conservative. After evaluating your risk questionnaire, financial goals, time frame and anticipated cash flows, we determine which of its model portfolios is most suitable. We then customize your portfolio taking into consideration your financial situation, goals, objectives, any limitations or restrictions, current market conditions and our economic outlook. You are advised that trades in your account, including account reallocations and rebalancing, may trigger a taxable event; exceptions are IRA accounts and other qualified retirement accounts. Mutual funds and annuities owned and transferred into accounts may carry deferred loads (i.e., sales charges) that will be paid upon sale. (However, all mutual funds are purchased without paying any sales charges or contingent deferred sales charges.) Advisory Representatives, acting as Registered Representatives, have a conflict of interest if they recommend mutual funds or annuities outside of our managed accounts that carry a load (sales charge), as they will receive a commission for sales made through them. IRA Rollover Considerations As part of our consulting and advisory services, we may provide you recommendations and advice concerning your employer retirement plan or other qualified retirement account. We may recommend you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA") that we manage. If you elect to roll the assets to an IRA that we manage, we will charge you an asset-based fee as described in Item 5. This presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating an asset management fee 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 the assets in an IRA managed by us. Many 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. Rollover the funds to a new employer's retirement plan. 3. Cash out and taking a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage, you should carefully consider the following: 5 of 15  Cosner Financial Group, LLC 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. 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 fees. 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. b. You should understand the various products and services you might take advantage of at an IRA provider and the costs of those products and services. c. 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. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy may have higher risk than the option(s) provided to you in your current plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets titled in a 401k or retirement account and you are still working, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401k 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 some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA and you may be able to make penalty free withdrawals from your 401K as early as age 55. 8. 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 home purchase. 9. If you own highly appreciated company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. Management Fees Our fee is based on the value of the assets in your portfolio. Illiquid assets are not managed nor are they charged any asset management fee. We will not receive any stock, exchange funds, or bond commissions when trades are made in your account. Since we and our Advisory Representatives are not paid commissions on trades, it removes a conflict of interest. 6 of 15  Cosner Financial Group, LLC Advisory Representatives, in their capacity as Registered Representatives, may receive asset-based service fees from variable insurance companies. The receipt of such fees could represent an incentive for Advisory Representatives, acting in their capacity as Registered Representatives, to recommend annuities with an asset-based service fee over annuities that have no such fee or have a lower fee. As a result, there is a conflict of interest. Registered Representatives working with our clients will receive a commission if a client adds money to previously purchased commissionable annuities. This commission will not exceed 0.35% per year based on the total value of all client accounts being managed in limited discretionary accounts and 1.0% per year based on the total value of all client accounts being managed in non-discretionary accounts. We, in our sole discretion, may charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, negotiations with client, prior relationships, referrals, etc.) Account values of direct family members, e.g., husband and wife and children under age 21 living with their parents will be aggregated to determine the management fee, unless you ask us not to. In special circumstances fees for a given period may be waived, on a fully discretionary basis. Such a fee waiver is not contingent on a specified level of performance, is purely voluntary and is non- contractual. Our employees/relatives may in some cases have management fees waived. Thereafter, advisory fees will be charged in advance of each calendar quarter. The quarterly advisory fee will be based on the value of the account on the last business day of completed calendar quarter. To simply accounting, fees will be rounded up or down to the nearest dollar. Therefore, $.50 or more will be rounded up and less than $.50 will be rounded down. Some quarters you may pay slightly more and some quarters slightly less than the exact formula amount. Over time, such rounding will tend to average out to the exact formula amount. We reserve the right to adjust billing regarding material interim additions to or withdrawals from the account during the quarter. Fee adjustments for additions and withdrawals made from an account will be reflected on the next billing cycle. The adjustment is calculated based on the number of days the money was under management and the client’s fee schedule. Option I Active Management Portfolio Size Option II Gradual Reallocation Quarterly Fee Annual Fee First $100,000 Next $150,000 Next $250,000 Next $500,000 Next $1,000,000 Next $3,000,000 Over $5,000,000 Quarterly Fee 0.40 - .45% 0.35 - .45% 0.325 - .35% 0.275% 0.2 - .25% 0.1625 – 0.1875% Negotiable Annual Fee 1.6 – 1.8% 1.4 – 1.8% 1.3 – 1.4% 1.1% 0.8 – 1% 0.65% - 0.75% Negotiable .250% .225% .175% .1375% .010% .0875% Negotiable 1.00% 0.90% 0.70% 0.50% 0.40% 0.35% Negotiable 7 of 15  Cosner Financial Group, LLC You should review the fees charged by the funds or subaccounts and the fees charged by us to fully understand the total amount of fees to be paid and to evaluate the advisory services being provided. You are advised that the fees charged by us may be higher than fees charged by other investment advisors for similar services. We aggregate or household all of your managed accounts together to determine your quarterly fee. For example, if you have four managed accounts with a value as of the just completed calendar quarter of $101,569.40, $55,498.46, $675,879.50, and $74,301.12 with a total value of $907,248.48, your management fee will be calculated as follows (based on an actively managed account): First $100,000 x .45% Next $150,000 x .45% Next $250,000 x .35% Remaining $407,248.48 x .275% Quarterly Fee - Rounded $450.00 $675.00 $875.00 $1,119.93 $3,120.00 We may increase the above fee schedule upon 30-days prior written or electronic notice to you or reduce the above fee schedule after providing written or electronic notice to you. You may pay fees for custodial services, account maintenance and/or other fees associated with maintaining your account such as wire transfers, overnight charges, and odd-lot differentials. Such fees are not charged by us, rather they are charged by your account custodian, a broker/dealer, or the investment product sponsor. We do not share in any portion of such fees. Additionally, you will pay your proportionate share of management and administrative fees and internal trading costs for any mutual funds or ETFs owned. Clients who own variable insurance contracts will pay additional insurance charges to the insurance company. Such fees are not shared with us and are compensation to the fund-manager or to pay for mortality charges. You should read mutual fund and variable insurance prospectuses prior to investing. Some mutual funds or ETFs bought or sold in your account may be purchased by us without a transaction fee. They are often referred to as no transaction fee (NTF) trades. This creates a conflict of interest, as we could reduce its trading costs by purchasing NTF mutual funds and ETFs. We minimize this conflict of interest by making its investing selections without regard as to whether or not an investment is available to us as an NTF security. If both a transaction fee and NTF option is available for the same security, we will purchase the transaction fee security if it will reduce client’s overall costs over the securities anticipated holding period. You will be responsible for any short-term redemption fees imposed by a mutual fund or annuity company. Additionally, you will be responsible for any short-term trading fees charged by your custodian for NTF mutual funds held less than 60 days. We shall seek to minimize such costs. However, market conditions will take priority in determining whether to make trades in your account. Advisory fees will be collected directly from your account, provided you have given us written authorization. You will be provided with an account statement from your custodian reflecting the deduction of the advisory fee. Additionally, we will provide you with an itemized billing statement reflecting the fee calculation. If the account does not contain sufficient funds to pay advisory fees, we 8 of 15  Cosner Financial Group, LLC have limited authority to sell or redeem securities in sufficient amounts to pay advisory fees. You may reimburse the account for advisory fees paid to us, except for ERISA and IRA accounts. If you elect to be invoiced directly for our management fees, fees will be due to us within 30 days after you receive your invoice. If fees remain unpaid after 30 days, we are authorized to deduct any outstanding fees directly from your account. Further, we are authorized to make sales of securities in your account, if needed, at your expense, to generate enough cash to pay overdue management fees. You are advised our Advisory Representatives who are dually registered representatives of Osaic Wealth, Inc. (“Osaic”), a registered broker/dealer, member of the Financial Regulatory Association (FINRA) and SIPC. Your Advisory Representative may act as a Registered Representative for non- advisory accounts. In such capacity, they may earn commissions and service/distribution fees. Load and no-load mutual funds may pay annual service/distribution compensation, sometimes referred to as 12b-1 fees. 12b-1 fees come from fund assets, therefore, indirectly from your assets. 12b-1 fees can be paid to Osaic with a portion paid to your Advisory Representative, in their capacity as registered representatives of Osaic. The compensation your Advisory Representative will receive if you participate in the wrap program may be more than what the Advisory Representative would receive if you participated in other management programs or paid separately for investment advice, brokerage, and other services. Therefore, it may be considered a financial incentive to recommend the wrap program over other programs or services. Wrap accounts may be more suitable for clients who prefer to pay one fee that covers both management and trading costs. Generally, actively traded (tactically managed) accounts will be better suited for a wrap account. A wrap program may cost you more or less than if you purchase execution (transactional services) and advisory management services separately. The factors that bear upon the relative cost of the program include level of transactional activity, execution costs, management fee, and amount of assets under management. Managed accounts that are infrequently traded or trade in no-transaction fee securities are better suited for a non-wrap fee structure. Termination Provisions Our services will continue and remain in full force until terminated. Should you die or be declared incompetent, our authority to manage your account will continue until we are notified of termination due to such death or incompetence by your legal representative or until the account is frozen by the custodian. You may terminate management services within five (5) business days of execution of the advisory agreement with us without penalty. Thereafter, management services may be terminated at any time and for any reason thirty (30) days after receipt of your written notice to terminate. Active management will continue during the thirty (30) day notice period in order to facilitate an orderly liquidation and/or transfer of assets. Upon cancellation, you will be entitled to a prorated refund of prepaid advisory fees. Refunds will be calculated as of the date following the thirty days after receipt of termination notification, or the date we terminate management if shorter. We will refund a pro-rata portion of the advisory fee for the quarter from the date of termination to the end of the calendar quarter. 9 of 15  Cosner Financial Group, LLC In the event of withdrawal of all or substantially all of the assets from your account, or the termination of our management of your account, you may be billed for trading costs incurred by us to liquidate or transfer security positions in your account and for any termination fees charged directly to your account or charged to us. You will also be responsible for any short-term redemption fees imposed by a mutual fund or annuity company due to account closure, as well as any short-term redemption fees imposed by the custodian or broker/dealer for NTF funds or ETFs held less than 60 days. Upon delivery of your written notice to terminate our services, you have sixty (60) days to transfer or liquidate securities unless another arrangement has been made and agreed upon by us in writing. After 60 days, we may contact the custodian and have your account reclassified as a retail account. Item 5 - Account Requirements and Types of Clients Wrap program is only available to Legacy FDM clients. Minimum account size guidelines: The minimum wrap fee account size is $150,000. We may make an exception to the account minimum and accept accounts less than $150,000 in size. However, you are advised performance may suffer due to difficulties in diversifying smaller accounts and the impact of higher management fees. Exceptions are at our sole discretion. We may grant exceptions based on an analysis of the account such as the size of the account, number of related accounts we managed, other services in which you participate, complexity of your account, and tenure of your relationship with us. Item 6 - Portfolio Manager Selection and Evaluation There are no other managers contracted to provide management services. We have an investment committee that generally meets on a as needed basis to discuss the market and economic outlook, asset allocation decisions, strategy and to share research. Members of the investment committee were selected based on interest, knowledge, industry experience and affiliation with us. Performance Based Fees We no longer offer this fee methodology. Methods of Analysis, Investment Strategies and Risk of Loss We use various resources and products to assist in analyzing securities and determining the portfolio allocations. We employ the use of the following methods of analysis:  Charting - Charting is a form of technical analysis in which various factors are diagrammed in order to illustrate patterns.  Fundamental - Fundamental analysis generally involves assessing a company’s or security’s value based on factors such as sales, assets, markets, management, products and services, earnings, and financial structure.  Technical - Technical analysis generally involves studying trends and movements in a security’s price, trading volume, and other market-related factors to discern patterns. 10 of 15  Cosner Financial Group, LLC  Cyclical - Cyclical is attempting to determine the patters of how the economy and/or the market affect a security and attempt to determine the highs and lows of the security. The following sources are used to conduct due diligence and research: Inspections of corporate activities and due diligence trips to product sponsors  Financial newspapers, magazines, and the internet   Annual reports issued by product sponsors and companies  Prospectuses and other filings with the Securities and Exchange Commission  Research materials prepared by third parties  Company press releases In selected cases, we use a computer asset allocation model. The model develops recommendations designed to provide:  Rational investment selection  Alternatives matched to your needs  Sound methodology for investment decision making  Measurable decision-making criteria You are advised investing in securities involves risk of loss, including the potential loss of principal. Therefore, your participation in any of the management programs offered by us will require you to be prepared to bear the risk of loss and fluctuating performance. We primarily use mutual funds, ETFs, and individual stocks and bonds in its managed accounts. The risks of mutual funds include internal costs and expenses that can impact performance, change of managers, and a fund straying from its stated objective. Open ended mutual funds typically are liquid and their price does not fluctuate throughout the trading day. You may purchase mutual fund shares directly without using our management services. However, some mutual funds that we purchase without a sales charge cannot be purchased directly by individuals unless they pay a sales charge or invest large sums of money in a fund family (typically $500,000 to $5,000,000 or more for institutional class shares) and some annuities used are designed for use only in connection with investment advisory services provided by an investment adviser and have reduced insurance company expenses. Also, you would not receive the services provided by us which are designed, among other things, to assist you in determining which mutual fund(s) or sub- accounts are most appropriate for your financial situation and investment objectives and to make tactical portfolio decisions on your behalf. The risks of individual stocks and bonds are constant price fluctuation and potential lack of liquidity. Stocks and bonds are riskier investments than mutual funds because they are less diversified. We do not represent, warrant or imply that the services or methods of analysis used by us can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to major market corrections or crashes. Past performance may not be an indicative of future performance. 11 of 15  Cosner Financial Group, LLC No guarantees can be offered that your goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by us will provide a better return than other investment strategies. Proxy Voting We do not have the authority to vote client security proxies. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. If a proxy is sent to our firm, we will forward it to you and ask the party who sent it to mail directly to you in the future. Item 7 - Client Information Provided to Portfolio Managers Financial and personal information such as income, net worth, investment objectives, investment time horizon, risk profile, social security number, identity, account numbers, etc. will be gathered by your Advisory Representative. At least annually, your Advisory Representative will offer to meet with you to update your personal information, review your account and determine if the management of your account remains suitable for your financial situation. Should your financial situation or investment goals and objectives change, it is important that you notify us promptly of the changes. Failure to notify us of any such changes could result in investment recommendations not meeting your needs. Item 8 - Client Contact with Portfolio Managers There are no restrictions or limitations on your ability to contact your Advisory Representative or any member of our management team. You and your Advisory Representative determine the frequency of meetings and reviews. You may contact the management team directly at any time by calling 970.482.3922 to schedule an appointment. Item 9 - Additional Information Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client or prospective client’s evaluation of our advisory business or the integrity of our management. We and our employees and supervised personnel have not been involved in any type of disciplinary actions, including criminal or civil actions in a domestic, foreign or military court; administrative proceedings before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority; or proceeds before a self-regulatory organization (SRO). Other Financial Industry Activities and Affiliations Our Advisory Representatives are dually registered as our Advisory Representatives and as Registered Representatives of Osaic. Your Advisory Representative may act as a Registered Representative for non-advisory accounts. In such capacity, they may earn fully disclosed commissions and trail 12 of 15  Cosner Financial Group, LLC commissions. You are under no obligation to purchase or sell securities in unmanaged accounts through your Advisory Representative. However, if you choose to implement investment advice through your Advisory Representative, acting in their Registered Representative capacity, your Advisory Representative may earn commissions in addition to any fees you pay for advisory services. Commissions may be higher or lower at Osaic than at other broker/dealers. Advisory Representatives acting as Registered Representatives may have a conflict of interest in having you purchase commissionable securities and/or insurance related products through Osaic. You should be aware that the higher a Registered Representative’s production with Osaic, the greater their potential for obtaining a higher pay-out on commissions and advisory fees. We are not affiliated with Osaic. We attempt to mitigate this conflict of interest by providing you with these disclosures and endeavors at all times to put the interest of our clients first as part of our fiduciary duty as a registered investment advisor. We take the following steps to address potential conflicts:  We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our advisory fees;  We disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies;  We collect, maintain and document accurate, complete and relevant client background information, including the client’s financial goals, objective and risk tolerance;  We conduct regular reviews of each client account to verify that all recommendations made to client are suitable to the client’s needs and circumstances.  We require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed;  We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm; and  We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investments provided to clients. You may consult other Advisory Representative professionals and may implement recommendations we prepare through other financial professionals should you desire. Advisory Representatives serving as Registered Representatives with Osaic are subject to a supervisory structure at Osaic for their securities business. Investment Adviser Relationships We do not currently recommend other investment advisers to our clients. Code Of Ethics We have adopted a Code of Ethics expressing our commitment to ethical conduct. We have a fiduciary duty to act in your best interest and always place your interests first and foremost. We take seriously our compliance and regulatory obligations and requires all staff to comply with such rules and 13 of 15  Cosner Financial Group, LLC regulations as well as our policies and procedures. As such, we maintain a code of ethics for its Advisory Representatives, supervised persons, and staff. The Code of Ethics contains provisions for standards of business conduct in order to comply with federal securities laws, personal securities reporting requirements, pre-approval procedures for certain transactions, code violation reporting requirements, and safeguarding of material non-public information about you and your accounts. Further, our Code of Ethics establishes our expectation for business conduct. A copy of our Code of Ethics will be provided to you upon request. You have the right to decline any investment recommendation. We and our associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations. Finally, we strive to handle your non-public information in such a way to protect information from falling into hands that have no business reason to know such information. We provide new clients with a Privacy Statement and all clients receive an annual Privacy Notice. Generally, your non-public information will not be disclosed to any third party unless required by law or to provide you services you have requested. Please See Privacy Notice for full details of our privacy policy. Participation or Interest in Client Transactions, Personal Trading, and Privacy Policy We and our associated persons may buy or sell securities identical to those securities recommended to you. Therefore, we and/or our associated persons may have an interest or position in certain securities that are also recommended and bought or sold to you. We and our associated persons will not put their interests before your interest. We and our associated persons may not trade ahead of you or trade in such a way to obtain a better price for themselves than for you or other clients. Review of Accounts You are advised that you should notify us promptly of any changes to your financial goals, objectives or financial situation as such changes may require us to review your portfolio allocation and make changes. You will be invited to participate in at least an annual review. The frequency of reviews will be determined at the beginning of the relationship and may be altered at any time. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Your review will typically be conducted by your Advisory Representative. You will be provided statements directly from the account custodian at least quarterly. Additionally, you will receive confirmations of all transactions directly from the account custodian. Taxable accounts will also receive a year-end tax summary prepared and delivered by Fidelity. Client Referrals and Other Compensation Product vendors recommended by us may provide monetary and non-monetary assistance for client events and provide educational tools and resources to us. We do not select products as a result of any 14 of 15  Cosner Financial Group, LLC monetary or non-monetary assistance. Our due diligence of a product is not influenced by any assistance it may receive; products are selected solely by such factors as quality and experience of management, prior track record, expenses, and investment structure. Therefore, we do not consider any monetary or non-monetary assistance received to be a conflict of interest. We do not pay referral fees (non-commission based) to independent solicitors (non-registered representatives) for the referral of their clients to our firm. Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client or more than six months in advance of services rendered. Therefore, we are not required to give you a financial statement. As an advisory firm that has discretionary authority for client accounts, we are also required to disclose any financial condition that is reasonably likely to impair our ability to meet any of our contractual obligations. We are not required to provide financial information to our clients because we do not: require the prepayment of more than $1,200 in fees six or more months in advance, or take custody of client funds or securities, or • • • currently have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. We have not been the subject of a bankruptcy petition at any time. Additional Disclosures You are advised that the investment recommendations and advice offered by us should not be considered legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform us promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify us of any such changes could result in investment recommendations not meeting your needs. 15 of 15