Csp Financial Group LLC

Item 1 Cover Page D I S C L O S U R E B R O C H U R E F O R M A D V P A R T 2 A CSP Financial Group, LLC Office Address: 14300 North Northsight Blvd. Suite 120 Scottsdale, AZ 85260 Tel: 480-600-9626 Fax: 240-331-0849 Email: charles@cspfgllc.com Website: www.cspfinancialgroup.com September 11, 2026 This brochure provides information about the qualifications and business practices of CSP Financial Group, LLC. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 480-600-9626. 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 CSP FINANCIAL GROUP, LLC (CRD #310819) IS AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV i  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since the last update of this brochure on March 18, 2026, the following changes have been made: • Item 4 has been amended to update current assets under management. • Item 12 has been updated to disclose an additional custodial relationship. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm. ii  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Full Brochure Available .................................................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 6 Wrap Fee Programs ......................................................................................................................................................... 6 Client Assets Under Management .............................................................................................................................. 6 Item 5: Fees and Compensation ....................................................................................................... 6 Method of Compensation and Fee Schedule .......................................................................................................... 6 Client Payment of Fees ................................................................................................................................................ 11 Additional Client Fees Charged ................................................................................................................................ 11 Prepayment of Client Fees ......................................................................................................................................... 12 External Compensation for the Sale of Securities to Clients ........................................................................ 12 Item 6: Performance-Based Fees and Side-by-Side Management ...................................... 12 Sharing of Capital Gains .............................................................................................................................................. 12 Item 7: Types of Clients ..................................................................................................................... 12 Description ....................................................................................................................................................................... 12 Account Minimums ....................................................................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .............................. 13 Methods of Analysis ...................................................................................................................................................... 13 Investment Strategy ..................................................................................................................................................... 13 Security Specific Material Risks ............................................................................................................................... 13 Item 9: Disciplinary Information ................................................................................................... 15 Criminal or Civil Actions ............................................................................................................................................. 15 Administrative Enforcement Proceedings .......................................................................................................... 16 Self- Regulatory Organization Enforcement Proceedings ............................................................................ 16 iii  Item 10: Other Financial Industry Activities and Affiliations ............................................. 16 Broker-Dealer or Representative Registration ................................................................................................. 16 Futures or Commodity Registration ...................................................................................................................... 16 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 16 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 16 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................................... 17 Code of Ethics Description ......................................................................................................................................... 17 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 17 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 17 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .................................................................................................................. 18 Item 12: Brokerage Practices ......................................................................................................... 18 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 18 Aggregating Securities Transactions for Client Accounts ............................................................................. 19 Item 13: Review of Accounts ........................................................................................................... 19 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 19 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 19 Content of Client Provided Reports and Frequency ........................................................................................ 20 Item 14: Client Referrals and Other Compensation ................................................................ 20 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 20 Advisory Firm Payments for Client Referrals .................................................................................................... 22 Item 15: Custody .................................................................................................................................. 22 Account Statements ...................................................................................................................................................... 22 Item 16: Investment Discretion ..................................................................................................... 22 Discretionary Authority for Trading...................................................................................................................... 22 Item 17: Voting Client Securities ................................................................................................... 22 Proxy Votes ...................................................................................................................................................................... 22 Item 18: Financial Information ...................................................................................................... 23 Balance Sheet .................................................................................................................................................................. 23 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 23 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 23 iv  Brochure Supplement (Part 2B of Form ADV) .......................................................................... 25 Principal Executive Officer – Charles Pettit, Jr., ChFC®, CLU®, ChFEBCSM ............................................... 25 Item 2 - Educational Background and Business Experience ....................................................................... 25 Item 3 - Disciplinary Information ........................................................................................................................... 26 Item 4 - Other Business Activities ........................................................................................................................... 27 Item 5 - Additional Compensation .......................................................................................................................... 27 Item 6 - Supervision ..................................................................................................................................................... 28 v  Item 4: Advisory Business Firm Description CSP Financial Group, LLC (“CSP Financial Group”) was founded in 2010. Charles Pettit, Jr. is 100% owner. Types of Advisory Services ASSET MANAGEMENT CSP Financial Group offers discretionary asset management services to advisory Clients. CSP Financial Group will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize CSP Financial Group discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. CO-ADVISOR CSP Financial Group will recommend Matson Money, a third-party investment adviser. CSP Financial Group conducts due diligence on the third-party investment adviser which includes the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. CSP Financial Group will assist a client with engagement with Matson Money by referring the client to Matson Money, the third-party adviser. CSP Financial Group will review the ongoing performance of the third-party adviser. CSP Financial Group will direct clients to Matson Money, Inc. Matson Money offers two advisory programs: (1) the Matson Fund Platform; and (2) Private Account Asset Allocation. Under the Matson Fund Platform, Matson money will invest Client assets primarily through the Free Market Funds. Under the Frontier Adjusted Portfolio program, Client assets are generally allocated to any one or a combination of the three affiliated Free Market Funds and participating Client portfolios are required to be adjusted annually to reduce their risk profile over time. In Private Account Asset Allocation, Client assets are primarily allocated within a family of no-load mutual funds managed by Dimensional Fund Advisors, LP (“DFA”), an unaffiliated, registered investment adviser. DFA mutual funds are generally not available to individual investors with small accounts except through the services of an investment adviser like Matson Money. CSP Financial Group will deliver the client a copy of the Part 2A brochure for Matson Money which describes the services offered in greater detail. PORTFOLIO ANALYSIS (MRI) SERVICES The Portfolio Analysis (MRI) Service is provided through Matson Money and is only available for use with Matson Money Clients. CSP Financial Group performs a portfolio “MRI” service; an analogy used to describe looking deeply into the holdings of a client’s existing portfolio. Specifically, CSP Financial Group will outline the client’s current financial situation, including annual income, savings, tax levels, and risk tolerance levels. CSP Financial Group will then prepare a report for the client and work with the client to ensure that investments match the client’s risk tolerance, goals, and time horizon. - 1 -  ASSETS HELD AWAY CSP Financial Group provides an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k), Thrift Savings Plan (TSP) accounts, HSAs, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. Specifically, the exact amount charged is determined by the daily average over the quarter. The current exception for this is directly managed held-away accounts, which are determined by the account value at the end of the quarter. In either case, if the Adviser only manages your assets for part of a quarter, the charge will be prorated. The advisory fee is a blended fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the chart below and applying the fee to the daily average of the account value or the account value as of the last day of the previous quarter (per the paragraph above), resulting in a combined weighted fee. For example, an account valued at $2,000,000.00 would pay an effective fee of 1% with the annual fee being $20,000.00 (a quarterly fee of $5,000.00). Investment management fees are generally directly debited on a pro rata basis from client accounts. DONOR ADVISED CHARITABLE GIVING CSP Financial Group offers non-discretionary asset management services to donor advised accounts. CSP Financial Group will recommend liquidation and purchase of investments to Client and Client will review and approve the recommendations as appropriate. CSP Financial Group will arrange for execution of approved purchases and sales. ERISA PLAN SERVICES CSP Financial Group provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. CSP Financial Group may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor CSP Financial Group has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using CSP Financial Group can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are: • Provide investment advice to the Client about asset classes and investment options available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. CSP Financial Group acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii). • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. - 2 -  • Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment option for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. • Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. • Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment options available to them under the Plan. Client understands CSP Financial Group’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, CSP Financial Group is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. CSP Financial Group will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. • Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. CSP Financial Group may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between CSP Financial Group and Client. 3. CSP Financial Group has no responsibility to provide services related to the following types of assets (“Excluded Assets”): • Employer securities; • Real estate (except for real estate funds or publicly traded REITs); • Stock brokerage accounts or mutual fund windows; • Participant loans; • Non-publicly traded partnership interests; • Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or • Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to CSP Financial Group on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. ERISA 3(38) Investment Manager. CSP Financial Group can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. - 3 -  CSP Financial Group would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are: • CSP Financial Group has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives. • Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. • Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment option for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment options available to them under the Plan. Client understands the CSP Financial Group’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the CSP Financial Group is not providing fiduciary advice as defined by ERISA to the Plan participants. CSP Financial Group will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. • Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. CSP Financial Group may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between CSP Financial Group and Client. 3. CSP Financial Group has no responsibility to provide services related to the following types of assets (“Excluded Assets”): • Employer securities; • Real estate (except for real estate funds or publicly traded REITs); • Stock brokerage accounts or mutual fund windows; • Participant loans; • Non-publicly traded partnership interests; • Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or • Other hard-to-value or illiquid securities or property. - 4 -  Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING AND CONSULTING CSP Financial Group offers the following financial planning and consulting services: Full Financial Plan Financial planning services include a complete evaluation of an investor's current and future financial state and will be provided by using currently known variables to predict future cash flows, asset values and withdrawal plans. CSP Financial Group will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Typical topics reviewed in a financial plan may include but are not limited to: • Financial goals: Based on an individual's or a family's clearly defined financial goals, including funding a college education for the children, buying a larger home, starting a business, retiring on time or leaving a legacy. Financial goals should be quantified and set to milestones for tracking. • Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring progress towards financial goals. • Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings and investing each month. • Retirement strategy: A strategy for achieving retirement independent of other financial priorities. Including a strategy for accumulating the required retirement capital and its planned lifetime distribution. • Comprehensive risk management plan: Identify all risk exposures and provide the necessary coverage to protect the family and its assets against financial loss. The risk management plan includes a full review of life and disability insurance, personal liability coverage, property and casualty coverage, and catastrophic coverage. for selecting, buying and selling • Long-term investment plan: Include a customized asset allocation strategy based on specific investment objectives and a risk profile. This investment plan sets guidelines investments and establishing benchmarks for performance review. • Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include identification of tax- favored investment vehicles that can reduce taxation of investment income. • Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life insurance, provide a second look at your current estate planning documents, and prompt you to update your plan when the legal environment changes or you have major life events such as a marriage, death, or births. Consultation Services This service is appropriate for clients who need assistance with individual topics. This is not a detailed financial review and will not provide/result in a complete financial plan. Client may select individual topics above, or other topics as may be deemed appropriate. The individual topics that will be included in this service will be outlined and agreed upon on the financial planning and consulting agreement. - 5 -  If a conflict of interest exists between the interests of CSP Financial Group and the interests of the Client, the Client is under no obligation to act upon CSP Financial Group’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through CSP Financial Group. Financial plans will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. SEMINARS AND WORKSHOPS CSP Financial Group holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs CSP Financial Group does not sponsor any wrap fee programs. Client Assets Under Management CSP Financial Group has the following Client assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $150,550,578 $0 September 2, 2026 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT CSP Financial Group offers discretionary direct asset management services to advisory Clients. CSP Financial Group charges an annual investment advisory fee based on the total assets under management as follows: Annual Fee 1.20% 1.00% Quarterly Fee .300% .250% 0.90% .225% 0.80% .200% 0.70% .175% Assets Under Management First $1,000,000 ($0-$1,000,000) Your next $2,000,000 ($1,000,000.01 - $3,000,000) Your next $2,000,000 ($3,000,000.01 - $5,000,000) Your next $5,000,000 ($5,000,000.01 - $10,000,000) Subsequent amounts ($10,000,000.01+) This is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. CSP Financial Group may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. - 6 -  For example (based on quarterly billing period): Client with $2,500,000 under management would pay $6,750.00 on a quarterly basis. AUM Quarterly fee Total First $1,000,000 x 0.300% = $3,000.00 Next $1,500,000 x 0.250% = $3,750.00 Grand total for the quarter $6,750.00 The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed quarterly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by CSP Financial Group with thirty (30) days written notice to Client and by the Client at any time with written notice to CSP Financial Group. No fee adjustment will be made for account deposits and/or withdrawals during a billing period. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to CSP Financial Group. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. CO-ADVISOR CSP Financial Group will direct clients to Matson Money, Inc. CSP Financial Group will assist the client to select a manager or managers and an appropriate allocation model. CSP Financial Group will assist the client in completing applications and any forms required to establish an account and engage the third party manager (TPM). At least annually, CSP Financial Group will meet with the client to review their account, discuss changes to the client’s financial situation, suitability of the model allocation and manager, and discuss any other financial issues. Generally, Matson is responsible for portfolio management, portfolio design, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. Our agreement with Matson Money requires us to maintain a relationship with the client. Matson Money requires us to ensure that information about your specific goals, financial situation and risk preference remain current, assist you in determining appropriate allocation models, review account activity periodically, meet with you annually, and respond to your inquiries. - 7 -  The annual fee schedule is as follows: Annual Fee 1.20% 1.00% Quarterly Fee .300% .250% 0.90% .225% 0.80% .200% 0.70% .175% Assets Under Management First $1,000,000 ($0-$1,000,000) Your next $2,000,000 ($1,000,000.01 - $3,000,000) Your next $2,000,000 ($3,000,000.01 - $5,000,000) Your next $5,000,000 ($5,000,000.01 - $10,000,000) Subsequent amounts ($10,000,000.01+) This is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. CSP Financial Group may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. For example (based on quarterly billing period): Client with $2,500,000 under management would pay $6,750.00 on a quarterly basis. AUM Quarterly fee Total First $1,000,000 x 0.300% = $3,000.00 Next $1,500,000 x 0.250% = $3,750.00 Grand total for the quarter $6,750.00 The value of the account as of the last business day of the quarter is used for purposes of calculating the advisory fee. The advisory fee is charged quarterly in advance. Matson collects CSP Financial Group’s co-advisor fee of up to 1.2% in advance and sends that to CSP Financial Group directly. These fees are negotiable and are separate from the expense ratio (0.49% annually) associated with the Matson Money funds in which the portfolio will be invested. Matson Money does not receive any advisory fee directly; it is compensated solely via the 0.49% internal management fee associated with its mutual funds. PORTFOLIO ANALYSIS (MRI) SERVICES The Portfolio MRI service will be offered to all Matson Money clients only. Clients will pay a one-time (non-recurring) fixed fee of $500 for the MRI service. It is the discretion of the CSP Financial Group advisor, as to whether to charge this fee. ASSETS HELD AWAY Specifically, the exact amount charged is determined by the daily average over the quarter. The current exception for this is directly managed held-away accounts, which are determined by the account value at the end of the quarter. In either case, if the Adviser only manages your assets for part of a quarter, the charge will be prorated. The advisory fee is a blended fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the chart above and applying the fee to the daily average of the account value or the account value as of the last day of the previous quarter (per the paragraph above), resulting in a combined weighted fee. For example, an account valued at - 8 -  $2,000,000.00 would pay an effective fee of 1% with the annual fee being $20,000.00 (a quarterly fee of $5,000.00). Investment management fees are generally directly debited on a pro rata basis from client accounts. DONOR ADVISED CHARITABLE GIVING CSP Financial Group charges an annual fee as follows: Annual Fee 1.00% 0.90% Quarterly Fee .250% .225% 0.80% .200% 0.70% .175% Assets Under Management First $3,000,000 ($0-$3,000,000) Your next $2,000,000 ($3,000,000.01 - $5,000,000) Your next $5,000,000 ($5,000,000.01 - $10,000,000) Subsequent amounts ($10,000,000.01+) The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed quarterly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous quarter. For example, an account with $2,500,000 would be billed as follows: $2,500,000 x .25% = $6,250 per quarter Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by CSP Financial Group with thirty (30) days written notice to Client and by the Client at any time with written notice to CSP Financial Group. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to CSP Financial Group. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. ERISA PLAN SERVICES The annual fees are based on the market value of the Included Assets and will be billed as follows: Annual Fee 1.20% 1.00% Quarterly Fee .300% .250% 0.90% .225% 0.80% .200% 0.70% .175% Assets Under Management First $1,000,000 ($0-$1,000,000) Your next $2,000,000 ($1,000,000.01 - $3,000,000) Your next $2,000,000 ($3,000,000.01 - $5,000,000) Your next $5,000,000 ($5,000,000.01 - $10,000,000) Subsequent amounts ($10,000,000.01+) - 9 -  This is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. CSP Financial Group may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. For example (based on quarterly billing period): Client with $2,500,000 under management would pay $6,750.00 on a quarterly basis. AUM Quarterly fee Total First $1,000,000 x 0.300% = $3,000.00 Next $1,500,000 x 0.250% = $3,750.00 Grand total for the quarter $6,750.00 The annual fee is negotiable and may be charged as a percentage of the Included Assets. Fees will be charged quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets). If the services to be provided start any time other than the first day of a quarter or month, the fee will be prorated based on the number of days remaining in the quarter or month. If this Agreement is terminated prior to the end of the billing cycle, CSP Financial Group shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the billing cycle. The fee schedule, which includes compensation of CSP Financial Group for the services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. CSP Financial Group does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, CSP Financial Group will disclose this compensation, the services rendered, and the payer of compensation. CSP Financial Group will offset the compensation against the fees agreed upon under the Agreement. FINANCIAL PLANNING AND CONSULTING CSP Financial Group charges either an hourly fee or fixed fee based on complexity and unique Client needs for financial planning. Prior to the planning process the Client will be provided an estimated plan fee. Full Financial Plan Fees for a Full Financial Plan are offered based on a fixed fee up to $1,200. Consultation Services Fees for Consultation Services are offered based on an hourly fee of $300. Fees for financial plans are either: • billed 50% in advance with the balance due upon plan delivery. • due upon delivery of the completed plan. • billed monthly for 1/12 of the agreed upon fee to Client credit card. Client will select billing option on the financial planning agreement. - 10 -  Services are completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to CSP Financial Group. SEMINARS AND WORKSHOPS CSP Financial Group holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. CSP Financial Group offers these seminars on a complimentary basis. Client Payment of Fees Fees for asset management services are: • Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. • Check – to be remitted by Client to CSP Financial Group • Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third party payment processor in which the client will securely input payment information and pay the advisory fee through a secure portal. CSP Financial Group will not have continuous access to the Client’s banking information.) Fees for co-advisor services are withdrawn directly from the client’s accounts with client’s written authorization. Fees for portfolio analysis (MRI) are: • Check – to be remitted by Client to CSP Financial Group • Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third party payment processor in which the client will securely input payment information and pay the advisory fee through a secure portal. CSP Financial Group will not have continuous access to the Client’s banking information.) Fees for asset held away services fees are generally directly debited on a pro rata basis from client accounts. Fees for ERISA services will either be deducted from Plan assets or paid directly to CSP Financial Group. The Client must consent in advance to direct debiting of their investment account. Fees for financial plans will be billed: • Check – to be remitted by Client to CSP Financial Group • Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third party payment processor in which the client will securely input payment information and pay the advisory fee through a secure portal. CSP Financial Group will not have continuous access to the Client’s banking information.) Additional Client Fees Charged Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money - 11 -  market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. CSP Financial Group does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to CSP Financial Group. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees CSP Financial Group does not require any prepayment of fees of more than $1,200 per Client and six months or more in advance. Fees for portfolio analysis (MRI) are paid in advance. Fees for ERISA 3(21) and/or 3(38) services are either billed from Plan assets or paid directly to CSP Financial Group. Fees for financial plans may be billed 50% in advance with the balance due upon plan delivery. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to CSP Financial Group. External Compensation for the Sale of Securities to Clients Investment Advisor Representatives of CSP Financial Group receive external compensation from sales of investment related products such as insurance as licensed insurance agents. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. This conflict is mitigated by disclosures, procedures, and CSP Financial Group’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. CSP Financial Group does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for CSP Financial Group to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description CSP Financial Group generally provides investment advice to individuals, high net worth individuals, and business entities. Client relationships vary in scope and length of service. Account Minimums CSP Financial Group does not require a minimum to open or maintain an account. - 12 -  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include Modern Portfolio Theory. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Modern Portfolio Theory is the theory of finance that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Modern Portfolio Theory assumes investors are risk averse which means when given two assets with the same expected return the investor will choose the less risky one. An investor is only willing to take more risk if the expected return is greater. Therefore, Modern Portfolio Theory aims to construct a portfolio of investments that has the best possible expected return for the level of risk. TPMs utilized by CSP Financial Group may use various methods of analysis to determine the proper strategy for the client referred and these will be disclosed in the TPM’s Form ADV Part 2. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance is not a guarantee of future returns. Other strategies utilized by TPMs may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options or spreading strategies). Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to CSP Financial Group. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Other strategies may include long-term purchases. Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with CSP Financial Group: • Market Risk: The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. - 13 -  • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the client’s portfolio may suffer. • Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid- cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. • Investment Companies Risk: When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. • Cash and Cash Equivalents Risk: Cash and cash equivalents consist of investments like money market funds, certificates of deposit (CDs), Treasury bills, and short-term government bonds. They are generally considered low-risk compared to other asset classes. While they offer safety, liquidity, and stability, they come with certain risks, such as inflation, interest rate fluctuations, and opportunity costs. - 14 -  • Foreign Securities Risk: Funds in which clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Long-term purchases: Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. • Foreign Investment Risk: Investments in foreign securities may be riskier than U.S. investments because of factors such as, unstable international, political and economic conditions, currency fluctuations, foreign controls on investment and currency exchange, foreign governmental control of some issuers, potential confiscatory taxation or nationalization of companies by foreign governments, withholding taxes, a lack of adequate company information, less liquid and more volatile exchanges and/or markets, ineffective or detrimental government regulation, varying accounting standards, political or economic factors that may severely limit business activities, and legal systems or market practices that may permit inequitable treatment of minority and/or non-domestic investors. Investments in emerging markets may involve these and other significant risks such as less mature economic structures and less developed and more thinly-traded securities markets. The risks associated with utilizing TPM’s include: • Manager Risk o TPM fails to execute the stated investment strategy • Business Risk o TPM has financial or regulatory problems • The specific risks associated with the portfolios of the TPM’s which is disclosed in the TPM’s Form ADV Part 2. Item 9: Disciplinary Information Criminal or Civil Actions CSP Financial Group and its management have not been involved in any criminal or civil action. - 15 -  Administrative Enforcement Proceedings CSP Financial Group and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings CSP Financial Group and its management have not been involved in any self-regulatory organizational enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of CSP Financial Group or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration CSP Financial Group is not registered as a broker-dealer and no affiliated representatives of CSP Financial Group are registered representatives of a broker-dealer. Futures or Commodity Registration Neither CSP Financial Group nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Mr. Charles Pettit, Jr. has a financial affiliated business as an independent insurance agent. Approximately 50% of his time is spent on this activity. He will offer Clients services from this activity. As an insurance agent, he will receive separate yet typical compensation. This practice represents a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest CSP Financial Group may at times utilize the services of third party money managers to manage client accounts. In such circumstances, Advisor will share in the third party asset management fee. Clients placed with TPM will be billed in accordance with the TPM’s fee schedule which will be disclosed to the Client prior to signing an agreement. When referring Clients to a TPM, the Client’s best interest will be the main determining factor of CSP Financial Group. CSP Financial Group ensures that before selecting other advisors for Client that the other advisors are properly licensed or registered as an investment advisor. These practices represent conflicts of interest because CSP Financial Group is paid a Referral Fee for recommending the TPM and may choose to recommend a particular TPM based on the fee CSP Financial Group is to receive. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to act in the best interest of his Clients. Clients are not required to accept any recommendation of TPM given by CSP Financial Group and have the option to receive investment advice through other money managers of their choosing. - 16 -  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of CSP Financial Group have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of CSP Financial Group affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of CSP Financial Group. The Code reflects CSP Financial Group and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. CSP Financial Group’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of CSP Financial Group may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. CSP Financial Group’s Code is based on the guiding principle that the interests of the Client are our top priority. CSP Financial Group’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. CSP Financial Group will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest CSP Financial Group and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest CSP Financial Group and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide CSP Financial Group with copies of their brokerage statements. - 17 -  The Chief Compliance Officer of CSP Financial Group is Charles Pettit, Jr. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest CSP Financial Group does not have a material financial interest in any securities being recommended. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide CSP Financial Group with copies of their brokerage statements. The Chief Compliance Officer of CSP Financial Group is Charles Pettit, Jr. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions CSP Financial Group will recommend the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. CSP Financial Group will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees, reporting ability, execution capability (speed and accuracy), financial stability and reputation, access to markets, technology and reporting platforms, quality of client service and availability of investment research and other brokerage services. CSP Financial Group relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by CSP Financial Group. CSP Financial Group does not receive any portion of the trading fees. CSP Financial Group will recommend the use of Charles Schwab & Co., Inc. or Altruist Financial LLC. • Research and Other Soft Dollar Benefits The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by CSP Financial Group from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although CSP Financial Group has no formal soft dollar arrangements, CSP Financial Group may receive products, research and/or other services from custodians or broker-dealers connected to - 18 -  client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, CSP Financial Group receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of CSP Financial Group. CSP Financial Group cannot ensure that a particular client will benefit from soft dollars or the client’s transactions paid for the soft dollar benefits. CSP Financial Group does not seek to proportionately allocate benefits to client accounts to any soft dollar benefits generated by the accounts. A conflict of interest exists when CSP Financial Group receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that CSP Financial Group has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Brokerage for Client Referrals CSP Financial Group does not receive client referrals from any custodian or third party in exchange for using that broker-dealer or third party. • Directed Brokerage Clients who direct brokerage outside our recommendation may be unable to achieve the most favorable execution of client transactions as client 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. Not all advisors require their clients to direct brokerage. Not all advisors require their clients to direct brokerage. Aggregating Securities Transactions for Client Accounts CSP Financial Group manages each account separately, and therefore, does not aggregate purchases and sales and other transactions. If orders are not aggregated, some clients purchasing securities around the same time may receive a less favorable price than other clients which may cost clients more money. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Chief Compliance Officer of CSP Financial Group, Charles Pettit, Jr. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, CSP Financial Group suggests updating at least annually. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. - 19 -  Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by CSP Financial Group’s custodian. Client receives confirmations of each transaction in account from custodian and an additional statement during any month in which a transaction occurs. CSP Financial Group does not provide additional reports to Clients. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Charles Schwab & Co., Inc. Advisor Services provides CSP Financial Group with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For CSP Financial Group client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to CSP Financial Group other products and services that benefit CSP Financial Group but may not benefit its clients’ accounts. These benefits may include national, regional or CSP Financial Group specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of CSP Financial Group by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist CSP Financial Group in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of CSP Financial Group’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of CSP Financial Group’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to CSP Financial Group other services intended to help CSP Financial Group manage and further develop its business enterprise. These services may legal and business consulting, publications and include professional compliance, conferences on practice management, information technology, business succession, - 20 -  regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to CSP Financial Group by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to CSP Financial Group. CSP Financial Group is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). CSP Financial Group receives additional economic benefits from external sources as described above in Item 12. CSP Financial Group receives a portion of the annual management fees collected by the TPM(s) to whom CSP Financial Group refers Clients. This situation creates a conflict of interest because CSP Financial Group and/or its Investment Advisor Representative have an incentive to decide what TPMs to use because of the higher referral fees to be received by CSP Financial Group. However, when referring Clients to a TPM, the Client’s best interest will be the main determining factor of CSP Financial Group. CSP Financial Group has entered into an arrangement with an unaffiliated third-party estate planning service provider (“Estate Planning Provider”). Under this arrangement, CSP Financial Group may receive a fee for assisting the Estate Planning Provider with administrative and information-gathering services, which may include collecting client data, coordinating communications, and facilitating the delivery of estate planning services. The fee paid to CSP Financial Group is not charged directly to the client by CSP Financial Group but is paid by the Estate Planning Provider. As a result, this arrangement creates a conflict of interest because CSP Financial Group has a financial incentive to recommend or refer clients to the Estate Planning Provider. Clients are under no obligation to engage the Estate Planning Provider and may select any estate planning professional of their choosing. CSP Financial Group does not provide legal or estate planning advice and does not supervise or control the services provided by the Estate Planning Provider. Clients should independently evaluate the Estate Planning Provider and are encouraged to ask questions regarding the qualifications, fees, and services offered. - 21 -  Upon request, CSP Financial Group will provide additional information regarding this compensation arrangement, including the nature of the services provided and the amount of compensation received. Advisory Firm Payments for Client Referrals CSP Financial Group does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to carefully compare the account statements received directly from their custodians to any documentation or reports prepared by CSP Financial Group. CSP Financial Group is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of CSP Financial Group. Item 16: Investment Discretion Discretionary Authority for Trading CSP Financial Group requires discretionary authority to manage securities accounts on behalf of Clients. CSP Financial Group has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. Client will authorize CSP Financial Group discretionary authority as stated within the Investment Advisory Agreement. CSP Financial Group allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to CSP Financial Group in writing. The Client approves the custodian to be used. CSP Financial Group does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes CSP Financial Group does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, CSP Financial Group will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires assistance or has questions, they can reach out to the investment advisor representatives of the firm at the contact information on the cover page of this document. - 22 -  Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because CSP Financial Group does not serve as a custodian for Client funds or securities and CSP Financial Group does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients CSP Financial Group has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years CSP Financial Group has not had any bankruptcy petitions in the last ten years. - 23 -  Item 1 Cover Page S U P E R V I S E D P E R S O N B R O C H U R E F O R M A D V P A R T 2 B Charles Pettit, Jr., ChFC®, CLU®, ChFEBCSM CSP Financial Group, LLC Office Address: 14300 North Northsight Blvd. Suite 120 Scottsdale, AZ 85260 Tel: 480-600-9626 Fax: 240-331-0849 Email: charles@cspfgllc.com Website: www.cspfinancialgroup.com September 11, 2026 This brochure supplement provides information about Charles Pettit, Jr. and supplements the CSP Financial Group, LLC brochure. You should have received a copy of that brochure. Please contact Charles Pettit, Jr. if you did not receive the brochure or if you have any questions about the contents of this supplement. ADDITIONAL INFORMATION ABOUT CHARLES PETTIT, JR. (CRD #2488074) IS AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV. - 24 -  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Charles Pettit, Jr., ChFC®, CLU®, ChFEBCSM • Year of birth: 1965 Item 2 - Educational Background and Business Experience Educational Background: • University of Maryland; Associate of Arts - General; 1993 Business Experience: • CSP Financial Group, LLC.; Chief Compliance Officer/Investment Advisor Representative; 11/2020-Present • CSP Financial Group, LLC.; Managing Member; 04/2020-Present • Charles Pettit, Sole Proprietor; Independent Insurance Agent; 06/1994-Present • ED 4 FEDS; Partner; 01/2020 – 12/2020 • Lifetyme Financial Group, LLC; Member/Insurance Agent; 01/2014-12/2020 • Lifetyme Financial Advisors, LLC; Investment Advisor Representative; 03/2012- 01/2021 Professional Certifications Charles Pettit, Jr. has earned certifications and credentials that are required to be explained in further detail. Chartered Financial Consultant® (ChFC®): Chartered Financial Consultant (ChFC®) is a designation issued by the American College of Financial Services. ChFC® designation requirements: • Complete ChFC® coursework within five years from the date of initial enrollment. • Pass the exams for all required elective courses. A minimum score of 70% must be achieved to pass. • Meet the experience requirements: Three years of full-time business experience within the five years preceding the date of the award. An undergraduate or graduate degree from an accredited educational institution qualifies as one year of business experience. • Take the Professional Ethics Pledge. • When you achieve your ChFC® designation, you must earn 30 hours of continuing education credit every two years. Chartered Life Underwriter (CLU®): Chartered Life Underwriter is a designation granted by the American College. CLU® designation requirements: • Successfully complete CLU® coursework: five required and three elective courses. • Meet the experience requirements: Three years of business experience immediately preceding the date of the use of the designation are required. An undergraduate or graduate degree from an accredited education institution qualifies as one year of business experience. - 25 -  • Take the Professional Ethics Pledge. • When you achieve the CLU® designation, you must complete 30 hours of continuing education credit every two years. Chartered Federal Employee Benefits Consultant (ChFEBC℠) is issued by the Federal Seminars & ChFEBC℠, Inc. It is recognized in the United States for is (1) high standard of professional education about Federal Employee Benefits; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. To earn the designation, a candidate must meet the following requirements: • Education – Complete 16 modules self-study or a two-day classroom course • Examination – Pass the two-hour exam (proctored, closed book); • Experience – o Three years of financial services experience and State Insurance License o Hold one of the following: Series 6, Series 7, Series 24, Series 66, or o Be an Investment Advisor Representative, or o Hold one of the following: (including three years of financial services experience) - Chartered Financial Consultant (ChFC) - Chartered Life Underwriter (CLU) - Chartered Financial Analyst (CFA) - Certified Financial Planner (CFP) - Master’s Degree in Business, Finance or Economics - Attorney’s License (JD) - Certified Public Accountant (CPA) • Continuing Education – Complete 10 hours continuing education every two years • Renewal Exam – Complete a 30 question renew exam every year to ensure they are staying current with all changes and updates with Federal Employee Benefits and review other relevant benefit questions. • Ethics – Agree to be bound by Snow Federal Seminars & ChFEBC℠, Inc. Code of Conduct outlining the ethical and practice standards for ChFEBC℠ professionals. • ChFEBC℠ designees who fail to comply with the above standards and requirements may be subject to Snow Federal Seminars & ChFEBC℠, Inc compliant and disciplinary process, which could result in suspension or permanent revocation of their ChFEBC℠ designation. Item 3 - Disciplinary Information A. Mr. Pettit, Jr. has never been involved in a criminal or civil action in a domestic, foreign or military court of competent jurisdiction for which he: 1. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; 2. Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; - 26 -  3. Was found to have been involved in a violation of an investment-related statute or regulation; or 4. Was the subject of any order, judgement or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment related activity, or from violating any investment-related statute, rule, or order. B. Mr. Pettit, Jr. never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: 1. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; 2. Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority (a)denying, suspending or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his association with an investment-related business; (c) otherwise significantly limiting his investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on him. C. Mr. Pettit, Jr. has never been the subject of a self-regulatory organization (SRO) proceeding in which he: 1. Was found to have caused an investment-related business to lose its authorization to do business; or 2. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. D. Mr. Pettit, Jr. has not been involved in any other hearing or formal adjudication in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Item 4 - Other Business Activities Mr. Charles Pettit, Jr. has a financial affiliated business as an independent insurance agent. Approximately 50% of his time is spent on this activity. He will offer Clients services from this activity. As an insurance agent, he will receive separate yet typical compensation. This practice represents a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Item 5 - Additional Compensation Mr. Charles Pettit, Jr. receives commissions on the insurance products he sells. He does not receive any performance-based fees and does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. - 27 -  Item 6 - Supervision Since Mr. Charles Pettit, Jr. is the owner and Chief Compliance Officer of CSP Financial Group and is responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. He can be reached at charles@cspfgllc.com or 480-600-9626. - 28 -