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Part 2A of Form ADV: Firm Brochure
Form ADV, Part 2A, Item 1
Cover Page
487 South Drake Road, Suite A
Kalamazoo, Michigan 49009
Tel: (269) 321-7472
Fax: (248) 886-9492
February 16, 2026
FORM ADV PART 2
FIRM BROCHURE
This brochure provides information about the qualifications and business practices of Daus
Financial Group, LLC. If you have any questions about the contents of this brochure, please
contact us at (269) 321-7472. 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 Daus Financial Group, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Daus Financial Group, LLC is
323054.
Daus Financial Group, LLC is a Registered Investment Adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a
certain level of skill or training.
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Form ADV, Part 2A, 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. Each year, we will ensure that
you receive a summary of any material changes to this and subsequent brochures by April 30th.
We will further provide you with our most recent brochure at any time at your request, without
charge. You may request a brochure by contacting us at (269) 321-7472.
Material Changes since the Last Update
Daus Financial Group, LLC was established as a new Registered Investment Advisor in March
2023 with the Securities and Exchange Commission (“SEC”), under the rules and regulations of
the US Investment Advisers Act of 1940, as amended (the "Advisers Act").
The following changes have been made since the last annual update on February 27, 2025:
• None
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Form ADV, Part 2A, Item 3
Table of Contents
Advisory Business…………………………………………………………… 4
Fees and Compensation…………………………………………………….. 6
Performance-Based Fees and Side-By-Side Management……………. 8
Types of Clients………………………………………………………………. 8
Methods of Analysis, Investment Strategies, and Risk of Loss……… 9
Disciplinary Information…………………………………………………….. 11
Other Financial Industry Activities and Affiliations……………………. 11
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Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading………………………………………………………………
Brokerage Practices………………………………………………………….. 12
Review of Accounts………………………………………………………….. 14
Client Referrals and Other Compensation……………………………….. 14
Custody………………………………………………………………………… 14
Investment Discretion……………………………………………………….. 15
Voting Client Securities……………………………………………………… 15
Financial Information………………………………………………………… 16
Requirements for State-Registered Advisers…………………………… 16
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Form ADV Part 2A, Item 4
Advisory Business
Daus Financial Group, LLC (hereinafter called “DFG”) is a Registered Investment Adviser
based in Kalamazoo, Michigan, and incorporated under the laws of the State of Michigan. DFG
is wholly owned by Ryan Daus. DFG is registered with the SEC and subject to the rules and
regulations of the US Advisers Act. Founded in March 2023, DFG provides investment advisory
services, which may include, but are not limited to, the review of client investment objectives
and goals, recommending asset allocation strategies of managed assets among investment
products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written
investment strategies. Our investment advice is tailored to meet our clients’ needs and
investment objectives. Clients may impose restrictions on investing in certain securities or types
of securities (such as a product type, specific companies, specific sectors, etc.) by providing a
signed and dated written notification, of which an e-mail is also an acceptable form of
notification. DFG also provides financial planning consulting services including, but not limited
to, risk assessment/management, investment planning, estate planning, financial organization, or
financial decision making/negotiation.
DFG provides investment advisory and other financial services through its Investment Advisory
Representatives ("IAR") to accounts opened with DFG. Managed Accounts are available to
individuals and high net worth individuals.
Private (Alternative) Investments
DFG gives certain clients the option of investing in private investments, such as private equity
funds, venture funds and hedge funds. Due to strict regulatory requirements, only certain clients
may invest in private investments. The clients must be classified as “accredited investors”, who
are generally clients that have over $1 million in total net worth, or individual income of greater
than $200,000 the previous 2 years and expect to do the same the current year, or the client and
spouse had a combined income of $300,000 per year the previous 2 years and expect to do the
same the current year. Accredited investors are permitted to invest in private investments but
may NOT be charged performance-based fees. Please see Item 6 – Performance-Based Fees and
Side-By-Side Management below, which confirms DFG does not charge performance-based fees
for any of our clients.
DFG provides discretionary and non-discretionary investment advisory services to some of its
clients through various managed account programs. DFG will assist clients in determining the
suitability of the Managed Account Programs for the client. The IAR is compensated through a
comprehensive single fee and the account may be assessed other charges associated with
conducting a brokerage business. DFG and its IAR, as appropriate, will be responsible for the
following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
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• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment
objectives and evaluate the investment vehicle selections
• Providing Firm Brochure (this document)
Company-Sponsored Retirement Plan Consulting Services
DFG provides company-sponsored retirement plan consulting services (hereinafter called
“retirement plan consulting services” or “401(k) plan advising”). These services may include
plan design, investment lineup selection and monitoring, plan administration support, education,
co-fiduciary support, and benchmarking.
We will meet with the client to discuss the major plan goals, identify key employees, evaluate
employer contribution options, and analyze income tax considerations. DFG will assist with the
development of an appropriate investment strategy that reflects the plan sponsor’s stated
investment objectives for management of the plan. DFG will design an investment lineup that
meets the plan sponsor’s goals and objectives and will monitor the investments for potential
changes. As a 3(21) fiduciary adviser DFG will not have discretionary authority, therefore, final
decisions relative to portfolio construction and changes will rest solely with the plan sponsors.
Third Party Investment Advisors
DFG utilizes the services of a technology platform provided by Envestnet, which provides a
selection of third-party investment advisors. After a review of a client’s portfolio(s), risk
tolerance and investment objectives, DFG may recommend some or all of a client’s portfolio to
be managed by one or more third party investment advisors (each, a “TPA”). Each TPA will
actively manage client portfolio(s) and will assume discretionary investment authority over that
portion of the portfolio(s) allocated to the TPA. Discretionary investment authority will allow the
TPA to place trades and make changes to the account or the portion of the account the TPA is
authorized to manage without the client’s prior approval. DFG will periodically monitor each
TPA’s performance to ensure its investment program remains aligned with the client’s goals and
objectives. The recommendation of TPAs is made on a non-discretionary basis with the specific
terms outlined in the State of Investment Selection (“SIS”). When TPA recommendations are
made on a non-discretionary basis, the client will need to execute an agreement directly with the
TPA. DFG is available and responsible to answer questions clients have regarding any portion of
their account managed by a TPA and will act as the communication conduit between the client
and the TPA. A complete description of the TPA’s services, practices and fees will be disclosed
in the TPA’s Form ADV Part 2A: Firm Brochure that will be provided to the client.
As of February 9, 2026, the firm has the following Assets Under Management:
Discretionary AUM - $0
Non-Discretionary AUM - $270,510,000.00
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Form ADV, Part 2A, Item 5
Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged monthly in arrears and are based primarily on asset size
and the level of complexity of the services provided. Accounts that are serviced through
Envestnet (a third-party money manager platform) will have advisory fees associated with that
service which are separate from those charged by DFG. Specifically, clients in the Envestnet
program will be charged to cover the money manager fee, and DFG does not share in any fees
assessed by Envestnet, which also may be charged on a different billing cycle than DFG. Details
will be provided to those clients that are utilizing Envestnet asset managers. In individual cases,
DFG has the sole discretion to negotiate fees that are lower than the standard fee shown or to
waive fees. Fees are not based on the share of capital gains or capital appreciation of the funds
or any portion of the funds. Comparable services for lower fees may be available from other
sources. Fees for the initial month will be prorated based upon the number of calendar days in
the calendar month that the advisory agreement is in effect. Fees are based on the market value
of the assets on the last business day of the month. Annual fees range from .65% - 1.50%,
depending on the amount of assets under management (“AUM”) – See chart below. Consulting
services are included in these fees for asset management services with the exception of unique
circumstances that may require a separate agreement for financial planning services (description
and fees are discussed below). If the situation warrants separate financial planning fees, it will
be discussed upfront and a separate agreement will be negotiated.
Fee Schedule for Asset Management:
Maximum Annual Advisory Fee
Total Account Value
Under $250,000 1.50%
Next $250,000 1.35%
Next $500,000 1.25%
Next $1,000,000 1.15%
Next $3,000,000 1.00%
Next $5,000,000 0.85%
Over $10,000,000 0.65%
*There is a minimum annual fee per household ranging between $2,500 and $7,500. The fee
charged is based on the program invested in and disclosed in the client agreement.
As authorized in the client agreement, the account custodian withdraws Daus Financial Group,
LLC’s advisory fees directly from the clients’ accounts according to the custodian’s policies,
practices, and procedures. The custodial statement includes the amount of any fees paid to DFG
for advisory services. You should carefully review the statement from your custodian/broker-
dealer’s statement and verify the calculation of fees. Your custodian/broker-dealer does not
verify the accuracy of fee calculations.
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Fees are charged in arrears on a monthly basis, meaning that advisory fees for a month are
charged on the first day of the following month. Clients may terminate investment advisory
services obtained from DFG, without penalty, upon written notice within five (5) business days
after entering into the advisory agreement with DFG. The client is responsible for any fees and
charges incurred by the client from third parties as a result of maintaining the account such as
transaction fees for any securities transactions executed and account maintenance or custodial
fees. Thereafter, the client may terminate advisory services upon written notice delivered to and
received by DFG. Clients who terminate investment advisory services during a month are
charged a prorated advisory fee based on the date of DFG’s receipt of client’s written notice to
terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and
unearned fees will be immediately refunded.
Financial Planning – Financial planning services are charged in advance through a fixed fee or
in arrears through an hourly arrangement as agreed upon between the client and Daus Financial
Group, LLC. There will never be an instance where $1,200 or more in fees is charged six or
more months in advance. Hourly fees are generally charged when the scope of services cannot
be determined or if the services are limited to one meeting. Fixed fees are generally quoted to
the client for longer-term consulting projects or on-going support (retainer services). Fees are
negotiable and vary depending upon the complexity of the client situation and services to be
provided. Hourly fees range from $250 - $1,000 per hour, depending on what is negotiated
between DFG and the client. Similar financial planning services may be available elsewhere for
a lower cost to the client. Fixed fees for longer-term consulting projects or on-going support
range from $1,500 to $50,000. An estimate for total hours and charges is determined at the start
of the advisory relationship.
Typically, clients will be invoiced monthly for hourly engagements, for all time spent by DFG as
agreed upon by client or upon completion of the services if less than a month. For on-going
support retainer services, clients will be billed quarterly in advance. Clients who wish to
terminate the planning process prior to completion may do so with written notice. The client
may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the
billing period by contacting Terra Loew at (269) 321-7472. Upon receipt of written notification,
any earned fee will immediately become due and payable, and any prepaid and unearned fees
will be immediately refunded. A client may terminate an advisory agreement without being
assessed any fees or expenses within five (5) days of its signing.
Additional Fees and Expenses
In addition to advisory fees paid to DFG as explained above, clients may pay custodial service,
account maintenance, transaction, and other fees associated with maintaining the account. These
fees vary by broker and/or custodian. Clients should ask DFG for details on transaction fees or
other custodial fees specific to their account, as these fees are not included in the annual advisory
fee. DFG does not share any portion of such fees. Additionally, for any mutual funds
purchased, the client may pay their proportionate share of the funds’ distribution, internal
management, investment advisory and administrative fees. Such fees are not shared with DFG
and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus
prior to investing.
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Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that
would not exist if the purchase or sale were made directly with the mutual fund company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund
management fees may be more or less than the mutual fund management fees charged if the
client held the mutual fund directly with the mutual fund company.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of DFG or paying the advisory fee
on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to
the public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the
applicable advisory fee. However, clients would not receive DFG’s assistance in developing an
investment strategy, selecting securities, monitoring performance of the account, and making
changes as necessary.
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.
Form ADV, Part 2A, Item 6
Performance-Based Fees and Side-By-Side Management
Daus Financial Group, LLC does not charge performance-based fees or participate in side-by-
side management. Side-by-side management refers to the practice of managing accounts that are
charged performance-based fees while at the same time managing accounts that are not charged
performance-based fees. Performance-based fees are fees that are based on a share of capital
gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and
Compensation section above, and are not charged on the basis of performance of your advisory
account.
Form ADV, Part 2A, Item 7
Types of Clients
DFG offers investment advisory services to individuals and high net worth individuals. There is
a $100,000 minimum account size to open and maintain an advisory account.
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Form ADV, Part 2A, Item 8
Methods of Analysis, Investment Strategies, and Risk of Loss
DFG’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. DFG is not bound to a specific
investment strategy for the management of investment portfolios, but rather consider the risk
tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis.
Examples of methodologies that our investment strategies may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk.
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time.
Technical Analysis – involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, interest rate risk, issuer risk, and general
economic risk. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.
DFG’s primary goal for investing is to help the client maintain purchasing power over the long
term. This may result in short term variability and loss of principal. Time horizon and risk
tolerance are key determinates of the proper asset allocation. DFG’s approach focuses on taking
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appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or
eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or
lack of portfolio risk).
Below are some more specific risks of investing:
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 the client or an underlying 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.
Management Risk. DFG’s investment approach may fail to produce the intended results. If our
perception of the performance of a specific asset class or underlying fund is not realized in the
expected time frame, the overall performance of 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 is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance
similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.),
conditions in the sector related to the project can affect the overall municipal market. Payment
of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue
generated by a specific project, the operator of the project, or government appropriation or aid.
There is a greater risk if investors can look only to the revenue generated by the project. In
addition, municipal bonds generally are traded in the “over-the-counter” market among dealers
and other large institutional investors. From time to time, liquidity in the municipal bond market
(the ability to buy and sell bonds readily) may be reduced in response to overall economic
conditions and credit tightening.
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Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of 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; (ii) the ETF may employ an investment
strategy that utilizes high leverage ratios; or (iii) 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. DFG has no control over the risks taken by the
underlying funds.
Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components. The use of artificial
intelligence and machine learning includes increased risk of data inaccuracies and security
vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks
related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, the Firm performs periodic due diligence of our service providers for assurance that the
service providers have appropriate controls in place to protect our clients’ information and to
limit data inaccuracies when artificial intelligence is used by the service provider.
Form ADV, Part 2A, Item 9
Disciplinary Information
Daus Financial Group, LLC or its Principal Executive Officers have not had any reportable
disclosable events in the past ten years.
Form ADV, Part 2A, Item 10
Other Financial Industry Activities and Affiliations
Neither DFG nor its representatives are currently registered with any broker dealer.
Neither DFG nor its representatives are registered as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor.
DFG and its representatives are also licensed insurance agents. From time to time, they will offer
clients advice or products from those activities. Clients should be aware that these services pay a
commission and involve a possible conflict of interest, as commissionable products can conflict
with the fiduciary duties of a registered investment adviser. DFG always acts in the best interest
of the client; including the sale of commissionable products to advisory clients. Clients are in no
way required to implement the plan through any representative of DFG in their capacity as an
insurance agent. Not more than 10% of representatives’ time is spent on this activity.
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Form ADV, Part 2A, Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
DFG’s Code of Ethics includes guidelines for professional standards of conduct for our
Associated Persons. Our goal is to protect client interests at all times and to demonstrate our
commitment to fiduciary duties of honesty, good faith, and fair dealing. All of DFG’s
Associated Persons are expected to strictly adhere to these guidelines. Persons associated with
Daus Financial Group, LLC are also required to report any violations to the Code of Ethics.
Additionally, the firm maintains and enforces written policies reasonably designed to prevent the
misuse or dissemination of material, non-public information about our clients or client accounts
by persons associated with our firm.
DFG and its employees may buy or sell securities that are also held by clients. It is the expressed
policy of the advisor that no person employed by our firm purchase or sell any security prior to the
transaction being implemented for an advisory account; therefore, preventing such employees
from benefiting from transactions placed on behalf of the advisory clients.
The advisor may have an interest or position in a certain security, which may also be recommended
to the client. As these situations may present a conflict of interest, the advisor has established the
following restrictions in order to ensure its fiduciary responsibilities should this issue ever arise:
1. A director, officer or employee of the advisor shall not buy or sell a security for their
personal portfolio(s) where their decision is substantially derived, in whole or part, by
reason of his or her employment, unless the information is also available to the investing
public. No owner/employee of DFG shall prefer their own interest to that of the client.
2. The advisor maintains a list of all securities held by the company and all directors, officers,
and employees. These holdings are reviewed on a quarterly basis by the principal of the
firm.
3. The advisor requires that all employees must act in accordance with all applicable Federal
and State regulations governing registered investment advisors.
4. The advisor may block personal trades with those of clients but will ensure that clients are
not at a disadvantage.
DFG’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of
Ethics by contacting Terra Loew at (269) 321-7472.
Form ADV, Part 2A, Item 12
Brokerage Practices
In order for DFG to provide asset management services, we request you utilize the brokerage and
custodial services of Charles Schwab & Co., Inc. (“Schwab”), with which we have an existing
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relationship. DFG and Schwab are not affiliated companies. In considering which independent
qualified custodian will be the best fit for DFG’s business model, we are evaluating the
following factors, which is not an all-inclusive list:
Financial strength
Reputation
Reporting capabilities
Execution capabilities
Pricing, and
Types and quality of research
While you are free to choose any broker-dealer or other service provider, we recommend that
you establish an account with a brokerage firm with which we have an existing relationship.
Such relationships may include benefits provided to our firm, including, but not limited to
research, market information, and administrative services that help our firm manage your
account(s). We believe that recommended broker-dealers provide quality execution services for
our clients at competitive prices. Price is not the sole factor we consider in evaluating best
execution. We also consider the quality of the brokerage services provided by the recommended
broker-dealers, including the value of research provided, the firm’s reputation, execution
capabilities, commission rates, and responsiveness to our clients and our firm.
You may direct us in writing to use a particular broker-dealer to execute some or all of the
transactions for your account. If you do so, you are responsible for negotiating the terms and
arrangements for the account with that broker-dealer. We may not be able to negotiate
commissions, obtain volume discounts, or best execution. In addition, under these circumstances
a difference in commission charges may exist between the commissions charged to clients who
direct us to use a particular broker or dealer and other clients who do not direct us to use a
particular broker or dealer.
DFG does not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
DFG does not have any formal soft dollar arrangements.
When DFG buys or sells the same security for two or more clients (including our personal
accounts), we may place concurrent orders to be executed together as a single “block” in order to
facilitate orderly and efficient execution. Each client account will be charged or credited with
the average price per unit. We receive no additional compensation or remuneration of any kind
because we aggregate client transactions. No client is favored over any other client. If an order
is not completely filled, it is allocated pro-rata based on an allocation statement prepared by DFG
prior to placing the order. Because of an order’s aggregation, some clients may pay higher
transaction costs, or greater spreads, or receive less favorable net prices on transactions than
would otherwise be the case if the order had not been aggregated.
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Form ADV, Part 2A, Item 13
Review of Accounts
Client accounts are reviewed at least quarterly by Ryan Daus, Principal Executive Officer of the
firm. Ryan Daus reviews clients’ accounts with regards to their investment policies and risk
tolerance levels. All accounts at DFG are assigned to this reviewer.
All financial planning accounts are reviewed upon financial plan creation and plan delivery by
Ryan Daus, Principal Executive Officer of the firm. There is only one level of review and that is
the total review conducted to create the financial plan.
Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Each client will receive at least quarterly a written report that details the clients’ account which
may come from the custodian. Clients are encouraged to review these statements to verify
accuracy and calculation correctness. DFG may provide further reports from the cloud-based
portfolio management, trading, and CRM system they utilize.
Clients are provided a one-time financial plan concerning their financial situation. After the
presentation of the plan, there are no further reports. Clients may request additional plans or
reports for a fee.
Form ADV, Part 2A, Item 14
Client Referrals and Other Compensation
DFG does not compensate any individual or firm for client referrals. In addition, DFG does not
receive compensation for referring clients to other professional service providers.
Form ADV, Part 2A, Item 15
Custody
DFG does not have physical custody of any client funds and/or securities and does not take
custody of client accounts at any time. Client funds and securities will be held with a bank,
broker dealer, or other independent qualified custodian. However, by granting DFG written
authorization to automatically deduct fees from client accounts, DFG is deemed to have limited
custody. You will receive account statements from the independent, qualified custodian holding
your funds at least quarterly. The account statement from your custodian will indicate the
amount of advisory fees deducted from your account(s) each billing cycle. Clients should
carefully review statements received from the custodian.
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Standing Letters of Authorization
Some clients may execute limited powers of attorney or other standing letters of authorization
that permit the firm to transfer money from their account with the client’s independent qualified
Custodian to third-parties. This authorization to direct the Custodian may be deemed to cause our
firm to exercise limited custody over your funds or securities and for regulatory reporting
purposes, we are required to keep track of the number of clients and accounts for which we may
have this ability. We do not have physical custody of any of your funds and/or securities. Your
funds and securities will be held with a bank, broker-dealer, or other independent, qualified
custodian. You will receive account statements from the independent, qualified custodian(s)
holding your funds and securities at least quarterly. The account statements from your
custodian(s) will indicate any transfers that may have taken place within your account(s) each
billing period. You should carefully review account statements for accuracy
Form ADV, Part 2A, Item 16
Investment Discretion
Before DFG can buy or sell securities on your behalf, you must first sign our discretionary
management agreement, a limited power of attorney, and/or trading authorization forms. By
choosing to do so, you may grant the firm discretion over the selection and amount of securities
to be purchased or sold for your account(s) without obtaining your consent or approval prior to
each transaction. Clients may impose limitations on discretionary authority for investing in
certain securities or types of securities (such as a product type, specific companies, specific
sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary
authority are required to be provided to the IAR in writing. Please refer to the “Advisory
Business” section of this Brochure for more information on our discretionary management
services.
Retirement Plan Consulting Services / 401(k) Plan Advising
In the capacity of 401(k) plan advising, DFG will be exclusively operating as a 3(21) fiduciary as
that term is detailed in Section 3(21) of the Employee Retirement Income Security Act of 1974
(ERISA). With this arrangement, the Adviser’s fiduciary responsibility is tied to the plan and
not directed to the individual investors in the plan. In keeping with limitations built into a 3(21)
relationship, the adviser makes recommendations to the plan sponsor but lacks discretionary
authority to implement those recommendations.
Form ADV, Part 2A, Item 17
Voting Client Securities
We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you
advice regarding corporate actions and the exercise of your proxy voting rights. If you own
shares of common stock or mutual funds, you are responsible for exercising your right to vote as
a shareholder.
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In most cases, you will receive proxy materials directly from the account custodian. However, in
the event we were to receive any written or electronic proxy materials, we would forward them
directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in
which case, we would forward any electronic solicitation to vote proxies.
Form ADV, Part 2A, Item 18
Financial Information
DFG is not required to provide financial information to our clients because we do not require or
solicit the prepayment of more than $1,200 six or more months in advance.
Form ADV, Part 2A, Item 19
Requirements for State-Registered Advisers
This section is not applicable as DFG is SEC registered and not state registered.
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