DAVIDSON ADVISORY GROUP, LLC

Beacon Capital Advisory Group Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Beacon Capital Advisory Group. If you have any questions about the contents of this brochure, please contact us at (877) 801-2322 or by email at: drotatori@beaconcag.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Beacon Capital Advisory Group is also available on the SEC’s website at www.adviserinfo.sec.gov. Beacon Capital Advisory Group’s CRD number is: 333090. 2901 Coltsgate Rd Suite 102 Charlotte, NC 28211 (877) 801-2322 drotatori@beaconcag.com https://www.beaconcag.com/ Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 07/2025 i  Item 2: Material Changes Beacon Capital Advisory Group has the following material changes to report. Material changes relate to Beacon Capital Advisory Group’s policies, practices or conflicts of interest. • Beacon Capital Advisory Group has removed Standing Letters of Authorization (SLOAs) from Custody as we do not have the ability to transfer funds on clients’ behalf. (Item 15) • Beacon Capital Advisory Group has amended Item 4 to omit the IPS form and replaced it with the Suitability form to better align with firm practices. • Beacon Capital Advisory Group has updated Item 5 to include more details on refunds. • Beacon Capital Advisory Group has added Educational Workshops/Seminars to their services. (item 5) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................6 Item 7: Types of Clients ..........................................................................................................................................6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................7 Item 9: Disciplinary Information ...........................................................................................................................9 Item 10: Other Financial Industry Activities and Affiliations .........................................................................10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............11 Item 12: Brokerage Practices ................................................................................................................................12 Item 13: Review of Accounts ................................................................................................................................13 Item 14: Client Referrals and Other Compensation ..........................................................................................14 Item 15: Custody ....................................................................................................................................................15 Item 16: Investment Discretion ............................................................................................................................15 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................15 Item 18: Financial Information .............................................................................................................................16 iii  Item 4: Advisory Business A. Description of the Advisory Firm Davidson Advisory Group, LLC dba Beacon Capital Advisory Group (hereinafter “BCAG”) is a Limited Liability Company organized in the State of North Carolina. The firm was formed in October 2017 and became registered as an investment adviser in October 2024. The principal owners are David Rotatori and Christopher Zaccarelli. B. Types of Advisory Services Portfolio Management Services BCAG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. BCAG creates an investment strategy for each client tailored to their specific needs and situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal Suitability Form Asset selection Regular portfolio monitoring BCAG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. BCAG will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the suitability form. BCAG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of BCAG’s economic, investment or other financial interests. To meet its fiduciary obligations, BCAG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, BCAG’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is BCAG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Subadviser Services BCAG may act as a subadviser to advisers unaffiliated with BCAG. BCAG would provide outsourced investment research and portfolio management services to these unaffiliated advisers. This relationship will be memorialized in each contract between BCAG and the unaffiliated advisor. 2  Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Educational Seminars/Workshops BCAG provides educational seminars and workshops. BCAG does not charge a fee for any seminars or workshops. Services Limited to Specific Types of Investments BCAG generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs and commodities. BCAG may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. . We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions BCAG will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by BCAG on behalf of the client. BCAG may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain 3  securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent BCAG from properly servicing the client account, or if the restrictions would require BCAG to deviate from its standard suite of services, BCAG reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. BCAG does not participate in wrap fee programs. E. Assets Under Management BCAG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $151,717,271 $0 December 2024 BCAG also has approximately $693,526,929 in assets under advisement. Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees The total annual assets under management fee will not exceed 2.00%. The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of BCAG's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Subadviser Fees BCAG may also act as a subadviser to unaffiliated third-party advisers and BCAG would receive a share of the fees collected from the third-party adviser’s client. The fees charged are negotiable and will not exceed any limit imposed by any regulatory agency. This relationship will be memorialized in each contract between BCAG and the third-party adviser. 4  Financial Planning Fees Fixed Fees The negotiated fixed rate for creating client financial plans will not exceed $10,000. Clients may terminate the agreement without penalty, for full refund of BCAG’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Educational Seminars/Workshops BCAG provides periodic educational seminars and workshops to clients and prospects. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from client's accounts and are billed quarterly in advance and calculated based on the account's market value on the last day of the quarter. The initial advisory fee will be billed on a pro-rata basis for the initial quarter in addition to the standard quarterly fee for the upcoming quarter. Payment of Financial Planning Fees Financial planning fees are paid via check or AdvicePay. Fixed financial planning fees are paid 100% in advance, but never more than six months in advance. Payment of Educational Seminar/Workshop Fees Educational seminars and workshops are offered free of charge. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by BCAG. Please see Item 12 of this brochure regarding broker-dealer/custodian. 5  D. Prepayment of Fees BCAG collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days after quarter end to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. E. Outside Compensation For the Sale of Securities to Clients BCAG and its representatives in their outside business activities (see Item 10 below) are licensed to accept compensation for the sale of investment products to BCAG clients. This presents a conflict of interest and gives BCAG and the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receives compensation, BCAG will document the conflict of interest in the client file and inform the client of the conflict of interest. Clients always have the right to decide whether to purchase BCAG-recommended products and, if purchasing, have the right to purchase those products through other brokers or agents that are not affiliated with BCAG. Commissions are not BCAG’s primary source of compensation for advisory services. Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management BCAG does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients BCAG generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals 6  There is no account minimum for any of BCAG’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis BCAG’s methods of analysis include Fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Investment Strategies BCAG uses long term trading and short term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. 7  Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading 8  conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options writing or trading involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value and the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings 9  There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither BCAG nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither BCAG nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests BCAG is a licensed insurance entity, therefore licensed insurance representatives of BCAG will offer insurance products and receive commissions. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of BCAG are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. BCAG addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. BCAG periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. BCAG will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be ties between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by BCAG’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. 10  D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections BCAG does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics BCAG has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. BCAG's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests BCAG does not recommend that clients buy or sell any security in which a related person to BCAG or BCAG has a material financial interest. C. Investing Personal Money in the Same Securities as Clients Personal investment transactions require high standards and those transactions need to be carried out in a way that does not endanger the interest of any client. However, our firm also believes that if investment goals are similar for clients and employees then common ownership of some securities is in the best interests of both parties. In order to prevent conflicts of interest, our firm has established procedures for transactions in the personal accounts of our representatives. In order to monitor compliance with our personal trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting system for all of our representatives. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests in accordance with our firm's Code of Ethics. 11  D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of BCAG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of BCAG to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, BCAG will never engage in trading that operates to the client’s disadvantage if representatives of BCAG buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on BCAG’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and BCAG may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in BCAG's research efforts. BCAG will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. BCAG will require clients to use Fidelity Brokerage Services LLC or Charles Schwab & Co., Inc. Advisor Services. 1. Research and Other Soft-Dollar Benefits BCAG does not receive products or services other than execution (“soft dollar benefits”) from a broker-dealer or third-party for generating commissions, but does receive additional economic benefits described in Item 14 2. Brokerage for Client Referrals BCAG receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use BCAG will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. 12  B. Aggregating (Block) Trading for Multiple Client Accounts If BCAG buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, BCAG would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. BCAG would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution. Any transactions where employees or related persons of our firm buy or sell securities for themselves, at or about the same time that they buy or sell the same securities for client accounts, will be done in a way that places our clients' interests ahead of their own. Related persons or employees will refrain from transacting in the same securities that will be bought or sold in client accounts until after the client execution, or ideally, concurrently as part of a block trade. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for BCAG's advisory services provided on an ongoing basis are reviewed at least annually by David Frank Rotatori, Financial Planner, with regard to clients’ respective investment goals and risk tolerance levels. All accounts at BCAG are assigned to this reviewer. The advisor will create, and present customized financial planning recommendations based on an analysis of the Client’s financial goals and objectives. This assessment may include topics ranging from: Retirement, Education, Estate, Cashflow/Budget, Insurance (Life, Disability and Long Term Care), Asset Allocation. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts 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). With respect to financial plans, BCAG’s services will generally conclude upon delivery of the financial plan. 13  C. Content and Frequency of Regular Reports Provided to Clients Each client of BCAG's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. The Client may receive a written financial plan covering the areas selected for review. Assessments may be presented via an online financial planning tool to which BCAG will provide client access. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Our firm may receive from Fidelity, Schwab or mutual fund companies, without cost and/or at a discount non soft-dollar support services and/or products, to assist us to better monitor and service client accounts maintained at such institutions. Included within the support services our firm may receive investment-related research, pricing information and market data, software and other technology that provides access to client account data, compliance and/or practice management-related publications, discounted or free consulting services, discounted and/or free attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by us to assist us in our investment advisory business operations. Our clients do not pay more for investment transactions effected and/or assets maintained at Fidelity as a result of this arrangement. There is no commitment made by us to Fidelity or any other institution because of the above arrangement. Our firm occasionally sponsors events in conjunction with our product providers to keep our clients informed as to the services we offer and the various financial products we utilize. These events are educational in nature and are not dependent upon the use of any specific product. While a conflict of interest may exist because these events are at least partially funded by product sponsors, all funds received from product sponsors are used for the education of our clients. We will always adhere to our fiduciary duty in recommending appropriate investments for our clients. Representatives of our firm will occasionally accept travel expense reimbursement provided by product sponsors to attend their educational events. The reimbursement is not directly dependent upon the recommendation of any specific product. Although we 14  may be incentivized to recommend products from product sponsors that reimburse our travel, our representatives will always adhere to their fiduciary duty in recommending appropriate investments for our clients. B. Compensation to Non – Advisory Personnel for Client Referrals BCAG does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, BCAG will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion BCAG provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, BCAG generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, BCAG’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to BCAG. Item 17: Voting Client Securities (Proxy Voting) Clients may email, call or write us to discuss questions they may have about proxy votes or other solicitations, and we will also encourage them to seek additional information directly from the issuer of the security. All decisions that clients make in these situations are their own as we do not accept proxy authority to vote their securities. 15  Item 18: Financial Information A. Balance Sheet BCAG neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither BCAG nor its management has any financial condition that is likely to reasonably impair BCAG’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years BCAG has never been the subject of a bankruptcy proceeding. 16