DE GROOTE FINANCIAL GROUP, LLC

Item 1: Cover Page Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure October 2025 De Groote Financial Wrap Fee Program Sponsored By De Groote Financial Group, LLC a Registered Investment Adviser 3013 Willow Lane Thousand Oaks, CA 91361 (805) 230-0111 www.degrootefinancial.com Firm Contact: Fadi Ahmed Chief Compliance Officer This brochure provides information about the qualifications and business practices of De Groote Financial Group, LLC. If you have any questions about the contents of this brochure, please contact Douglas C. De Groote at (805) 230-0111. 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 De Groote Financial Group, LLC is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD# 168178. De Groote Financial Group, LLC is an SEC registered investment adviser. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes De Groote Financial is required to make clients aware of information that has changed since the last annual update to the Wrap Brochure (“Wrap Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. The have been no material changes since our last annual amendment filing on February 29, 2024. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 2 De Groote Financial  Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................................... 1 Item 2: Material Changes ........................................................................................................................................................ 2 Item 3: Table of Contents ....................................................................................................................................................... 3 Item 4: Services, Fees & Compensation ............................................................................................................................ 4 Item 5: Account Requirements & Types of Clients ....................................................................................................... 7 Item 6: Portfolio Manager Selection & Evaluation ........................................................................................................ 7 Item 7: Client Information Provided to Portfolio Manager(s) ............................................................................... 12 Item 8: Client Contact with Portfolio Manager(s) ...................................................................................................... 12 Item 9: Additional Information ......................................................................................................................................... 13 ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 3 De Groote Financial  Item 4: Services, Fees & Compensation The De Groote Financial Wrap Fee Program (the “Program”) is an investment advisory program sponsored by De Groote Financial, a registered investment adviser which has been in business since August of 2013. This Wrap Fee Brochure describes the business of De Groote Financial as it relates to clients receiving services through the Program. Certain sections also describe the activities of the Firm’s Supervised Persons, which refer to any officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or other persons who provide investment advice on De Groote Financial’s behalf and are subject to the Firm’s supervision. In addition to the Program, the Firm also provides financial planning, consulting, and investment management services under different arrangements than those described in this brochure. Information about these services is contained in De Groote Financial’s Disclosure Brochure. Description of the Program: The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement under which clients receive investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of their transactions for a specified fee. Prior to engaging De Groote Financial to provide services through the Program, the client is required to enter into a written agreement with De Groote Financial setting forth the terms and conditions under which De Groote Financial renders its services (the “Agreement”). Clients must also open a new securities brokerage account and complete a new account agreement with Charles Schwab & Co., Inc. (“Schwab”), or National Financial Services, LLC and Fidelity Brokerage Services, LLC (“Fidelity”) or another broker-dealer De Groote Financial approves under the Program (collectively “Financial Institutions”). At the onset of the Program, clients complete an investor profile describing their individual investment objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors pertinent to their specific financial situations. After an analysis of the relevant information, De Groote Financial assists its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are generally managed on a discretionary basis by either De Groote Financial’s investment adviser representatives or an independent investment manager (collectively “Independent Managers”), as recommended or selected by De Groote Financial. De Groote Financial and/or the Independent Managers generally allocate clients’ assets among the various investment products available under the Program, as described further in Item 6 (below). Fees for Participation in the Program: Investment management services are offered through the Program on a fee basis, meaning that clients pay a single annualized fee based upon assets under management. The Firm also offers advisory services outside of the Program under different fee arrangements than those discussed below. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 4 De Groote Financial  De Groote Financial provides investment management services for an annual fee based on the amount of assets under the Firm’s management or for a flat fee. The specific billing arrangement and payment frequency will be disclosed in the signed Agreement. Flat fees will not exceed $500,000. The annual fee generally varies between 85 and 150 basis points (0.85% – 1.50%) in accordance with the following blended fee schedule: Assets Under Management Up to $4999,999 $500,000 to $999,999 $1,000,000 - $2,000,000 Over $2,000,000 Annual Percentage of Assets Charge 1.50% 1.25% 1.00% 0.85% Clients participating in the Firm’s Core Conservative, Core Balanced, and Core Growth portfolios are generally charged 25 basis points (0.25%) in addition to the blended fee schedule above. For all assets, the annual fee is prorated and charged quarterly in advance, based upon the market value of the assets being managed by De Groote Financial on the last day of the previous billing period. Alternative investments are also charged in accordance with the blended fee schedule above. De Groote Financial bills on cash unless indicated otherwise in writing. If assets in excess of $10,000 are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is prorated to account for the change in portfolio value. For the initial term of the Program, the fee is calculated on a pro rata basis. In the event the Agreement is terminated, the fee for the final quarter is prorated through the effective date of the termination and the remaining balance is refunded to the client, as appropriate. As discussed above, De Groote Financial uses Dynasty’s TAMP services. TAMP related charges are not included in the investment management fee you pay to De Groote Financial. You will be charged, separate from and in addition to your investment management fee, any applicable Platform Fees as well as applicable independent manager fees. De Groote Financial does not receive any portion of the fees paid directly to the service providers made available through Dynasty’s platform, including the independent managers. Each of the Platform Fee and independent manager fees are determined by the particular program(s) and manager(s) with which your assets are invested and are calculated based upon a percentage of your assets under management, as applicable. The Platform Fee generally ranges from 0 - .45% annually, independent fixed income manager fees generally range from 0 - .90% annually, and independent equity manager fees generally range from 0 – 1.50% annually. The specific fees charged by each party will be detailed in the signed Agreement or other written disclosure. You will note the total fee reflected on your custodial statement will represent the sum of De Groote Financial’s investment management fee, Platform Fee(s) and independent manager fee(s), accordingly. You should review such statements to determine the total amount of fees associated with your requisite investments, and you should review your investment management agreement with De Groote Financial to determine the investment management fee you pay to us. Fee Comparison: A portion of the fees paid to De Groote Financial are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. Services provided through the Program may cost clients more or less than purchasing these services ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 De Groote Financial  separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Since De Groote Financial will pay the transaction/executions costs associated with equities transactions, there is a conflict of interest because the Firm has a disincentive to trade securities. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds. Since we pay the transaction fees charged by the custodian to clients participating in our wrap fee program, this presents a conflict of interest because we are incentivized to recommend equities and exchange traded funds over other types of securities in order to reduce our costs. Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. This presents a conflict of interest because we are incentivized to recommend U.S. listed equities and exchange traded funds over other types of securities in order to reduce our costs for qualifying clients. Fee Discretion: De Groote Financial, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention and pro bono activities. Fee Debit: The Firm’s Agreement and the separate agreement with any Financial Institutions generally authorize De Groote Financial and/or the Independent Managers to debit its clients’ accounts for the amount of the Program fee and to directly remit that fee to De Groote Financial or the Independent Managers. Any Financial Institutions recommended by De Groote Financial have agreed to send statements to clients not less than quarterly indicating all amounts disbursed from the account, including the amount of Program fees paid directly to De Groote Financial. Alternatively, clients may elect to have De Groote Financial send them an invoice for payment. Account Additions and Withdrawals: Clients may make additions to and withdrawals from their account at any time, subject to De Groote Financial’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to De Groote Financial, subject to the usual and customary securities settlement procedures. However, De Groote Financial designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. De Groote Financial may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 De Groote Financial  Other Charges: Clients may incur certain charges imposed by third parties in addition to the Program fee. These additional charges may include fees charged by the Independent Managers, charges imposed directly by a mutual fund or exchange-traded fund (“ETF”) in the account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Compensation for Recommending the Program: De Groote Financial has no internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation as a result of clients’ participation. Item 5: Account Requirements & Types of Clients Types of Clients: Services through the Program are offered to individuals, investment companies, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and business entities. No Minimum Account Requirements: De Groote Financial does not impose a stated minimum fee or minimum portfolio value for participation in the Program. Certain Independent Managers may, however, impose more restrictive account requirements and varying billing practices than De Groote Financial. In these instances, De Groote Financial may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 6: Portfolio Manager Selection & Evaluation De Groote Financial acts as the sponsor and sole portfolio manager under the Program. Clients’ investment portfolios are managed either directly by De Groote Financial or through the use of certain Independent Managers, as referenced above. Portfolio Management: De Groote Financial manages its clients’ investment portfolios on a discretionary basis. For accounts managed through the Program, De Groote Financial primarily allocates assets among various Independent Managers, mutual funds, ETFs, bonds, and individual debt and equity securities in accordance with the investment objectives of its individual clients. In addition, De Groote Financial may also recommend that clients who qualify as accredited investors, as defined under Rule 501 of the Securities Act of 1933, invest in private placement securities, which may include debt, equity and/or pooled investment vehicles (e.g., hedge funds). The Firm also provides advice about any type of legacy position or investment otherwise held in its clients’ portfolios. De Groote Financial tailors its advisory services to accommodate the needs of its individual clients and continuously seeks to ensure that its clients’ portfolios are managed in a manner consistent with ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 De Groote Financial  their specific investment profiles. Clients are advised to promptly notify De Groote Financial if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if De Groote Financial determines, in its sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to the Firm’s management efforts. De Groote Financial manages investment portfolios through the Program in substantially the same manner as those it manages outside of the Program. In return for these services, De Groote Financial receives a portion of the fees paid for participation in the Program, as described in Item 4. Selection of Independent Managers: De Groote Financial evaluates various information about the Independent Managers in which it selects to manage client portfolios under the Program. The Firm generally reviews a variety of different resources, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves, and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposures. De Groote Financial also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other related factors. De Groote Financial generally monitors the performance of those accounts being managed by Independent Managers by reviewing the account statements and trade confirmations produced by the Financial Institutions, as well as other performance information furnished by the Independent Managers and/or other third-party providers. The Firm does not verify the accuracy of any such performance information and does not ensure its compliance with presentation standards. Clients are advised that any performance information they receive from the Independent Managers may not be calculated on a uniform and consistent basis. Clients should compare all supplemental materials with the account statements they receive from their respective custodians. The terms and conditions under which the client engages an Independent Manager are set forth in a separate written agreement between De Groote Financial or the client and the designated Independent Manager. In addition to this Wrap Fee Brochure, the client also receives the disclosure brochure of the designated Independent Managers engaged to manage their assets. Turnkey Asset Management Program: De Groote Financial has entered into a contractual relationship with Dynasty Financial Partners, LLC (“Dynasty”), which provides De Groote Financial with operational and back office support including access to a network of service providers. Through the Dynasty network of service providers, De Groote Financial may receive preferred pricing on trading technology, reporting, custody, brokerage, compliance and other related services. Dynasty charges a “Platform Fee,” for which, unless otherwise disclosed, the client will be charged, separate from and in addition to such client’s annual investment management fee, as described in Item 4 above. In addition, Dynasty’s subsidiary, Dynasty Wealth Management, LLC (“DWM”) is an SEC registered investment adviser, that provides access to a range of investment services including: separately managed accounts (“SMA”), mutual fund and ETF asset allocation strategies, and unified managed accounts (“UMA”) managed by external third party managers (collectively, the “Investment Programs”). De Groote Financial and its clients may ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 8 De Groote Financial  separately engage the services of Dynasty and/or its subsidiaries to access the Investment Programs. Under the SMA and UMA programs, De Groote Financial will maintain the ability to select the specific, underlying third party managers that will, in turn, have day-to-day discretionary trading authority over the requisite client assets. DWM sponsors an investment management platform (the “Platform” or the “TAMP") that is available to the advisers in the Dynasty Network, such as De Groote Financial. Through the Platform, DWM and Dynasty collectively provide certain technology, administrative, operations and advisory support services that allow advisers to manage their own portfolios and access independent third-party managers that provide discretionary services in the form of traditional managed accounts and investment models. Advisers can allocate all or a portion of client assets among the different independent third-party managers via the Platform. Advisers may also use the model management feature of the TAMP by creating their own asset allocation model and underlying investments that comprise the model. Through the model management feature, advisers may be able to outsource the implementation of trade orders and periodic rebalancing of the model when needed. De Groote Financial will maintain the direct contractual relationship with each client and obtain, through such agreements, the authority to engage independent third-party managers, DWM and/or Dynasty, as applicable, for services rendered through the Platform in service of such client. De Groote Financial may delegate discretionary trading authority to DWM and/or independent third-party managers to effect investment and reinvestment of client assets with the ability to buy, sell or otherwise effect investment transactions and allocate client assets. If a client is participating in certain Investment Programs, DWM or the designated manager, as applicable, is also authorized without prior consultation of De Groote Financial or the client to buy, sell, trade or allocate such client’s assets in accordance with the client’s designated portfolio and to deliver instructions to the designated broker-dealer and/or custodian of such client’s assets. Additionally, De Groote Financial uses DWM’s customized portfolio solutions, which are offered to investment advisers through its Outsourced Chief Investment Officer Program (the “OCIO Program”). Through the OCIO Program, DWM provides discretionary investment management services through its Investment Committee, in concert with research furnished by Callan Associates and iCapital Securities, LLC. Portfolios are constructed, implemented and monitored through an institutional due diligence program that functions at the sub-manager and product level. Methods of Analysis: De Groote Financial generally utilizes a combination of fundamental and technical methods of analysis. Fundamental analysis involves an evaluation of an issuer’s fundamental financial condition and competitive position. De Groote Financial generally analyzes the financial condition, capabilities of management, earnings capacity, new products and services, as well as the company’s markets and position amongst its industry competitors in order to determine the recommendations made to clients. A substantial risk in relying upon fundamental analysis is that while the overall health and position of a company may be good, market conditions may negatively impact the security. Technical analysis involves the examination of past market data rather than specific company information in determining the recommendations made to clients. Technical analysis may involve the use of mathematical based indicators and charts, such as moving averages and price correlations, to identify market patterns and trends which may be based on investor sentiment rather than the ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 9 De Groote Financial  fundamentals of the company. A substantial risk in relying upon technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that De Groote Financial will be able to accurately predict such a reoccurrence. Investment Strategies: De Groote Financial Group focuses its portfolio investments primarily in ETFs, but it will also utilize a variety of other traditional bonds and equities to further diversify the Firm’s managed portfolios. The firm will also utilize separate account managers, and occasionally invest in private placement funds, REITs and MLPs. Risks of Loss: General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear potential losses. Market Risks The profitability of a significant portion of De Groote Financial’s recommendations may depend to a great extent upon correctly assessing the future course of price movements of stocks and bonds. There can be no assurance that De Groote Financial will be able to predict those price movements accurately. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 10 De Groote Financial  Use of Independent Managers: De Groote Financial may recommend the use of Independent Managers. In these situations, De Groote Financial continues to do ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, De Groote Financial generally may not have the ability to supervise the Independent Managers on a day-to-day basis. Use of Private Collective Investment Vehicles: De Groote Financial recommends that certain clients invest in privately placed collective investment vehicles (e.g., hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments which may be traded and no requirement to diversify. Hedge funds may trade on margin or otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not registered as investment companies, there is an absence of regulation. There are numerous other risks in investing in these securities. Clients should consult each fund’s private placement memorandum and other offering documents explaining such risks prior to investing. Master Limited Partnerships (MLPs) Master Limited Partnerships (“MLPs”) are collective investment vehicles, the partnership interests of which are publicly traded on national securities exchanges. MLPs invest primarily in companies within the energy sector that engage in qualifying lines of business, such as natural resource production and mineral refinement. MLPs are therefore subject to the underlying volatility of the energy industry and may be adversely affected by changes to supply and demand, regional instability, currency spreads, inflation and interest rate fluctuations, among other such factors. In addition, MLPs operate as pass-through tax entities, meaning that investors are liable for their pro rata share of the partnership taxes, regardless of the types of accounts where the interests are held. Real Estate Investment Trusts (REITs) De Groote Financial may recommend an investment in, or allocate assets among, various real estate investment trusts (“REITs”), the shares of which exist in the form of either publicly traded or privately placed securities. REITs are collective investment vehicles with portfolios comprised primarily of real estate and mortgage related holdings. Many REITs hold heavy concentrations of investments tied to commercial and/or residential developments, which inherently subject REIT investors to the risks associated with a downturn in the real estate market. Investments linked to certain regions that experience greater volatility in the local real estate market may give rise to large fluctuations in the value of the vehicle’s shares. Mortgage related holdings may give rise to additional concerns pertaining to interest rates, inflation, liquidity and counterparty risk. Management Through Similarly Managed “Model” Accounts: De Groote Financial manages certain accounts through the use of similarly managed “model” portfolios, whereby the Firm allocates all or a portion of its clients’ assets among various mutual funds and/or securities on a discretionary basis using one or more of its proprietary investment strategies. In managing assets through the use of models, the Firm remains in compliance with the safe harbor provisions of Rule 3a-4 of the Investment Company Act of 1940. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 11 De Groote Financial  The strategy used to manage a model portfolio may involve an above average portfolio turnover that could negatively impact clients’ net after tax gains. While the Firm seeks to ensure that clients’ assets are managed in a manner consistent with their individual financial situations and investment objectives, securities transactions effected pursuant to a model investment strategy are usually done without regard to a client’s individual tax ramifications. Clients should contact De Groote Financial if they experience a change in their financial situation or if they want to impose reasonable restrictions on the management of their accounts. Performance‐Based Fees and Side‐By‐Side Management: De Groote Financial does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Voting of Client Securities: Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Independent Managers selected or recommended by our firm may vote proxies for clients. Except in the event an Independent Manager votes proxies, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Therefore (except for proxies that may be voted by an Independent Manager), our firm and/or the client shall instruct the qualified custodian to forward copies of all proxies and shareholder communications relating to the client’s investment assets. Item 7: Client Information Provided to Portfolio Manager(s) Clients participating in the Program generally grant De Groote Financial the authority to discuss certain non-public information with the Independent Managers engaged to manage their accounts. Depending upon the specific arrangement, the Firm may be authorized to disclose various personal information including, without limitation: names, phone numbers, addresses, social security numbers, tax identification numbers and account numbers. De Groote Financial may also share certain information related to its clients’ financial positions and investment objectives in an effort to ensure that the Independent Managers’ investment decisions remain aligned with its clients’ best interests. This information is communicated on an initial and ongoing basis, or as otherwise necessary to the management of its clients’ portfolios. Item 8: Client Contact with Portfolio Manager(s) There are no restrictions on clients’ ability to contact and consult with De Groote Financial. Clients can generally contact the Independent Managers managing their portfolios through De Groote Financial by providing the Firm with written request and identification of the questions or issues to be discussed with the Independent Managers. After receiving the client’s written request, De Groote ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 12 De Groote Financial  Financial, at its sole discretion, may contact the Independent Managers for the client or arrange for the Independent Managers and the client to communicate directly. Item 9: Additional Information Disciplinary Information: De Groote Financial has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of management. Financial Industry Activities & Affiliations: Douglas C. De Groote is a licensed insurance agent/broker. He will not, however, be offering insurance products nor will he receive customary fees as a result of insurance sales. De Groote Financial maintains a business relationship with Dynasty Financial Partners, LLC (“Dynasty”). Dynasty offers operational and back office core service support including access to a network of service providers. Through the Dynasty network of service providers, De Groote Financial may receive preferred pricing on trading technology, transition support, reporting, custody, brokerage, compliance, and other related consulting services. While De Groote Financial believes this open architecture structure for operational services best serves the interests of its clients, this relationship presents certain conflicts of interest due to the fact that Dynasty is paid by De Groote Financial or its clients for the services referenced above. In light of the foregoing, De Groote Financial seeks at all times to ensure that any material conflicts are addressed on a fully-disclosed basis and handled in a manner that is aligned with its clients’ best interests. De Groote Financial receives a portion of the fees paid directly to Dynasty, its affiliates or the service providers made available through Dynasty’s platform. In addition, De Groote Financial reviews such relationships, including the service providers engaged through Dynasty, on a periodic basis in an effort to ensure clients are receiving competitive rates in relation to the quality and scope of the services provided. De Groote Financial has entered into an agreement with Dynasty Capital Strategies, LLC, a wholly- owned subsidiary of Dynasty and an affiliate of Dynasty Wealth Management, LLC, a registered investment adviser, to sell, via a note, an agreed percentage of the revenue generated by De Groote Financial and in return received equity in Dynasty Financial Partners, LLC. This relationship of being an investor in Dynasty presents certain conflicts of interest due to the fact DeGroote Financial has a financial incentive to see that Dynasty is successful and which could influence decision making in selecting their services. Such funds may be used for business transition expenses and other costs associated with launching operations and for business expansion. De Groote Financial is not obligated to enter into such a note in order to obtain other services from Dynasty, however, such notes are only made available for advisers who remain members of the Dynasty Network of registered investment advisers. The notes are subject to standard underwriting practices by Dynasty and are based on commercially reasonable terms. De Groote Financial used the proceeds of the note to acquire ownership interest in Dynasty. De Groote Financial’s ownership interest in Dynasty presents a conflict of interest because clients are providing revenue to Dynasty, which is an entity owned in part by De Groote Financial. As a result, De Groote Financial is incentivized to recommend Dynasty’s services over the services of Dynasty’s ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 13 De Groote Financial  competitors. De Groote Financial initially examined this conflict of interest and has determined that the recommendation of Dynasty is in the best interest of De Groote Financial’s clients and satisfies our fiduciary obligations based on the services provided by Dynasty. De Groote Financial will continue to assess whether Dynasty’s services remain in the best interest of De Groote Financial’s clients at least annually. Individuals of De Groote Financial have ownership interest in NSI, LLC, which is the sponsor and owner of the NSI ETF. As a result, individuals of the firm can receive pro-rata distributions from the profits generated by NSI ETF. This ownership creates a potential conflict of interest because individuals of the Firm have an economic incentive to recommend the NSI ETF to clients. To mitigate this conflict, the Firm employs an independent due diligence process to ensure that all investment recommendations, including those involving the NSI ETF, are made in the best interest of clients. De Groote Financial has entered into an agreement with Yrefy SLP4, LLC, a Delaware limited liability company. As a result, De Groote Financial receives an additional advisory fee from client enrollment in the Yrefy SLP4, LLC investment. This agreement creates a conflict of interest because De Groote Financial has an economic incentive to place clients into the Yrefy SLP4, LLC investments. To mitigate this conflict, the Firm employs a due diligence process to ensure that all investment recommendations, including Yrefy SLP4, LLC, are properly vetted as a suitable investment selection for our clients. Additionally, we mitigate this conflict by acting in the best interest of our clients. Code of Ethics: De Groote Financial and persons associated with De Groote Financial (“Associated Persons”) are permitted to buy or sell securities that it also recommends to clients consistent with De Groote Financial’s policies and procedures. De Groote Financial has adopted a code of ethics that sets forth the standards of conduct expected of its associated persons and requires compliance with applicable securities laws (“Code of Ethics”). De Groote Financial’s Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public information by De Groote Financial or any of its associated persons. The Code of Ethics also requires that certain of De Groote Financial’s personnel (called “Access Persons”) report their personal securities holdings and transactions and obtain pre-approval of certain investments such as initial public offerings and limited offerings. When De Groote Financial is engaging in or considering a transaction in any security on behalf of a client, no Access Person may effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household as the Access Person) a transaction in that security unless: • • the transaction has been completed; the transaction for the Access Person is completed as part of a batch trade (as defined in Item 12 of the Firm Brochure) with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 14 De Groote Financial  This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by Access Persons to be completed without any appreciable impact on the markets of such securities. Therefore, under certain limited circumstances, exceptions may be made to the policies stated above. Account Reviews: De Groote Financial monitors its clients’ investment portfolios on a continuous and ongoing basis, and conducts regular account reviews at least annually. Such reviews are conducted by one of the Firm’s investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with De Groote Financial and to keep De Groote Financial informed of any changes thereto. De Groote Financial contacts ongoing investment advisory clients at least annually to review its previous services and recommendations, and to discuss the impact resulting from any changes in their financial situation and/or investment objectives. Account Statements and General Reports: Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions. Clients in the Program also receive reports from De Groote Financial that may include relevant account and/or market-related information, such as an inventory of account holdings and account performance as clients may request from time to time. Clients should compare any supplemental reports they receive from De Groote Financial and/or the Independent Managers with the account statements they receive from the Financial Institutions. Client Referrals: In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, De Groote Financial provides cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Such compensation arrangements will not result in higher costs to the referred client. In this regard, De Groote Financial maintains a written agreement with each unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12- month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: • Whether or not the unaffiliated person is a current client of De Groote Financial, • A description of the cash or non-cash compensation provided directly or indirectly by De Groote Financial to the unaffiliated person in exchange for the referral, if applicable, and • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm’s relationship with such unaffiliated person. In cases where state law requires licensure of promoters, De Groote Financial ensures that no referral fees are paid unless the promoter is registered as an investment adviser representative of our firm. If our firm is paying referral fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. Receipt of Economic Benefit: De Groote Financial has arrangements in place whereby the Firm receives an economic benefit from a third-party for providing investment advice to clients participating in the Program. Specifically, Schwab or Fidelity may provide the Firm with computer software and related systems support, which allow De Groote Financial to better monitor client accounts maintained at Schwab or Fidelity. De ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 15 De Groote Financial  Groote Financial may receive the software and related support without cost because De Groote Financial renders investment management services to clients that maintain assets at Schwab or Fidelity. The software and related systems support may benefit De Groote Financial, but not its clients directly. In fulfilling its duties to its clients, De Groote Financial endeavors at all times to put the interests of its clients first. Clients should be aware, however, that De Groote Financial’s receipt of economic benefits from a broker-dealer creates a conflict of interest since these benefits may influence De Groote Financial’s choice of broker-dealer over another that does not furnish similar software, systems support, or services. Clients and prospective clients should review Item 10 of the Firm Brochure for information about parties De Groote Financial may refer clients to and additional compensation De Groote Financial may receive from these parties. Financial Information: De Groote Financial is not required to disclose any financial information pursuant to this Item due to the following: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 16 De Groote Financial 

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure October 2025 De Groote Financial Group, LLC a Registered Investment Adviser 3013 Willow Lane Thousand Oaks, CA 91361 (805) 230-0111 www.degrootefinancial.com Firm Contact: Fadi Ahmed Chief Compliance Officer This brochure provides information about the qualifications and business practices of De Groote Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at (805) 230-0111 or fadi@degrootefinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about our firm is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD# 168178. De Groote Financial is an SEC registered investment adviser. Registration does not imply any level of skill or training. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes De Groote Financial is required to discuss any material changes that have been made to the brochure since the last annual amendment. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. There have been no material changes since our last annual amendment filing on February 29, 2024. ADV Part 2A – Firm Brochure Page 2 De Groote Financial Group  Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................................... 1 Item 2: Material Changes ........................................................................................................................................................ 2 Item 3: Table of Contents ....................................................................................................................................................... 3 Item 4: Advisory Business ...................................................................................................................................................... 4 Item 5: Fees & Compensation ............................................................................................................................................... 8 Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 11 Item 7: Types of Clients & Account Requirements .................................................................................................... 11 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .................................................................... 11 Item 9: Disciplinary Information ...................................................................................................................................... 14 Item 10: Other Financial Industry Activities & Affiliations .................................................................................... 14 Item 11: Code of Ethics, Participation or Interest in ................................................................................................. 15 Client Transactions & Personal Trading ........................................................................................................................ 15 Item 12: Brokerage Practices ............................................................................................................................................. 15 Item 13: Review of Accounts or Financial Plans ......................................................................................................... 17 Item 14: Client Referrals & Other Compensation ....................................................................................................... 18 Item 15: Custody..................................................................................................................................................................... 19 Item 16: Investment Discretion ........................................................................................................................................ 20 Item 17: Voting Client Securities ...................................................................................................................................... 20 Item 18: Financial Information ......................................................................................................................................... 20 ADV Part 2A – Firm Brochure Page 3 De Groote Financial Group  Item 4: Advisory Business De Groote Financial offers a variety of advisory services, which include financial planning and investment management services. Prior to the rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with De Groote Financial setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). De Groote Financial began conducting business as an investment adviser in August 2013, and is owned by its Managing Member, Douglas C. De Groote. As of December 31st, 2024, De Groote Financial had $750,623,008 in assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of De Groote Financial, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on De Groote Financial’s behalf and is subject to the Firm’s supervision or control. Types of Advisory Services Offered Investment Management and Wealth Management Services: De Groote Financial provides clients with wealth management services, which include discretionary management of investment portfolios and a broad range of comprehensive financial planning services. De Groote Financial primarily allocates client assets among various independent investment managers (“Independent Managers”), mutual funds, exchange-traded funds (“ETFs”), bonds, individual debt and equity securities in accordance with the investment objectives of its individual clients. De Groote Financial also allocates client assets in similarly managed “model” portfolios, whereby the Firm allocates all or a portion of its clients’ assets among various investments, including fixed income securities, equities, and cash, on a discretionary basis using one or more its proprietary investment strategies. These portfolios include the following: • The Core Conservative Portfolio – In this portfolio, client assets are primarily invested in fixed income securities across all markets and sectors and cash (approximately seventy percent). A portion of client assets are also invested in equities across all sectors and markets, depending on the global economy (approximately thirty percent). • The Core Balanced Portfolio – In this portfolio, client assets are invested in fixed income securities across all markets and sectors and cash (approximately fifty percent) and equities across all sectors and markets, depending on the global economy (approximately fifty percent). • The Core Growth Portfolio – In this portfolio, client assets are primarily invested in equities across all sectors and markets, depending on the global economy (approximately ninety- seven percent). The portfolio will maintain approximately three percent in cash. The above-described portfolios are rebalanced quarterly. ADV Part 2A – Firm Brochure Page 4 De Groote Financial Group  In addition, De Groote Financial may also recommend that clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may also engage De Groote Financial to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, De Groote Financial directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. De Groote Financial tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. De Groote Financial consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify De Groote Financial if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if De Groote Financial determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers: As mentioned above, De Groote Financial may select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement between the designated Independent Manager and either De Groote Financial or the client. De Groote Financial does not receive compensation from any such Independent Managers. De Groote Financial evaluates various information about the Independent Managers it chooses to manage client portfolios, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. De Groote Financial also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. De Groote Financial continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. De Groote Financial seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. ADV Part 2A – Firm Brochure Page 5 De Groote Financial Group  Turnkey Asset Management Program: De Groote Financial has entered into a contractual relationship with Dynasty Financial Partners, LLC (“Dynasty”), which provides De Groote Financial with operational and back office support including access to a network of service providers. Through the Dynasty network of service providers, De Groote Financial may receive preferred pricing on trading technology, reporting, custody, brokerage, compliance and other related services. Dynasty charges a “Platform Fee,” for which, unless otherwise disclosed, the client will be charged, separate from and in addition to such client’s annual investment management fee, as described in Item 5 below. In addition, Dynasty’s subsidiary, Dynasty Wealth Management, LLC (“DWM”) is an SEC registered investment adviser, that provides access to a range of investment services including: separately managed accounts (“SMA”), mutual fund and ETF asset allocation strategies, and unified managed accounts (“UMA”) managed by external third party managers (collectively, the “Investment Programs”). De Groote Financial and its clients may separately engage the services of Dynasty and/or its subsidiaries to access the Investment Programs. Under the SMA and UMA programs, De Groote Financial will maintain the ability to select the specific, underlying third party managers that will, in turn, have day-to-day discretionary trading authority over the requisite client assets. DWM sponsors an investment management platform (the “Platform” or the “TAMP") that is available to the advisers in the Dynasty Network, such as De Groote Financial. Through the Platform, DWM and Dynasty collectively provide certain technology, administrative, operations and advisory support services that allow advisers to manage their own portfolios and access independent third-party managers that provide discretionary services in the form of traditional managed accounts and investment models. Advisers can allocate all or a portion of client assets among the different independent third-party managers via the Platform. Advisers may also use the model management feature of the TAMP by creating their own asset allocation model and underlying investments that comprise the model. Through the model management feature, advisers may be able to outsource the implementation of trade orders and periodic rebalancing of the model when needed. De Groote Financial will maintain the direct contractual relationship with each client and obtain, through such agreements, the authority to engage independent third-party managers, DWM and/or Dynasty, as applicable, for services rendered through the Platform in service of such client. De Groote Financial may delegate discretionary trading authority to DWM and/or independent third-party managers to effect investment and reinvestment of client assets with the ability to buy, sell or otherwise effect investment transactions and allocate client assets. If a client is participating in certain Investment Programs, DWM or the designated manager, as applicable, is also authorized without prior consultation of De Groote Financial or the client to buy, sell, trade or allocate such client’s assets in accordance with the client’s designated portfolio and to deliver instructions to the designated broker-dealer and/or custodian of such client’s assets. Additionally, De Groote Financial uses DWM’s customized portfolio solutions, which are offered to investment advisers through its Outsourced Chief Investment Officer Program (the “OCIO Program”). Through the OCIO Program, DWM provides discretionary investment management services through its Investment Committee, in concert with research furnished by Callan Associates and iCapital Securities, LLC. Portfolios are constructed, implemented and monitored through an institutional due diligence program that functions at the sub-manager and product level. ADV Part 2A – Firm Brochure Page 6 De Groote Financial Group  Financial Planning Services: De Groote Financial offers clients a range of financial planning and consulting services, which may include any or all of the following functions: Investment Consulting Insurance Needs Analysis • Business Planning • Cash Flow Forecasting • Asset Allocation • Retirement Planning • Estate Planning • • • Risk Management While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (as described below). In performing these services, De Groote Financial is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. De Groote Financial may recommend the services of itself, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage De Groote Financial to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by De Groote Financial under a financial planning engagement or to engage the services of any such recommended professionals, including De Groote Financial itself. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising De Groote Financial’s previous recommendations and/or services. Retirement Plan Consulting: De Groote Financial provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include: • Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. • • Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk. Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. • Participant Education – Our firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other ADV Part 2A – Firm Brochure Page 7 De Groote Financial Group  illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Participation in Wrap Fee Programs: De Groote Financial is the sponsor and manager of the De Groote Financial Wrap Fee Program (the “Program”), a wrap fee program (i.e., an arrangement where brokerage commissions and transaction costs are absorbed by the firm). De Groote Financial’s investment management services are only offered through the Program. Participants in the Program may pay a higher aggregate fee than if investment management and brokerage services are purchased separately. Additional information about the Program is available in De Groote Financial’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV. Item 5: Fees & Compensation De Groote Financial offers its services on a fee basis, which may include fixed fees and hourly fees, as well as fees based upon assets under management or advisement. Compensation for Our Advisory Services Investment Management and Wealth Management Fees: De Groote Financial provides investment management services for an annual fee based on the amount of assets under the Firm’s management or for a flat fee. The specific billing arrangement and payment frequency will be disclosed in the signed Agreement. Flat fees will not exceed $500,000. The annual fee generally varies between 85 and 150 basis points (0.85% – 1.50%) in accordance with the following blended fee schedule: Assets Under Management Up to $499,999 $500,000 to $999,999 $1,000,000 - $2,000,000 Over $2,000,000 Annual Percentage of Assets Charge 1.50% 1.25% 1.00% 0.85% Clients participating in the Firm’s Core Conservative, Core Balanced, and Core Growth portfolios are generally charged 25 basis points (0.25%) in addition to the blended fee schedule above. For all assets, the annual fee is prorated and charged quarterly in advance, based upon the market value of the assets being managed by De Groote Financial on the last day of the previous billing period. Alternative investments are also charged in accordance with the blended fee schedule above. De Groote Financial bills on cash unless indicated otherwise in writing. If assets in excess of $10,000 of the existing portfolio value are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted ADV Part 2A – Firm Brochure Page 8 De Groote Financial Group  to reflect the change in portfolio value. For the initial term of an engagement, the fee is calculated on a pro rata basis. In the event the Agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the unearned portion is refunded to the client, as appropriate. As discussed in Item 4, De Groote Financial uses Dynasty’s TAMP services. TAMP related charges are not included in the investment management fee you pay to De Groote Financial. You will be charged, separate from and in addition to your investment management fee, any applicable Platform Fees as well as applicable independent manager fees. De Groote Financial does not receive any portion of the fees paid directly to the service providers made available through Dynasty’s platform, including the independent managers. Each of the Platform Fee and independent manager fees are determined by the particular program(s) and manager(s) with which your assets are invested, and are calculated based upon a percentage of your assets under management, as applicable. The Platform Fee generally ranges from 0 - .45% annually, independent fixed income manager fees generally range from 0 - .90% annually, and independent equity manager fees generally range from 0 – 1.50% annually. The specific fees charged by each party will be detailed in the signed Agreement or other written disclosure. You will note the total fee reflected on your custodial statement will represent the sum of De Groote Financial’s investment management fee, Platform Fee(s) and independent manager fee(s), accordingly. You should review such statements to determine the total amount of fees associated with your requisite investments, and you should review your investment management agreement with De Groote Financial to determine the investment management fee you pay to us. Fee Debit: Clients generally provide De Groote Financial with the authority to directly debit their accounts for payment of the Firm’s investment advisory fees. The Financial Institutions that act as qualified custodian for client accounts have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to De Groote Financial. Alternatively, clients may elect to have De Groote Financial send them an invoice for direct payment. Fee Discretion: De Groote Financial, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention and pro bono activities. Account Additions and Withdrawals: Clients may make additions to and withdrawals from their account at any time, subject to De Groote Financial’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to De Groote Financial, subject to the usual and customary securities settlement procedures. However, De Groote Financial designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. De Groote Financial may consult with its clients about the options and implications of transferring securities. Clients are advised that when ADV Part 2A – Firm Brochure Page 9 De Groote Financial Group  transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Financial Planning Fees: De Groote Financial generally charges a negotiable flat fee or hourly fee to provide clients with stand- alone financial planning services. These fees are largely determined by the scope and complexity of the agreed upon services. Flat fees will not exceed $25,000. Hourly fees will not exceed $1,000. The specific terms and fee structure are negotiated in advance and set forth in the Agreement with De Groote Financial. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within six months. If the client engages De Groote Financial for additional investment advisory services, De Groote Financial may offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. In the event the Agreement is terminated, the client will receive a pro-rata refund of unearned fees based on the time and effort expended by our firm. Retirement Plan Consulting: For Retirement Plan Consulting services, De Groote Financial charges a fee based on the percentage of Plan assets under management. Fees based on a percentage of managed Plan assets will not exceed 1.00%. The fee-paying arrangement will be detailed in the signed consulting agreement. Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written notice to the other party. Full refunds will only be made in cases where cancellation occurs within 5 business days of signing an agreement. After 5 business days from initial signing, either party must provide the other party 30 days written notice to terminate billing. Billing will terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work completed by our firm on behalf of the client. Clients will incur charges for bona fide advisory services rendered up to the point of termination (determined as 30 days from receipt of said written notice) and such fees will be due and payable. Other Types of Fees & Expenses: In addition to the advisory fees paid to De Groote Financial, non-wrap clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges may include securities brokerage commissions, transaction fees, custodial fees, fees charged by the Independent Managers, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds. Fidelity Brokerage Services (“Fidelity”) does not charge transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Non-wrap clients who do not meet either criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds. ADV Part 2A – Firm Brochure Page 10 De Groote Financial Group  Commissionable Securities Sales: Our firm and representatives do not sell securities for a commission in advisory accounts. Item 6: Performance‐Based Fees & Side‐By‐Side Management De Groote Financial does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7: Types of Clients & Account Requirements De Groote Financial provides its services to individuals, investment companies, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. No Minimum Account Requirements: De Groote Financial does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an investment management relationship. Certain Independent Managers may, however, impose more restrictive account requirements and varying billing practices than De Groote Financial. In these instances, De Groote Financial may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis: De Groote Financial may utilizes a combination of fundamental and technical methods of analysis. Fundamental analysis involves an evaluation of the fundamental financial condition and competitive position of a particular fund or issuer. For De Groote Financial, this process typically involves an analysis of an issuer’s management team, investment strategies, style drift, past performance, reputation and financial strength in relation to the asset class concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in relying upon fundamental analysis is that while the overall health and position of a company may be good, evolving market conditions may negatively impact the security. Technical analysis involves the examination of past market data rather than specific issuer information in determining the recommendations made to clients. Technical analysis may involve the use of mathematical based indicators and charts, such as moving averages and price correlations, to identify market patterns and trends which may be based on investor sentiment rather than the fundamentals of the company. A substantial risk in relying upon technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that De Groote Financial will be able to accurately predict such a reoccurrence. Investment Strategies We Use: De Groote Financial focuses its portfolio investments primarily in ETFs, but it will also utilize a variety of other traditional bonds and equities to further diversify the Firm’s managed portfolios. The ADV Part 2A – Firm Brochure Page 11 De Groote Financial Group  Firm will also utilize separate account managers, and occasionally invest in private placement funds, REITs and MLPs. Risk of Loss: General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear potential losses. Market Risks The profitability of a significant portion of De Groote Financial’s recommendations may depend to a great extent upon correctly assessing the future course of price movements of stocks and bonds. There can be no assurance that De Groote Financial will be able to predict those price movements accurately. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers De Groote Financial may recommend the use of Independent Managers. In these situations, De Groote Financial continues to do ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, De Groote Financial generally may not have the ability to supervise the Independent Managers on a day-to-day basis. ADV Part 2A – Firm Brochure Page 12 De Groote Financial Group  Use of Private Collective Investment Vehicles De Groote Financial recommends that certain clients invest in privately placed collective investment vehicles (e.g., hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments which may be traded and no requirement to diversify. Hedge funds may trade on margin or otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not registered as investment companies, there is an absence of regulation. There are numerous other risks in investing in these securities. Clients should consult each fund’s private placement memorandum and other offering documents explaining such risks prior to investing. Master Limited Partnerships (MLPs) Master Limited Partnerships (“MLPs”) are collective investment vehicles, the partnership interests of which are publicly traded on national securities exchanges. MLPs invest primarily in companies within the energy sector that engage in qualifying lines of business, such as natural resource production and mineral refinement. MLPs are therefore subject to the underlying volatility of the energy industry and may be adversely affected by changes to supply and demand, regional instability, currency spreads, inflation and interest rate fluctuations, among other such factors. In addition, MLPs operate as pass-through tax entities, meaning that investors are liable for their pro rata share of the partnership taxes, regardless of the types of accounts where the interests are held. Real Estate Investment Trusts (REITs) De Groote Financial may recommend an investment in, or allocate assets among, various real estate investment trusts (“REITs”), the shares of which exist in the form of either publicly traded or privately placed securities. REITs are collective investment vehicles with portfolios comprised primarily of real estate and mortgage related holdings. Many REITs hold heavy concentrations of investments tied to commercial and/or residential developments, which inherently subject REIT investors to the risks associated with a downturn in the real estate market. Investments linked to certain regions that experience greater volatility in the local real estate market may give rise to large fluctuations in the value of the vehicle’s shares. Mortgage related holdings may give rise to additional concerns pertaining to interest rates, inflation, liquidity and counterparty risk. Management Through Similarly Managed “Model” Accounts De Groote Financial manages certain accounts through the use of similarly managed “model” portfolios, whereby the Firm allocates all or a portion of its clients’ assets among various mutual funds and/or securities on a discretionary basis using one or more of its proprietary investment strategies. In managing assets through the use of models, the Firm remains in compliance with the safe harbor provisions of Rule 3a-4 of the Investment Company Act of 1940. The strategy used to manage a model portfolio may involve an above average portfolio turnover that could negatively impact clients’ net after tax gains. While the Firm seeks to ensure that clients’ assets are managed in a manner consistent with their individual financial situations and investment objectives, securities transactions effected pursuant to a model investment strategy are usually done without regard to a client’s individual tax ramifications. Clients should contact De Groote Financial if they experience a change in their financial situation or if they want to impose reasonable restrictions on the management of their accounts. ADV Part 2A – Firm Brochure Page 13 De Groote Financial Group  Item 9: Disciplinary Information De Groote Financial has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10: Other Financial Industry Activities & Affiliations Douglas C. De Groote is a licensed insurance agent/broker. He will not, however, be offering insurance products nor will he receive customary fees as a result of insurance sales. De Groote Financial maintains a business relationship with Dynasty Financial Partners, LLC (“Dynasty”). Dynasty offers operational and back office core service support including access to a network of service providers. Through the Dynasty network of service providers, De Groote Financial may receive preferred pricing on trading technology, transition support, reporting, custody, brokerage, compliance, and other related consulting services. While De Groote Financial believes this open architecture structure for operational services best serves the interests of its clients, this relationship presents certain conflicts of interest due to the fact that Dynasty is paid by De Groote Financial or its clients for the services referenced above. In light of the foregoing, De Groote Financial seeks at all times to ensure that any material conflicts are addressed on a fully-disclosed basis and handled in a manner that is aligned with its clients’ best interests. De Groote Financial receives a portion of the fees paid directly to Dynasty, its affiliates or the service providers made available through Dynasty’s platform. In addition, De Groote Financial reviews such relationships, including the service providers engaged through Dynasty, on a periodic basis in an effort to ensure clients are receiving competitive rates in relation to the quality and scope of the services provided. De Groote Financial has entered into an agreement with Dynasty Capital Strategies, LLC, a wholly- owned subsidiary of Dynasty and an affiliate of Dynasty Wealth Management, LLC, a registered investment adviser, to sell, via a note, an agreed percentage of the revenue generated by De Groote Financial and in return received equity in Dynasty Financial Partners, LLC. This relationship of being an investor in Dynasty presents certain conflicts of interest due to the fact DeGroote Financial has a financial incentive to see that Dynasty is successful and which could influence decision making in selecting their services. Such funds may be used for business transition expenses and other costs associated with launching operations and for business expansion. De Groote Financial is not obligated to enter into such a note in order to obtain other services from Dynasty, however, such notes are only made available for advisers who remain members of the Dynasty Network of registered investment advisers. The notes are subject to standard underwriting practices by Dynasty and are based on commercially reasonable terms. De Groote Financial used the proceeds of the note to acquire ownership interest in Dynasty. De Groote Financial’s ownership interest in Dynasty presents a conflict of interest because clients are providing revenue to Dynasty, which is an entity owned in part by De Groote Financial. As a result, De Groote Financial is incentivized to recommend Dynasty’s services over the services of Dynasty’s competitors. De Groote Financial initially examined this conflict of interest and has determined that the recommendation of Dynasty is in the best interest of De Groote Financial’s clients and satisfies our fiduciary obligations based on the services provided by Dynasty. De Groote Financial will continue to assess whether Dynasty’s services remain in the best interest of De Groote Financial’s clients at least annually. ADV Part 2A – Firm Brochure Page 14 De Groote Financial Group  Individuals of De Groote Financial have ownership interest in NSI, LLC, which is the sponsor and owner of the NSI ETF. As a result, individuals of the firm can receive pro-rata distributions from the profits generated by NSI ETF. This ownership creates a conflict of interest because individuals of the Firm have an economic incentive to recommend the NSI ETF to clients. To mitigate this conflict, the Firm employs a due diligence process to ensure that all investment recommendations, including those involving the NSI ETF, are made in the best interest of clients. De Groote Financial has entered into an agreement with Yrefy SLP4, LLC, a Delaware limited liability company. As a result, De Groote Financial receives an additional advisory fee from client enrollment in the Yrefy SLP4, LLC investment. This agreement creates a conflict of interest because De Groote Financial has an economic incentive to place clients into the Yrefy SLP4, LLC investments. To mitigate this conflict, the Firm employs a due diligence process to ensure that all investment recommendations, including Yrefy SLP4, LLC, are properly vetted as a suitable investment selection for our clients. Additionally, we mitigate this conflict by acting in the best interest of our clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading De Groote Financial has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. De Groote Financial’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Firm and its associated persons may invest in or have an interest in securities, including the NSI ETF, that are recommended to clients. The Firm maintains and enforces a Code of Ethics, which requires that all recommendations be made with fiduciary duty to clients as the highest priority. The Firm discloses any material conflicts of interest and ensures that clients are treated fairly. In addition, the Firm monitors personal trading activity of its personnel to prevent conflicts of interest from affecting client recommendations. The Code of Ethics also requires certain of De Groote Financial’s personnel (called “Access Persons”) to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, De Groote Financial Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a manner consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by Access Persons to be completed without any appreciable impact on the markets of such securities. Therefore, under certain limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client where there may be a potential for conflict, no Access Person may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household as the Access Person) a transaction in that security unless: • • the transaction has been completed; the transaction for the Access Person is completed as part of a batch trade (as defined below in Item 12) with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial ADV Part 2A – Firm Brochure Page 15 De Groote Financial Group  paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients may contact De Groote Financial to request a copy of its Code of Ethics. Item 12: Brokerage Practices De Groote Financial generally recommends that clients utilize the brokerage, clearing and custodial services of Schwab Advisor ServicesTM (“Schwab”) or National Financial Services LLC and Fidelity Brokerage Services LLC ("Fidelity") for investment management accounts. Factors which De Groote Financial considers in recommending Schwab, Fidelity, or any other broker- dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Schwab and Fidelity enable De Groote Financial to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. In addition, Schwab and Fidelity have agreed to compensate clients for any transfer fees that may be assessed for moving their account(s) to Schwab or Fidelity. The commissions and/or transaction fees charged by Schwab or Fidelity may be higher or lower than those charged by other Financial Institutions. The commissions paid by De Groote Financial’s clients comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where De Groote Financial determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. De Groote Financial seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Transactions may be cleared through other Financial Institutions with whom De Groote Financial and the Financial Institutions have entered into agreements for prime brokerage clearing services. De Groote Financial periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. The client may direct De Groote Financial in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by De Groote Financial (as described below). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, De Groote Financial may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Transactions for each client generally will be effected independently, unless De Groote Financial decides to purchase or sell the same securities for several clients at approximately the same time. De Groote Financial may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among De Groote Financial’s clients differences in prices and commissions or other transaction costs that might not ADV Part 2A – Firm Brochure Page 16 De Groote Financial Group  have been obtained had such orders been placed independently. Under this procedure, transactions will generally be averaged as to price and allocated among De Groote Financial’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that De Groote Financial determines to aggregate client orders for the purchase or sale of securities, including securities in which De Groote Financial’s Supervised Persons may invest, the Firm generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. De Groote Financial does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, De Groote Financial may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Consistent with obtaining best execution, brokerage transactions may be directed to certain broker- dealers in return for investment research products and/or services which assist De Groote Financial in its investment decision-making process. Such research generally will be used to service all of the Firm’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because De Groote Financial does not have to produce or pay for the products or services. Software and Support Provided by Financial Institutions: De Groote Financial may receive from Schwab and Fidelity, without cost to De Groote Financial, computer software and related systems support, which allow De Groote Financial to better monitor client accounts without cost because De Groote Financial renders investment management services to clients that maintain assets at Schwab or Fidelity. The software and support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The software and related systems support may benefit De Groote Financial, but not its clients directly. In fulfilling its duties to its clients, De Groote Financial endeavors at all times to put the interests of its clients first. Clients should be aware, however, that De Groote Financial’s receipt of economic benefits from a broker- dealer creates a conflict of interest since these benefits may influence De Groote Financial’s choice of broker-dealer over another broker-dealer that does not furnish similar software, systems support or services. Additional Services Provided by Financial Institutions: Additionally, De Groote Financial may receive the following benefits from Schwab through its Schwab Advisor Services division or from Fidelity: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk; access to block trading which provides the ability to ADV Part 2A – Firm Brochure Page 17 De Groote Financial Group  aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network for client order entry and account information. Item 13: Review of Accounts or Financial Plans For those clients to whom De Groote Financial provides investment management services, De Groote Financial monitors those portfolios as part of an ongoing process while regular account reviews are conducted on at least annually. For those clients to whom De Groote Financial provides financial planning and/or consulting services, reviews are conducted on an “as needed” basis. Such reviews are conducted by one of De Groote Financial’s investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives with De Groote Financial and to keep De Groote Financial informed of any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Account Statements and Reports: Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from De Groote Financial and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with those they receive from De Groote Financial or an outside service provider. Item 14: Client Referrals & Other Compensation Client Referrals: In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, De Groote Financial provides cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Such compensation arrangements will not result in higher costs to the referred client. In this regard, De Groote Financial maintains a written agreement with each unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12- month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: • Whether or not the unaffiliated person is a current client of De Groote Financial, • A description of the cash or non-cash compensation provided directly or indirectly by De Groote Financial to the unaffiliated person in exchange for the referral, if applicable, and • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm’s relationship with such unaffiliated person. In cases where state law requires licensure of promoters, De Groote Financial ensures that no referral fees are paid unless the promoter is registered as an investment adviser representative of our firm. If our firm is paying referral fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. ADV Part 2A – Firm Brochure Page 18 De Groote Financial Group  Other Economic Benefits: De Groote Financial has arrangements in place whereby the Firm receives an economic benefit from a third-party for providing investment advice to clients participating in the Program. Specifically, Schwab and Fidelity may provide the Firm with computer software and related systems support, which allow De Groote Financial to better monitor client accounts maintained at Schwab or Fidelity. De Groote Financial may receive the software and related support without cost because De Groote Financial renders investment management services to clients that maintain assets at Schwab or Fidelity. The software and related systems support may benefit De Groote Financial, but not its clients directly. In fulfilling its duties to its clients, De Groote Financial endeavors at all times to put the interests of its clients first. Clients should be aware, however, that De Groote Financial’s receipt of economic benefits from a broker-dealer creates a conflict of interest since these benefits may influence De Groote Financial’s choice of broker-dealer over another that does not furnish similar software, systems support, or services. Clients and prospective clients should review Item 10 for information about parties De Groote Financial may refer clients to and additional compensation De Groote Financial may receive from these parties. Item 15: Custody De Groote Financial’s Agreement and/or the separate agreement with any Financial Institution may authorize De Groote Financial through such Financial Institution to debit the client’s account for the amount of De Groote Financial’s fee and to directly remit that management fee to De Groote Financial in accordance with applicable custody rules. The Financial Institutions recommended by De Groote Financial have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to De Groote Financial. In addition, as discussed in Item 13, De Groote Financial also sends periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from De Groote Financial. Trustee Arrangement: Representatives of our firm act as a trustee for certain client accounts. As such, our firm is deemed to have custody of those accounts. In accordance with Rule 206(4)-2 of the Investment Advisers Act of 1940, client funds and securities of which our firm is deemed to have custody are verified by actual examination at least once during each calendar year by an independent public accountant (“IPA”) registered with the Public Company Accounting Oversight Board (“PCAOB”), at a time that is chosen by the accountant without prior notice or announcement to DGFG and that is irregular from year to year. Third Party Money Movement: The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with the account custodian: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third ADV Part 2A – Firm Brochure Page 19 De Groote Financial Group  party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion De Groote Financial is given the authority to exercise discretion on behalf of clients. De Groote Financial is considered to exercise investment discretion over a client’s account if it can effect transactions for the client without first having to seek the client’s consent. De Groote Financial is given this authority through a power-of-attorney included in the agreement between De Groote Financial and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). De Groote Financial takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; • The Financial Institutions to be utilized; and • The Independent Managers to be hired or fired. Item 17: Voting Client Securities Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Independent Managers selected or recommended by our firm may vote proxies for clients. Except in the event an Independent Manager votes proxies, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Therefore (except for proxies that may be voted by an Independent Manager), our firm and/or the client shall instruct the qualified custodian to forward copies of all proxies and shareholder communications relating to the client’s investment assets. ADV Part 2A – Firm Brochure Page 20 De Groote Financial Group  Item 18: Financial Information De Groote Financial is not required to disclose any financial information pursuant to this Item due to the following: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. ADV Part 2A – Firm Brochure Page 21 De Groote Financial Group