Overview

Assets Under Management: $174 million
Headquarters: MAITLAND, FL
High-Net-Worth Clients: 46
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (DAG ADV PART 2A MARCH 2025)

MinMaxMarginal Fee Rate
$0 and above 2.95%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $29,500 2.95%
$5 million $147,500 2.95%
$10 million $295,000 2.95%
$50 million $1,475,000 2.95%
$100 million $2,950,000 2.95%

Clients

Number of High-Net-Worth Clients: 46
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 57.77
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 892
Discretionary Accounts: 892

Regulatory Filings

CRD Number: 105966
Last Filing Date: 2024-04-01 00:00:00
Website: https://deltaadvisory.com

Form ADV Documents

Primary Brochure: DAG ADV PART 2A MARCH 2025 (2025-03-31)

View Document Text
Item 1 Cover Page DELTA ADVISORY GROUP, INC. FIRM BROCHURE Part 2A of Form ADV 696 North Maitland Avenue Maitland, Florida 32751 407-331-9213 www.DeltaAdvisory.com March 2025 of this brochure, please contact us at 407-331-9213 This brochure provides information about the qualifications and business practices of Delta Advisory Group, Inc. (“DAG” or the “Firm”). If you have any questions about the or contents MJohnson@DeltaAdvisory.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. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. Additional information about Delta Advisory Group, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The firm’s CRD number is 105966. Item 2 Material Changes This brochure, dated March 2025, provides you with a summary of DAG’s advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. Any material changes made since the last Brochure update in March 2024 will be listed below. Material Changes Should a material change in our operations occur, depending on the nature of the change, DAG will promptly communicate this change to Clients (and it will be summarized in this Item). “Material changes” requiring prompt notification will include changes in ownership or control; location; disciplinary proceedings; significant changes to our advisory services or advisory affiliates; or any information that is critical to a Client’s full understanding of who the Firm is; how to find us, and how we do business. • There are no material changes. 2 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 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 and Compensation ................................................................................ 8 Item 6 Performance-Based Fees and Side-By-Side Management ......................... 11 Item 7 Types of Clients ........................................................................................... 12 Item 8 Methods of Analysis, Investment Strategies, & Risk of Loss ....................... 13 Item 9 Disciplinary Information ................................................................................ 16 Item 10 Other Financial Industry Activities & Affiliations ........................................... 17 Item 11 Code of Ethics, Participation or Interest in Client Transactions, & Personal Trading ........................................................................................................ 17 Item 12 Brokerage Practices..................................................................................... 19 Item 13 Review of Accounts ..................................................................................... 21 Item 14 Client Referrals and Other Compensation ................................................... 22 Item 15 Custody ........................................................................................................ 23 Item 16 Investment Discretion .................................................................................. 24 Item 17 Voting Client Securities ................................................................................ 25 Item 18 Financial Information ................................................................................... 26 Item 19 Requirements for State-Registered Advisers Error! Bookmark not defined. 3 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 4 Advisory Business About Delta Advisory Group, Inc. (“DAG”) DAG is a Florida corporation founded in 1996. DAG is an investment adviser registered with the Securities & Exchange Commission (“SEC”) with its home office located at 696 North Maitland Avenue, Maitland, Florida, 32751. DAG maintains a branch office at 698 North Maitland Avenue Suite 201, Maitland, Florida 32751. Please note that the words “we,” “us,” and “our” may be used to refer to DAG throughout this brochure, as the context may require. Furthermore, the words “you,” “your,” and “Client” may be used to refer to you as either a client or a prospective client of DAG, as the context may require. DAG’s principal shareholder (i.e., those individuals and/or entities controlling 25% or more of this company) is: • Clarence – Pelton, LTD Advisory Services Offered Prior to forming an investment advisor-client relationship, DAG may offer a complimentary general consultation to prospective Clients to discuss the nature of its service offerings and to determine the possibility of a potential advisory relationship. Investment advisory services begin only after the prospective Client and DAG formalize their relationship with a properly executed written advisory agreement. Portfolio Management DAG provides continuous advice to a Client regarding the investment of Client funds and non-continuous asset management of Client funds based on individual needs of the Client. Through personal discussions and the data gathering process, the Client’s goals and objectives based on a his/her particular circumstances are established to determine the appropriate manner in which to manage the Client’s portfolio. During our data gathering process, we determine the Client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. DAG manages these advisory accounts on a discretionary basis. Account supervision is guided by the client’s stated objectives and tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. DAG’s investment recommendations are not limited to any specific product or service offered by a broker/dealer or insurance company. Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended 4 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 when consistent with the Client’s stated investment objectives, tolerance for risk, liquidity, and suitability. Selection of Broker by DAG As a condition of participation in most services with DAG, Clients are generally required to maintain their brokerage account(s) at Charles Schwab & Co. Inc. (“Schwab”). Financial Planning Services DAG provides financial planning services. Financial planning is a comprehensive evaluation of a Client’s current and future financial state by using currently known variables to predict the future cash flows, asset values, and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the Client. Clients purchasing this service receive a written report which provides the Client with a detailed financial plan designed to assist the Client in achieving his/her financial objectives. Generally, the financial plan addresses any or all of the following areas: personal situations, tax and cash flow, investments, insurance, retirement, death and disability, and estate. DAG gathers required information through written information and documentation provided by the Client, as well as in-depth personal interviews. The information gathered includes the Client’s current financial status, tax status, future goals, return objectives, and attitudes towards risk. Should the Client choose to implement the recommendations contained in the plan, we will suggest the Client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of the financial plan recommendations is entirely at the Client’s discretion. DAG also provides general non-securities advice on topics that may include tax and budgetary planning, estate planning, and business planning. Typically, the financial plan is presented to the Client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial planning recommendations are not limited to any specific product or service offered by a broker/dealer or insurance company. Consulting There are situations in which a DAG investment advisor provides advice on specific topics not involving a comprehensive financial plan. Often, these situations are associated with events such as divorce, death, retirement, or a child entering college. Newsletters 5 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 DAG provides Clients with newsletters sent monthly that include updates and investment- related advice. Client Tailored Services and Client Imposed Restrictions DAG will tailor services for each individual Client based on industry standards and information gathered from Client suitability forms such as the Risk Tolerance Questionnaire and the Client Profile. Clients may impose restrictions in receiving recommendations for investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent DAG from making proper recommendations for the Client account, DAG reserves the right to end the relationship. IRA Rollover Considerations & Recommendations As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account (IRA) that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. We comply with the Department of Labor (“DOL”) Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable. Our firm is providing the following additional acknowledgment: When the Adviser provides investment advice to individuals regarding a retirement plan account or individual retirement account, the firm is deemed a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way the Adviser makes money creates potential conflicts with a client’s interest. Therefore, the Adviser, operates under a special rule which requires the firm to act in a client’s best interest and not put the Adviser’s interest ahead of the client. Under this special rule’s provisions, the Adviser must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put the Adviser’s financial interests ahead of a client when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees and investments; • Follow policies and procedures designed to ensure advice given is in the client’s best interest; • Charge no more than is reasonable for services; and • Provide basic information about conflicts of interest. 6 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Client Assets Under Management As of December 31, 2024, DAG provides continuous management services for $192,575,000.00 in client assets for 466 clients on a discretionary basis. DAG does not currently provide any non-discretionary portfolio management. 7 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 5 Fees and Compensation Portfolio Management Fees DAG’s annual fees for Portfolio Management are based upon a percentage of assets under management up to 2.95%. The fees are billed quarterly or semiannually, in advance, at the beginning of each calendar period based upon the value (market value or fair market value in the absence of market value), of the client’s account(s) at the end of the previous period. For some Clients, the value of fees to be paid six months or more, in advance, may exceed $500. For most Clients, fees will be debited from the account in accordance with the client authorization in the Client Services Agreement; however, under certain circumstances and at DAG’s discretion, the Client has the option of being billed for advisory fees. Though the fees charged by DAG are generally considered to be reasonable, Clients could find the same or similar services offered by other investment advisors who charge fees that are lower than the fees charged by DAG. Limited Negotiability of Advisory Fees DAG retains the discretion to negotiate alternative fees on a client-by-client basis. Client’s facts, circumstances, and needs are considered in determining the fee schedule, including but not limited to, the complexity of the client’s situation, assets to be placed under management, anticipated future business, related accounts, portfolio style, account composition, among other factors. The specific annual fee schedule is identified in the investment advisory agreement between DAG and the Client. DAG may group certain related Client accounts for the purposes of achieving the minimum account size requirements and determining annualized fee. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons. Financial Planning and Consulting Fees DAG’s financial planning fee is determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. Financial planning fees are calculated and charged on an hourly basis, ranging from $195 to $295 per hour. Although the length of time it takes to provide a financial plan depends on each client’s personal situation, DAG will provide an estimate for the total hours at the start of the advisory relationship. 8 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 The fee for this service is separated into two payments: 50% of the estimated planning hours are due upon entering into the agreement for financial planning services and the balance, based on actual hours of service accrued, is due upon delivery of the completed financial plan. Newsletters Newsletters are sent to all Clients, free of charge, on a monthly basis. General Information Mutual Fund Fees All fees paid to DAG for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or exchange traded funds. These fees and expenses are described in each fund’s prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. Accordingly, the Client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the Client and to thereby evaluate the advisory services Termination of the Advisory Relationship A client agreement can be cancelled at any time with written notice of cancellation and will become effective ninety days following receipt of written notice by DAG. Client is entitled to a refund of any unearned portion of the management fee. For Clients who are residents of California, Maryland, Massachusetts, and Pennsylvania, the termination notifications will become effective thirty days following receipt by DAG. Clients will receive a copy of Form ADV Part 2A prior to entering into an advisory agreement. For Clients who are residents of Pennsylvania, if a copy of Form ADV Part 2A is not provided to the Client at least 48 hours prior to signing an agreement, the Client has five (5) business days to cancel the agreement, with no penalty. Where Client is entitled to a refund of unearned management fees, such fees will be prorated based upon the number of days that DAG’s advisory services were actually rendered during the termination quarter. Any unearned fees will be returned to the Client. Additional Fees and Expenses In addition to our advisory fees, clients are also responsible for other fees and expenses charged by custodians and imposed by broker/dealers, including but not limited to, any transaction imposed by a broker/dealer with which an independent investment manager effects transactions for the client’s account(s). Please refer to Item 10 of this brochure, “Brokerage Practices”, for additional information. 9 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 ERISA Accounts Pursuant to the Employee Retirement Income and Securities Act (“ERISA”), and regulations under the Internal Revenue Code of 1986, the Firm is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts. As such, we are subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, we may only charge fees for investment advice about products for which the Firm and/or related persons do not receive any commissions or 12b-1 fees, except that the Firm and/or related persons may provide investment advice about products for which we receive commissions or 12b-1 fees, only if such fees are used to offset our advisory fees. 10 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 6 Performance-Based Fees and Side-By-Side Management DAG does not charge performance-based fees. DAG’s personnel may manage accounts which belong either to themselves, individually, or to their family (collectively, Proprietary Accounts) or the accounts of affiliated entities (Affiliated Accounts) while simultaneously continuing to manage DAG's accounts. It is possible that orders for Proprietary Accounts and Affiliated Accounts may be entered opposite to orders for Clients' Accounts, pursuant to, for instance, a different trading strategy, or trading at a different risk level. The management of any Proprietary Account or Affiliated Account is subject to the duty of DAG and its personnel to exercise good faith and fairness in all matters affecting its Clients' account. 11 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 7 Types of Clients DAG provides advisory services to a variety of Clients including, but not limited to: Individuals (other than high net worth individuals) • • High net worth individuals Minimum Account Size DAG does not have a minimum account size. 12 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 8 Methods of Analysis, Investment Strategies, & Risk of Loss Methods of Analysis The firm uses the following methods of analysis in formulating our investment advice and/or managing client assets: Charting In this type of technical analysis, DAG reviews charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend may last and when that trend might reverse. Fundamental Analysis DAG attempts to measure intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be a time to sell). Fundamental analysis does not attempt to anticipate market movements, which presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis DAG analyzes past market movements and applies that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company and, therefore, presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis In this type of technical analysis, DAG measures the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Risks for all forms of analysis DAG securities analysis methods rely on the assumption that the companies whose securities DAG purchases and sells, the rating agencies that review these securities, and other publicly available sources of information about these securities are providing accurate and unbiased data. While DAG is alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. 13 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Investment Strategies DAG uses the following strategies in managing Client accounts, provided that such strategies are appropriate to the needs of the Client and consistent with the Client’s investment objectives, risk tolerance, and time horizons, among other considerations: Long-Term Purchases DAG purchases securities with the idea of holding them in the Client’s account for a year or longer. Typically, we employ this strategy when we believe the securities to be currently undervalued and/or want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to the Client. Moreover, if we are incorrect, a security may decline sharply in value before we make the decision to sell. Short-Term Purchases When utilizing this strategy, DAG purchases securities with the idea of selling them within a relatively short time (less than a year). Typically, we employ this strategy in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. A short-term purchase strategy poses the risk that, should the anticipated price swing not materialize, we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Trading DAG purchases securities with the idea of selling them very quickly (30 days or less), in an attempt to take advantage of brief price swings. Utilizing a trading strategy creates the potential for sudden losses if the anticipated price swing does not materialize. Moreover, under those circumstances, we are then left with the option of having a long-term investment in a security that was designed to be a short- term purchase, or potentially taking a loss. In addition, because this strategy involves more frequent trading than does a longer-term strategy, there will be a resultant increase in brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. 14 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Margin Transactions DAG will purchase stocks for a Client’s portfolio with money borrowed from the Client’s brokerage account. Purchasing on margin allows a Client to purchase more stock than he/she would be able to with his/her available cash and allows us to purchase stock without selling other holdings. Option Writing DAG may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative, because it derives its value from an underlying asset. The two types of options are calls and puts: • A call gives us the right to buy an asset at a certain price within a specific period of time. We will buy a call if we believe that the stock will increase substantially before the option expires. • A put gives the holder the right to sell an asset at a certain price within a specific period of time. We will buy a put if we believe that the price of the stock will fall before the option expires. DAG will use options to hedge on the possibility of a sharp price swing or hedge a purchase of the underlying security. In other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for the Client’s portfolio. DAG uses “covered calls”, in which we sell an option on a security the Client owns. In this strategy, the Client receives a fee for making the option available, and the person purchasing the option has the right to buy the security from the Client at an agreed upon price. We use a “spreading strategy”, in which two or more option contracts for the same underlying security. This strategy effectively puts the Client on both sides of the market, but with the ability to vary price, time, and other factors. Risks of Loss The assets in the portfolios are financial securities. Any investment of this type involves a risk of loss, not only of income but of investment dollars which the investor client must be prepared to bear. An extended period of market uncertainty or economic recession could result in significant loss of value. 15 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 9 Disciplinary Information DAG is required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. There are no reportable disciplinary events for DAG or its management personnel. 16 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 10 Other Financial Industry Activities & Affiliations Broker-Dealer or other Investment Advisors As of the date of this brochure, neither DAG nor its management are or intend to become registered as a broker-dealer and no individuals affiliated with our firm are currently registered representatives of a broker-dealer. Futures or Commodities Registration Neither DAG nor its management are or intend to become registered as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of any of the foregoing. Material Relationships with Related Persons Mr. Donald Nestor is licensed to sell insurance products and may receive separate, yet customary commission compensation for effecting insurance sales. This may represent a potential conflict of interest because he may have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. However, you are under no obligation, contractually or otherwise, to purchase products through any person affiliated with our firm. Mr. Anthony DeLuca is licensed to sell insurance products and may receive separate, yet customary commission compensation for effecting insurance sales. This may represent a potential conflict of interest because he may have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. However, you are under no obligation, contractually or otherwise, to purchase products through any person affiliated with our firm. Mr. Roy Miranda is the managing member of Delta Insurance Group, LLC (“DIG”) through which he licensed to sell insurance products and may receive separate, yet customary commission compensation for effecting insurance sales. This may represent a potential conflict of interest because he may have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. However, you are under no obligation, contractually or otherwise, to purchase products through any person affiliated with our firm. Since no investment advisers are licensed to sell insurance products in the state of Pennsylvania, insurance products will not be offered by DAG to Clients who reside in Pennsylvania. 17 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Interest in Client Item 11 Code of Ethics, Participation or Transactions, & Personal Trading Code of Ethics DAG has adopted a Code of Ethics (“Code”) which sets forth high ethical standards of business conduct that DAG requires of its employees, including compliance and applicable federal securities laws. The Code is designed to ensure that the personal securities transactions, activities, and interests of our employees will not interfere with: (i) making decisions in the best interest of advisory clients; and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. A copy of the Code is available to our advisory clients and prospective clients. You may request a copy by email to MJohnson@DeltaAdvisory.com, or by calling us at 407-331- 9213. Participation or Interest in Client Transactions & Personal Trading From time to time, DAG and/or individuals associated with DAG may buy or sell for their personal accounts securities identical to or different from those recommended to the Clients. In addition, any related person may have an interest or position in a certain security which may also be recommended to a Client. It is our expressed policy that no person employed by DAG may purchase or sell any security prior to transactions being implemented for an advisory account, thereby preventing such employee(s) from benefiting from transactions placed on behalf of advisory accounts. DAG may aggregate employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro rata basis. In the instances where there is a partial fill of a particular batched order, DAG will allocate all purchases pro rata, with each account paying the average price. Our employee accounts will be included in the pro rata allocation. 18 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 12 Brokerage Practices For discretionary clients, DAG requires clients to provide us with written authority to: (1) determine the broker/dealer to use; (2) the commission costs that will be charged to these clients for those transactions; and (3) provide limitations on discretionary authority. Clients may amend these limitations as required. Such amendments must be provided to us in writing. DAG has an arrangement with Charles Schwab & Co. Inc. (“Schwab”) through which Schwab provides us with “institutional platform services”. The institutional platform services include, among others, brokerage, custody, and other related services. Schwab’s institutional platform services that assist us in managing and administering clients’ accounts include software and other technology that: (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. We will arrange for the execution of securities brokerage transactions for the account through Schwab. In seeking best execution, the determinative factor is not lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealers’ service, including the value of research provided, execution capability, commission rates and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rate for account transactions. Clients are encouraged, but not required, to establish an account with Schwab. The client may direct DAG to use a particular broker-dealer (subject to our right to decline and/or terminate the engagement) to execute some or all transactions for the client’s account. In such event, the Client will negotiate terms and arrangements for the account with that broker-dealer and DAG will not seek better execution services or prices from other broker- dealers. As a result, Client may pay higher commissions or other transaction costs or greater spreads or receive less favorable net prices on transactions for the accounts than would otherwise be that case. In the event that transactions for client accounts are executed through a broker-dealer that refers clients to DAG, the potential for conflict of interest may arise. Order Aggregation We may, but are not obligated to, combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "block trading"). In the event orders are block traded, we will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion regarding factual and market conditions, when we combine orders, each participating account pays an average price per share 19 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 for all transactions and pays a proportionate share of all transaction costs on any given day. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. In the event orders are not block traded, you may pay different prices for the same securities transactions than other clients pay. Furthermore, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than if orders were aggregated. 20 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 13 Review of Accounts Portfolio Management While the underlying securities within accounts for which DAG provides Portfolio Management services are continually monitored, Client accounts are reviewed quarterly. Accounts are reviewed in the context of each Client’s stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the Client’s individual circumstances, or the market, political, or economic environment. Mr. Alexander Petsos is responsible for the quarterly review of Client accounts. Financial Planning While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for financial planning clients unless the Client contracts for additional services. Financial planning Clients will receive a completed financial plan. Additional reports will not typically be provided unless the client contracts for additional services. Reports You will receive account statements from Schwab or other qualified custodian at least quarterly. Account performance reports are used in account reviews with Clients. In some instances, copies of those performance reports may be provided to the Client. 21 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 14 Client Referrals and Other Compensation It is our policy not to engage solicitors or to pay related or non-related persons for referring potential clients to DAG. Other Compensation DAG and/or its associated persons are eligible to receive incentive awards (including prizes such as trips or bonuses) for recommending certain types of investment product. While we endeavor at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving incentive awards creates a conflict of interest and may influence the judgement of these individuals when making recommendations. As listed in Item 10, the firm principals and some access persons receive additional compensation from their outside business activities. Some of these outside business activities can create a conflict of interest because these persons could be incentivized by compensation to make certain recommendations. 22 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 15 Custody DAG is considered to take custody of Client assets in two ways. DAG has limited custody of Client assets due to the debiting of advisory fees from the Client’s account. DAG is also considered to take custody of Client assets for which there is a standing letter of authorization (“SLOA”) signed by the Client and submitted to the qualified custodian. Debiting of Fees As previously disclosed in Item 5 of this Brochure, “Fees and Compensation”, we directly debit advisory fees from most client accounts which imputes limited custody of those assets. As part of this billing process, the Client’s qualified custodian is advised of the amount of the fee to be deducted from the Client’s account. You will receive account statements from Schwab, or other qualified custodian, at least quarterly. These account statements will indicate the amount of our advisory fees deducted from your account(s) each billing period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Standing Letters of Authorization Some Clients also have SLOAs that allow DAG’s advisors to disburse funds or move funds between specified accounts on the Client’s behalf. This ability causes DAG to exercise custody over the funds or securities for which there is a SLOA as noted in Form ADV Part 1, Item 9A. You will receive account statements from Schwab or other qualified custodian at least quarterly. These account statements will indicate any transactions made during that period. You should carefully review account statements sent to you reflecting the amount of advisory fee deducted from your account. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, please contact us directly at the telephone number on the cover page of this brochure. DAG complies with the safekeeping provisions required of firms that maintain custody as described above. 23 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 16 Investment Discretion Clients may hire DAG to provide discretionary asset management services, in which case we are not required to obtain the client’s permission prior to placing trades in a client’s account. This discretionary authority includes the ability to determine the security to buy or sell and/or the amount of the security to buy or sell without first contacting the client. Clients give DAG discretionary authority when they sign a discretionary agreement with us and may limit this authority by giving us written instructions. Clients may also amend such authority by providing us with written instructions. 24 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 17 Voting Client Securities As a matter of policy, we do not vote proxies on behalf of Clients. Therefore, although we may provide investment advisory services as to client investment of assets, 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 of events pertaining to client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward copies of all proxies and shareholder communications relating to the client’s investment assets to the Client. DAG may provide a client with consulting assistance regarding proxy issues if the client contacts us with questions at our principal place of business. 25 Delta Advisory Group, Inc. Form ADV Part 2A March 2025 Item 18 Financial Information Prepayment of Fees – Financial Statements There are some Clients for which DAG requires prepayment of more than $500 in fees more than six months in advance. As such, financials have been prepared and submitted by an independent public accountant. Financial Conditions DAG also maintains discretionary authority of Client assets. There are no financial conditions that are reasonably likely to impair our ability to meet any contractual commitments to our Clients. Bankruptcy DAG has not been the subject of a bankruptcy petition at any time during the past ten years. 26 Delta Advisory Group, Inc. Form ADV Part 2A March 2025

Additional Brochure: DAG AUDITED FINANCIAL STATEMENTS DEC 2024 (2025-03-31)

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DELTA ADVISORY GROUP, INC. Financial Statements December 31, 2024 (With Independent Auditors' Report Thereon) DELTA ADVISORY GROUP, INC. Table of Contents Page Independent Auditors' Report 1 Financial Statements: Statement of Financial Position 3 Statement of Operations and Changes in Stockholder’s Equity 4 Statement of Cash Flows 5 Notes to Financial Statements 6 Independent Auditors' Report To the Board of Directors Delta Advisory Group, Inc. Maitland, Florida Opinion We have audited the accompanying financial statements of Delta Advisory Group, Inc. (a Florida corporation), which comprise of the statement of financial position as of December 31, 2024 and the related statements of operations and changes in stockholder’s, and cash flows for the year then ended, and the related notes to the financial statements. In our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of Delta Advisory Group, Inc. as of December 31, 2024, and the results of its operations and its cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America. Basis for Opinion We conducted our audit in accordance with auditing standards generally accepted in the United States of America. Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our report. We are required to be independent of Delta Advisory Group, Inc. and to meet our other ethical responsibilities in accordance with the relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion. Responsibilities of Management for the Financial Statements Management is responsible for the preparation and fair presentation of the financial statements in accordance with accounting principles generally accepted in the United States of America, and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. In preparing the financial statements, management is required to evaluate whether there are conditions or events, considered in the aggregate, that raise substantial doubt about Delta Advisory Group, Inc.’s ability to continue as a going concern within one year after the date that the financial statements are available to be issued. Erin M Perdue, CPA, LLC 322 E Central Blvd, Suite 605, Orlando, Florida 32801 Phone 407-383-7668 Auditor’s Responsibilities for the Audit of the Financial Statements Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with generally accepted auditing standards will always detect a material misstatement when it exists. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered material if there is a substantial likelihood that, individually or in the aggregate, they would influence the judgment made by a reasonable user based on the financial statements. In performing an audit in accordance with generally accepted auditing standards, we: • Exercise professional judgment and maintain professional skepticism throughout the audit. • Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error, and design and perform audit procedures responsive to those risks. Such procedures include examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. • Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of Delta Advisory Group, Inc’s internal control. Accordingly, no such opinion is expressed. • Evaluate the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluate the overall presentation of the financial statements. • Conclude whether, in our judgment, there are conditions or events, considered in the aggregate, that raise substantial doubt about Delta Advisory Group, Inc’s ability to continue as a going concern for a reasonable period of time. We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control related matters that we identified during the audit. Erin Perdue CPA, LLC March 25, 2025 - 2 - DELTA ADVISORY GROUP, INC. Statement of Financial Position December 31, 2024 Assets $ Assets: Cash Accounts receivable Total assets $ 47,400 1,808 49,208 Liabilities and Stockholder's Equity Liabilities: $ Accounts payable Unearned management fees Total liabilites 7,000 5,615 12,615 Stockholder's equity: Common stock, $1 par value, 1,000 shares authorized, issued and outstanding Additional paid-in capital Retained earnings 1,000 34,000 1,593 36,593 Total liabilities and stockholder's equity $ 49,208 See accompanying notes to the financial statements - 3 - DELTA ADVISORY GROUP, INC. Statement of Operations and Changes in Stockholder's Equity Year Ended December 31, 2024 Revenue: Management fee revenue $ 1,412,752 Expenses: Overhead and labor allocation Advisory fees Regulatory fees Accounting fees Website Development Bank fees Printing 1,086,100 311,549 10,296 7,000 888 312 240 Total expenses 1,416,385 Net loss (3,633) Stockholder's equity, beginning of the year 5,226 Stockholder's equity, end of the year $ 1,593 See accompanying notes to the financial statements - 4 - DELTA ADVISORY GROUP, INC. Statement of Cash Flows Year Ended December 31, 2024 Cash flows from operating activities: $ (3,633) Net loss Adjustments to reconcile net loss to net cash used in operating activities: Increase in accounts receivable Decrease in unearned management fees (1,808) (495) Net cash used in operating activities (5,936) Decrease in cash (5,936) CASH, beginning of year 53,336 CASH, end of year $ 47,400 See accompanying notes to the financial statements - 5 - DELTA ADVISORY GROUP, INC. Notes to Financial Statements December 31, 2024 (1) Nature of Operations Delta Advisory Group, Inc. (the Company) is a Florida corporation. The Company is an investment advisor registered with the Securities and Exchange Commission and provides money management services to individuals, trusts, corporations and other legal entities in various states. On December 2, 2009, the Company’s Articles of Incorporation were amended to change its name from Delta Advisory Services, Inc. to Delta Advisory Group, Inc. (2) Summary of Significant Accounting Policies (a) Basis of Accounting The accompanying financial statements have been prepared on the accrual basis of accounting. (b) Cash and Cash Equivalents For purposes of the statement of cash flow, the Company considers all highly liquid investments available for current use with an initial maturity of three months or less to be cash equivalents. (c) Fair Value of Financial Instruments Professional standards require disclosure of an estimate of fair value of certain financial instruments. The Company’s significant financial instruments are cash and other short-term assets and liabilities. For these financial instruments, carrying values approximate fair value due to the short-term nature of these instruments. (d) Unearned Management Fees The Company receives asset management fees in advance on a quarterly and semiannual basis with 30-day and 90-day cancellation provisions. Management fees are deferred and recognized when they become non-refundable. Management fees received but not recognized as revenue are recorded as unearned. (e) Use of Estimates The preparation of financial statements in conformity with generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amount of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. - 6 - DELTA ADVISORY GROUP, INC. Notes to Financial Statements December 31, 2024 (2) Summary of Significant Accounting Policies (continued) (f) Income Taxes The Company accounts for income taxes using the liability method under which deferred tax assets and liabilities are determined based upon the differences between financial statement carrying amounts and the tax bases of existing assets and liabilities. These temporary differences are measured at prevailing enacted tax rates that will be in effect when the differences are settled or realized. The Company has no deferred tax assets or liabilities as of December 31, 2024. The Company has a net operating loss carryover for 2023. Due to this, it has no income tax expense or liability for the year ended December 31, 2024. The Company accounts for uncertain tax positions, if any, in accordance with ASC Section 740. In accordance with these professional standards, the Company recognized tax positions only to the extent that management believes it is “more likely than not” that its tax positions will be sustained upon IRS examination. Management believes that it has no uncertain tax positions that qualify for either recognition or disclosure in the financial statements for the year ended December 31, 2024. The Company believes that its income tax filing positions will be sustained upon examination and does not anticipate any adjustments that would result in a material adverse affect on the Company’s financial condition, results of operations or cash flows. Accordingly, the Company has not recorded any reserves, or related accruals for interest and penalties for uncertain income tax positions at December 31, 2024, The Company is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax period in progress. The Company believes it is no longer subject to income tax examinations for fiscal years ending prior to December 31, 2022. The Company’s policy is to classify income tax related interest and penalties in interest expense and other expenses, respectively. (g) Subsequent Events Management has evaluated subsequent events through March 25, 2025, the date on which the financial statements were available to be issued. (3) Related Party Transactions In September 2022, the Company entered into a verbal agreement to acquire DCMs book of business. In consideration DAG agreed to pay out to DCM an amount up to the total amount of billing for fees of DCM’s legacy clients. Additionally, DCM agreed to provide and pay all expenses incurred for the operations of DAG’s business. These expenses are inclusive of, but not limited to items such as, portfolio management, client services, staff labor/payroll, rent, utilities, insurance, computer expenses, etc. - 7 -