Elios Financial Group, Inc.

Center Pointe West 30700 Center Ridge Road Westlake, OH 44145 P: (440) 617-9100 Email: jim@eliosfinancial.com Website: www.eliosfinancial.com Form ADV Part 2A Firm Brochure March 14, 2026 Item 1 – Cover Page This brochure provides information about the qualifications and business practices of Elios Financial Group, Inc. If you have any questions about the contents of this brochure, please contact us at (440) 617-9100. 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. Elios Financial Group, Inc. is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Elios Financial Group, Inc. is available on the SEC’s website www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Elios Financial Group, Inc. CRD number is 119873.  Item 2 - Material Changes We have no material changes to report since our last annual update filing on March 27, 2025. Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 - Material Changes ............................................................................................................................. 2 Item 3 – Table of Contents ............................................................................................................................ 2 Item 4 – Advisory Business ............................................................................................................................ 3 Item 5 – Fees and Compensation .................................................................................................................. 6 Item 6 – Performance-Based Fees and Side by Side Management ............................................................... 9 Item 7 – Types of Clients ............................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 9 Item 9 – Disciplinary Information ................................................................................................................ 12 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transaction and Personal Trading ................. 13 Item 12 – Brokerage Practices ..................................................................................................................... 13 Item 13 – Review of Accounts ..................................................................................................................... 17 Item 14 – Client Referrals and Other Compensation ................................................................................... 17 Item 15 – Custody ....................................................................................................................................... 18 Item 16 – Investment Discretion ................................................................................................................. 19 Item 17 – Voting Client Securities ............................................................................................................... 19 Item 18 – Financial Information .................................................................................................................. 20 Elios Financial Group, Inc. Page 2 ADV Part 2A – 3/14/2026  Item 4 – Advisory Business OWNERSHIP/ADVISORY HISTORY Elios Financial Group, Inc. (EFG) is an Ohio Corporation established on July 18, 1994. EFG was registered as an Ohio investment adviser on January 3, 1997. We subsequently registered with the Securities and Exchange Commission (SEC) on August 10, 2018. James T. Elios is the majority owner while Brandon Steinhagen is a minority owner. He is also Founder, President, CEO and Chief Compliance Officer. Additional information about Mr. Elios and Mr. Steinhagen can be found in their supplemental brochures, ADV Part 2B. ADVISORY SERVICES OFFERED We specialize in the following types of services: Financial Planning, Financial Consulting, Wealth Management, Investment Management, and referrals to Third-Party Money Managers. All material conflicts of interest are disclosed regarding the investment adviser, its representatives, or employees, which could be reasonably expected to impair the rendering of unbiased objective advice. FINANCIAL PLANNING, FINANCIAL CONSULTING AND WEALTH MANAGEMENT SERVICES We provide a variety of financial planning and consulting services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Personal Financial Planning, Investment Planning, Retirement and Income Planning, Estate Planning, Charitable Planning, Education Planning, Personal Tax Planning, and Insurance Analysis. We offer wealth management services that consist of ongoing financial advice that is tailored to meet each clients' specific needs and investment objectives. If you retain our firm for wealth management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you investment recommendations consistent with your financial goals. Our wealth management services may include, but are not limited to, the following components: 1. ENVISION Financial Plan (Custom) Our ENVISION (Advanced) Financial Plan package includes a combination of features and services designed to create exceptional value. This package will include a comprehensive financial plan with recommendations and analysis of asset allocation, retirement planning, college funding, and investments. Typical areas of focus may be cash flow management and forecasting, portfolio risk profiling, real estate strategies, tax planning, tax-efficient income distribution planning or estate concerns. A client may also receive access to a personal planning and account aggregation website to organize and track all of a client’s accounts as well as a printed plan presented in a binder for personal use. One of the important differences is that we make our client’s financial Elios Financial Group, Inc. Page 3 ADV Part 2A – 3/14/2026  plan central to our process. We create a plan for each Financial Planning client that is dynamic and designed to grow and evolve as a representation of the clients’ most current financial position. Each plan is a combination of the client’s assets, liabilities, risk tolerance, goals, objectives, time horizons, and financial attitudes. 2. Comprehensive Financial Plan The Comprehensive Plan is the backbone of a client’s long-term financial planning process. This plan is an objective evaluation and assessment of a focused area of the client’s finances. The process begins with a general snapshot of the client’s financial situation. We then help clarify the client’s main area of concern and provide the resources to develop a general assessment of his/her situation with potential options to achieve improvements. 3. Financial Assessment “Second Opinion” A Financial Assessment is an objective analysis and assessment of a focused area of concern. Areas of assessment include asset allocation, retirement planning, college funding, and investments. The Second Opinion (similar to asking for a second physician’s opinion) service is designed to provide an objective, no-obligation evaluation of a clients’ current portfolio or other advisors recommendations, the client’s existing plan, a financial product or a specific financial situation. INVESTMENT AND PORTFOLIO MANAGEMENT SERVICES We offer discretionary and non-discretionary portfolio management services to clients that consist of giving continuous advice to the client about the investment of funds based on the client's individual needs and objectives. The asset allocation of the client's assets will be structured to follow the recommended asset allocation model within their financial plan. In the case where a financial plan has not yet been constructed, the recommended asset allocation will be determined from an in-depth profile and interview with the client regarding their goals, current financial condition, timeline, risk tolerance, along with other financial suitability information. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you engage our firm for discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities to be purchased or sold for your account without your approval prior to each transaction. When appropriate and if needed, this discretionary authority will also provide our firm with authorization to delegate discretionary investment management services to other unaffiliated Third-Party Money Managers selected by our firm based on your investment objectives and portfolio strategy. Discretionary authority is granted by the advisory agreement you sign with our firm and the appropriate trading authorization forms. In our sole discretion, we may accept instructions from you that limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold in your account). Such requests must be presented to our firm in writing. To the extent we engage a Third-Party Money Elios Financial Group, Inc. Page 4 ADV Part 2A – 3/14/2026  Manager to assist us with managing your account on a discretionary basis, we will regularly monitor the performance of your accounts. We emphasize continuous and ongoing account supervision. As part of our investment management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), crypto-currency ETF’s, no-load and/or institutional mutual funds and other public and private securities as core investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all the previously mentioned securities. Each portfolio will be initially designed to meet the client’s investment goal; together with the client we determine what is suitable with respect to many factors including risk assessment, time horizon, need for liquidity etc. to his or her circumstance. Under the clients’ direction and instruction, we may also recommend screens for ESG Investing (Environmental, Societal and Governance)Once the portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based on the client’s individual needs, stated goals, market conditions and personal objectives. When appropriate and if needed, we may use a Third Party Money Manager where we select an investment portfolio and provide ongoing corresponding asset management services on a fee- only basis for a percentage of assets in conjunction with another investment advisory firm. Before selecting other advisers, we will perform due diligence and make sure that the other advisers are properly licensed or registered and have a demonstrated track record or success. Management of Accounts Held Away We provide an additional service with full discretion for accounts not directly held in our custody. Using the latest technology, we can analyze, recommend, trade, and implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, 403(b) accounts, HSA’s, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. WRAP PROGRAM We are a portfolio manager and a sponsor of a Wrap Fee Program, which is a type of investment program where clients pay a single fee that includes management fees and certain other brokerage costs. If you participate in our Wrap Fee Program, you will pay our firm a single fee, which includes our money management fees and certain transaction and trading costs. We receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our Wrap Fee Program may be higher or lower than you might incur by separately purchasing the types of securities available in the program. For more information concerning the Wrap Fee Program, please see our firm's Wrap Fee Disclosure Brochure (Form ADV Part 2A Appendix 1). CLIENT ASSETS MANAGED As of December 31, 2025, we manage $316,689,000 in client assets on a discretionary basis and $14,811,000 on a non-discretionary basis. Elios Financial Group, Inc. Page 5 ADV Part 2A – 3/14/2026  Item 5 – Fees and Compensation FINANCIAL PLANNING, FINANCIAL CONSULTING AND WEALTH MANAGEMENT SERVICES We charge an hourly or fixed fee for these services. The total estimated fee, as well as the ultimate fee, is based on the scope and complexity of our engagement with the client. Our hourly fee ranges from $100 to $300. Our fixed fee generally ranges between $1,500 and $3,000. The hourly and fixed fees are negotiable. We require a retainer of fifty-percent (50%) of the ultimate fee with the remainder of the fee directly billed to the client and due to us within thirty (30) days of the financial plan, financial consulting or wealth management service being delivered or rendered to the client. The client may cancel the financial planning and consulting service agreement for any reason during the first five (5) business days from the date of signing the agreement and he or she will receive a refund of 100% of all prepaid fees. To cancel the agreement, a client must notify us and return any materials received to that date. After the first five (5) business days, the client may cancel the agreement by giving ten (10) days written notice to Elios Financial Group, Inc., 30700 Center Ridge Road, Westlake, OH 44145. After five (5) business days if a client cancels, any prepaid fixed fees will be refunded on a pro-rated basis based upon a percentage of work completed and any prepaid hourly fees will be refunded based on the number of hours completed. INVESTMENT AND PORTFOLIO MANAGEMENT SERVICES We asses an investment management fee based on a percentage of assets under management in the client’s account. The annual management fee is based on the following fee schedule: Custodian Reported Account Value Annual Investment Management Fee First $100,000 2.00% Next $150,000 1.50% Next $250,000 1.00% Next $1,500,000 0.75% Next $3,000,000 0.50% Above $5,000,000 Negotiable Our investment management fee is billed quarterly, in advance, meaning we collect the investment management fee at the beginning of the quarter. The investment management fee will be based on the custodian reported account value as of the last business day of the previous Elios Financial Group, Inc. Page 6 ADV Part 2A – 3/14/2026  quarter. Cash balances and investments in money market funds are counted toward the account value and are included in the investment management fee calculations. Certain clients may be billed based on previous retired investment management (legacy) fee schedules. The investment management fee is tiered. A tiered investment management fee means the applicable rate will be applied to the custodian reported value in each appropriate range of account value. For example, an account with a quarter end value of $200,000 will be charged 2.00% on the first $100,000 and 1.50% on the remaining $100,000. In addition to our investment management fee, the client pays an annual program fee of 0.25%. The program fee is waivable at our discretion. The client will be asked to authorize us with to instruct the custodian to deduct our management fee directly from the account. The client may terminate this authorization at any time. As part of this process, the client understands and acknowledges the following: 1. The custodian selected to open investment accounts (i.e., Schwab) sends statements at least quarterly to client showing all disbursements for his/her account, including the amount of the advisory fees paid to us 2. The client provides written authorization through the Investment Advisory Agreement (IAA) permitting us to be directly paid by these terms. 3. We provide the client with a quarterly statement which will reflect the advisory fee billed through the independent custodian as well as historical performance reporting. Clients may incur certain other charges imposed by custodians, brokers, and other third parties such as custodial fees, 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. Mutual funds, index funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to, our fee and we will not receive any portion of these commissions, fees, and costs. For more information about our brokerage practice please see Item 11. Management of Accounts Held Away All clients engaging in investment management services of accounts held away must either engage in Comprehensive Financial Planning or meet a $150,000 minimum of assets under management. The fee for these accounts held away under our discretionary management will be assessed and billed quarterly. Specifically, the exact amount charged is determined by the daily average over the course of the quarter. The current exception for this is directly managed held-away accounts, which are determined by the account value at the end of the quarter. In either case, if the Adviser only manages your assets for part of a quarter, the charge will be prorated. The advisory fee is a blended fee and calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the daily average of the account value or the account value as of the last day of the previous quarter (per the paragraph above), resulting in a combined weighted fee. For example, an account valued at $2,000,000 would pay an effective fee of 1% with the annual fee being $20,000 (a quarterly fee Elios Financial Group, Inc. Page 7 ADV Part 2A – 3/14/2026  of $5,00). Investment management fees are generally directly debited on a pro rata basis from client accounts. The exception for this is directly-managed held-away accounts, such as 401(k)’s. As it is impossible to directly debit the fees from these accounts, those fees will be assigned to the client’s taxable accounts on a pro-rata basis. If the client does not have a taxable account, those fees will be billed directly to the client. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no rebate will be needed upon termination of the account. The client may terminate the Investment Advisory Agreement (IAA) for any reason at any time and, within the first five (5) business days after signing the contract, without any cost or penalty. Thereafter, the contract may be terminated at any time by giving ten (10) days written notice. Upon written notice of termination, the management fee will be prorated and refunded based upon the number of days in which services were rendered after the account’s valuation date. Please note the prorated refund may be adjusted for additional deposits and withdraws to the advisory account within the termination quarter. If permitted by the client’s custodian, the refund will be deposited into the client’s account; otherwise, the refund will be paid to the client by company check directly to the client within 30 days of the termination notice receipt. SECURITIES COMPENSATION THROUGH BROKER-DEALER Our owner and associates are registered representatives of independent broker-dealer Private Client Services, LLC, member FINRA/SIPC. Through this affiliation, they may engage in non- advisory brokerage business and accept compensation for the sale of securities or other investment products, including distribution or service (“trail”) fees from the sale of mutual funds or variable annuities. Clients should be aware that the practice of accepting commissions for the sale of securities presents a conflict of interest that gives our firm and representatives an incentive to recommend investment products based on the compensation receives, rather than on the client’s needs. We attempt to mitigate the conflict of interest by explaining to the client that commissionable securities sales create an incentive to recommend products based on compensation we and/or our representatives may earn and may not necessarily be in the best interest of the client. We also inform clients when recommending mutual funds that “no-load” funds are available through our firm if the client wishes to become an investment advisory client. Clients are always free to purchase investment products recommended by us through other brokers or agents that are not affiliated with us. RETIREMENT ROLLOVER CONFLICTS OF INTEREST When we recommend you rollover a retirement account for us to manage, this creates a financial incentive because we charge a fee for our services. We attempt to mitigate the conflict of interest by acting in your best interest and applying an impartial conduct standard to all rollovers. Please note that you are not under any obligation to roll over a retirement account to an account managed by us. Elios Financial Group, Inc. Page 8 ADV Part 2A – 3/14/2026  Item 6 – Performance-Based Fees and Side by Side Management We do not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or provide side by side management. Item 7 – Types of Clients We offer our services to individuals, families, pension and profit-sharing plans, trusts, estates, charitable organizations and corporations or other business. We may require a minimum account balance. Third-Party Advisers may have a minimum account size. Please refer to the Third-Party’s Form ADV Part 2A for details. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS AND INVESTMENT STRATEGIES We use various methods of analysis to help us manage client investment account(s). These may include one or more of the following: Asset Allocation- is an investment strategy that aims to balance risk and reward by apportioning a portfolio’s assets according to an individual’s goals, risk tolerance and investment horizon. The asset classes typically include equities, fixed-income, international, and cash and equivalents. The risk associated with asset allocation is that each class has different levels of risk and return, so each will behave differently over time. There is no guarantee that diversification among asset classes will grow a portfolio. Fundamental Analysis- is a technique that attempts to determine a security’s value by focusing on underlying factors that affect a company's actual business and its’ prospects. The analysis is performed on historical and present data. On a broader scope, one can perform fundamental analysis on industries or the macro economy. The term refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. The risk associated with fundamental analysis is that despite that appearance that a security is undervalued, it may not rise in value as predicted. Modern Portfolio Theory- proposes that investing in a predetermined asset mix derived from the efficient frontier (dictated to achieve a specific client objective within a certain risk tolerance) and rebalancing with discipline, the portfolio is diversified across the various asset classes to mitigate unnecessary risk. This also provides for a portfolio that can operate without reliance on market timing and security selection; however, as with all equity investments positive returns are not guaranteed. In conjunction to investing in a diversified portfolio, each portfolio is constructed to meet specific parameters set forth in the individual client’s investment policy statement and/or other documents. These parameters can include - but are not limited to - tax efficiency, concentrated stock positions and management history. Once again, the risk associated with a diversified portfolio is that each class has different levels of risk and return, so each will behave differently over time and despite being diversified there is no guarantee that an account will grow. Technical Analysis- is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a Elios Financial Group, Inc. Page 9 ADV Part 2A – 3/14/2026  security’s intrinsic value, but instead us charts and other tools to identify patterns that can suggest future activity. The risk associated with technical analysis is that there is no broad consensus among technical traders on the best method of identifying future price movements. We use various investment strategies when managing client investment accounts. These may include one or more of the following: Long-Term Purchases- We purchase securities with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. The risk associated with using a long-term purchase strategy is that it generally assumes the financial markets will go up in the long-term, which may not be the case. There is also the risk that the segment of the market that the client is invested in or perhaps just that client’s particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. Short-Term Purchases- We purchase certain securities with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations. The risk associated with using a short-term purchase strategy is that it generally assumes that we can predict how financial markets will perform in the short-term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. Periodic Rebalancing- Rebalancing is the process of realigning the weighting of a portfolio of assets. Rebalancing involves periodically buying or selling assets in a portfolio to maintain an original desired level of asset allocation. Unless otherwise negotiated with the client, we rebalance client accounts on a quarterly basis. The risk associated with rebalancing is that an account may miss out on the full upside of asset allocation because of the realigning of the account’s assets. INVESTMENT RISKS All investments bear different types and degrees of risk and investing in securities involves risk of loss that clients should be prepared to bear. While we use investment strategies that are designed to provide appropriate investment diversification, but some investments have significantly greater risks than others. Obtaining higher rates of return on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. The client should feel free to ask questions about risks that he or she does not understand; we would be pleased to discuss them. RECOMMENDED SECURITIES AND RISKS We use several types of securities in client portfolios including, but not limited to, exchange traded funds (ETFs), mutual funds and stocks. Some of the risks associated with these securities include: Elios Financial Group, Inc. Page 10 ADV Part 2A – 3/14/2026  • Credit Risk: This is the risk that an issuer of a bond could suffer an adverse change in financial condition that results in a payment default, security downgrade, or inability to meet a financial obligation. • Exchange-Traded Funds (ETFs): ETFs are typically investment companies that are legally classified as open-end mutual funds or UITs, however, they differ from traditional mutual funds because ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as investment companies under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, including those that invest in commodities, are not registered as investment companies. • Inflation Risk: This is the risk that inflation will undermine the performance of an investment and/or the future purchasing power of a client's assets. • Interest Rate Risk: The chance that bond prices overall will decline because of rising interest rates. Interest rate risk will vary for the Firm, depending on the amount of client assets invested in bonds. • International Investing Risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, as well as regulatory and financial reporting standards, that differ from those of the U.S. • Manager Risk: The chance that the proportions allocated to the various securities will cause the client’s account to underperform relevant to benchmarks or other accounts with a similar investment objective. • Portfolio Concentration: Accounts that are not diversified among a wide range of types of securities, countries or industry sectors may have more volatility and are considered to have more risk than accounts that are invested in a greater number of securities because changes in the value of a single security may have more of a significant effect, either negative or positive. Accordingly, portfolios are subject to more rapid changes in value than would be the case if the client maintained a more diversified portfolio. • Stock Market Risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising stock prices and periods of falling stock prices. • Digital Asset Risk: The investment characteristics of “Digital Assets” (e.g., a digital representation of value that will or can be digitally traded) generally differ from those of traditional fiat currencies, commodities or securities. Importantly, Digital Assets are typically Elios Financial Group, Inc. Page 11 ADV Part 2A – 3/14/2026  not backed by a central bank or a national, supra-national or quasi-national organization, any hard assets, human capital, or other form of credit. Rather, Digital Assets are market-based: a Digital Asset’s value is determined by (and fluctuates often, according to) supply and demand factors, the number of merchants that accept it, and the value that various market participants place on it through their mutual agreement, barter or transactions. The term “Digital Assets” includes, without limitation, virtual currencies, digital currencies, crypto assets, cryptocurrencies, digital coins and tokens. We may make “digital” investments in portfolio companies, for example, by participating in offerings, sales or presales of Digital Assets (e.g., initial, subsequent or secondary “coin offerings” and offerings of agreements for future delivery of Digital Assets (collectively, “Digital Asset Offerings”)) facilitated by blockchain marketplaces. The growth of this industry is subject to a high degree of uncertainty. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would-be material to your evaluation of each supervised person providing investment advice. We do not have information applicable to this item. Item 10 – Other Financial Industry Activities and Affiliations BROKER DEALER AFFILIATION As described under Item 5.E, above, our owner and associates are registered representatives of broker-dealer Private Client Services, LLC. Please see above for additional details about the relationship and any conflicts of interest. FUTURES/COMMODITIES FIRM AFFILIATION We are not affiliated with a futures or commodities broker. OTHER INDUSTRY AFFILIATIONS Our owner and associates may be licensed insurance agents and appointed with various insurance companies. They may recommend insurance products to the firm’s clients. This service pays them commissions that are separate from the investment adviser fees outlined in Item 5 above. This is a conflict of interest because it creates a financial incentive to recommend insurance products. However, they attempt to mitigate any conflicts of interest to the best of their ability by placing the client’s interests ahead of their own and through the implementation of policies and procedures that address the conflict. Additionally, the client is informed that he or she always has the right to choose whether to act on the recommendation and he or she has the right to purchase recommended insurance through any licensed insurance agent. RECOMMENDATION OF THIRD- PARTY INVESTMENT ADVISER We may recommend the services of third-party investment advisers. This information can be found under Items 4 and 5. We will ensure that the Third-Party Adviser is properly registered or exempt from registration in the client’s state of residence prior to making any recommendation. We receive a portion of the Third-Party Adviser’s management fee, which creates a financial incentive to recommend Third Party Advisers that pay a higher percentage of the management Elios Financial Group, Inc. Page 12 ADV Part 2A – 3/14/2026  fee. We attempt to mitigate the conflict of interest to best of our ability by placing the client’s interest ahead of our own, through our fiduciary duty and by following our Code of Ethics that establishes ideals for ethical conduct. Item 11 – Code of Ethics, Participation or Interest in Client Transaction and Personal Trading DESCRIPTION Our Code of Ethics establishes ideals for ethical conduct based upon fundamental principles of openness, integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any client or prospective client upon request. Our Code of Ethics covers all supervised persons, and it describes our high standard of business conduct and fiduciary duty to our clients. The Code of Ethics includes, among other things, provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition on rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons must acknowledge the terms of the Code of Ethics annually or as amended. MATERIAL INTEREST IN SECURITIES We do not have a material interest in any securities. INVESTING IN OR RECOMMENDING THE SAME SECURITIES Our owner may buy or sell for his own accounts the same securities at or about the same time that they recommend those securities to clients or purchase them for client accounts. A conflict of interest may exist because they can trade ahead of client accounts. We mitigate any conflicts of interest in two ways. First, our Code of Ethics requires employees to report personal securities transactions on at least a quarterly basis and provide us with a detailed summary of certain holdings (both initially upon commencement of employment and quarterly thereafter) in which employees have a direct or indirect beneficial interest. The reports are reviewed to endure we do not trade ahead of client accounts. Second, we require client transactions be placed ahead of our associates’ personal trades or our associates can place personal trades as part of a block trade (Please see Item 11 for details on our block trading practices). The records of all associates’ personal and client trading activities are reviewed and made available to regulators to review on the premises. Item 12 – Brokerage Practices RECOMMENDATION CRITERIA We do not maintain custody of your assets [that we manage/on which we advise], although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, as the qualified Elios Financial Group, Inc. Page 13 ADV Part 2A – 3/14/2026  custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with Schwab, then we cannot manage your account. HOW WE SELECT BROKERS/CUSTODIANS We seek to use Schwab, a custodian/broker that will hold your assets and execute transactions. When considering whether the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: We recommend Schwab, a custodian/ broker, to hold your assets and execute transactions. When considering whether the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: • Combination of transaction execution services and asset custody services generally without a separate fee for custody) • Capability to execute, clear, and settle trades ( buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security, and stability • Prior service to us and our clients • Services delivered or paid for by Schwab • Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) YOUR BROKERAGE AND CUSTODY COSTS Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Elios Financial Group, Inc. Page 14 ADV Part 2A – 3/14/2026  Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). By using another broker or dealer you may pay lower transaction costs. PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events Elios Financial Group, Inc. Page 15 ADV Part 2A – 3/14/2026  • Consulting on technology and business needs • Consulting on legal and related compliance needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. OUR INTEREST IN SCHWAB’S SERVICES The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. [These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody.] The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. [In some cases, the services that Schwab pays for are provided by an affiliate of ours or by another party that has some pecuniary, financial or other interests in us (or in which we have such an interest). This creates an additional conflict of interest.] We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s services that benefit only us. BROKERAGE FOR CLIENT REFERRALS We do not receive client referrals from any broker-dealer or custodian. DIRECTED BROKERAGE Some clients may direct us to use a specific broker-dealer to execute securities transactions for their accounts. When so directed, we may not be able to effectively achieve best execution on client’s transactions. TRADE AGGREGATION We will have the authority to aggregate or block client orders placed with the same custodian. To the extent any aggregated or block orders are placed, we will cause those orders to be affected through an average price account or similar account such that each account at the same custodian participating in the order shares in the securities purchased or sold, price, and transaction costs pro rata (unless pro rata would be unfair under the circumstances). As a result, the average price account will allocate proportionate shares to each client’s account. It will also provide clients with an average price for the securities transaction or transactions, which could reduce the transaction costs for the client. Elios Financial Group, Inc. Page 16 ADV Part 2A – 3/14/2026  Item 13 – Review of Accounts PERIODIC REVIEWS We review accounts on at least a quarterly basis for our Investment Management and Third-Party Money Management clients. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. We review our client’s financial plans annually with the calendar triggering the review. The client’s representative will conduct the review. OTHER REVIEWS Additional reviews are conducted on demand by the client or periodically depending on market conditions, economic or political events, or by changes in a client’s financial situation (such as retirement, termination of employment, physical move, or inheritance). REPORTS Our Portfolio Management clients receive at least quarterly account statements from their custodian. Third-Party money manager clients will receive at least quarterly account statements from the Third-Party Investment Adviser or the custodian of their account. We urge clients to carefully review such statements. Financial planning clients receive a list of recommendation upon the completion of the financial planning process. Item 14 – Client Referrals and Other Compensation OTHER COMPENSATION We can receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the referral arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices) CLIENT REFERRALS We may offer our portfolios to other independent registered investment advisers pursuant to third-party management or solicitor agreements. When registered investment advisers use our portfolios, they receive a portion of our annual management fee, but not a portion of the program fee. The registered investment advisers will likely share a portion of the fees with their own representatives. It is important to note that the annual management fee is determined by Elios Financial Group, Inc. Page 17 ADV Part 2A – 3/14/2026  our fee schedule. The registered advisers’ portion is deducted from the management fee, not added to it. We are aware of the special considerations promulgated pursuant to SEC Rule 206(4)-3 of the Investment Adviser Act of 1940 (the “Act”). As such, appropriate disclosures describing the terms and fee arrangements between the us and a solicitor will be made to our clients, all required written records will be maintained, and all applicable laws and regulations will be observed. A Solicitor’s Disclosure Document will be provided to each client, as required under the Act, and we will retain the client’s signed acknowledgement of receiving the Adviser’s Form ADV Part 2A and the Solicitors Disclosure Document. Item 15 – Custody All client funds, securities and accounts are held at a qualified custodian. We do not take possession of a client’s securities. However, the client will be asked to authorize us with the ability to instruct the account’s custodian to deduct our management fee directly from the client’s account. The client may terminate this authorization at any time. The client will receive at least a quarterly account statement from the qualified custodian that holds the client’s assets. We urge each client to carefully review the account statement. Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least quarterly. They will be sent to the email or postal mailing address you provided to Schwab. You should carefully review those statements promptly when you receive them. We also urge you to compare Schwab’s account statements with the periodic account statements you will receive from us. Pursuant to Rule 206(4)-2 of the Advisers Act, Elios Financial is deemed to have custody of client funds because the Firm has the authority and ability to debit its’ fees directly from clients’ accounts. To mitigate any potential conflicts of interests, all Elios Financial client account assets will be maintained with an independent qualified custodian. Elios Financial is also deemed to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and under that SLOA authorize Elios Financial to facilitate the transfer. When your money is transferred between accounts with different titles, this is considered a limited form of custody. In 2017, 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 SEC has set forth a set of standards intended to protect client assets in such situations, which Elios Financial follows. • 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 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. Elios Financial Group, Inc. Page 18 ADV Part 2A – 3/14/2026  • 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 We offer discretionary and non-discretionary investment management services. The client grants us discretionary power over his or her account when the investment management agreement is signed. Our investment management agreement contains a limited power of attorney that allows us to select the securities to be bought and sold, the amount of securities to be bought and sold, and time they can be bought and sold. It allows us to place each trade without the client’s prior approval. In addition to our investment management agreement, the client’s custodian may request the client sign the custodian’s limited power of attorney form. This varies with each custodian. We will discuss all limited powers of attorney prior to their execution. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the client’s account, and any other investment policies, limitation, or restrictions. A non-discretionary investment account requires us to receive permission from the client prior to buying and/or selling securities in the client’s account. The client retains full discretion to supervise, manage, and direct the assets of the account. The client maintains full power and authority to purchase, sell, invest, reinvest, exchange, convert, and trade assets in the account in any manner deemed appropriate and to place all orders for the purchase and sale of account assets with or through broker, dealers, or issuers selected by the client. The client is free to manage the account with or without our recommendation and all with or without its prior consultation. Item 17 – Voting Client Securities We may accept authority to vote proxy solicitations for client securities. Clients can retain the right to vote all proxies that are solicited for securities held in the account. Clients may receive proxies or other solicitations from the custodian. If clients have questions regarding the solicitation, they should contact us or the contact person that the issuer identifies in the proxy materials. In addition, we do not accept authority to act with respect to legal proceedings relating to securities held in the account. Elios Financial Group, Inc. Page 19 ADV Part 2A – 3/14/2026  Item 18 – Financial Information BALANCE SHEET At no time will fees of more than $1,200 be charged six or more months in advance. As such, a balance sheet is not required to be provided at this time. FINANCIAL CONDITION We are required in this Item to provide clients with certain financial information or disclosures about our financial condition if we have a financial commitment that impairs our ability to service clients. We do not have a financial commitment that impairs our ability to service clients. BANKRUPTCY We have never been the subject of a bankruptcy proceeding. Elios Financial Group, Inc. Page 20 ADV Part 2A – 3/14/2026 

Center Pointe West 30700 Center Ridge Road Westlake, OH 44145 Phone: (440) 617-9100 Email: jim@eliosfinancial.com Website: www.eliosfinancial.com ADV Part 2A Appendix 1: Wrap Fee Program Brochure March 14, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Elios Financial Group, Inc. If you have any questions about the contents of this brochure, please contact us at (440) 617-9100. 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 Elios Financial Group, Inc. is 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 CRD number for Elios Financial Group, Inc. is 119873.  Item 1 - Material Changes We have no material changes to report since our last annual update filing on March 27, 2025. Item 2 – Table of Contents Item 1 - Material Changes ............................................................................................................................. 2 Item 2 – Table of Contents ............................................................................................................................ 2 Item 3 – Services, Fees and Compensation .................................................................................................. 3 Item 4 – Account Requirements and Types of Clients .................................................................................. 6 Item 5 – Portfolio Manager Selection and Evaluation .................................................................................. 7 Item 6 – Client Information Provided to Portfolio Managers ..................................................................... 10 Item 7 – Client Contract with Portfolio Managers ...................................................................................... 11 Item 8 – Client Referrals and Other Compensation .................................................................................... 11 Item 9 – Additional Information ................................................................................................................. 12 Item 10 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12 Item 11 - Financial Information .................................................................................................................. 13 Elios Financial Group, Inc. Page 2 Appendix 1 – 3/14/2026  Item 3 – Services, Fees and Compensation INVESTMENT AND PORTFOLIO MANAGEMENT SERVICES We offer discretionary portfolio management services to clients that consist of giving continuous advice to the client about the investment of funds based on the client's individual needs and objectives. The asset allocation of the client's assets will be structured to follow the recommended asset allocation model within their financial plan. In the case where a financial plan has not been constructed, the recommended asset allocation will be determined from an in-depth profile and interview with the client regarding their goals, current financial condition, timeline, risk tolerance, along with other financial suitability information. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. DISCRETION If you engage our firm for discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. This discretionary authority will also provide our firm with authorization to delegate discretionary investment management services to other unaffiliated Sub-Advisors selected by our firm based on your investment objectives and portfolio strategy. Discretionary authority is granted by the advisory agreement you sign with our firm and the appropriate trading authorization forms. In our sole discretion, we may accept instructions from you that limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account). Such requests must be presented to our firm in writing. To the EXTENT we engage a Sub- Advisor to assist us with managing your account on a discretionary basis, we will regularly monitor the performance of your accounts. ONGOING MANAGEMENT We emphasize continuous and ongoing account supervision. As part of our investment management service, we generally create a portfolio, consisting of individual stocks, exchange traded funds (“ETFs”), and other public and private securities as core investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all the previously mentioned securities. Each portfolio will be initially designed to meet the client’s investment goal; together with the client we determine what is suitable with respect to many factors including risk assessment, time horizon, need for liquidity, etc. and his or her circumstances. Once the portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based on the client’s individual needs, stated goals and objectives. Each client can place reasonable restrictions on the types of investment to be held in the portfolio. We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks, exchange traded funds Elios Financial Group, Inc. Page 3 Appendix 1 – 3/14/2026  (“ETFs”), and other public and private securities as core investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all the previously mentioned securities. Each portfolio will be initially designed to meet an investment goal; together with the client we determine what is suitable to the client’s circumstances. Once the portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based on the client’s individual needs, stated goals and objectives. Each client can place reasonable restrictions on the types of investment to be held in the portfolio. We may use Third Party Independent Money Managers, where we may select an investment portfolio and provide ongoing corresponding asset management services on a fee-only basis for a percentage of assets in conjunction with another investment advisory firm. Before selecting other advisers, we will perform due diligence and make sure that the other advisers are properly licensed or registered. FEES The investment management fee for wrap accounts is calculated and billed quarterly in advance using the following annualized rates: Custodian Reported Account Value Annual Investment Management Fee First $100,000 2.00% Next $150,000 1.50% Next $250,000 1.00% Next $1,500,000 0.75% Next $3,000,000 0.50% Above $5,000,000 Negotiable Our investment management fee is billed quarterly, in advance, meaning we collect the investment management fee at the beginning of the quarter. The investment management fee will be based on the custodian reported account value as of the last business day of the previous quarter. Cash balances and investments in money market funds are counted toward the account value and are included in the investment management fee calculations. Certain clients may be billed based on previous retired investment management (legacy) fee schedules. The investment management fee is tiered. A tiered investment management fee means the applicable rate will be applied to the custodian reported value in each appropriate range of account value. For example, an account with a quarter end value of $200,000 will be charged 2.00% on the first $100,000 and 1.50% on the remaining $100,000. In addition to our investment management fee the client may pay an annual program fee of 0.25%. The program fee is waivable at our discretion. Elios Financial Group, Inc. Page 4 Appendix 1 – 3/14/2026  In a wrap account, clients pay a single annual advisory fee for advisory services and execution of transactions. Clients do not pay brokerage commissions, markups or transaction charges for execution of transactions in addition to the advisory fee. TERMINATION OF PORTFOLIO MANAGEMENT SERVICES A client may terminate the Investment Management Agreement for any reason at any time and, within the first 5 business days after signing the contract, without any cost or penalty. Thereafter, the contract may be terminated at any time by giving 10 days' written notice. To cancel the Agreement, the client must notify the firm in writing at Elios Financial Group, Inc. 30700 Center Ridge Road, Westlake, OH 44145. Upon written notice of termination, the client will receive a prorated refund based on the amount of the time elapsed during the quarter. For example, if the client cancels 45-days into a 90-day quarter, the client will receive a refund of 50% of the fees (45 divided by 90 equals 50 percent). Please note the prorated refund may be adjusted for additional deposits and withdraws to the advisory account within the termination quarter. If permitted by the client’s custodian, the refund will be deposited into the client’s account; otherwise, the refund will be paid to the client by company check directly to the client within 30- days of the termination notice receipt. OTHER TYPES OF FEES AND CHARGES Program accounts may incur additional fees and charges from parties other than us as noted below. These fees and charges are in addition to the normal advisory fees. Charles Schwab, as the custodian and broker-dealer providing brokerage and execution services on program accounts, will impose certain fees and charges. Charles Schwab notifies clients of these charges at account opening and we can provide a copy at the client’s request. Charles Schwab will deduct these fees and charges directly from the client’s program account. There are other fees and charges that are imposed by other third parties that apply to investments in program accounts. Some of these fees and charges are described below: • If a client’s assets are invested in mutual funds or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. Client will also pay us the advisory fee with respect to those assets. Most of the mutual funds available in the program may be purchased directly. Therefore, clients could generally avoid the second layer of fees by not using our management services and by making their own investment decisions. • If client holds a variable annuity as part of an account, there are mortality, expense and administrative charges, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. Further information regarding fees assessed by a mutual fund, or variable annuity is available in the appropriate prospectus, which is available upon request from us or from the product sponsor directly. Elios Financial Group, Inc. Page 5 Appendix 1 – 3/14/2026  OTHER IMPORTANT CONSIDERATIONS • The advisory fee is an ongoing wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. The advisory fee may cost the client more than purchasing the program services separately, because the client could pay an advisory fee plus commissions for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the type and size of the account, historical or expected size or number of trades for the account, and number and range of supplementary advisory and client-related services provided to the client. • The advisory fee also may cost the client more than if assets were held in a traditional brokerage account. In a brokerage account, a client is charged a commission for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than a program account. • The investment products available to be purchased in the program can be purchased by clients outside of a program account, through broker-dealers or other investment firms not affiliated with us. RETIREMENT ROLLOVER CONFLICTS OF INTEREST When we recommend you rollover a retirement account for us to manage, this creates a financial incentive because we charge a fee for our services. We attempt to mitigate the conflict of interest by acting in your best interest and applying an impartial conduct standard to all rollovers. Please note that you are not under any obligation to roll over a retirement account to an account managed by us. Item 4 – Account Requirements and Types of Clients We offer our services to individuals, families, pension and profit-sharing plans, trusts, estates, charitable organizations and corporations or other business. We may require a minimum account balance. Third-Party Advisers may have a minimum account size. Please refer to the Third-Party’s Form ADV Part 2A for details. Wrap Fee Program Disclosures The benefits under a wrap fee program depend, in part, upon the size of the account, the • costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not • limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap fee arrangement is appropriate for you, you should • compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker- Elios Financial Group, Inc. Page 6 Appendix 1 – 3/14/2026  dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. Conflict of Interest. When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. • For example, our wrap fee arrangement creates incentives for our advisers to trade less frequently or select investments that that reduce our costs, and in some cases increase expenses that are borne by the client. Additionally, Schwab generally does not charge commissions [or transaction fees] for online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these types of securities, we can do so without paying commissions to Schwab. Item 5 – Portfolio Manager Selection and Evaluation In our wrap program, we do not select, review or recommend other investment advisors or portfolio managers. We, through our associated persons, are responsible for the investment advice and management offered to clients. For more information about the associated person managing the account, the client should refer to the Brochure Supplement (ADV Part 2B) for the associated person, which the client should have received along with this Brochure at the time client opened the account. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS We use various methods of analysis to help us manage client investment account(s). These may include one or more of the following: ASSET ALLOCATION- is an investment strategy that aims to balance risk and reward by apportioning a portfolio’s assets according to an individual’s goals, risk tolerance and investment horizon. The asset classes typically include equities, fixed-income, international, and cash and equivalents. The risk associated with asset allocation is that each class has different levels of risk and return, so each will behave differently over time. There is no guarantee that diversification among asset classes will grow a portfolio. FUNDAMENTAL ANALYSIS- is a technique that attempts to determine a security’s value by focusing on underlying factors that affect a company's actual business and its prospects. The analysis is performed on historical and present data. On a broader scope, one can perform fundamental analysis on industries or the economy. The term refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. The risk associated with fundamental analysis is that despite that appearance that a security is undervalued, it may not rise in value as predicted. Elios Financial Group, Inc. Page 7 Appendix 1 – 3/14/2026  MODERN PORTFOLIO THEORY- proposes that investing in a predetermined asset mix derived from the efficient frontier (dictated to achieve a specific client objective within a certain risk tolerance) and rebalancing with discipline, the portfolio is diversified across the various asset classes to mitigate unnecessary risk. This also provides for a portfolio that can operate without reliance on market timing and security selection; however, as with all equity investments positive returns are not guaranteed. In conjunction to investing in a diversified portfolio, each portfolio is constructed to meet specific parameters set forth in the individual client’s investment policy statement and/or other documents. These parameters can include - but are not limited to - tax efficiency, concentrated stock positions and management history. Once again, the risk associated with a diversified portfolio is that each class has different levels of risk and return, so each will behave differently over time and despite being diversified there is no guarantee that an account will grow. TECHNICAL ANALYSIS- is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value, but instead us charts and other tools to identify patterns that can suggest future activity. The risk associated with technical analysis is that there is no broad consensus among technical traders on the best method of identifying future price movements. We use various investment strategies when managing client investment accounts. These may include one or more of the following: LONG-TERM PURCHASES- We purchase securities with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. The risk associated with using a long-term purchase strategy is that it generally assumes the financial markets will go up in the long-term, which may not be the case. There is also the risk that the segment of the market that the client is invested in or perhaps just that client’s particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. SHORT-TERM PURCHASES- We purchase certain securities with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations. The risk associated with using a short-term purchase strategy is that it generally assumes that we can predict how financial markets will perform in the short-term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. PERIODIC REBALANCING- Rebalancing is the process of realigning the weighting of a portfolio of assets. Rebalancing involves periodically buying or selling assets in a portfolio to maintain an original desired level of asset allocation. Unless otherwise negotiated with the client, we rebalance client accounts on a quarterly basis. The risk associated with rebalancing is that an account may miss out on the full upside of asset allocation because of the realigning of the account’s assets. Elios Financial Group, Inc. Page 8 Appendix 1 – 3/14/2026  INVESTMENT RISKS- All investments bear different types and degrees of risk and investing in securities involves risk of loss that clients should be prepared to bear. While we use investment strategies that are designed to provide appropriate investment diversification, but some investments have significantly greater risks than others. Obtaining higher rates of return on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. The client should feel free to ask questions about risks that he or she does not understand; we would be pleased to discuss them. RECOMMENDED SECURITIES AND RISKS We use several types of securities in client portfolios including, but not limited to, mutual funds, exchange traded funds (ETFs), stocks and bonds. Some of the risks associated with these securities include: • Credit Risk: This is the risk that an issuer of a bond could suffer an adverse change in financial condition that results in a payment default, security downgrade, or inability to meet a financial obligation. • Exchange-Traded Funds (ETFs): ETFs are typically investment companies that are legally classified as open-end mutual funds or UITs, however, they differ from traditional mutual funds because ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as investment companies under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, including those that invest in commodities, are not registered as investment companies. • Inflation Risk: This is the risk that inflation will undermine the performance of an investment and/or the future purchasing power of a client's assets. • Interest Rate Risk: The chance that bond prices overall will decline because of rising interest rates. Interest rate risk will vary for the Firm, depending on the amount of client assets invested in bonds. • International Investing Risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, as well as regulatory and financial reporting standards, that differ from those of the U.S. • Manager Risk: The chance that the proportions allocated to the various securities will cause the client’s account to underperform relevant to benchmarks or other accounts with a similar investment objective. Elios Financial Group, Inc. Page 9 Appendix 1 – 3/14/2026  • Portfolio Concentration: Accounts that are not diversified among a wide range of types of securities, countries or industry sectors may have more volatility and are considered to have more risk than accounts that are invested in a greater number of securities because changes in the value of a single security may have more of a significant effect, either negative or positive. Accordingly, portfolios are subject to more rapid changes in value than would be the case if the client maintained a more diversified portfolio. • Stock Market Risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising stock prices and periods of falling stock prices. • Digital Asset Risk: The investment characteristics of “Digital Assets” (e.g., a digital representation of value that will or can be digitally traded) generally differ from those of traditional fiat currencies, commodities or securities. Importantly, Digital Assets are typically not backed by a central bank or a national, supra-national or quasi-national organization, any hard assets, human capital, or other form of credit. Rather, Digital Assets are market-based: a Digital Asset’s value is determined by (and fluctuates often, according to) supply and demand factors, the number of merchants that accept it, and the value that various market participants place on it through their mutual agreement, barter or transactions. The term “Digital Assets” includes, without limitation, virtual currencies, digital currencies, crypto assets, cryptocurrencies, digital coins and tokens. We may make “digital” investments in portfolio companies, for example, by participating in offerings, sales or presales of Digital Assets (e.g., initial, subsequent or secondary “coin offerings” and offerings of agreements for future delivery of Digital Assets (collectively, “Digital Asset Offerings”)) facilitated by blockchain marketplaces. The growth of this industry is subject to a high degree of uncertainty. VOTING CLIENT SECURITIES We may accept authority to vote proxy solicitations for client securities. Clients can retain the right to vote all proxies that are solicited for securities held in the account if expressed upon the opening of client accounts. Clients may receive proxies or other solicitations from the custodian. If clients have questions regarding the solicitation, they should contact us or the contact person that the issuer identifies in the proxy materials. In addition, we do not accept authority to act with respect to legal proceedings relating to securities held in the account. Item 6 – Client Information Provided to Portfolio Managers In our wrap program, we are responsible for account management; there is no separate portfolio manager involved. We obtain the necessary financial data from the client and assist the client in setting an appropriate investment objective for the account. We obtain this information by having the client complete an advisory agreement and other documentation. Clients are encouraged to contact us if there have been any changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Clients should be aware that the investment objective selected for the program is an overall objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time. Clients should Elios Financial Group, Inc. Page 10 Appendix 1 – 3/14/2026  further be aware that achievement of the stated investment objective is a long-term goal for the account. Item 7 – Client Contract with Portfolio Managers Clients should contact us at any time with questions regarding program accounts. Item 8 – Client Referrals and Other Compensation OTHER COMPENSATION We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the referral arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described below. PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. These products and services, how they benefit us, and the related conflicts of interest are described in Form ADV Part 2A, Item 12 – Brokerage Practices. CLIENT REFERRALS We may offer our portfolios to other independent registered investment advisers (RIA’s) pursuant to third-party management or solicitor agreements. When registered investment advisers use our portfolios, they receive a portion of our annual management fee, but not a portion of the program fee. The registered investment advisers will likely share a portion of the fees with their own representatives. It is important to note that the annual management fee is determined by our fee schedule. The registered advisers’ portion is deducted from the management fee, not added to it. We are aware of the special considerations promulgated pursuant to SEC Rule 206(4)-3 of the Investment Adviser Act of 1940 (the “Act”). As such, appropriate disclosures describing the terms and fee arrangements between the us and a solicitor will be made to our clients, all required written records will be maintained, and all applicable laws and regulations will be observed. A Solicitor’s Disclosure Document will be provided to each client, as required under the Act, and we will retain the client’s signed acknowledgement of receiving the Adviser’s Form ADV Part 2A and the Solicitors Disclosure Document. Elios Financial Group, Inc. Page 11 Appendix 1 – 3/14/2026  Item 9 – Additional Information DISCIPLINARY INFORMATION Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events within the past 10-years that would be material to a client's evaluation of us or the integrity of our management. We have no information applicable to this Item because we have not been the subject of any administrative, civil, criminal, or regulatory proceedings. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Our associates are registered representatives of Private Client Services, LLC, a full-service broker/dealer and member FINRA/SIPC (“PCS”). Through PCS, we may offer insurance or annuity products only available through a Broker-Dealer. These products may pay a commission unrelated to any advisory fee arrangements with the RIA, EFG, Inc. This causes a conflict of interest because the commission is separate from the fees outlined above. They attempt to mitigate this conflict of interest to the best of their ability by placing the client’s interest ahead of their own through their fiduciary duty. Additionally, it is our policy that recommended securities purchases do not have to be purchased through our associates. Our associates may be licensed insurance agents and appointed with various insurance companies. They may recommend insurance products to our clients. This service pays them commissions that are separate from the investment adviser fees outlined in Item 4 above. This creates a financial incentive to recommend insurance products. However, they attempt to mitigate any conflicts of interest to the best of their ability by placing the client’s interests ahead of their own and through the implementation of policies and procedures that address the conflict. Additionally, the clients are informed that they always have the right to choose whether to act on the recommendation and they have the right to purchase recommended insurance products through any licensed insurance agent. Item 10 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading DESCRIPTION Our Code of Ethics establishes ideals for ethical conduct based upon fundamental principles of openness, integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any client or prospective client upon request. Our Code of Ethics covers all supervised persons, and it describes our high standard of business conduct and fiduciary duty to our clients. The Code of Ethics includes, among other things, provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition on rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons must acknowledge the terms of the Code of Ethics annually or as amended. Elios Financial Group, Inc. Page 12 Appendix 1 – 3/14/2026  MATERIAL INTEREST IN SECURITIES We do not have a material interest in any securities. INVESTING IN OR RECOMMENDING THE SAME SECURITIES Our associates may buy or sell for their own accounts the same securities at or about the same time that they recommend those securities to clients or purchase them for client accounts. A conflict of interest may exist because they can trade ahead of client accounts. We mitigate any conflicts of interest in two ways. First, our Code of Ethics requires employees to report personal securities transactions on at least a quarterly basis and provide us with a detailed summary of certain holdings (both initially upon commencement of employment and quarterly thereafter) in which employees have a direct or indirect beneficial interest. The reports are reviewed to endure we do not trade ahead of client accounts. Second, we require client transactions be placed ahead of our associates’ personal trades or our associates can place personal trades as part of a block trade (Please see Item 12.B for details on our block trading practices). The records of all associates’ personal and client trading activities are reviewed and made available to regulators to review on the premises. REVIEW OF ACCOUNTS For our Portfolio and Third-Party Money Management clients, our Chief Investment officer and principal, James Elios will review accounts on at least a quarterly basis. We will also attempt to meet with each client on an annual basis either in person or by telephone. REVIEW TRIGGERS Other factors triggering an account review include material market, economic or political events, and changes in a client's financial or personal situation or performance of the account in general. REPORTS AND ACCOUNT STATEMENTS A client will receive at least quarterly statements from the account’s custodian. However, the client will receive a monthly statement, if his or her account(s) has activity during the month. These account statements will show any activity in the account, as well as period ending position balances. Performance reports will be generated on demand and be made available via mail, in- person reviews and through secured email and/or online client portals. Item 11 - Financial Information BALANCE SHEET At no time will fees of more than $1,200 be charged six or more months in advance. As such, a balance sheet is not required to be provided at this time. FINANCIAL CONDITION We are required in this Item to provide clients with certain financial information or disclosures about our financial condition if we have a financial commitment that impairs our ability to service clients. We do not have a financial commitment that impairs our ability to service clients. BANKRUPTCY - We have not been the subject of a bankruptcy proceeding. Elios Financial Group, Inc. Page 13 Appendix 1 – 3/14/2026