Overview

Headquarters
Cumming, GA
Total Firm Assets
$188 million
Average High-Net-Worth Client Portfolio Size
$1.8 million

Fee Structure

Primary Fee Schedule (ADV BROCHURE PART 2A)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $2,000,000 0.90%
$2,000,001 $3,000,000 0.80%
$3,000,001 $5,000,000 0.65%
$5,000,001 and above 0.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $40,000 0.80%
$10 million $65,000 0.65%
$50 million $265,000 0.53%
$100 million $515,000 0.52%

Clients

High-Net-Worth Share of Firm Assets
62.74%
Number of High-Net-Worth Clients
64
Total Client Accounts
577
Discretionary Accounts
567
Non-Discretionary Accounts
10

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

SEC CRD Number
108062

Additional Brochure: ADV BROCHURE PART 2A (2026-07-22)

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Financial Consultants Group, Inc Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Financial Consultants Group, Inc. If you have any questions about the contents of this brochure, please contact us at (770) 627-2121 or by email at: Sandee@ForYourFuture.net. 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 Financial Consultants Group, Inc is also available on the SEC’s website at www.adviserinfo.sec.gov. Financial Consultants Group, Inc’s CRD number is: 108062. 1080 Sanders Rd., Suite 300 Cumming, GA 30041 (770) 627-2121 Sandee@ForYourFuture.net https://www.ForYourFuture.net Registration does not imply a certain level of skill or training. Version Date: July 22, 2026 i Item 2: Material Changes The material changes in this brochure from the last annual update amendment of Financial Consultants Group, Inc, on 03/11/2026 are described below. Material changes relate to Financial Consultants Group, Inc’s policies, practices or conflicts of interests. • Created Fountain Wealth Partners to serve as a DBA for the firm (See Item 4) ii Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ...................................................................................................................................................................................................................... ii Item 3: Table of Contents ..................................................................................................................................................................................................................... iii Item 4: Advisory Business .................................................................................................................................................................................................................... 5 A. Description of the Advisory Firm ............................................................................................................................................................................................ 5 B. Types of Advisory Services ........................................................................................................................................................................................................ 5 C. Client Tailored Services and Client Imposed Restrictions ................................................................................................................................................... 6 D. Wrap Fee Programs .................................................................................................................................................................................................................... 6 E. Assets Under Management ........................................................................................................................................................................................................ 6 Item 5: Fees and Compensation ........................................................................................................................................................................................................... 7 A. Fee Schedule ................................................................................................................................................................................................................................. 7 B. Payment of Fees ............................................................................................................................................................................................................................ 7 C. Client Responsibility For Third Party Fees ............................................................................................................................................................................. 8 D. Prepayment of Fees ..................................................................................................................................................................................................................... 8 E. Outside Compensation For the Sale of Securities to Clients................................................................................................................................................ 8 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................................................................................. 8 Item 7: Types of Clients ......................................................................................................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ............................................................................................................................................ 9 Methods of Analysis and Investment Strategies ......................................................................................................................................................... 9 A. Material Risks Involved.................................................................................................................................................................................................... 9 B. Risks of Specific Securities Utilized.............................................................................................................................................................................. 10 C. Item 9: Disciplinary Information ....................................................................................................................................................................................................... 11 Criminal or Civil Actions ............................................................................................................................................................................................... 11 A. Administrative Proceedings .......................................................................................................................................................................................... 11 B. Self-regulatory Organization (SRO) Proceedings ...................................................................................................................................................... 11 C. Item 10: Other Financial Industry Activities and Affiliations ...................................................................................................................................................... 11 Registration as a Broker/Dealer or Broker/Dealer Representative ...................................................................................................................... 11 A. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ................................... 11 B. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ................................................................ 11 C. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ..................................................... 12 D. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................................... 12 Code of Ethics................................................................................................................................................................................................................... 12 A. Recommendations Involving Material Financial Interests ...................................................................................................................................... 12 B. Investing Personal Money in the Same Securities as Clients .................................................................................................................................. 12 C. Trading Securities At/Around the Same Time as Clients’ Securities ................................................................................................................... 12 D. Item 12: Brokerage Practices ............................................................................................................................................................................................................... 13 iii Factors Used to Select Custodians and/or Broker/Dealers .................................................................................................................................... 13 A. Research and Other Soft-Dollar Benefits ............................................................................................................................................................... 13 1. Brokerage for Client Referrals.................................................................................................................................................................................. 13 2. Clients Directing Which Broker/Dealer/Custodian to Use .............................................................................................................................. 13 3. Aggregating (Block) Trading for Multiple Client Accounts.................................................................................................................................... 14 B. Item 13: Review of Accounts .............................................................................................................................................................................................................. 14 Frequency and Nature of Periodic Reviews and Who Makes Those Reviews .................................................................................................... 14 A. Factors That Will Trigger a Non-Periodic Review of Client Accounts ................................................................................................................. 14 B. Content and Frequency of Regular Reports Provided to Clients ........................................................................................................................... 14 C. Item 14: Client Referrals and Other Compensation ....................................................................................................................................................................... 15 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ......................... 15 A. Compensation to Non – Advisory Personnel for Client Referrals ......................................................................................................................... 15 B. Item 15: Custody ................................................................................................................................................................................................................................... 15 Item 16: Investment Discretion .......................................................................................................................................................................................................... 15 Item 17: Voting Client Securities (Proxy Voting) ........................................................................................................................................................................... 16 Item 18: Financial Information ........................................................................................................................................................................................................... 16 Balance Sheet .................................................................................................................................................................................................................... 16 A. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ................................................... 16 B. Bankruptcy Petitions in Previous Ten Years .............................................................................................................................................................. 16 C. Item 19: Requirements For State Registered Advisers .................................................................................................................................................................. 16 iv Item 4: Advisory Business A. Description of the Advisory Firm Financial Consultants Group, Inc (hereinafter “FCG”) is a Corporation organized in the State of Georgia. The firm was formed in January 1996, and the principal owner is David Lytal Fountain. The firm has established a DBA of Fountain Wealth Partners, but will retain Financial Consultants Group, Inc as the legal name going forward. The new name will reflect a broader array of services available through relationships with unaffiliated firms. B. Types of Advisory Services Portfolio Management Services FCG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. FCG creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring • • • FCG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. FCG will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement. FCG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of FCG’s economic, investment or other financial interests. To meet its fiduciary obligations, FCG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, FCG’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is FCG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and 5 debt/credit planning. Upon review of an investor's financial status, FCG may propose that the investor include, as part of his or her financial portfolio, one or more types of products that are not part of the investment advisory services provided by FCG, such as insurance products. If the investor chooses to include such a product in his or her financial portfolio, the company recommends that the investor work closely with his or her attorney, accountant, insurance agent and other related professionals. Incorporation of the non-advisory financial product into the investor's financial plan is entirely at the client's discretion. For insurance products, the company provides access to a platform providing insurance products by RetireOne, Inc. (“RetireOne”). The investor is under no obligation to use RetireOne's service and may seek insurance advice from any licensed agent. The insurance products and fee structures available from RetireOne may differ from those available from other third-party insurance agents. FCG recommends that the investor fully evaluate products and fee structures to determine which arrangements are most favorable to the investor prior to making an investment decision. C. Client Tailored Services and Client Imposed Restrictions FCG will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by FCG on behalf of the client. FCG may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, financial statements, needs, goals and risk tolerances. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FCG from properly servicing the client account, or if the restrictions would require FCG to deviate from its standard suite of services, FCG reserves the right to end the relationship. D. Wrap Fee Programs FCG does not have a Wrap Fee Program. E. Assets Under Management FCG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $184,693,037 $3,478,523 December 31, 2025 6 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees The table below represents the maximum fee schedule for FCG. These fees are negotiable depending upon the needs of the client and complexity of the situation, and the final fee schedule is attached to the Investment Advisory Agreement as Exhibit II. Clients may terminate the agreement without penalty for a full refund of FCG's fees within five business days of signing the Investment Advisory Agreement. Thereafter, clients may terminate the Investment Advisory Contract generally with 5 days' written notice. Total Assets Under Management Maximum Annual Fees First $1,000,000 1.00% Next $1,000,000 0.90% Next $1,000,000 0.80% Next $2,000,000 0.65% Over $5,000,000 0.50% Advisory fee calculations will be based on the platform used, with accounts using American Funds to be calculated using daily average balance. For other platforms, the advisory fee is calculated using the fair market value of the assets in the Account on the last business day of the prior billing period as calculated by the custodian. Financial Planning Fees The negotiated fixed rate for creating client financial plans is between $2,500 and $10,000. Clients may terminate the agreement without penalty, for full refund of FCG’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly or quarterly basis depending on the custodian being used. Fees are paid in advance or in arrears, depending on the platform used. 7 Payment of Financial Planning Fees Financial planning fees are paid via check, Venmo, or credit card. FCG will never possess client credit card information. Fixed financial planning fees are paid in arrears upon completion. C. Client Responsibility For Third Party Fees Client accounts are responsible for the payment of all third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by FCG. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees FCG collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation For the Sale of Securities to Clients Neither FCG nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management FCG does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients FCG generally provides advisory services to the following types of clients: Individuals and Families High-Net-Worth Individuals Corporations and Trusts ❖ ❖ ❖ There is no account minimum for any of FCG’s services. 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis FCG’s methods of analysis include Fundamental analysis, Modern portfolio theory and Technical analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies FCG uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. 9 Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the Firm to service client accounts have artificial intelligence components. The use of artificial intelligence and machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our clients, the Firm performs periodic due diligence of our service providers for assurance that the service providers have appropriate controls in place to protect our clients’ information and to limit data inaccuracies when artificial intelligence is used by the service provider. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the 10 possibility of inadequate regulatory compliance. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither FCG nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither FCG nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests David Lytal Fountain is a member of the board of directors at Forsyth County Chamber of Commerce. 11 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections FCG does not utilize nor select third-party investment advisers. All assets are managed by FCG management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics FCG has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. FCG's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests FCG does not recommend that clients buy or sell any security in which a related person to FCG or FCG has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of FCG may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of FCG to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. FCG will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of FCG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of FCG to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such 12 transactions may create a conflict of interest; however, FCG will never engage in trading that operates to the client’s disadvantage if representatives of FCG buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on FCG’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and FCG may also consider the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in FCG's research efforts. FCG will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. FCG will require clients to use Axos Advisor Services, Capital Group (American Funds), Ascensus and/or Charles Schwab & Co., Inc. 1. Research and Other Soft-Dollar Benefits While FCG has no formal soft dollars program in which soft dollars are used to pay for third party services, FCG may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). FCG may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and FCG does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. FCG benefits by not having to produce or pay for the research, products or services, and FCG will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that FCG’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals FCG receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use FCG will require clients to use a specific broker-dealer to execute transactions. Not all 13 advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If FCG buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, FCG would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. FCG would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for FCG's advisory services provided on an ongoing basis are reviewed at least Annually by the Client’s assigned advisor, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at FCG are assigned to this reviewer. All financial planning-only accounts are reviewed upon financial plan creation and plan delivery by the Client’s assigned advisor. Financial planning-only clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, FCG’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of FCG's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. 14 Each financial planning-only client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) FCG has a material relationship with an issuer of securities and may receive support in reference to seminar events. There is no requirement for FCG to invest client assets with any issuer of securities in return for this economic benefit. B. Compensation to Non – Advisory Personnel for Client Referrals FCG does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, FCG will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Some clients may execute limited powers of attorney or other standing letters of authorization that permit the firm to transfer money from their account with the client’s independent qualified custodian to third-parties. This authorization to direct the custodian may be deemed to cause our firm to exercise limited custody over your funds or securities and for regulatory reporting purposes, we are required to keep track of the number of clients and accounts for which we may have this ability. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate any transfers that may have taken place within your account(s) each billing period. You should carefully review account statements for accuracy. Item 16: Investment Discretion FCG provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, FCG generally manages the client’s account and makes investment 15 decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, FCG’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to FCG). Item 17: Voting Client Securities (Proxy Voting) FCG will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet FCG neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither FCG nor its management has any financial condition that is likely to reasonably impair FCG’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years FCG has not been the subject of a bankruptcy petition in the last ten years. Item 19: Requirements For State Registered Advisers This section is not applicable because the firm is registered with the Securities and Exchange Commission. 16

Frequently Asked Questions