FINANCIAL GRAVITY ASSET MANAGEMENT, INC.

Item 1 Cover Page Financial Gravity Asset Management, Inc. Firm CRD #144008 Form ADV Part 2A – Disclosure Brochure Effective: December 10th, 2025 2501 Ranch Road 620 S Ste 110 Lakeway, TX 78738 Phone: (800) 588-3893 This Brochure provides information about the qualifications and business practices of Financial Gravity Asset Management, Inc. If you have any questions about the contents of this Brochure, please contact us at (800) 588-3893. 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. Registration as a registered investment advisor does not imply a certain level of skill or training. Additional information about Financial Gravity Asset Management, Inc, CRD #144008 also is available on the SEC’s website at www.adviserinfo.sec.gov. 1 Financial Gravity Asset Management, Inc.  Item 2: Material Changes The material changes in this brochure from the last other than annual updating amendment of Financial Gravity Asset Management, Inc. (“FG Asset Management”) on 12/10/2024 are described below. This list summarizes changes to policies, practices, or conflicts of interest only. 1. Updated Item 4 to update the AUM Amount 2 Financial Gravity Asset Management, Inc.  Item 3: Table of Contents Item 1 Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 5 Description of the Advisory Firm 5 Types of Advisory Services 5 Client Tailored Services and Client Imposed Restrictions 8 Wrap Fee Programs 8 Amounts Under Management 8 Item 5: Fees and Compensation 8 Fee Schedule 8 Payment of Fees 9 Clients Are Responsible For Third Party Fees 10 Prepayment of Fees 10 Outside Compensation For the Sale of Securities to Clients 10 Item 6: Performance-Based Fees and Side-By-Side Management 10 Item 7: Types of Clients 10 Item 8: Methods of Analysis, Investment Strategies,and Risk of Investment Loss 11 Methods of Analysis and Investment Strategies 11 Material Risks Involved 11 Risks of Specific Securities Utilized 12 Item 9: Disciplinary Information 12 Item 10: Other Financial Industry Activities and Affiliations 12 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading 12 Advisor Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests 12 Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 13 Code of Ethics 13 Recommendations Involving Material Financial Interests 13 Investing Personal Money in the Same Securities as Clients 13 Trading Securities At/Around the Same Time as Clients’ Securities 14 3 Financial Gravity Asset Management, Inc.  Item 12: Brokerage Practices 14 Factors Used to Select Custodians and/or Broker/Dealers 14 Aggregating (Block) Trading for Multiple Client Accounts 15 Item 13: Reviews of Accounts 15 Frequency and Nature of Periodic Reviews and Who Makes Those Reviews 15 Factors That Will Trigger a Non-Periodic Review of Client Accounts 15 Content and Frequency of Regular Reports Provided to Clients 15 Item 14: Client Referrals and Other Compensation 15 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or 15 Other Prizes) Compensation to Non –Advisory Personnel for Client Referrals 16 Item 15: Custody 16 Investment Supervisory Services Accounts 16 Selection of Other Advisors Accounts 16 Item 16: Investment Discretion 16 Item 17: Voting Client Securities (Proxy Voting) 16 Item 18: Financial Information 17 Balance Sheet 17 Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients 17 Bankruptcy Petitions in Previous Ten Years 17 4 Financial Gravity Asset Management, Inc.  Item 4: Advisory Business Description of the Advisory Firm This firm has been in business since May of 2007, and the principal owner is Financial Gravity Companies, Inc. (“FGC”) (OTCQB: FGCO). Types of Advisory Services Financial Gravity Asset Management, Inc. (hereinafter “FG Asset Management”) offers the following services to advisory clients: Investment Supervisory Services FG Asset Management offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Investment Supervisory Services include, but are not limited to, the following: Investment strategy ● ● Asset allocation ● Asset selection ● Regular portfolio monitoring ● Asset location optimization when applicable ● Tax lot harvesting when requested FG Asset Management endeavors to provide clients with risk appropriate investment management but using our Real Risk System. Real Risk is defined as the percentage decline of an investment from peak to trough. Each investor has a Real Risk Tolerance, and each portfolio of investments has a Real Risk Score. The client’s Real Risk Tolerance, meaning maximum amount of Real Risk a client is willing to take with the investments to be managed, is measured using the Risk Meter, a proprietary software designed to help clients understand and consider the relationship between expected risk and expected return. The highest level of Real Risk available is 50% and the lowest is zero. FG Asset Management recommends portfolios whose Real Risk Score is equal to or less than the client’s Real Risk Tolerance. FG Asset Management will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Real Risk Tolerance is documented in the Investment Policy Statement, which is given to each client. FG Asset Management Strategies All strategies are managed by FG Asset Management’s Investment Committee chaired by Chief Investment Officer William R. Nelson, PhD. We feel 4 Alpha invests in individual equities and focuses on dominant companies, loved brands, and great products that are understandable, inspire confidence, and are on the right side of long-term trends. The long term trends include, but are not limited to, the electrification of vehicles, renewable energy (as opposed to fossil fuel dependence), autonomous vehicles, biotech, genetic engineering, the growing global middle class, the move from a purchase to a service model, the reduction in the 5 Financial Gravity Asset Management, Inc.  importance of location versus other amenities, the increase in e-commerce accompanied by reduction in conventional retail, proliferation of online platforms, increased economies of scale, aging of developed nation populations, healthier eating including veganism, direct contact between micro-producers and clients, and the reduced influence of traditional push marketing. The 4 Alpha model invests solely in individual stocks that, while actively monitored and managed, are chosen based on the long-term growth prospects. While many of the stocks pay dividends, income is the program’s secondary objective. The three 4 Beta strategies invest in-cost Exchange-Traded Funds (“ETFs”). 4 Beta Taxable Fixed Income diversifies across corporate and sovereign; USA and foreign; short, medium, and long duration; and investment grade to high yield with the objective of earning an efficient risk adjusted return. The 4 strategies are typically blended, often along with insurance products, to accommodate the client’s Real Risk Tolerance. FG Asset Management strives to manage the different models in a low turnover, tax-efficient manner. Additional tax-efficiencies may be gained through location optimization which places securities from the same household in different account types taxed, tax-deferred, and after tax based upon security type (like equity or fixed income) and yield. This strategy only applies to households whose accounts have more than one tax treatment governed by the same investment policy statement. Depending on the size of the account(s) and/or the model or blend chosen, there may be instances where certain higher-priced securities are not purchased. In these cases, the Advisor may replace the security not purchased with a substitute security to maximize the percentage of assets invested. FG Asset Management is a proprietary investment advisory program and the Advisor may benefit financially by recommending these programs over other programs that are not managed by the advisor but any recommendation made by the Advisor should be in the client’s best interest and not based on the interests of the Advisor. Additionally, the Representative acting as a solicitor for the proprietary programs may own stock in or may be a participant in a stock option or stock appreciation plan sponsored by FGC (“Stock Ownership”). Representatives may benefit from placing assets with the Manager in that the value of the FGC stock may be enhanced by such placement. In approving the investment of funds in a Manager Portfolio, Clients should consider whether Representative’s recommendation is influenced by the Stock Ownership. The full extent of the relationship between FCG and Financial Professional is described in Financial Professional’s ADV. Tax Advice Policy Representatives may reference common tax features associated with specific accounts or products offered by or through FG Asset Management (e.g., tax deferral associated with IRAs or tax-free benefits of insurance products, ie death benefits), but may not provide individualized tax advice in connection with the recommendation of such accounts or products. In connection with services 6 Financial Gravity Asset Management, Inc.  being provided by or through FG Asset Management, representatives may not recommend any tax strategy or engage in any conduct that would cause the representative or FG Asset Management to be a “material advisor” as defined by the IRS. Representatives may not recommend or participate in any way in the formation or execution of an IRS “transaction of interest,” IRS “listed transaction,” or potentially abusive tax structure. Services Limited to Specific Types of Investments FG Asset Management limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, hedge funds, third party money managers, REITs, private placements, government securities. FG Asset Management may use other securities as well to help diversify a portfolio when applicable. With the client's consent, FG Asset Management may use a third-party platform to incorporate client investment assets held at custodians that are not on our approved list (“held away assets”). These held away assets are not in an account with FG Asset Management. Use of the third-party platform will allow us to include the held away assets in consolidated reporting and analytics as part of our portfolio review and risk tolerance analysis services. These held away assets will be treated substantially as assets under FG Asset Management's management. Incorporating these held away assets may affect performance reporting, asset allocation analysis, style analysis, transparent fee reporting, risk analysis, and other oversight of clients' consolidated reports. The inclusion of these held away assets provides a more holistic view of each client's range of assets when generating guidance regarding account investment selections and asset class exposures. However, typically, the investment choices for held away assets are limited to the assets that have been approved, sometimes by a retirement plan sponsor, or other fiduciary. In those circumstances, FG Asset Management will recommend allocations from among the available investment choices. See Item 5 for fees on held away assets. Client Tailored Services and Client Imposed Restrictions FG Asset Management offers the same suite of services to all its clients. However, specific investment allocations and their implementation are dependent upon the client's Investment Policy Statement which outlines each client’s current Real Risk Tolerance and provides a risk appropriate portfolio. 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 FG Asset Management from properly servicing the client account, or if the restrictions would require FG Asset Management to deviate from its standard suite of services, FG Asset Management reserves the right to end the relationship. Wrap Fee Programs FG Asset Management does not participate in a wrap fee program and no transaction costs are wrapped in the program fees. Amounts Under Management FG Asset Management has the following assets under management as calculated in the last ADV filing: 7 Financial Gravity Asset Management, Inc.  Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $523,441,243.67 $0 09/31/2025 Item 5: Fees and Compensation Fee Schedule FG Asset Management Programs For investment advisory models managed within the FG Asset Management Program, clients will be charged an asset-based fee that covers advisory, custodial, portfolio management, and certain reporting services. Accounts are billed monthly in arrears based on the average daily balance of program-eligible assets. The fee includes the Financial Professional’s fee, which is typically negotiated between the Investment Advisor Representative and client. The amount agreed upon will be charged as stated in the client agreement and will not exceed the maximum annual amount of 2.00%. The fee includes the Program fee, which is typically negotiated among the program sponsor, Investment Advisor Representative, and client as stated in the client agreement. The amount agreed upon will be charged as stated in the client agreement and will not exceed the maximum annual program fee of 0.65%. Total Assets Annual Fee All Assets Negotiable with a 0.65% maximum These material changes were made on March 1st, 2023 and accounts opened prior to this change will be charged in conjunction to their client agreement based on their model allocation with the annual program fee for the 4 Alpha model being. 55% while the program fee for the 4 Beta Equity and Taxable Fixed Income models at .35%, and the Dependable Return Model 0.15%. Refer to prior client agreement for blended model and breakpoint details. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Thereafter, clients may terminate their contracts with ten days written notice. Fees are calculated by FG Asset Management using third-party software. FG Asset Management and advisory fees will be billed using the average of the daily closing market values of the account during the month multiplied by the applicable annual percentage divided by applicable annual percentage divided by the number of days in the month. The fees are aggregated and charged as one fee, please refer to your monthly custodial statement provided by the Custodian. As to held away assets that are treated as assets under FG Asset Management’s management, fees will be debited from the account holding the assets, but if we are unable to debit fees from the accounts holding the assets, those fees will be assigned to the client’s accounts with FG Asset 8 Financial Gravity Asset Management, Inc.  Management, and debited from those accounts. Additionally there is a cost to the third-party platform, which cost may be an additional expense charged to the client. Payment of Fees FG Asset Management and Advisory fees are paid monthly in arrears. Fees are withdrawn directly from the client’s accounts with Client written authorization and FG Asset Management will therefore: A. Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. B. Use a custodian that sends at least quarterly statements. C. Use a custodian that has online access to statements. Clients Are Responsible For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by FG Asset Management. Please see Item 12 of this brochure regarding broker/custodian. Prepayment of Fees FG Asset Management collects its portfolio management fees in arrears. Outside Compensation For the Sale of Securities to Clients Investment Advisor Representatives of FG Asset Management may also be licensed insurance agents and, in this role, accept compensation for the sale of insurance products to FG Asset Management clients. This presents a conflict of interest and gives the supervised persons an incentive to recommend insurance based on the compensation received rather than on the client’s needs. However, each Investment Advisor Representative is required to base insurance sales on the best interest of the clients and based on FG Asset Management’s investment philosophy seen in Item 8 of this brochure. To help mitigate the conflict of interest, FG Asset Management always attempts to act in the best interest of the client consistent with its fiduciary duty and uses and presents the firm’s investment methodology outlined in Item 8. Additionally, clients will always have the right to purchase FG Asset Management-recommended products through other brokers or agents that are not affiliated with FG Asset Management. In addition, supervised persons will only offer insurance products to clients in the respective states in which the supervised person is properly licensed as an insurance agent. Item 6: Performance-Based Fees and Side-By-Side Management FG Asset Management does not accept performance-based fees nor other fees based on a share of capital gains on or capital appreciation of the assets of a client. 9 Financial Gravity Asset Management, Inc.  Item 7: Types of Clients FG Asset Management generally provides investment advice and/or management supervisory services to the following Types of Clients: Individuals ● ● Business Owners ● Entrepreneurs ● High-Net-Worth Individual There is $25,000 account minimum but may be waived under certain circumstances at the discretion of FG Asset Management Item 8: Methods of Analysis, Investment Strategies,and Risk of Investment Loss Methods of Analysis and Investment Strategies Methods of Analysis FG Asset Management uses fundamental, long-term trend, and economic moat analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Control the Controllable™ We work to control what can be controlled. An analogy we use is don’t try to control the weather, take an umbrella. There are 5 areas we look to control for our clients. ● Costs – 4 Alpha focuses on directly owned equities and 4 Beta strategies invest in ETFs that for which the expense ratio is scrutinized. ● Taxes – Reduce Tax Friction which comes from aggressive turnover in a portfolio. ● Volatility – We can’t control the volatility of the market; we can manage the volatility of the portfolio. ● Overconcentration – We seek proper diversification to help increase the risk adjusted return. ● Risk – The Real Risk System is used to measure the investors’ Real Risk Tolerance and provide a blend of strategies with an appropriate Real Risk Score. Material Risks Involved Methods of Analysis FG Asset Management offers four strategies 4 Alpha, 4 Beta Dependable Return, 4 Beta Equity, and 4 Beta Taxable Fixed Income. These four strategies are typically blended into a portfolio that is appropriate for the investor’s risk tolerance and/or cash flow requirements. 4 Alpha is typically 30 to 40 individual stocks that we consider to be dominant companies with 10 Financial Gravity Asset Management, Inc.  strong brands on the right side of long term trends, such as the growing middle class, the increasing influence of technology , the electrification of vehicles, and the decline of fossil fuel use. All 4 Beta strategies contain ETFs that follow a modern portfolio methodology focused on broad diversification within the mandated asset category. 4 Beta Dependable return contains a variety of shorter term fixed income ETFs. 4 Beta Equity contains a variety of domestic and international equity ETFs typically with a tilt toward value and small cap companies relative to what a market cap portfolio would own, in large part to counterbalance the more large capitalization and growth oriented approach of 4 Alpha. 4 Beta Taxable Fixed Income contains a wide range of issuers including, but not limited to, the US Treasury, foreign governments, investment grade corporate bonds, and high yield securities. The average duration of the portfolio tends to be a bit less than a total bond market index. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Risks of Specific Securities Utilized FG Asset Management generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business or the integrity of our management. Item 10: Other Financial Industry Activities and Affiliations Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither FG Asset Management nor its representatives are registered as a FCM, CPO, or CTA. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Investment Advisor Representatives of FG Asset Management can hold additional licenses and/or registrations. Please refer to the individual’s disclosure document for additional information. To help mitigate the conflict of interest, all supervised persons agree to adhere to the guidelines of FG Asset Management that always acts in the best interest of the client consistent with its fiduciary duty. Moreover, supervised persons will only offer insurance products to clients to FG Enhanced Markets. Registration as a Broker/Dealer or Broker/Dealer Representative FG Asset Management and its representatives are not registered as a broker/dealer or as representatives of a broker/dealer. 11 Financial Gravity Asset Management, Inc.  Relationship with FG Family Office Services (FGFOS) FG Asset Management has a material relationship with FG Family Office Services (FGFOS), an affiliated entity. This relationship may present potential conflicts of interest as FGAM and FGFOS collaborate to provide financial and investment advisory services to clients. Specifically: Scope of Relationship: FGFOS provides certain financial planning and family office services to clients who may also engage FG Asset Management for investment advisory services. Potential Conflicts of Interest: The relationship between FGAM and FGFOS may create incentives for FGFOS to recommend FGFAM services, or vice versa, which could result in clients being directed toward affiliated services without fully exploring unaffiliated alternatives. Mitigating Conflicts of Interest: FG Asset Management has implemented the following policies and procedures to address conflicts of interest arising from its relationship with FGFOS: ● Client-First Fiduciary Duty: FGAM and its representatives are committed to acting in the best interests of clients. Recommendations for services provided by FGAM or FGFOS are made solely based on the client’s needs and objectives. ● Disclosure and Transparency: All material relationships, including FGAM’s affiliation with FGFOS, are fully disclosed to clients. Clients are encouraged to evaluate all available options and are not obligated to use FGFOS services. ● Separation of Responsibilities: FGAM and FGFOS maintain separate operational and compliance oversight to ensure that recommendations and services are not unduly influenced by the affiliation. ● Periodic Review: FGAM conducts regular reviews of recommendations and client interactions to monitor adherence to fiduciary standards and ensure transparency in all dealings with FGFOS. ● Client Choice: Clients are under no obligation to engage with FGFOS for financial planning or family office services and may seek unaffiliated service providers. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections FG Asset Management will direct clients to various third-party money manager(s). This relationship will be disclosed in each contract between FG Asset Management and the third-party money manager. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that FG Asset Management has an incentive to direct clients to the third-party money managers that provide FG Asset Management with a larger fee split. FG Asset Management will always act in the best interests of the client, including when determining which third party manager to recommend to clients. 12 Financial Gravity Asset Management, Inc.  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics We have 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. Clients may request a copy of our Code of Ethics from management. Recommendations Involving Material Financial Interests FG Asset Management does not recommend that clients buy or sell any security in which a related person to FG Asset Management has a material financial interest. Investing Personal Money in the Same Securities as Clients From time to time, representatives of FG Asset Management may buy or sell securities for themselves that they also recommend to clients and may do so at or around the same time as clients. This may provide an opportunity for representatives of FG Asset Management to buy or sell the same securities before or after recommending securities to clients, resulting in representatives profiting off the recommendations they provide to clients. Such transactions create conflicts of interest. To address these conflicts of interest, FG Asset Management will always document any such transactions and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Moreover, FG Asset Management will always act in the best interest of the client consistent with its fiduciary duty. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of FG Asset Management may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of FG Asset Management to buy or sell the same securities before or after trading securities for clients, resulting in representatives profiting off the recommendations they provide to clients. Such transactions create conflicts of interest. To address these conflicts of interest, FG Asset Management will always document any such transactions and will never engage in trading that operates to the client’s disadvantage when trading at or around the same time as client accounts. Moreover, FG Asset Management will always act in the best interest of the client consistent with its fiduciary duty. Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on FG Asset Management’ 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 13 Financial Gravity Asset Management, Inc.  lowest commission or commission equivalent, and FG Asset Management may also consider the market expertise and research access provided by the broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in FG Asset Management's research efforts. The Advisor recommends Charles Schwab & Co., Inc. and Axos Financial, Inc. as their main Custodians. As needed, we also have a relationship with Community National Bank (“CNB”), Fidelity, and FOLIOfn Investments. 1. Research and Other Soft-Dollar Benefits While FG Asset Management has no formal soft dollars program in which soft dollars are used to pay for third party services, FG Asset Management may receive research, products, or other services from its broker/dealer in connection with client securities transactions (“soft dollar benefits”) and may consider these benefits in recommending brokers. There can be no assurance that any particular client will benefit from any particular soft dollar research or other benefits. FG Asset Management benefits by not having to produce or pay for the research, products or services, and FG Asset Management will have an incentive to recommend a broker dealer based on receiving research or services. Clients should be aware that FG Asset Management’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals FG Asset Management 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 FG Asset Management will not allow clients to direct FG Asset Management to use a specific Custodian to execute transactions. Clients must use FG Asset Management’s recommended custodian (broker-dealer). Not all investment advisers require their clients to use a specific Custodian. By requiring clients to use our specific custodian, FG Asset Management may be unable to achieve the most favorable execution of client transactions, and this may cost clients’ money over using a lower-cost custodian. Aggregating (Block) Trading for Multiple Client Accounts FG Asset Management maintains the ability to block trade purchases across accounts. While block trading may benefit clients by purchasing larger blocks in groups, we do not feel that the clients are at a disadvantage due to the best execution practices of our custodian. The timing of trades may be subject to limitations imposed by the custodians or by billing/trading systems. Item 13: Reviews of Accounts Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed periodically by the Chief Compliance officer or other firm assigned personnel. Accounts are rebalanced as needed and reviewers are instructed to review clients’ accounts with regard to their investment policies and risk tolerance levels. 14 Financial Gravity Asset Management, Inc.  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. Content and Frequency of Regular Reports Provided to Clients FG Asset Management does not provide regular reports to clients, written or otherwise. Item 14: Client Referrals and Other Compensation Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) FG Asset Management also has access to soft dollar benefits (as described in Item 12 above) and economic benefits provided by custodians. Compensation to Non –Advisory Personnel for Client Referrals FG Asset Management does not provide any compensation to any persons who are not duly registered as an investment advisor representative for client referrals. Item 15: Custody Investment Supervisory Services Accounts FG Asset Management does not have custody other than via direct fee deduction. When advisory fees are deducted directly from client accounts at client's custodian, FG Asset Management will follow the procedures below. A. Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. B. Use a custodian that sends at least quarterly invoices. C. Send the qualified custodian written notice of the amount of the fee to be deducted and send the client a written invoice itemizing the fee upon or prior to fee deduction, including the formula used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was based. Clients will receive account statements from the custodian and should carefully review those statements. Selection of Other Advisors Accounts The third-party adviser, rather than FG Asset Management, sends the client statements for these accounts. FG Asset Management does not have custody over these accounts. Item 16: Investment Discretion For those client accounts where FG Asset Management provides ongoing supervision, FG Asset Management maintains limited power of authority over client accounts with respect to securities to 15 Financial Gravity Asset Management, Inc.  be bought and sold and the amount of securities to be bought and sold. All buying and selling of securities is explained to clients in detail before an advisory relationship has commenced. Item 17: Voting Client Securities (Proxy Voting) FG Asset Management 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 Balance Sheet FG Asset Management does not require nor solicit prepayment of more than $500 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither FG Asset Management nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years FG Asset Management has not been the subject of a bankruptcy petition. 16 Financial Gravity Asset Management, Inc.