FWG HOLDINGS, LLC

Form ADV Part 2A – Disclosure Brochure Effective: October 30, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of FWG Holdings, LLC d/b/a Fortress Wealth Group (“Fortress” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact Fortress at (407) 999-8998 or by email at info@fortresswealthgroup.com. Fortress is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Fortress to assist you in determining whether to retain the Advisor. Additional information about Fortress and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 308968. Fortress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 www.fortresswealthgroup.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Fortress. Fortress believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Fortress encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with Fortress. Material Changes The following material changes have been made to the Disclosure Brochure since the last annual amendment filing on February 28, 2025: • The Advisor now utilizes the services of sub-advisors. Please see Item 4 for additional information. Future Changes From time to time, Fortress may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 308968. You may also request a copy of this Disclosure Brochure at any time by contacting Fortress at (407) 999-8998 or by email at info@fortresswealthgroup.com. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Advisory Services ................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................................................. 4 C. Client Account Management .......................................................................................................................................... 7 D. Wrap Fee Programs ....................................................................................................................................................... 7 E. Assets Under Management ............................................................................................................................................ 7 Item 5 – Fees and Compensation ......................................................................................................................... 8 A. Fees for Advisory Services ............................................................................................................................................. 8 B. Fee Billing ....................................................................................................................................................................... 8 C. Other Fees and Expenses ............................................................................................................................................. 9 D. Advance Payment of Fees and Termination ................................................................................................................ 10 E. Compensation for Sales of Securities .......................................................................................................................... 11 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 11 Item 7 – Types of Clients ..................................................................................................................................... 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 11 A. Methods of Analysis ..................................................................................................................................................... 11 B. Risk of Loss .................................................................................................................................................................. 12 Item 9 – Disciplinary Information ....................................................................................................................... 13 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 14 A. Code of Ethics .............................................................................................................................................................. 14 B. Personal Trading with Material Interest ........................................................................................................................ 15 C. Personal Trading in Same Securities as Clients .......................................................................................................... 15 D. Personal Trading at Same Time as Client ................................................................................................................... 15 Item 12 – Brokerage Practices ............................................................................................................................ 15 A. Recommendation of Custodian[s] ................................................................................................................................ 15 B. Aggregating and Allocating Trades .............................................................................................................................. 16 Item 13 – Review of Accounts ............................................................................................................................ 16 A. Frequency of Reviews .................................................................................................................................................. 16 B. Causes for Reviews ..................................................................................................................................................... 16 C. Review Reports ............................................................................................................................................................ 16 Item 14 – Client Referrals and Other Compensation ........................................................................................ 17 A. Compensation Received by Fortress ........................................................................................................................... 17 B. Client Referrals from Solicitors ..................................................................................................................................... 18 Item 15 – Custody ................................................................................................................................................ 18 Item 16 – Investment Discretion ......................................................................................................................... 18 Item 17 – Voting Client Securities ...................................................................................................................... 18 Item 18 – Financial Information .......................................................................................................................... 18 Privacy Policy ...................................................................................................................................................... 19 Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 3  Item 4 – Advisory Services A. Firm Information FWG Holdings, LLC d/b/a Fortress Wealth Group (“Fortress” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Fortress is organized as a Limited Liability Company (“LLC”) under the laws of the State of Florida. Fortress was founded in March 2020 and became a registered investment advisor in May 2020. Fortress is owned by Ledford Holdings, LLC, which is wholly owned and operated by John E. Ledford (Chief Executive Officer and Chief Compliance Officer) and Capital Rock, LLC, which is wholly owned by Cole R. Linquist (President). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Fortress. B. Advisory Services Offered Fortress offers investment advisory services to: individuals, high net worth individuals, corporations, and charitable organizations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. The Advisor’s fiduciary commitment is further described in Fortress’ Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Fortress provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management services. Fortress works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a diversified portfolio strategy. Fortress will then construct an investment allocation, consisting of exchange-traded funds (“ETFs”), mutual funds, or individual stocks to achieve the Client’s investment goals. The Advisor may also utilize bonds, options contracts, alternative investments, and/or real estate investment trusts (“REITs”) to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Fortress’ investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Fortress will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Fortress evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Fortress may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Fortress may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Fortress may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Independent Manager - Fortress will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 4  Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). When deemed to be in the Client’s best interest, the Advisor will introduce Clients to a non-purpose loan program made available through the recommended custodian. In such instances, the Client’s assets in their account[s] at the custodian will be utilized as collateral for a non-purpose loan. The recommendation of a non-purpose loan presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the non- purpose loan. For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. At no time will Fortress accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Use of Sub-Advisors – Fortress may utilize third-party investment advisors for asset management, investment opportunities, and back-office services (herein “Sub-Advisor”) for all or a portion of a Client’s portfolio. In these instances, the Advisor will engage the Sub-Advisor to provide these services for its Clients. Clients are not charged an additional fee by the Sub-Advisor. Fortress will remain the Client’s primary Advisor and will direct the Sub-Advisor as to the Client’s investment objectives. The Advisor will perform initial and ongoing oversight and due diligence over the Sub-Advisor to ensure the strategy remains aligned with Client investment objectives and overall best interests. The Client will be provided with the Sub-Advisor’s Form ADV Part 2A (or a brochure that makes the appropriate disclosures). Financial Planning Services Fortress typically provides financial planning services to Clients as part of its overall investment management services. Fortress may also provide financial planning services on a standalone basis pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, cash management, tax savings, insurance and asset protection, investment allocation, charitable giving and retirement planning. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Fortress may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For financial consulting engagements, the Advisor may not provide a written summary. Plans or consultations are completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. The Advisor may recommend clients engage with a third party, where compensated is received, please see Item 14 for additional detail. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 5  Financial Institution Consulting Services Fortress provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting services, pursuant to a written agreement with Fortress. Consulting services are strictly on products Clients have purchased through Mutual Securities, Inc. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details. Non-Purpose Loans Fortress may introduce certain Clients to various commercial banks for non-purpose loans that are sourced and collateralized through Fidelity or other custodians that offer such services (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s], however, the Advisor will not receive an advisory fee on any loaned assets. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Investment Management Platform Fortress may recommend that certain Clients implement their investment portfolios through Betterment Institutional, a division of Betterment LLC (herein “Betterment Institutional” or the “Investment Platform”). Betterment Institutional is what is often termed a “robo-advisor”, an online wealth management service that provides automated, algorithm-based portfolio management advice. Robo-advisors use technology to deliver similar services as traditional advisors, but generally only offer portfolio management and do not get involved in a Client’s personal situation, such as taxes and retirement planning. Fortress chose to affiliate with Betterment Institutional due to the Investment Platform’s customized portfolio allocations, automated rebalancing, and competitive fees. Fortress utilizes Betterment Institutional as a complement to its investment strategies as it provides cost effective implementation of the Advisor’s investment strategy[ies]. To establish accounts with Betterment Institutional, the Client will also enter into one or more agreements with Betterment that provides the authority for discretionary investment management by the Investment Platform. Fortress remains the Client’s primary advisor and relationship contact and will select or construct a portfolio of ETFs and/or cash equivalents from the universe of investments included on the Investment Platform. Fortress will have the discretionary authority to instruct Betterment Institutional with respect to portfolio construction, asset allocation and other investment decisions, subject to the limitations described herein. Betterment Institutional will implement the portfolio and be responsible for the discretionary trading of the ETFs in the Client’s portfolio, including the purchase and sale of investments and the automatic rebalancing back to targets. Betterment Institutional utilizes ETFs, representing various asset classes for the construction of investment portfolios. As discussed above, Fortress will work with each Client to select/construct a portfolio to meets the needs of the Client. The Client has limited ability to put restrictions on its accounts. The account[s] cannot contain investments that are not included in the Betterment Institutional universe of ETFs and cash equivalents. Betterment Institutional, under its discretionary authority, will automatically adjust and rebalance the Client’s accounts daily based on the drift tolerance established for the positions in the investment portfolio. The Advisor’s investment philosophy is long-term, but the Advisor may make such tactical overrides to take advantage of market pricing anomalies or strong market sectors. The Advisor does not actively trade in the Client’s account[s] and is also limited to a enter one allocation change per account per trading day through Betterment Institutional, the Client should be aware of these potential disadvantages. For its services, Betterment Institutional will charge an asset-based fee that is in addition to the Advisor’s fee. Betterment Institutional’s fee includes the securities transaction fees for all trades. The Advisor will only receive its investment advisory fees as detailed in Item 5.A. below and does not share in any fees earned by Betterment Institutional. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 6  The Client, prior to entering into an agreement with the Investment Platform, will be provided with the Investment Platform’s Form ADV Part 2A (or a brochure that makes the appropriate disclosures). Retirement Plan Advisory Services Fortress provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor may provide 3(21) (non-discretionary) retirement plan advisory services on behalf of the Plan and Plan Sponsor, which may be in either a 3(21) (non-discretionary consulting) or 3(38) (discretionary management) basis. For 3(38) services, the Advisor shall have the discretion to select the investments for the Plan and/or make investment decisions on behalf of Plan Participants. The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Retirement plan advisory services are provided by Fortress serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Fortress’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Fortress to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Fortress, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Fortress will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Fortress will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Fortress will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Fortress does not sponsor a wrap fee program in connection with investment management services, but does recommend that Clients establish accounts through Betterment Institutional, which delivers its investment management services through a wrap fee program structure. A wrap fee program is an investment program where investment management services and securities transaction costs are combined into a single combined fee. A complete description of Investment Platform and related fees, charges, when due and termination procedures are described in Betterment Institutional’s Disclosure Brochure and its Appendix 1 (“Betterment Wrap Fee Program Brochure”) which is provided to each Client prior to establishing an account with Betterment Institutional. E. Assets Under Management As of December 31, 2024, Fortress manages $345,016,442 in Client assets, all of of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 7  Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid monthly, in advance of each month, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior month. Investment advisory fees range from 0.75% to 2.00% annually based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a tiered fee schedule, not to exceed the range of fees described above. All securities held in accounts managed by Fortress will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Independent Manager - As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. The Advisor will allocate a portion of the advisory fee collected to the Independent Manager pursuant to the terms of the executed agreement between the Advisor and the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.50% annually. Financial Planning Services Fortress typically offers financial planning services as a component of investment management services as described above. Fortress may also offer its financial planning as a standalone service, which may be billed on an hourly or fixed fee basis. Hourly engagements are billed at a rate of $350 per hour. Fixed engagements range from $1,500 to $40,000. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Financial Institution Consulting Services Fortress receives a consulting fee based on the assets under MSI’s management from Brokerage Customers who have provided written consent to MSI to receive the investment consulting services from Fortress. The consulting fee is calculated from the assets under MSI’s management at the end of the calendar quarter multiplied by the annualized rate of 0.30%. The initial fee is paid only after the completion of one full calendar quarter period following the date of the executed agreement with MSI. Investment Management Platform Client accounts implemented through Betterment Institutional will be charged an annual fee of 1.00% by the Advisor plus the Betterment Institutional wrap fee of up to 0.20% annually, based on the level of assets implemented through Betterment Institutional. The Client authorizes this fee deduction through the investment platform agreement signed by the Client, the Advisor and Betterment Institutional. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 8  Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00%, billed quarterly in arrears, pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the quarter. Fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective month. The amount due is calculated by applying the monthly rate (annual rate divided by 12) to the total assets under management with Fortress at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Fortress to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Independent Manager - For Client accounts implemented through an Independent Manager, the Client’s overall fees may include Fortress’s investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. The Advisor is only entitled to the investment advisory fee as noted in Item 4 above. Betterment Institutional Platform - The overall fee will be calculated by Betterment Institutional and deducted from the Client’s account[s]. The Advisor’s portion of the fee is directly remitted to the Advisor’s account. Fees are calculated based on the average daily market value of the assets in the Client’s accounts for the quarter. Clients will be provided a statement, at least quarterly from MTG, LLC dba Betterment Securities (CRD# 47788 / SEC# 8- 51906). Betterment Securities is a broker-dealer affiliate of Betterment Institutional, which serves as both the broker-dealer and custodian for Client accounts at Betterment Institutional. Please see Item 12 – Brokerage Practices. Financial Planning Services Financial planning fees invoiced in advance of the of the agreed upon deliverable[s]. Financial Institution Consulting Services MSI shall calculate and pay Fortress for its consulting services on or before thirty (30) days past the end of each calendar quarter. Retirement Plan Advisory Services Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Fortress, in connection with investments made on behalf of the Client’s account[s]. With the exception of accounts at Betterment Institutional, the Client is responsible for all custody and securities execution fees charged by the Custodian, if applicable. Client accounts managed through Betterment Institutional are offered a wrap fee structure, where securities transaction fees are included as a part of the overall platform and advisory fee. The Advisor’s recommended custodian does not charge securities transaction fees for ETF and individual stock trades in Client accounts provided that the accounts meet the terms and conditions of the custodian’s brokerage requirements. However, the custodian typically charges for mutual funds and other types of investments. The fees charged by Fortress are separate and distinct from these custody and execution fees. In addition to trade execution fees, the most common third-party fee is the prime brokerage trade away fee discussed in Item 12 – Prime Brokerage. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 9  In addition, all fees paid to Fortress for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Fortress, but would not receive the services provided by Fortress which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Fortress to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Fortress is compensated for its services in advance of the month in which investment advisory services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the month. The Client’s investment advisory agreement with the Advisor is non- transferable without the Client’s prior consent. Betterment Institutional Platform – Fees charged for Betterment Institutional accounts are collected monthly, after services are provided. The Client may terminate the account[s] with Betterment Institutional, at any time, by providing advance written notice to the Advisor and Betterment Institutional. The Advisor will assist the Client with this process upon request. The Client shall be responsible for platform and advisory fees up to an including the effective date of termination. The Client may be subject to other terms as provided through the tri-party agreement with Betterment Institutional. Independent Manager - In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest, the Advisor will have the discretion to terminate the relationship with the Independent Manager. The terms for termination are set forth in the respective agreements between the Advisor and the Independent Managers. Financial Planning Services For stand-alone financial planning engagements, Fortress may require an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning engagement times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Institution Consulting Services Either party may terminate the consulting agreement by providing thirty (30) days’ advance written notice to the other party. The Advisor will be entitled to fees up to the date of termination. Retirement Plan Advisory Services Fortress is compensated for its services at the end of the quarter in which retirement plan advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. Upon termination, the Client shall be responsible for retirement plan advisory fees up to and including the effective date of termination. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 10  E. Compensation for Sales of Securities Fortress does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Fortress does not charge performance-based fees for its investment advisory services. The fees charged by Fortress are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Fortress does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Fortress offers investment advisory services to individuals, high net worth individuals corporations, and charitable organizations. The amount of each type of Client is available on Fortress’ Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Fortress generally requires a minimum relationship size of $500,000 to effectively implement its investment process. This minimum may be waived at Fortress’ sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Fortress primarily employs fundamental and technical analysis in developing investment strategies for its Clients. Research and analysis from Fortress are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Fortress will be able to accurately predict such a reoccurrence. As noted above, Fortress generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Fortress will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Fortress may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 11  B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Fortress will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 12  Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For Example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self- liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving Fortress or its Supervised Persons to disclose. Fortress values the trust Clients place in the Advisor. Fortress encourages Clients to perform the requisite due diligence on any advisor or service provider with whom the Client engages. The backgrounds of the Advisor and Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 308968. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliations The Advisor also serves as a licensed insurance agency, and as such, may offer insurance products on a commission basis. The Advisor shall generally introduce the Client to an unaffiliated insurance agency to manage the insurance process. The Advisor shall receive a portion of the insurance commission earned by the unaffiliated insurance agency. No client shall be under any obligation to purchase any insurance products from the Advisor or such introduced insurance agency. The recommendation by an Advisory Person that a Client purchase an insurance product presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than based on a Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 13  particular Client’s need. Clients are reminded that they remain free to purchase insurance products through other insurance agencies. FWG Capital, LLC FWG Capital, LLC (“FWG”) serves as the sponsor to the Fund advised by the Advisor, where Mr. Ledford and certain advisory persons have ownership and control of FWG. Certain Clients of the Advisor may be recommended to invest in the Fund. The Advisor receives a portion of the management fee in connection with investments in the fund. In addition, due to the affiliation, Mr. Ledford and certain Advisory Persons will financially benefit separately through revenues generated through the Fund. This practice presents a conflict of interest in recommending interests of the private fund. For Client assets placed in the fund, the Advisor will mitigate its investment advisory fee. Clients are not obligated to implement any recommendations made by Advisory Persons or the Advisor regarding the Fund. The Advisor will provide additional disclosure information to each Client, which will include relevant details regarding material financial interests and compensation surrounding the Fund. FWG Investment Management FWG Investment Management (“FWGIM”), a related advisor, serves as an advisor to a pooled investment vehicle (herein a “Fund”), where FWG serves as the sponsor. The service is detailed in the offering document of the fund and respective Disclosure Brochure, which include, as applicable: operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Document”). The Advisor will recommend that certain Clients invest in the Fund, managed by FWGIM. The recommendation to invest in the fund poses a conflict between the interests of the Advisor and the interests of the Client, as the Advisor, through its affiliation with the Fund, is incentivized to increase the amount of assets in the fund, in order to increase the revenue generated to the Advisor and its affiliates. Clients of the Advisor are under no obligation to invest in the Fund. Please see Item 10 for additional details. For more detailed information on investment objectives, policies and guidelines, please refer to the respective Fund’s Offering Document. Financial Institution and Consulting Services Fortress has an agreement with MSI to provide investment consulting services to Brokerage Customers, as noted in Item 4 – Advisory Services. MSI compensates Fortress for providing consulting services to Clients who have purchased products through MSI. This consulting arrangement does not include assuming discretionary authority over Brokerage Customers’ brokerage accounts or the monitoring of securities. These consulting services offered to Brokerage Customers includes a general review of Brokerage Customers’ investment holdings, which will result in Fortress’ Advisory Persons making specific securities recommendations or offering general investment advice. This relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive consulting services from Fortress. In addition, Fortress will not accept or bill for additional compensation on asset under MSI’s management, beyond the consulting fees disclosed in Item 5 above. Advisory Persons of the Advisor will not engage or hold itself as a registered representative of MSI, as Advisory Persons are not registered to conduct commission based activities under a broker-dealer. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Fortress has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Fortress (our “Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding Fortress’ duties to each Client. Fortress and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Fortress’ Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 14  conflicts of interest. To request a copy of the Code, please contact Fortress at (407) 999-8998 or via email at info@fortresswealthgroup.com. B. Personal Trading with Material Interest Fortress allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Fortress does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Fortress does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Fortress allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities Fortress recommends (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, Fortress must disclose to Clients and mitigate through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non- public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Fortress by conducting a coordinated review of personal accounts and the accounts of the Clients. The Advisor has also adopted written policies and procedures to detect the misuse of material, non- public information. D. Personal Trading at Same Time as Client While Fortress allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Fortress, or any Supervised Person of Fortress, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Fortress does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Fortress to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Fortress does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-by-trade basis. Where Fortress does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Fortress. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Fortress may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Fortress will generally recommend that Clients establish their account[s] with Fidelity Clearing and Custody Solutions and related divisions of Fidelity Investments, Inc. (collectively “Fidelity”), Charles Schwab & Co., Inc. (“Schwab”), MTG, LLC dba Betterment Securities (“Betterment Securities”) and Interactive Brokers LLC (“Interactive Brokers”), FINRA-registered broker-dealers and members SIPC (herein the “Custodian”). The Custodian will serve as the Client’s “qualified custodian”. Fortress maintains an institutional relationship with the Custodian, whereby the Advisor receives economic benefits from the Custodian. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 15  1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Fortress does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 – Client Referrals and Other Compensation. 2. Brokerage Referrals - Fortress does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Fortress will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Fortress will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. 4. Prime Brokerage - The Advisor may execute securities transactions either through the Custodian or through another unaffiliated broker-dealer in connection with a prime brokerage relationship established with the Custodian. Should a Client’s account[s] make use of prime brokerage, the Client is required to execute additional agreement[s] with the Custodian authorizing the Advisor to trade-away from and settle to the Client’s established account[s] at the Custodian. The Custodian will charge an additional trade-away fee for these transactions in addition to the normal securities transaction costs. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Fortress will execute its transactions through the Custodian as authorized by the Client. Fortress may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Fortress and periodically by John E. Ledord, the CCO of Fortress. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Fortress if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 16  statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Fortress Fortress may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Fortress may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform – Fidelity and Interactive Brokers Fortress has established an institutional relationship with Fidelity and Interactive Brokers to assist the Advisor in managing Client account[s]. Access to the Fidelity and Interactive Brokers platform is provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity and Interactive Brokers. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor has the following benefits from Fidelity and Interactive Brokers: reimbursement to Clients for transfer costs to the platform/Custodian; financing services, receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. Participation in Institutional Advisor Platform - Schwab Fortress has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Fortress. As a registered investment advisor participating on the Schwab Advisor Services platform, Fortress receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Fortress that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Fortress believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 17  Third Party Referrals Certain Clients may be referred by the Advisor to services of a Third Party as a part of the Advisor’s financial planning recommendations. As a result, the Advisor is compensated a fee for the introductions made and/or leads generated to the third party. The Advisor makes recommendations based on the needs and objectives of the Client. Clients are not obligated to engage any third party recommended by the Advisor. B. Client Referrals from Promoters Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Item 15 – Custody Fortress does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Fortress to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Fortress to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Fortress generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Fortress. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Fortress will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Fortress does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Fortress, nor its management, have any adverse financial situations that would reasonably impair the ability of Fortress to meet all obligations to its Clients. Neither Fortress, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Fortress is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 18  Privacy Policy Effective: October 30, 2025 Our Commitment to You FWG Holdings, LLC d/b/a Fortress Wealth Group (“Fortress” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Fortress (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Fortress does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 19  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Fortress does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Fortress or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Fortress does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting Fortress at (407) 999-8998 or via email at info@fortresswealthgroup.com. Fotress Wealth Group 1099 W Morse Blvd, Winter Park FL 32789 Phone: (407) 999-8998 * Fax: (407) 601-3308 www.fortresswealthgroup.com Page 20