GENEVA FINANCIAL GROUP

Form ADV Part 2A: Firm Brochure Geneva Financial Group, LLC 2060 W. County Line Rd Jackson, NJ 08532 732-719-4101 March 31, 2026 This Form ADV Part 2A Brochure (“Brochure”) provides information about the qualifications and business practices of Geneva Financial Group, LLC (“GFG” or the “Firm”). If you have any questions about the contents of this Brochure, please contact us at 732-719-4101 or jf@genevafingroup.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC does not imply that GFG or any individual providing investment advisory services on GFG’s behalf possesses a certain level of skill or training. Additional information about the Firm also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2 – Material Changes GFG has made the following material changes to its Brochure since it last published it in March 2025: - Added Pershing as Custodian; - Removed BNY Mellon as Custodian; and - Removed GFG Group as Outside Business Activity for Jacques Frenkel. Item 3 – Table of Contents Table of Contents Item 2 – Material Changes ............................................................................................................... 2 Item 3 – Table of Contents ............................................................................................................... 2 Item 4 – Advisory Business ............................................................................................................... 3 Description of Advisory Services ................................................................................................................ 3 Types of Investments ................................................................................................................................ 5 Client Assets Managed by the Firm ........................................................................................................... 6 Item 5 – Fees and Compensation ..................................................................................................... 6 Asset Management Services ...................................................................................................................... 6 Item 6 –Performance-Based Fees ..................................................................................................... 7 Item 7 – Types of Clients .................................................................................................................. 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................. 7 Methods of Analysis .................................................................................................................................. 7 Investment Strategies ................................................................................................................................ 8 Risk of Loss ................................................................................................................................................ 9 Item 9 – Disciplinary Information ................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ......................................................... 11 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading...................... 11 Code of Ethics Summary .......................................................................................................................... 11 Affiliate and Employee Personal Securities Transactions Disclosure ........................................................ 12 2  Item 12 – Brokerage Practices ....................................................................................................... 12 Asset Custodian Services and Brokerage Services .................................................................................... 12 Soft Dollar Benefits .................................................................................................................................. 13 Block Trading Policy ................................................................................................................................. 13 Item 13 – Review of Accounts ........................................................................................................ 13 Account Reviews ..................................................................................................................................... 13 Statements and Reports .......................................................................................................................... 13 Item 14 – Client Referrals ............................................................................................................... 13 Item 15 – Custody .......................................................................................................................... 14 Item 16 – Investment Discretion .................................................................................................... 14 Item 17 – Voting Client Securities .................................................................................................. 14 Item 18 – Financial Information ..................................................................................................... 14 Item 4 – Advisory Business Geneva Financial Group (GFG) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a limited liability company (LLC) formed under the laws of the State of New Jersey. Description of Advisory Services The following are descriptions of the primary advisory services of GFG. Please understand that you must execute a written agreement that details the exact terms of GFG’s service to our Clients (or “investors”, “you” or “your” or similar references) before our Firm can provide you the services described below. Asset Management Services – GFG offers asset management services, which involve GFG providing you with continuous and ongoing supervision over your specified accounts. GFG serves as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separately managed account(s) held by qualified independent custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities in the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive account statements and transaction confirmations) of the Account. The Account is managed based on your financial situation, investment objectives, financial information, and risk tolerance. GFG actively monitors the Account and provides advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. 3  GFG will obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are also available to consult with you concerning your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that the Firm manages investments for other clients and may give them advice or take actions for them, or for our personal accounts, that is different from the advice we provide to you, or actions taken for you. GFG is not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that the Firm manages. GFG strives to allocate investment opportunities among its clients equitably and consistent with the best interests of all clients involved. However, there can be no assurance that a particular investment opportunity that comes to the Firm’s attention will be allocated in any particular manner. If GFG or its personnel obtains material, non-public information about a security or its issuer that we may not lawfully use or disclose, the Firm has absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Retirement Plan Rollover Recommendations - When GFG provides investment advice about your retirement plan account or individual retirement account (“IRA”), including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, you acknowledge that GFG is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. GFG operates under a rule that requires GFG to act in your best interest and not put its interests ahead of you. Under this rule’s provisions, GFG must as a fiduciary to a retirement plan account or IRA under ERISA/IRC: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put the financial interests of GFG ahead of you when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that GFG gives advice that is in your best interest; • Charge no more than is reasonable for the services of GFG; and • Give a client basic information about conflicts of interest. GFG earns increased investment advisory fees by recommending that you roll over your account at 4  the retirement plan to an IRA managed by our Firm. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by GFG. Thus, our investment adviser representative(s) have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA. GFG has taken steps to manage this potential conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representative(s) will: (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below; (ii) not recommend investments which result in GFG receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA; and (iii) fully disclose compensation received by GFG and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a retirement plan account or IRA, GFG representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of our Firm or our affiliated personnel. Types of Investments GFG provides investment advice on the following types of investments • Structured Notes • Mutual Funds • Exchange Traded Funds (ETFs) • Exchange-listed Securities • Securities Traded Over-the-Counter • Foreign Issues (including ADRs/GDRs) • Corporate Debt Securities • Commercial Paper • Certificates of Deposit • Municipal Securities • U.S. Government Securities • U.S. Government Agency Securities • Options • Unregistered Securities 5  We reserve the right to offer advice on any investment product that we deem appropriate for each client’s specific circumstances, needs, goals and objectives. You have the ability to impose reasonable restrictions on the accounts we manage for you, including specific investment selections and sectors. It is not GFG’s typical investment strategy to attempt to time the market, but we may increase cash holdings as deemed appropriate based on your risk tolerance and our expectations of market behavior. GFG may modify the established investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information. Client Assets Managed by the Firm As of December 31, 2025, the Firm managed $233,663,445 of client assets, $162,171,215 of which the Firm manages on a discretionary basis and $71,492,229 of which it manages on a non-discretionary basis. Item 5 – Fees and Compensation This section describes how GFG is compensated for its services. The exact fees and other terms will be outlined in the agreement between you and GFG. Lower fees for comparable services may be available from other advisers. Asset Management Services The annual fee for asset management services will be between 0.75% and 1.50%. There is a minimum account size of $250,000. Fees charged for our asset management services are negotiable and depend on various factors, including, but not limited to, the type of client, the complexity of the client's situation, the composition of the client's account, the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client or client household. GFG believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to our compensation, you may also incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses). Fees charged for our asset management services are charged based on a percentage of assets under management, billed in arrears (at the end of the billing period) on a monthly basis and calculated based on the fair market value of your Account as of the last day of the current billing period. Cash balances are also considered billable assets in this assessment. Fees are prorated based on the number of days service is provided during the initial billing period for your Account if you open it at any time other than the beginning of the billing period. The prorated fee for that billing period will be billed in arrears at the end of that billing period. The asset management services continue in effect until you or GFG terminates your agreement by providing written notice of termination to the other party. When fees are billed in arrears, GFG will prorate the final fee payment based on the number of days services are provided during the final period. The amount of client assets on the termination date will be used to determine the final fee payment. You will authorize the custodian(s) of your account to deduct fees from your account and pay such 6  fees directly to GFG. You should review your account statements received from the custodian(s) and verify that appropriate investment advisory fees are being deducted. The custodian(s) will not verify the accuracy of the investment advisory fees deducted. Brokerage expenses and/or transaction fees charged are billed directly to you. GFG does not receive any portion of such commissions or fees from you or any other party. In addition, you will incur certain charges imposed by third parties other than GFG in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1 fees applicable to registered investment companies and contingent deferred sales charges, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by GFG are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus or applicable product’s offering memorandum. Item 6 –Performance-Based Fees GFG’s fee is not based on whether there are any gains and is not contingent on a share of capital gains or capital appreciation of the assets held in a client’s account Item 7 – Types of Clients GFG generally provides investment advice to individuals, high net worth individuals, corporations or business entities and Family Offices. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis GFG uses the following methods of analysis in formulating investment advice: Charting - This is a set of techniques used in technical analysis in which charts are used to plot price movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future price movements. Users of these techniques believe that past trends in these indicators can be used to extrapolate future trends. Charting is likely the most subjective analysis of all investment methods since it relies on proper interpretation of chart patterns. The risk of reliance upon chart patterns is that the next day's data can always negate the conclusions reached from prior days' patterns. Also, reliance upon chart patterns bears the risk of a certain pattern being negated by a larger, more encompassing pattern that has not shown itself yet. Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, 7  overpriced = sell or short). Fundamental analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong and could therefore lead to an unfavorable investment decision. Technical – This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Technical analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given security's price and trading volume data. A decision might be made based on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading decision being made incorrectly since future trading volume is an unknown. Technical analysis is also done through observation of various market sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then there are very few traders left in a position to sell the security in question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result in a premature purchase of a security. There are risks involved in using any analysis method. Investment Strategies GFG uses a variety of investment strategies when managing client assets and providing investment advice, including, but not limited to: Long-term purchases. Investments are held for at least a year. Short-term purchases. Investments sold within a year. Short sales. A short sale is generally the sale of a stock not owned by the investor. Investors sell short when they believe the price of the stock will fall. If the price drops, the investor can buy the stock at the lower price and make a profit. If the price of the stock rises and the investor buys it back later at the higher price, the investor will incur a loss. Short sales require a margin account. 8  Margin transactions. When an investor buys a stock on margin, the investor pays for part of the purchase and borrows the rest of the purchase price from a brokerage firm. Buying and selling options. including selling covered options, uncovered options. Trading of Structured Products. This includes structured notes, which are products that attempt to meet specific investment objectives such as growth, income, or risk management. Structured notes combine a traditional security, like a bond, with a derivative component in which the issuer promises to pay a return based on the performance of one or more reference assets, such as an index or any other asset. Unlike mutual funds or exchange-traded funds (ETFs), structured notes do not hold an underlying portfolio of investments. Strategic asset allocation. Calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, Structured Products, bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Structured Products: Structured Products can come with or without principal protection. Structured Products with principal protection offer a full or partial return of principal at maturity, regardless of the performance of the underlying assets. However, any guarantee of principal protection depends on the financial strength of the issuer of the security. Structured Products can offer higher potential returns compared to their reference assets but also involve unique risks and complexities in their terms and features. Investors should recognize that other factors may also affect their investment outcomes. Therefore, it is crucial to carefully review the offering documents associated with these investments. Issuers of Structured Products are not under an obligation to provide liquidity in all circumstances. Even when a market is provided you might not be able to obtain an appropriate price for the product when you sell it. It might also be difficult or impossible to determine a fair price or even compare prices at all, as there is often only one market maker. Always read the investment prospectus to be sure you know whether a specific note offers full or less than full protection or has protection that is conditional or contingent on other factors. Because of the inherent risk of loss associated with investing, GFG is unable to represent, guarantee, or even imply that its services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities as described below: Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. 9  Equity (Stock Market) Risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. Company Risk - When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Fixed Income Risk - When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. Margin Risk - When you purchase securities, you may pay for the securities in full or borrow part of the purchase price from your account custodian or clearing firm. If you intended to borrow funds to purchase securities in your Account, you will be required to open a margin account, which will be carried by the clearing firm. The securities purchased in such an account are the clearing firm’s collateral for its loan to you. If those securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and as a result, the brokerage firm is required to act to maintain the necessary level of equity in your account. The brokerage firm may issue a margin call and/or sell other assets in your account. It is important that you fully understand the risks involved in trading securities on margin. These risks include the following: • You can lose more funds than you deposit in your margin account. • The account custodian or clearing firm can force the sale of securities or other assets in your account. • The account custodian or clearing firm can sell your securities or other assets without contacting you. • You are not entitled to choose which securities or other assets in your margin account may be liquidated or sold to meet a margin call. • The account custodian or clearing firm may move securities held in your cash account to your margin account and pledge the transferred securities. 10  • The account custodian or clearing firm can increase its “house” maintenance margin requirements at any time and they are not required to provide you advance written notice. • • You are not entitled to an extension of time on a margin call. Management Risk – The value of your Account varies with the success and failure of GFG’s investment strategies, research, analysis and determination of portfolio securities. Foreign (Non-U.S.) Risk - A portfolio’s investments in securities of non-U.S. (or foreign) issuers may involve more risk than those of U.S. issuers. These securities may fluctuate more widely in price and may be less liquid due to adverse market, economic, political, regulatory or other factors. Emerging Markets Risk - Securities of companies in emerging markets may be more volatile than those of companies in developed markets. By definition, markets, economies and government institutions are generally less developed in emerging market countries. Investment in securities of companies in emerging markets may entail special risks relating to the potential for social instability and the risks of expropriation, nationalization or confiscation. Investors may also face the imposition of restrictions on foreign investment or the repatriation of capital and a lack of hedging instruments. Currency Risk - Fluctuations in currency exchange rates may negatively affect the value of a portfolio’s investments or reduce its returns. Interest Rate Risk - Changes in interest rates will affect the value of a portfolio’s investments in fixed income securities. When interest rates rise, the value of investments in fixed income securities tend to fall and this decrease in value may not be offset by higher income from new investments. Interest rate risk is generally greater for fixed income securities with longer maturities or durations. Credit Risk - An issuer, obligor or guarantor of a fixed income security or a structured note, may be unable to make timely payments of interest or principal. Item 9 – Disciplinary Information GFG has no legal or disciplinary events to disclose. Item 10 – Other Financial Industry Activities and Affiliations Jacques Frenkel is the owner of Geneva Enterprises, which owns the Firm. He also owns GFG Realty LLC and Geneva Realty LLC, both of which are real estate companies. GFG does not advise its clients to invest in these entities, nor will any of these entities accept investments from GFG clients. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary In accordance with Rule 204A-1 of the Investment Advisers Act of 1940, GFG has established a Code of Ethics (“Code”) that reflects its fiduciary obligations and those of its supervised persons. The Code covers all individuals that are classified as “supervised persons”. The Code also requires 11  compliance with federal securities laws. It also requires that supervised persons consistently act in your best interest in all advisory activities. GFG imposes certain requirements on its supervised persons to ensure that they meet the firm’s professional obligations. If you wish to receive a copy the Code in its entirety, please contact our Firm using the information on the cover page of this Brochure. Affiliate and Employee Personal Securities Transactions Disclosure GFG’s supervised persons may buy and sell for their personal accounts investment products similar or identical to those recommended to clients. To mitigate possible conflicts of interest that can occur when access persons manage their personal accounts at the same time GFG manages client accounts, GFG has developed written procedures that include personal investment and trading policies for its representatives, employees and their immediate family members (collectively, supervised persons). Further, GFG’s policy that all persons associated in any manner with the Firm must place clients’ interests ahead of their own when implementing personal investments. GFG and its supervised persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with GFG unless the information is also available to the investing public upon reasonable inquiry. Item 12 – Brokerage Practices The Firm is responsible for ensuring that its clients receive best execution. Best execution does not necessarily mean that clients receive the lowest possible commission costs, but that the qualitative execution is best. In other words, all conditions considered, the transaction execution is in your best interest. When considering best execution, the Firm considers a number of factors besides prices and rates including, but not limited to: • Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with my existing systems, ease of monitoring investments); • Products and services offered (e.g., investment programs, back-office services, technology, regulatory compliance assistance, research and analytic services); • Financial strength, stability and responsibility; and • Reputation and integrity. Asset Custodian Services and Brokerage Services GFG currently uses Pershing, Interactive Brokers, and Charles Schwab as custodians, and may choose to engage additional custodians in the future. We maintain professional relationships with a range of qualified brokerage firms, allowing us to select the broker we believe is best suited for each individual transaction. This approach ensures optimal service for our clients. 12  Soft Dollar Benefits GFG does not have a formal commission sharing arrangement with any financial institution nor participate in transactions involving soft dollar commissions with a broker-dealer or a third-party. Block Trading Policy GFG may elect to purchase or sell the same securities for several clients at approximately the same time, which is referred to as aggregating orders, batch trading or block trading. GFG uses this when it believes such action may prove advantageous to clients. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. If GFG aggregates client orders, allocating securities among client accounts is done on a fair and equitable basis. GFG does not receive additional compensation for aggregating trades. GFG uses the average price allocation method for transaction allocation. Under this procedure GFG will calculate the average price and transaction charges for each transaction included in a block order and assign the average price and transaction charge to each allocated transaction executed for the client’s account. If GFG includes proprietary accounts of the Firm or personal accounts of its supervised persons in an aggregated client order (i.e., block trade), then each account participating in the order will participate at an average share price of all GFG’s transactions in that security on the day of execution and transaction costs will be shared on a pro rata base for each client’s participation in the transaction. Item 13 – Review of Accounts Account Reviews Managed accounts are reviewed at least quarterly and/or conducted at your request. Account reviews will include investment strategy and objectives review and making a change if strategy and objectives have changed. Reviews are conducted by the GFG representative assigned to the Account. Statements and Reports For our asset management services, you will receive account statements in writing directly from the qualified custodian, which also provides online access to your account. You are encouraged to compare any correspondence, reports, or statements provided by GFG against the account statements delivered by the qualified custodian. If you have questions about your account statement or anything you see online, you should contact both our firm and the qualified custodian responsible for preparing the statement. Item 14 – Client Referrals GFG does not directly or indirectly compensate any person for client referrals. 13  Item 15 – Custody GFG may be deemed to have custody of client funds and securities if it is given the authority to have fees deducted directly from client accounts. For accounts in which GFG is deemed to have custody, it has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from GFG. When clients have questions about their account statements, they should contact GFG or the qualified custodian preparing the statement. Item 16 – Investment Discretion GFG maintains trading authorization over your account and offers both discretionary and non- discretionary account options. When discretionary authority is granted, GFG will have the authority to determine the type of securities and the amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction. If you decide to engage GFG on a non-discretionary basis, GFG will be required to contact you prior to implementing changes in your account. This can have an adverse impact on the timing of trade implementations and the price you receive for your transactions. You will have the ability to place reasonable restrictions on the types of investments that may be purchased in your Account. You may also place reasonable limitations on the discretionary power granted to Geneva Financial Group so long as the limitations are specifically outlined in writing or included as an attachment to the client agreement. Item 17 – Voting Client Securities GFG does not vote proxies on behalf of Clients. Therefore, it is your responsibility to vote all proxies for securities held in the Account. You will receive proxies directly from the qualified custodian or transfer agent. You are encouraged to read the information provided with the proxy-voting documents and decide based on the information provided. Item 18 – Financial Information GFG does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. GFG has not been the subject of a bankruptcy petition at any time. 14