Gfg Solutions

Item 1 – Cover Page Registered as GFG Wealth, LLC | Doing Business as GFG Solutions | CRD No. 331977 Form ADV Part 2A – Firm Disclosure Brochure 150 N Orange Ave, Suite 340 | Orlando, FL 32801 Phone: (407) 627-0091 | Website: https://gfgsolutions.com/ May 6, 2026 This brochure provides information about the qualifications and business practices of GFG Solutions. If you have any questions about the contents of this brochure, please contact us at Phone: (407) 627-0091. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about GFG Solutions is also available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD No: 331977. Registration does not imply a certain level of skill or training.  Item 2 – Material Changes Item 2: Material Changes This brochure reflects an update to the version dated March 30, 2026. This update is intended to clarify the brand name under which the Adviser provides investment advisory services; to clarify that any financial planning provided as part of the Adviser’s investment advisory services is provided without a separate fee; and to identify the Adviser’s affiliated entity through which non-investment- advisory financial planning services are provided. Except as described above, no other material changes have been made. At any time, the current Disclosure Brochure is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching the firm name or CRD number 331977. A copy of this Disclosure Brochure may be requested at any time, by contacting (407) 627-0091. Page 2 of 48 Disclosure Brochure  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 Item 5 – Fees and Compensation ........................................................................................................................................... 16 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................................... 20 Item 7 – Types of Clients ........................................................................................................................................................ 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .............................................................................. 20 Item 9 – Disciplinary Information ......................................................................................................................................... 33 Item 10 – Other Financial Industry Activities and Affiliations ........................................................................................... 33 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................. 35 Item 12 – Brokerage Practices ............................................................................................................................................... 35 Item 13 – Review of Accounts ................................................................................................................................................ 38 Item 14 - Client Referrals and Other Compensation ........................................................................................................... 39 Item 15 – Custody ................................................................................................................................................................... 40 Item 16 – Investment Discretion ............................................................................................................................................ 40 Item 17 – Voting Client Securities ......................................................................................................................................... 40 Item 18 – Financial Information ............................................................................................................................................ 41 Privacy Policy ........................ 47 Page 3 of 48 Disclosure Brochure  Item 4 – Advisory Services Firm Information GFG Wealth LLC (“Advisor”) is an SEC-registered investment adviser with its principal office located at 150 N. Orange Ave, Suite 340, Orlando, FL 32801, doing business under GFG Solutions. The firm is organized as a limited liability company (“LLC”) under the laws of Florida. GFG Solutions was registered as an investment advisor with the U.S. Securities and Exchange Commission (“SEC”) in 2023. This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services GFG Solutions offers. Tailored and thorough financial planning is at the core of what we do. We aim to empower our clients to be great stewards of their money. To achieve this, we must understand someone’s financial life. Once we see the full picture, we begin to help in the exact way our clients need, whether that be the full planning approach or a specific financial planning service. Principal Owner Claudio Gambin President, Chief Executive Officer & Financial Advisor Claudio graduated from the University of Central Florida with a major in Entrepreneurship. After graduating, he started as an intern in the financial services business and quickly fell in love with the work. He became a full-time Financial Advisor in 2010 and founded GFG Solutions. Claudio’s passion lies in working with business owners and specializes in helping those clients in the areas of risk management, cumulative tax planning, estate distribution strategies, and business transfer planning. Outside Business Activities Mr. Gambin is involved in several outside business activities, both investment-related and non-investment-related. These activities present conflicts of interest due to the compensation received and time commitments required, which may impact the services provided to advisory clients. PGW Partners, LLC Mr. Gambin is the indirect owner1 of this holding company that was organized to own and manage real estate rental properties. This activity represents a passive engagement that requires approximately 1 hour a month. GG Investments LLC Mr. Gambin serves as the President and dedicates approximately 1 hour per month to overseeing budgets, staff, and executives as well as evaluating the overall company success. GG Group Ventures LLC Mr. Gambin serves as the CEO (Change U4) and dedicates approximately 100 hours per month to this activity. The primary function of GG Group Ventures, LLC is to provide business consulting services that are outside the scope of services provided by GFG Solutions, a registered investment advisor. Offline Brands LLC Mr. Gambin is the owner of a that sells fishing apparel and gear, He commits approximately 1 hour a month to this facilitate and guide company operations and progress towards goals. GFG Marketing LLC Legal entity to process employee payroll. GFG Insurance LLC Legal entity organized to receive commission revenue from the sale of insurance products. 1 PGW Partners, LLC is directly owned by GG Investments, LLC, which is 100% owned by Claudio Gambin. Page 4 of 48 Disclosure Brochure  LABC Cost Segregation LLC Mr. Gambin is part owner of a cost segregation company. Cost segregation is a tax planning strategy used by real estate investors to accelerate depreciation deductions, defer taxes, and improve cash flow by reclassifying certain components of a commercial or income-producing property into shorter depreciation categories. (Less than 1 hour a month) Channel Marker Advisors LLC Mr. Gambin serves as the Co-founder and Chief Executive Officer. Channel Marker Advisors is not an investment advisor. The advice offered pertains to capital formation, planning, growth initiatives, and operational improvements, to help clients make informed business decisions. (Approximately 5 to 10 hours a month.) CRZ Holding LLC CRZ Holding LLC is a hard money lending group2 who pays Mr. Claudio a finder’s fee (2 basis points) to introduce clients who would benefit from hard money lending opportunities. The finder's fee is paid by CRZ Holding LLC. The costs are not charged to clients; instead, they are paid by the lender. Mr. Claudio does not maintain a management position nor is he subject to any contractual obligations or minimum standards. CRZ Holding LLC is not a client of GFG. (Approximately 1 hour or less a month.) SOLYCO Capital Mr. Claudio serves as a general partner of the SOLYCO Capital SPV2 fund; however, he is not involved in any decision- making and is not included in any internal meetings regarding the fund or the company. His title is a courtesy based on a personal capital contribution of $5 Million. Investment advisor representatives are compensated with a management fee for introducing RIA clients who invest in the fund. Prior to making an introduction, investment advisor representatives have a fiduciary duty to ensure any client investing in the fund is fully educated on it, understand the risks, and most importantly, do the due diligence to make sure it is a recommendation in their best interest for the client based on their whole financial picture. (Approximately 1 hour or less a month.)  GFG Solutions does not have a sales goal or production requirement.  The minimum funding amount is $100,000.  GFG Solutions is working with other similar partners that have funds with comparative returns potential.  Certain clients have used leverage to invest in this SPV2 fund, by taking a line of credit against other investments. Such an investment strategy is considered high risk as a client can lose more than then the principal amount invested. Each outside business activity represents an independent conflict of interest based on compensation and time commitment. Given the collective demand for Mr. Gambin’s time and the number of activities, this conflict of interest should be considered significant. Types of Advisory Services Offered GFG Solutions offers discretionary3 and non-discretionary asset management and financial planning services to individuals, high net worth individuals, and business owners (each referred to as a “client”). Investment accounts are maintained at Charles Schwab & Co., 2 Hard money lending is a type of real estate loan secured by the value of the property itself rather than the creditworthiness of the borrower. These loans are typically short-term, often ranging from 6 to 24 months, and are used for real estate transactions that require quick funding or for borrowers who may not qualify for conventional financing due to credit issues or other reasons. Hard money lenders are often private individuals or companies willing to lend based on the property's value, which serves as collateral. Hard money loans generally come with higher interest rates compared to traditional financing. This reflects the increased risk for the lender and the short- term nature of the loans. 3 Client grants Advisor ongoing and continuous authority to execute its investment recommendations without the Client's prior approval of each specific transaction. Under this authority, Client shall allow Advisor to purchase and sell securities and instruments in this Account(s), arrange for delivery and payment in connection with the foregoing, select and retain sub-advisors, and act on behalf of the Client in all matters necessary or incidental. Page 5 of 48 Disclosure Brochure  Inc. “(Schwab”).) a FINRA4/SIPC5 member broker/dealer and registered with the Securities & Exchange Commission , to serve as the custodian for client funds (“Custodian”).  GFG Solutions is independently owned and operated and not affiliated with Schwab.  Schwab will act solely as a broker/dealer and not an investment advisor and will have no discretion to execute trades.  Schwab does not open accounts, monitor or supervise investment activity  Investment advice is not limited to certain types of investments. Advisory services are tailored to the individual needs of clients who may impose restrictions on investing in certain securities or types of securities. Planning For Families GFG Solutions assists families in navigating the intricate landscape of financial planning, recognizing that each stage of family life brings distinct challenges and opportunities. Here's a closer look at how they support families in preparing for their financial future:  Marriage: Entering marriage often involves merging finances, setting joint financial goals, and creating a budget that reflects shared priorities. GFG Solutions helps couples establish a solid financial foundation by facilitating discussions about spending habits, savings goals, and future financial plans. They also offer guidance on managing debt and building a financial safety net.  Parenthood: The arrival of children introduces new financial responsibilities, from managing everyday expenses to planning for education costs. GFG Solutions assists families in developing strategies to save for their children's education, such as setting up college savings plans or exploring scholarships and financial aid options. They also address the importance of having adequate insurance coverage to protect the family’s financial future.  College Planning: As children grow, the focus often shifts to preparing for college expenses. GFG Solutions provides insights into various savings vehicles, such as 529 plans, and offers advice on navigating financial aid, scholarships, and student loans. Their goal is to help families create a sustainable plan that aligns with their educational aspirations for their children.  Retirement Planning: Preparing for retirement is a critical component of family financial planning. GFG Solutions works with families to establish retirement savings goals, evaluate investment strategies, and assess potential income streams. By considering factors such as life expectancy, healthcare costs, and lifestyle goals, they help families build a retirement plan that ensures financial security in later years.  Legacy and Estate Planning: Beyond retirement, GFG Solutions assists families in planning for the transfer of wealth to future generations. This involves creating wills, setting up trusts, and considering tax implications to ensure that assets are distributed according to the family’s wishes. Effective estate planning helps minimize potential conflicts and preserves family wealth for future generations.  Ongoing Financial Guidance: As families evolve, so do their financial needs. GFG Solutions provides continuous support and advice, adapting financial plans to reflect changing circumstances, such as career transitions, relocations, or unexpected life events. This ongoing partnership ensures that families remain on track to achieve their long-term financial goals. By offering tailored financial planning services, GFG Solutions empowers families to manage their financial complexities with confidence. Their comprehensive approach ensures that families are well-prepared for each stage of life, fostering financial stability and peace of mind for the present and the future. 4 FINRA (Financial Regulatory Authority) is dedicated to investor protection and market integrity through effective and efficient regulation of the securities industry. FINRA is not part of the government but an independent, not-for-profit organization authorized by Congress to protect America’s investors by making sure the securities industry operates fairly and honestly. http://www.finra.org. 5 SIPC (Securities Investors Protection Corporation) was created under the Securities Investor Protection Act as a non-profit membership corporation. SIPC oversees the liquidation of member broker-dealers that close when the broker-dealer is bankrupt or in financial trouble, and customer assets are missing. http://sipc.org Page 6 of 48 Disclosure Brochure  Planning For Businesses GFG Solutions offers comprehensive support to business owners at every stage of their business life cycle, addressing the unique challenges and opportunities that arise during each phase. Here’s a more detailed look at how they assist business owners:  Startup Phase: During this initial phase, GFG Solutions assists entrepreneurs in laying a solid foundation for their business. This includes helping with business planning, securing initial funding, and establishing financial management practices. They provide guidance on setting up appropriate business structures, managing startup costs, and ensuring compliance with financial regulations.  Growth Phase: As a business begins to grow, GFG Solutions helps owners manage increased cash flow and operational demands. They offer strategies for optimizing financial performance, managing resources effectively, and planning for sustainable growth. This may involve exploring options for reinvestment, expanding operations, or entering new markets.  Expansion Phase: In this phase, businesses often seek to scale operations or diversify their offerings. GFG Solutions provides expertise in evaluating investment opportunities, securing additional financing, and managing the complexities of expansion. They assist in developing strategies for mergers, acquisitions, or partnerships, ensuring that growth aligns with the owner’s overall vision and goals.  Maturity Phase: At this stage, businesses face challenges in maintaining competitiveness and maximizing profitability. GFG Solutions helps owners refine their financial strategies, manage risk, and optimize asset allocation. They focus on ensuring the business remains agile and responsive to market changes, while also preparing for long-term sustainability.  Exit Phase: When it’s time to transition out of the business, GFG Solutions provides support for a smooth and successful exit. Whether the goal is to sell the business, merge with another company, or transition ownership to the next generation, they offer guidance on valuation, succession planning, and tax-efficient exit strategies. They help business owners clarify their personal financial goals post-exit, such as retirement planning or other ventures. Throughout these phases, GFG Solutions emphasizes understanding the business owner’s true desires and goals. Whether the business is seen as an engine for funding retirement or as a legacy to be passed on, they offer personalized financial planning that aligns with these objectives. By addressing uncertainties and providing strategic clarity, GFG Solutions enables business owners to navigate the complexities of the business life cycle with confidence and financial certainty. Insurance Strategy & Analysis Building a strong foundation is pillar number one of our planning philosophy and nothing is more foundational than ensuring you and those you love the most are properly protected. In the context of financial planning, the foundational principle of ensuring proper protection involves several key aspects. These are designed to safeguard not only your financial assets but also the well-being of your loved ones. Here’s an elaboration on this principle:  Risk Management and Insurance: One of the primary ways to protect your financial foundation is through effective risk management strategies, including adequate insurance coverage. This can include life insurance, health insurance, disability insurance, and property insurance. Having the right insurance policies in place ensures that unexpected events, such as illness, injury, or loss of property, do not derail your financial goals or place an undue burden on your family.  Estate Planning: Proper estate planning is crucial to protecting your assets and ensuring that they are distributed according to your wishes. This can involve creating wills, trusts, and powers of attorney. Estate planning helps avoid legal complications and ensures that your loved ones are cared for in the event of your passing.  Asset Protection: This involves strategies to protect your assets from potential creditors or legal claims. It can include structuring ownership of assets in a way that minimizes risk, such as through the use of trusts or other legal entities. Page 7 of 48 Disclosure Brochure   Emergency Funds: Establishing an emergency fund is a critical component of a strong financial foundation. This fund provides a financial cushion in case of unexpected expenses, such as medical emergencies or job loss, ensuring you can maintain your lifestyle and financial commitments during challenging times.  Financial Literacy and Education: Educating yourself and your family about financial management is foundational to long- term financial health. Understanding how to budget, save, invest, and manage debt empowers you to make informed decisions that protect and grow your wealth. By focusing on these areas, GFG Solutions aims to build a robust financial plan that not only grows your wealth but also protects it, ensuring peace of mind for you and your family. This holistic approach is about more than just numbers; it's about securing your future and the futures of those you care about most. Wealth Management At GFG Solutions, it is important to us that we let your goals and the financial plan lead the conversation because they play a strong role in the decisions we make with your investment portfolio. Additionally, having a thorough understanding of your risk tolerance and past experience is crucial to us delivering recommendations that align with your goals and values. Many firms will provide cookie- cutter, proprietary portfolios for their clients but we pride ourselves on offering customized solutions to meet your goals. GFG Solutions incorporates a variety of important aspects and strategies:  Customized Investment Portfolio Creation  Savings & Investment Philosophy  Thorough Investment Analysis  Retirement Goals  Past Experiences & What You Truly Want Out of  Risk Tolerance An Advisor  Time Horizon  Tax/loss Harvesting Wrap Fee Program Transaction fees are paid by GFG Solutions instead of the client, which make the advisory accounts offered by GFG Solutions a wrap fee program6. Clients should understand that the cost of transaction charges can be a factor that GFG Solutions considers when deciding which securities to select and how frequently to place transactions. GFG Solutions has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares are available. This is a conflict of interest which might incline GFG Solutions , consciously or unconsciously, to render advice that is not disinterested. GFG Solutions generally does not pay transaction charges for Class A Share mutual fund transactions accounts, but generally does pay transaction charges for Platform Share mutual fund transactions. The cost7 to GFG Solutions of transaction charges generally can be a factor Advisor considers when deciding which securities to select and whether or not to place transactions in the account.  Single Fee: Clients are charged one all-inclusive advisory fee, typically expressed as a percentage of assets under management (AUM). This fee covers both the advisory services provided by the investment advisor and the transaction costs incurred when buying or selling securities within the client’s account.  Simplicity and Predictability: The wrap fee simplifies billing by consolidating various fees into one predictable charge, making it easier for clients to understand their costs. 6 A wrap fee program is a comprehensive advisory account with a single fee that covers a bundle of services, such as, portfolio management, advice, and investment research as well as trade execution, custody, and reporting fee. 7 The lack of transaction charges to GFG Solutions for Class A Share purchases and sales, together with the fact that Platform Shares generally are less expensive for a client to own, presents a significant conflict of interest between GFG Solutions and the client. In short, it costs less to recommend and select Class A share mutual funds than Platform shares, but Platform shares will generally outperform Class A mutual fund shares on the basis of internal cost structure alone. Clients should understand this conflict and consider the additional indirect expenses borne as a result of the mutual fund fees when negotiating and discussing with your Advisor the advisory fee for management of an account. Page 8 of 48 Disclosure Brochure   Cost Predictability: Clients benefit from knowing their total investment costs upfront, without worrying about fluctuating transaction fees.  Aligned Interests: This fee structure can align the advisor’s interests with those of the client, as the advisor is compensated based on the client's total assets managed rather than the volume of trades executed.  Comprehensive Services: Clients receive a bundle of services, which may include portfolio management, financial planning, and ongoing advisory support.  Cost Comparison: Depending on the level of trading activity, a wrap fee program may be more or less expensive than paying for advisory services and transaction fees separately. Clients with low trading activity might end up paying more under a wrap fee structure.  Reverse Churning Risk: There is a potential conflict of interest known as "reverse churning," where an advisor might limit trading activity to maintain profitability under the fixed wrap fee, possibly compromising the active management of the account.  Active Traders: For clients who engage in frequent trading, a wrap fee program can be cost-effective, as it may result in lower overall fees compared to paying individual transaction charges.  Passive Investors: Clients with less active trading strategies might find that the wrap fee exceeds what they would pay if they were charged separately for advisory services and each transaction. Clients should evaluate their trading patterns and investment strategy to determine if a wrap fee program is financially beneficial. It's important to assess the range of services included in the wrap fee and ensure they align with personal financial needs and goals. A wrap fee program offers a streamlined and predictable fee structure that can be advantageous for clients with higher trading activity. However, it requires careful consideration of the client’s investment behavior and financial goals to ensure it provides the best value. Wrap Fee Program – Other Fees While the wrap fee covers advisory services and transaction costs, it does not include the expenses charged by mutual funds, ETFs, or other investment products within the portfolio. These underlying fund expenses, such as management fees and operating costs, are deducted from the fund's assets and can impact overall returns. Clients can incur additional charges not covered by the wrap fee, such as account maintenance fees, wire transfer fees, and fees for specific account activities (e.g., account termination or transfers). It's important to review these costs in the account agreement or fee schedule.  Please see Appendix 1 –Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. Sub-Advisory Agreement GFG Solutions can enter into a sub-advisory agreement. A sub-advisory agreement is a contractual arrangement between two registered investment advisors, where one firm (the "sub-adviser") is hired by another firm to manage a portion of the assets of a specific investment fund or client account. In this arrangement, GFG Solutions retains overall responsibility for managing the client account while delegating a portion of the investment decisions and portfolio management functions to the sub-advisor. A sub-advisory agreement outlines the terms and conditions of the collaboration between the two firms, including the scope of the sub- advisor's responsibilities, the compensation structure, and any other relevant terms. The agreement will clearly define the specific duties and responsibilities of the sub-advisor. This can include investment strategy, asset allocation, security selection, risk management, and performance reporting. The compensation structure for the sub-advisor is usually outlined in the agreement. Compensation can be a fixed fee, a percentage of assets under management, or a combination of both. The agreement also addresses any additional fees or expenses the sub-advisor is entitled to. The non-exclusive functions of a sub-advisor generally include determining the composition and portfolio allocation, the nature and timing of the changes therein and the manner of implementing such changes, investment monitoring, and research. GFG Solutions delegates to the Sub-Advisor the power and authority to effectuate its investment decisions, including the execution and delivery of all investment related documents, placing trades, and billing. A sub-advisor has a fiduciary duty to GFG Solutions and its clients. Page 9 of 48 Disclosure Brochure  Held Away Assets GFG Solutions can use a third-party platform to facilitate discretionary management of held away assets such as a defined contribution plan participant account or 401(k) accounts. The platform allows us to avoid being considered to have custody of client funds since we do not have direct access to client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is connected to the platform, GFG Solutions will review the current account allocations. When deemed necessary, GFG Solutions will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Real Estate Investments GFG Solutions may advise on commercial real estate, multi-family developments and land acquisition opportunities that may be appropriate for accredited investors as defined under SEC Rule 501 of Regulation D and applicable Florida securities laws. Such advice will only be provided to clients who meet the legal definition of an accredited investor and have completed appropriate verification procedures. Such investments may include investing in land zoned for mixed use such as retail shopping, restaurants, schools and universities as well as medical facilities, parks and residential properties. There are various risks to consider such as a lack of public interest and the lack of registration with the SEC or the securities commission of any state or country. In addition, the following, not limited, risks apply:  Lack of Liquidity  Zoning Restrictions and Potential Changes  Lack of Control  Minimal Transparency  Changing Economic Conditions affecting Consumer Demand  Construction Delays due to Costs of Materials or Labor Disputes  Unexpected Environmental Complications  Tenants/Residents Ability to make Rent/Mortgage Payments (Risk of Default) Like other Alternative Investments and Limited Partnerships, performance can be volatile. Investments are subject to a complete loss of the principal amount invested with extended time frames before a potential return on capital, if any. In addition, such investments often have concentrated positions that can exaggerate investment risk. Clients with the appropriate risk profile should only consider a portion of their total assets to be help in high risk, volatile positions. Private Equity GFG can introduce and advise qualified clients on private equity opportunities. Private equity investments involve a higher degree of risk compared to public equity investments due to a lack of registration and disclosure requirements, the potential for operational and managerial challenges as well as market risks, and a potentially high debt position. However, successful private equity investments can yield significant returns for investors. Private equity investments are generally suitable for sophisticated investors with a high-risk tolerance, a long-term investment horizon, and the ability to sustain losses up to the entire principal amount invested. Private equity investments are complex and are not suitable for all investors. Investments in private equity are often illiquid, meaning that it can be challenging to sell or exit the investment before the agreed-upon holding period, which is typically several years. This lack of liquidity can tie up capital for an extended period, limiting the investor's ability to react to changing financial needs or market conditions. Page 10 of 48 Disclosure Brochure  Retirement Plan Rollovers An employee generally has four (4) options for their retirement plan when they leave an employer: 1. Leave the money in his/her former employer’s plan, if permitted 2. Rollover the assets to his/her new employer’s plan if one is available and permitted 3. Rollover to an Individual Retirement Account (IRA), or 4. Cash out the account value, which has significant tax considerations Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so:  Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments.  Employer retirement plans generally have a more limited investment menu than IRAs.  Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds.  Your current plan may have lower fees than our fees. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because Investment Advisor Representatives have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically be investing only in mutual funds, you should understand the cost structure of the share classes, available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. Clients should understand the various products and services they might take advantage of at an IRA provider and the potential costs of those products and services.  Our strategy may have higher risk than the option(s) provided to you in your plan.  Your current plan may also offer financial advice.  If you keep your assets titled in a 401k or retirement account, participants could potentially delay their required minimum distribution beyond age.  A 401(k) may offer more liability protection than a rollover IRA; each state may vary.  Participants may be able to take out a loan on your 401k, but not from an IRA.  IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital gains tax rate.   Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name. Page 11 of 48 Disclosure Brochure  Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. It is important to understand the differences between these types of accounts and to decide whether a rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative, or call our main number as listed on the cover page of this brochure. GFG Solutions generally provides educational services to retirement plan participants with assets that could be rolled-over to an IRA advisory account. Education is based on a particular Client’s financial circumstances and best interests. Again, Advisor has an incentive to recommend such a rollover based on the compensation received, which is mitigated by the fiduciary duty to act in a Client’s best interest and acting accordingly. If GFG Solutions provides investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and, Give you basic information about conflicts of interest. Asset Under Management As of March 17, 2026, the assets under management are: Discretionary Non-Discretionary $306,638,684 $0.00 Clients may request more current information at any time. Insurance Planning Insurance planning is an integral component of financial planning that involves evaluating and managing risk exposure to ensure that individuals and families are adequately protected against unforeseen events. This aspect of financial planning focuses on identifying potential financial losses due to events such as illness, disability, death, or property damage, and providing solutions to mitigate these risks through insurance products.  Risk Assessment: This involves analyzing an individual's or family's financial situation to identify potential risks that could negatively impact their financial stability. This assessment considers factors such as health, lifestyle, occupation, and financial obligations.  Coverage Evaluation: Once risks are identified, the next step is to evaluate existing insurance coverage to determine if it is adequate. This includes reviewing life, health, disability, property, and liability insurance policies to ensure they provide sufficient protection.  Policy Selection: Based on the risk assessment and coverage evaluation, financial planners recommend appropriate insurance policies to fill any gaps. This may involve selecting life insurance to provide for dependents, disability insurance to protect against loss of income, or property insurance to safeguard assets.  Cost-Benefit Analysis: Insurance planning involves analyzing the costs of premiums against the benefits provided by the coverage. The goal is to ensure that the insurance is cost-effective and aligns with the financial goals and budget of the client. Integration with Financial Goals: Insurance planning is aligned with broader financial goals, such as wealth accumulation,  Page 12 of 48 Disclosure Brochure  retirement planning, and estate planning. Insurance products can be used strategically to ensure that financial plans remain intact in the face of unexpected events.  Regular Review and Adjustment: As financial situations and personal circumstances change over time, regular reviews of insurance coverage are necessary to ensure continued adequacy and relevance. Adjustments to policies may be needed to reflect life changes such as marriage, the birth of a child, or changes in employment. Overall, insurance planning helps provide peace of mind by ensuring that individuals and families are protected from the financial impact of unexpected events, allowing them to focus on achieving their long-term financial objectives. Insurance Products Investment Advisor Representatives can sell life insurance and annuities as agents of an insurance company. Investment Advisor Representatives acting as insurance agents do so in their individual capacity as licensed insurance agents for commission compensation. Life Insurance – Advantages  Provides an income tax-free death benefit to beneficiaries.  Accumulates cash value on a tax-deferred basis when structured as whole life or indexed universal life.  Offers creditor protection in certain jurisdictions.  Creates liquidity for estate settlement, survivor income, and business succession planning.  Enables tax-advantaged loans or withdrawals that can supplement retirement income if properly structured. Life Insurance – Disadvantages Carries high upfront commissions and internal fees that immediately reduce the cash value of the policy.  Imposes surrender charges that lock in the policyholder for years, creating liquidity constraints.  Reduces death benefits when loans or withdrawals are taken; unpaid loans will trigger taxable events upon policy lapse.  Requires consistent premium payments to avoid lapse; missed payments will jeopardize coverage.  Has poor investment performance compared to traditional investment accounts, especially in early years.  Once issued, policies are costly and difficult to unwind without financial penalties.  Annuities – Advantages Defers taxes on investment gains during the accumulation phase.  Guarantees lifetime income through contractual guarantees, shielding against longevity risk.  Offers death benefits that ensure beneficiaries receive a minimum payout.  Protects principal from market losses when structured as fixed or indexed annuities.  Annuities – Disadvantages Imposes high internal costs, including mortality and expense risk charges, administrative fees, and rider charges.   Restricts liquidity with surrender periods often exceeding 7–10 years, imposing penalties on early withdrawals.  Delivers lower returns compared to traditional portfolios after fees and expenses are deducted.  Will not outperform traditional investment accounts in most cases, especially when adjusted for liquidity and cost. Page 13 of 48 Disclosure Brochure   Duplicates tax deferral benefits when purchased inside qualified accounts like IRAs, providing no additional tax benefit but imposing substantial cost.  Locks capital, limiting clients’ ability to adjust investment strategies or respond to financial emergencies. Life insurance and annuity sales create unavoidable and significant conflicts of interest. These products are expensive, illiquid, and inflexible relative to traditional investment vehicles. Recommendations involving insurance products will financially benefit the investment advisor representative through commission compensation in their individual capacity as an insurance agent, often at the client’s direct expense. Recommendations involving life insurance or annuities carry higher costs, longer lock-up periods, reduced liquidity, and lower expected investment returns than traditional investment options. Clients must carefully evaluate whether the benefits of insurance products justify the costs and restrictions imposed. Insurance Products Compensation Commission compensation refers to the earnings received by individuals in their capacity as insurance agents for the sale of life insurance and/or annuity products. This form of compensation is typically calculated based on the value or volume of the sales made. Commissions are usually paid as a percentage of the sales price or premium of the product sold. There are different types of commissions:  First-Year Commissions (FYC): These are commissions paid upfront when a product is initially sold. They are typically higher and serve as an incentive for the agent to make the sale.  Renewal Commissions: These are paid on an ongoing basis as long as the client continues to renew the product, such as an insurance policy, providing a steady stream of income for the agent.  Chargebacks: If a client cancels a product within a certain period, the agent might have to return a portion of the commission received, known as a chargeback. Commission compensation creates conflicts of interest because the agent is incentivized to recommend products that offer higher commissions rather than those that are in the best interest of the client. Commission rates can vary significantly between different products and companies.  Commission compensation is often paid as a large lump sum payment upon product delivery up to 140% of the first-year annual premium.  Commission compensation can be substantial.  Commission compensation is a conflict of interest.  Commissions are paid only on premiums received and retained.  First-Year Commissions (FYC) and Renewal Commissions (Renewals) apply by product and contract.  Chargebacks apply for early terminations, surrenders, or billing changes.  Agents are responsible for negative balances upon termination. Compensation is different between carriers and products, which is another conflict of interest because it creates an incentive to sell the product with the highest compensation structure rather than the best interest of the Client. Commission-based compensation affects the cost of a product. Overall, while commissions can be a significant source of income for investment advisor representatives in their individual capacity as insurance agents. Insurance Replacements Agents recommend the replacement of existing insurance policies for commission compensation when it is objectively in the Client’s best interest. Common reasons for recommending a replacement include the availability of improved product features such as enhanced long-term care riders, the opportunity to accelerate premium payments into limited-pay policies to optimize long- Page 14 of 48 Disclosure Brochure  term cash value accumulation and eliminate future payment obligations, and securing policies with stronger guarantees or better underwriting classifications. Additionally, when feasible, we recommend moving policies we can directly service to provide a higher level of client support, policy monitoring, and claims management. Replacing existing policies can have surrender charges or penalties for early termination, which could offset any financial benefits of a new policy. The benefits that have accrued in the old policy, such as cash value or dividends may terminate. A new policy will typically restart the incontestability period (usually two years), during which the insurer can deny claims or cancel the policy based on misrepresentations or suicide. If the client's health has deteriorated, they might face higher premiums or be unable to secure new coverage at all. New policies often have upfront costs or commissions that can be higher than maintaining an existing policy. Before proceeding with a replacement, it's crucial to conduct a thorough evaluation comparing the existing and proposed policies, considering costs, benefits, and long-term objectives. 1035 Exchanges A 1035 exchange refers to a provision in the U.S. Internal Revenue Code that allows policyholders to exchange their life insurance policy, endowment policy, or annuity contract for a new one without incurring a tax liability on the cash value. One of the primary advantages of a 1035 exchange is the ability to defer taxes. Policyholders can replace an existing policy with a new one without triggering a taxable event on any gains from the original policy. An exchange allows policyholders to switch to a new policy that may offer better benefits, such as increased death benefits, lower premiums, or enhanced riders (e.g., long-term care). As financial circumstances and goals change, a 1035 exchange allows policyholders to adjust their coverage to better suit their current needs, such as moving from a life insurance policy to an annuity for retirement income. The new policy might offer lower fees or more favorable terms, which can result in cost savings over time. The existing policy may have surrender charges that apply if the policy is terminated early, potentially offsetting the benefits of the exchange. A new life insurance policy will typically reset the contestability period (usually two years), during which the insurer can contest claims based on misrepresentations in the application or suicide. Existing policies may have accrued benefits, such as cash value or favorable loan terms, that could be lost upon exchange. The new policy might have initial costs, fees, or commissions that could be higher than maintaining the current policy. If the policyholder's health has deteriorated, they might face higher premiums or less favorable terms on the new policy.  Commission Compensation is earned on the amount subject to a 1035 Exchange, which is a conflict of interest because it creates an incentive to recommend an exchange-based compensation rather than a Client’s best interest.  Conducting a careful evaluation of both the existing and proposed policies, considering all costs, benefits, and personal financial goals, is essential to ensure that a 1035 exchange is in the policyholder's best interest. Artificial Intelligence Artificial Intelligence (AI) refers to the simulation of human intelligence in machines designed to think and learn like humans. AI encompasses a range of technologies that enable systems to perform tasks such as recognizing speech, making decisions, and understanding complex ideas. AI tools can be used to enhance our services, improve operational efficiency, and deliver overall better outcomes. By integrating AI into our processes, we aim to stay at the forefront of technological innovation while maintaining a strong commitment to ethical practices and data privacy. Advisor utilizes AI for real-time note-taking to enhance accuracy, efficiency, and productivity. Our AI tool transcribes spoken content, generates summaries, and identifies key takeaways. Participants are informed of AI usage and have the right to opt out of AI-generated note-taking. Should a client have any questions or concerns, please contact us at our email address, phone number, or through our website. Advisor has incorporating artificial intelligence (AI) into its practice to enhance service delivery, improve decision-making, and provide better outcomes for their clients. Examples of AI include all or some of the following: Page 15 of 48 Disclosure Brochure   Automation of Administrative Tasks: AI can automate routine tasks such as data entry, compliance checks, and report generation, freeing advisors to focus on higher-value activities.  Enhanced Client Communication: Chatbots and virtual assistants powered by AI can handle basic client inquiries, schedule meetings, and provide updates, improving responsiveness and client satisfaction.  Regulatory Compliance: AI tools can monitor communications for compliance with regulatory requirements.  Notetaking: Advisor uses AI for real-time note-taking during web calls to enhance accuracy, efficiency, and productivity. The AI tool transcribes spoken content, generates summaries, and identifies key takeaways from web-based calls. Participants are informed of AI usage and have the right to opt out of AI-generated note-taking during web-based calls. Should a client have any questions or concerns, please contact us at our email address, phone number, or through our website. By leveraging AI technology, Advisor can enhance their analytical capabilities, deliver more personalized services, improve operational efficiency, and ultimately provide better outcomes for their clients. However, while AI offers significant advantages, Advisor maintains human oversight to ensure that AI-driven functions align with clients' best interests and fiduciary requirements. Business Continuity Plan GFG Solutions has a business continuity and contingency plan in place designed to respond to significant business disruptions. These disruptions can be both internal and external. Internal disruptions that could impact our ability to communicate and do business, such as a fire in the office building. External disruptions will prevent the operation of the securities markets or the operations of a number of firms, such as earthquakes, wildfires, hurricanes, terrorist attack or other wide-scale, regional disruptions. Our continuity and contingency plan have been developed to safeguard employees’ lives and firm property, to allow a method of making financial and operational assessments, to quickly recover and resume business operations, to protect books and records, and to allow clients to continue transacting business. The plan includes the following:  Alternate locations to conduct business  Hard and electronic back-ups of records  Alternative means of communications with employees, clients, critical business constituents and regulators; and Details on the firms’ employee succession plan. Our business continuity and contingency plan is reviewed and updated on a regular basis to ensure that the policies in place are sufficient and operational. Item 5 – Fees and Compensation Financial Planning Financial planning is offered in connection with the Advisor’s investment advisory services and is provided without a separate fee. Non- investment-advisory financial planning services, if offered, are provided by an affiliated entity of the Advisor (and not by the Adviser) pursuant to a separate agreement; any fees for such services are charged by the affiliated entity. Asset Under Management Advisory fees are billed in advance based on portfolio value as of the 15th of each month. Fees are according to the below schedule: Assets Under Management Percentage of Assets Under $250,000 1.20% $250,000 - $499,999 1.10% $500,000 - $999,999 1.00% $1,000,000 - $1,99,999 0.90% $2,000,000 - $2,99,999 0.80% $3,000,000 - $4,99,999 0.65% $5,000,000 - $9,999,999 0.55% Above $10,000,000 0.50% Page 16 of 48 Disclosure Brochure   The fee for Fixed Income only accounts 0.55%  An additional 0.25% fee applies to held away accounts Performance Fee A performance fee is a type of compensation structure for investment advisors that is based on the performance of an investment portfolio. This fee is typically calculated as a percentage of the capital gains or the appreciation of the assets under management. Performance fees are designed to align the interests of the investment advisor with those of the client. Advisors are incentivized to achieve the best possible returns for their clients by tying compensation to the portfolio's success. While performance fees can align advisor and client interests, they can also create conflicts. For example, an advisor might be tempted to take excessive risks to achieve higher returns if their compensation is directly tied to performance. The performance fee is not subject to high-water mark where performance fees only apply to gains above the highest level previously attained. If a portfolio subject to a performance fee experiences losses, the Advisor must recover those losses before earning additional performance fees.  Performance fees are calculated based on the billing cycle end value compared to the previous billing cycle end value.  Performance fees for subsequent billing cycles are based on the previous billing cycle end value. GFG Solutions charges a fixed management fee of 1% for our leveraged equity portfolios. For qualified clients meeting SEC requirements under Rule 205-3, a year after account opening, in addition to the 1% fixed fee, GFG Solutions also charges a 20% performance fee (net of the 1% fee) on carried interest above a 15% minimum internal rate of return (IRR) hurdle. The advisory fee a $1,000,000 account with a 20% return would equal: Fee Type Fee Amount 1% Annual Fixed Fee $10,000 20% Performance Fee [20% of ($200,000 - $150,000) $10,000 Total Fee $20,000 or 2% Friends & Family Fees can be waived, in whole or in part, for clients who are members of the family or friends. In certain other circumstances, fees and account minimums are negotiable and therefore, fees can vary from client to client. In addition, Fees for special circumstances may be offered at a reduced rate. Valuation All securities held in accounts managed by GFG Solutions will be independently valued by the Custodian. GFG Solutions will not have the authority or responsibility to value portfolio securities. While GFG leverages the valuation services of the custodian, it is directly responsible for the accuracy of billing. Mutual Fund Fees and Other Fees and Expenses Client assets are primarily invested in mutual funds managed by third parties. The funds pay their investment managers and other service providers fees, which reduce the funds’ investment returns and are borne proportionately by all fund shareholders, including clients of GFG Solutions . These mutual fund fees, or “expense ratios,” are described in the funds’ prospectuses, and are separate from and in addition to the fees charged by GFG Solutions . Client assets are also held in brokerage accounts which are subject to certain custodial fees; such as, checks returned or debit declines for insufficient funds as well as a full transfer out fee and potential third-party service provider costs. These fees and expenses are further described in the brokerage agreement. Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees) Section 206 of the Investment Advisers Act of 1940 (“Advisers Act”) imposes a fiduciary duty to act in a client’s best interests and specifically prohibits investment advisers, directly or indirectly, from engaging in any transaction, practice, or course of business which operates as a fraud or deceit upon any client or prospective client. However, the fiduciary duty to which advisers are subject is not specifically defined in the Advisers Act or the Commission rules but reflects a Congressional recognition “of the delicate fiduciary Page 17 of 48 Disclosure Brochure  nature of an investment advisory relationship” as well as a Congressional intent to eliminate, or at least expose, all conflicts of interest which might incline an investment adviser, consciously or unconsciously, to render advice which was not disinterested. When selecting a mutual fund for a client’s advisory account, the investment advisor representative has a fiduciary duty to select the share class that helps manage the overall fee structure of the account. Mutual funds offer different share classes, each with varying fee structures and features, to accommodate different types of investors. Below is a breakdown of the most common mutual fund share classes.  Class A Shares: These shares typically charge a front-end sales load, which is a fee paid when the shares are purchased. This fee is a percentage of the total investment. o Generally, have lower ongoing expenses compared to other share classes because the front-end load compensates the broker or advisor for their services. o Investors can receive discounts on the front-end load based on the size of the investment, known as breakpoint discounts.  Class B Shares: Class B shares often have a contingent deferred sales charge (CDSC), which is a fee paid when shares are sold, typically decreasing over time (usually over six to eight years). o These shares generally have higher ongoing expenses than Class A shares. o Usually convert to Class A shares after the CDSC period ends, resulting in lower ongoing fees.  Class C Shares: Class C shares typically charge a level load, which is an annual fee as long as the shares are held, in addition to higher ongoing expenses. Include 12b-1 fees to cover marketing and distribution expenses. o Unlike Class B shares, Class C shares do not convert to Class A shares, meaning the higher fees continue indefinitely. o o Often have a small back-end load if shares are sold within a short period (usually one year).  Class I Shares: also known as Institutional Shares, are a class of mutual fund shares designed primarily for institutional investors, such as pension funds, endowments, and large-scale investment managers. o Typically have lower expense ratios compared to other share classes, such as A, B, or C shares. This is because institutional investors usually invest larger amounts, allowing the fund to spread its costs over a larger asset base. o Generally, require a higher minimum investment, often starting at $500,000 or more, making them more suitable for institutional investors or high-net-worth individuals.  R Shares: Designed for retirement plans like 401(k) plans. o Offer various fee structures to meet the needs of different retirement plan sponsors. o Each share class is structured to meet the needs and preferences of different investors, balancing the cost of investing with the services provided. The choice between them should be based on the investor's financial situation, investment goals, and how long they plan to hold the investment.  NTF (No Transaction Fee) Mutual Funds: Mutual funds without a transaction fee or commission to the brokerage or platform through which they are purchased. o Not all funds are available as NTF funds, can be subject to minimum investment amounts, and availability can vary by broker/dealer o Some NTF mutual funds include 12b-1 fees as part of their expense structure. This helps the fund cover distribution and marketing costs, potentially allowing the fund to be offered without transaction fees. Page 18 of 48 Disclosure Brochure   Direct Purchase Mutual Funds: Often available directly from the mutual fund company. Direct purchase mutual funds can be a cost-effective option for knowledgeable investors who are comfortable managing their own investments and wish to avoid intermediary fees. However, it requires a proactive approach to research and decision-making. The choice of the most beneficial mutual fund share class involves considering ticket charges, 12b-1 fees and the asset management fee. Fees are considered in totality, not in isolation. Sometimes, investing in a share class with 12b-1 fees can be the more cost-effective option rather than simply avoiding 12b-1 fees. Advisor has a fiduciary duty to select the share class that best serves the client's interests, ensuring a comprehensive fee analysis to determine the optimal choice. For a wrap fee account, a different conflict of interest is introduced because the advisor has an incentive to not trade as frequently (reverse churning) to avoid the ticket charges which can compromise active management. This conflict is mitigated by the fiduciary duty to act in a client’s best interest while also considering the higher asset management fee charged for wrap fee accounts. Legacy Mutual Fund Holdings When a client moves their assets into a managed account, the portfolio advisor reviews the client's mutual fund holdings. If the mutual funds are not part of the Advisor's recommended list, they are generally sold unless selling would result in a taxable gain that outweighs the benefits of the preferred holdings or higher fee structure. If it is determined that converting the legacy positions to a different share class is in the client’s best interest, Advisor will execute on such changes.  Assessment: Advisor first conducts a thorough assessment of the client's current mutual fund holdings. This involves evaluating the fees, performance, and fit within the client's overall investment strategy and objectives.  Comparison: Advisor compares the current share class with alternative options available. This comparison includes analyzing expense ratios, 12b-1 fees, potential loads, and any other costs associated.  Eligibility & Requirements: Advisor ensures that the client meets any minimum investment amounts and other eligibility criteria required for the new share class.  Benefit Analysis: Advisor evaluates the potential benefits of conversion, such as lower fees, better alignment with investment goals, or improved tax efficiency. The goal is to determine whether the conversion will result in cost savings or other advantages for the client. After a conversion or decision to maintain a legacy position, Advisor continues to monitor the investment to ensure it remains aligned with the client’s goals. This ongoing review helps in making any necessary adjustments in the future. Payment of Fees and Termination Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Compensation for Selling Securities GFG Solutions, as outlined in the document, operates as a fee-based advisory firm. This means that the firm does not engage in buying or selling securities to earn commission-based compensation. Instead, GFG Solutions charges fees for the advisory services it provides, which are typically structured as asset-based fees or other forms that align with the services offered to clients. This approach helps to mitigate conflicts of interest that could arise if the firm were to earn commissions from the sale of securities. Client recommendations are based purely on the clients' best interests rather than potential earnings from sales commissions Compensation Insurance Products Investment advisor representatives, in their capacity as insurance agents, can receive commission compensation for selling insurance products. Commission rates differ from product to product and carrier to carrier. In addition to commissions, investment advisor representatives as insurance agents can receive marketing support, reasonable meals and entertainment, and reimbursement of the cost to attend training, conferences, and events hosted by insurance companies and third-party marketing organizations contracted with and receive compensation from the insurance company. Insurance commissions and other benefits are significant sources of compensation Page 19 of 48 Disclosure Brochure  and are paid separately from advisory fees on assets in a client’s managed securities account. Commissions are generally paid up-front, at the time of sale, unlike asset-based fees which are paid periodically over the course of the relationship. The amount and form of insurance compensation creates a conflict of interest in that investment advisor representatives in their individual capacity as insurance agents are incentivized to recommend insurance products based on the compensation received rather than on a client’s needs. Investment advisor representatives as insurance agents are not required to offer the products of a specific insurance company. The compensation received from selling securities or insurance is separate from and does not offset regular advisory fees.  GFG Solutions will not charge advisory fees on any insurance products.  Clients are not obligated to implement any recommendations and can implement such recommendations through a different registered representative or insurance agent. Exclusivity Clients of GFG Solutions are not restricted to purchasing investment products solely through GFG Solutions. They have the flexibility to choose other brokers or agents to purchase investment products. This means that even though GFG Solutions provides advisory services, clients are not obligated to implement any recommendations through GFG Solutions or its associated representatives. This freedom allows clients to compare offerings, seek competitive pricing, or leverage existing relationships with other financial service providers, ensuring that they make decisions that best align with their financial goals and preferences Additional Compensation Advisor can receive economic benefits from sources other than the client for providing advisory services. These benefits can take various forms, including sales awards, gifts, meals, or entertainment such as tickets to concerts, shows, or sporting events. Here's a more detailed explanation:  Sales Awards: Recognitions or bonuses given for achieving certain targets or performance metrics, often provided by product sponsors or financial institutions.  Gifts: These can range from small tokens of appreciation to more significant items, potentially offered by business partners or vendors.  Meals & Entertainment: Occasional meals, invitations to events, or tickets to entertainment activities provided by third-party entities, such as product sponsors or other financial service providers. These economic benefits create a conflict of interest, as they can unconsciously influence decisions regarding the selection of products and/or services. For instance, an advisor might be more inclined to recommend products from a sponsor that offers more generous incentives. This influence can affect the objectivity of recommendations; however, Advisor has a fiduciary duty to act in a client’s best interest. Item 6 – Performance-Based Fees and Side-By-Side Management GFG Solutions charges performance-based fees for accounts held by accredited investors. Performance-based fees are fees based on a share of capital gains on, or capital appreciation of, the assets of a client. GFG Solutions does not participate in side-by-side management, where an advisor manages accounts that are both charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or fixed fee or an asset-based fee. Item 7 – Types of Clients The clients served by GFG Solutions are generally individuals, high net worth individuals and business owners. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss GFG Solutions primarily employs fundamental, technical and tactical analysis in developing investment strategies for its Clients. Research and analysis from GFG Solutions are derived from numerous sources, including unaffiliated third-party registered investment Page 20 of 48 Disclosure Brochure  advisors, financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research or market signals prepared by others. Fundamental Method of Investing The fundamental method of investing is an approach that involves analyzing the fundamental factors of an asset, such as a stock or a bond, to determine its underlying value and make investment decisions based on that assessment. This method focuses on understanding the financial health, performance, and prospects of a company or asset, rather than relying solely on market trends or price movements. It aims to identify assets that are mispriced relative to their intrinsic value and have the potential for long-term appreciation. Financial Statements Analysis Fundamental investors analyze a company's financial statements to evaluate its financial health and performance. They review the balance sheet, income statement, and cash flow statement to assess revenue growth, profitability, debt levels, and cash flow generation. By examining these financial metrics, investors can gain insights into the company's financial stability and its ability to generate sustainable earnings. Company Analysis Understanding the company's business model, competitive advantage, and industry position is crucial in fundamental investing. Investors assess market share, product differentiation, management quality, and growth prospects. They analyze the company's competitive landscape, industry trends, and regulatory environment to determine how these factors may impact its future performance and value. Valuation Methods Fundamental investors employ various valuation methods to estimate the fair value of an asset. Common valuation techniques include price-to-earnings (P/E) ratio, price-to-book (P/B) ratio, discounted cash flow (DCF) analysis, and comparable company analysis. These methods help investors determine whether an asset is overvalued or undervalued compared to its intrinsic worth. Economic Analysis Fundamental investors consider macroeconomic factors and trends affecting an asset's performance. They analyze GDP growth, interest rates, inflation rates, and consumer sentiment to understand the broader economic environment. By assessing the impact of these factors on the company or asset, investors can make more informed investment decisions. Long-Term Orientation The fundamental method of investing typically takes a long-term perspective. Investors focus on the long-term value of an asset and aim to hold it for an extended period, allowing the market to recognize its true worth. This approach requires patience and the ability to withstand short-term market fluctuations. Risk Management Fundamental investors consider risk management as an integral part of their investment process. They assess the risks associated with an investment, such as industry-specific, financial, or regulatory risks. By understanding and managing these risks, investors aim to protect their capital and minimize potential losses. Continuous Monitoring Fundamental investing involves ongoing monitoring of the asset's performance and relevant factors. Investors stay updated on company news, industry developments, and economic trends that may impact the asset's value. Regular analysis and reassessment of the investment thesis help investors make informed decisions about their positions. Fundamental investing involves thorough research, analysis, and a deep understanding of financial concepts and business fundamentals. Successful application of this method often involves a combination of quantitative analysis (financial metrics) and qualitative analysis (industry trends, competitive dynamics). Technical Method of Investing The technical method of investing, also known as technical analysis, is an investment strategy that focuses on analyzing an asset's historical price patterns, market trends, and trading volume data to make investment decisions. It primarily studies charts and uses Page 21 of 48 Disclosure Brochure  various technical indicators to identify potential buying or selling opportunities. Unlike fundamental analysis, which assesses the intrinsic value of an asset, technical analysis aims to predict future price movements based on historical patterns and market behavior. Price Patterns Technical analysts study historical price patterns in charts to identify trends, support and resistance levels, and chart patterns. They look for recurring patterns such as head and shoulders, double tops or bottoms, triangles, or trend lines. These patterns are believed to provide insights into potential future price movements. Technical Indicators Technical analysts use various technical indicators to gain additional insights into market trends and momentum. Examples of popular technical indicators include moving averages, relative strength index (RSI), stochastic oscillators, and MACD (Moving Average Convergence Divergence). These indicators help investors identify overbought or oversold conditions, trend reversals, or bullish or bearish signals. Volume Analysis Technical analysts analyze trading volume data, which represents the number of shares or contracts traded, to understand the strength and confirmation of price movements. Higher trading volume during an uptrend or downtrend is considered a positive sign, indicating market participation and confirming the trend. Trend Identification Technical analysis focuses on identifying trends in the price movement of an asset. Trends can be upward (bullish), downward (bearish), or sideways (range-bound). By identifying the prevailing trend, investors attempt to align their positions with the momentum of the market. Support and Resistance Levels Technical analysts identify support levels (price levels where buying is expected to emerge) and resistance levels (price levels where selling pressure is expected to increase). These levels are determined based on historical price data and are believed to influence future price movements. Traders use these levels to set entry and exit points for their trades. Timing and Entry/Exit Points Technical analysis aims to determine optimal timing for entering or exiting a trade. Technical indicators and patterns help investors identify potential entry points to buy an asset during an uptrend or sell during a downtrend. Similarly, exit points are identified to take profits or cut losses based on the analysis of price patterns, indicators, or predefined risk management strategies. Risk Management Risk management is an important aspect of technical analysis. Traders use stop-loss orders, which automatically trigger the sale of an asset if it reaches a predetermined price, to limit potential losses. Risk-reward ratios are also considered to ensure that potential profits outweigh potential losses. Short-term Focus Technical analysis is often used for short-term trading and shorter investment horizons. Technical traders aim to capture shorter- term price movements and may frequently enter and exit positions based on technical signals. It's important to note that technical analysis has its limitations and critics. Some argue that it does not consider fundamental factors or market conditions, and it relies on historical data that may not accurately predict future price movements. Additionally, technical analysis is subject to interpretation, and different analysts may have varying conclusions based on the same data. Therefore, combining technical analysis with other forms of analysis, such as fundamental analysis, can provide a more comprehensive perspective for investment decision-making. Tactical Method of Investing The tactical method of investing refers to an investment strategy that involves actively adjusting a portfolio's asset allocation based on short-term market conditions, economic trends, or other factors. Unlike a passive strategy that follows a long-term buy-and-hold Page 22 of 48 Disclosure Brochure  approach, tactical investing aims to capitalize on short-term opportunities and mitigate risks by making strategic allocation shifts. Here are the key components and principles of tactical investing: Asset Allocation Tactical investing places significant emphasis on asset allocation. Investors continuously monitor various asset classes, such as stocks, bonds, cash, commodities, and real estate, to identify attractive opportunities and potential risks. They may allocate or reallocate their portfolio across these assets based on their assessment of current market conditions. Market Analysis Tactical investors actively analyze market indicators, economic data, and other relevant factors to assess the market's overall health and individual asset classes. They may consider technical analysis, fundamental analysis, or a combination of both to make informed decisions. This analysis helps them identify trends, market cycles, and potential catalysts for price movements. Risk Management Risk management is a crucial aspect of tactical investing. Investors strive to minimize downside risk and protect their portfolios during market downturns. They may reduce exposure to riskier assets or increase allocation to defensive assets like bonds or cash when they anticipate market turbulence. Additionally, they may employ stop-loss orders or other risk mitigation strategies to limit potential losses. Active Trading Tactical investors engage in active trading, taking advantage of short-term market fluctuations. They may buy or sell securities based on their market analysis and to align their portfolio with their desired asset allocation. This may involve frequent buying and selling, adjusting positions as market conditions change. Flexibility Tactical investing requires flexibility and adaptability. Investors need to be open to changing market dynamics and adjust their investment strategy accordingly. They may swiftly reallocate assets, shift focus between sectors or industries, or even rotate from one asset class to another based on their analysis and outlook. Monitoring and Rebalancing Tactical investing involves regular monitoring of portfolio performance and market conditions. Investors continuously evaluate their positions and adjust their asset allocation to maintain alignment with their investment objectives. This may involve rebalancing the portfolio periodically or in response to significant market events. It's important to note that tactical investing requires active decision-making and market timing, which can be challenging even for experienced investors. It requires a thorough understanding of market dynamics, analysis tools, and the ability to react swiftly to changing conditions. Due to its active nature, tactical investing may also involve higher transaction costs and tax implications compared to a passive buy-and-hold approach. Behavioral Behavioral investing, often referenced within the broader realm of behavioral finance, examines how psychological and emotional factors influence the investment decisions of individuals and institutions. It challenges the traditional finance paradigm, which assumes that investors are always rational and markets are always efficient. Instead, behavioral investing posits that investors are often irrational due to cognitive biases that can lead to systematic errors in decision making. Here are some core concepts: Cognitive Biases These are systematic patterns of deviation from norm or rationality in judgment. Some common biases in investing include: Overconfidence Overestimating one's knowledge or abilities, leading to excessive trading or taking on undue risk. Confirmation Bias Focusing on and valuing information that confirms one’s pre-existing beliefs, while ignoring contradictory evidence. Page 23 of 48 Disclosure Brochure  Recency Bias Overemphasizing recent events or trends and extrapolating them into the future. For example, assuming that a stock that has recently risen will continue to do so. Loss Aversion Feeling the pain of losses more acutely than the pleasure of gains. This can lead to holding onto losing investments too long or selling winning investments too soon. Anchoring Relying heavily on an initial piece of information (the "anchor") when making subsequent judgments. For instance, becoming anchored to the price at which one bought a stock and basing future decisions on it. Emotional Factors Emotions play a significant role in investment decisions. Fear and greed are two major emotional drivers: Fear Can cause investors to avoid necessary risks or sell assets hastily during market downturns. Greed Can lead investors to take on excessive risk or chase after speculative bubbles. Herd Mentality Investors often follow what others are doing, leading to bubbles and crashes. Instead of relying on independent analysis, they are influenced by the actions and opinions of their peers. Mental Accounting Treating money differently depending on its source or intended use. For example, being more willing to take risks with "house money" (previous gains) or categorizing and treating inheritance money differently from regular income. Asset Allocation Asset allocation is a key concept in investment management and refers to how an investor divides their investments among different asset classes. The primary goal of asset allocation is to create a balanced portfolio that aligns with the investor's goals, risk tolerance, and investment horizon. Risk and Return Balance Different asset classes (like stocks, bonds, and real estate) have varying levels of risk and expected returns. By diversifying investments across multiple asset classes, you can potentially achieve a desired return while managing your risk. Diversification Benefits No single asset class consistently outperforms the others. Allocating resources across different assets can reduce the impact of any one asset's poor performance on the overall portfolio. Investment Goals Asset allocation helps align your portfolio with your investment goals. For example, someone saving for retirement 30 years away might have a different allocation compared to someone who is retiring in 5 years. Financial Goals Whether you're saving for retirement, a home, or education can influence your allocation. Current Financial Situation Existing financial resources, debts, and other obligations can also influence decisions. Rebalancing Over time, due to the varying returns of asset classes, a portfolio can drift from its target allocation. Rebalancing involves adjusting the portfolio back to the desired allocation. This might mean selling some assets that have performed well and buying more of those that have underperformed. Page 24 of 48 Disclosure Brochure  Strategic Asset Allocation This involves setting and maintaining a long-term asset mix based on expected returns and risk for each asset class. Tactical Asset Allocation Allows for short-term deviations from the strategic allocation to exploit market anomalies or opportunities. Investment Diversity Investment diversity is a risk management strategy that mixes a wide variety of investments within a portfolio. The rationale behind this approach is that a portfolio constructed of diverse investments will, on average, yield higher returns and pose a lower risk than any individual investment found within the portfolio. Purpose of Diversification Diversification spreads investments across various assets or asset classes. This spread can reduce the negative impact any single investment's poor performance might have on the overall portfolio. Potential for Higher Returns With investments spread across different areas, there's a possibility that at least one of them might perform exceptionally well, thus boosting the portfolio's overall returns. Asset Class Diversification This involves spreading investments across different types of assets like stocks, bonds, real estate, commodities, etc. Each asset class reacts differently to market events, providing a balancing effect. Geographical/Regional Diversification Investing in assets from different countries or regions. This minimizes risks associated with downturns in any particular country or region's economy. Sectoral Diversification Investing across different industries or sectors, such as technology, healthcare, finance, etc. This ensures that a downturn in one sector doesn't drag down the entire portfolio. Instrument Diversification Using various financial instruments, like equities, fixed deposits, mutual funds, etc., to spread risk. Diversification by Strategy Implementing multiple investment strategies, such as growth, value, income, etc. Time Diversification Spreading out investments over various time horizons, often achieved through techniques like dollar-cost averaging. Limitations of Diversification While diversification reduces risk, it doesn't eliminate it. There's still the potential for loss. Diluted Returns If one investment in a diversified portfolio skyrockets, its positive impact will be diluted by other investments that might not be performing as well. Over-diversification There's a point where adding more investments might not offer additional diversification benefits and might make the portfolio harder to manage. Risk of Loss Investing in securities involves risk. Securities tend to fluctuate in value and can lose value. Clients should be prepared to bear the potential risk of loss. GFG Solutions will assist Clients in determining an appropriate strategy based on their investment objective and Page 25 of 48 Disclosure Brochure  tolerance for risk. However, there is no guarantee that a Client will meet their investment goals or assets will increase in value. GFG Solutions will rely on 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 advise of any changes in financial condition, goals or other factors. The following are some of the general risks associated with investing that Clients should understand, consider and determine the amount of risk they are able to accept prior to opening an account: Business Risk The measure of risk associated with a particular security. It is also known as unsystematic risk and refers to the risk associated with a specific issuer of a security. Generally speaking, all businesses in the same industry have similar types of business risk. More specifically, business risk refers to the possibility that the issuer of a particular company stock or a bond may go bankrupt or be unable to pay the interest or principal in the case of bonds. Call Risk The risk specific to bond issues and refers to the possibility that a debt security will be called prior to maturity. Call risk usually goes hand in hand with reinvestment risk because the bondholder must find an investment that provides the same level of income for equal risk. Call risk is most prevalent when interest rates are falling, as companies trying to save money will usually redeem bond issues with higher coupons and replace them on the bond market with issues with lower interest rates. Credit Risk The risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. Crypto Currencies and Crypto Asset Risks Crypto assets represent a speculative investment and involve a high degree of risk. Supply is determined by a computer code, not by a central bank, and prices can be extremely volatile. Crypto currency and crypto asset exchanges have been closed due to fraud, failure, security breaches, and legal noncompliance. Client assets held on an exchange that shuts down may be lost. Several factors may affect the price of crypto currencies and other crypto assets, including, but not limited to supply and demand, investors’ expectations with respect to the rate of inflation, interest rates, currency exchange rates or future regulatory measures (if any) that restrict the trading of crypto currencies/crypto assets or the use of crypto currencies/crypto assets as a form of payment. There is no assurance that crypto currencies and/or other crypto assets will maintain their long-term value in terms of purchasing power in the future, or that acceptance of crypto currency payments by mainstream retail merchants and commercial businesses will grow. The prior performance of a crypto asset is not necessarily indicative of future results. Many crypto assets have experienced high levels of performance and rapid increases in price, followed by significant downturns in performance and similarly rapid decreases in price. Crypto Exchange Risks The crypto currency and crypto asset exchanges on which crypto currency and other crypto assets trade are relatively new and may not be registered as brokers, exchanges, or alternative trading systems. They may therefore be out of compliance with federal or state law. In addition, these exchanges may be more exposed to theft, fraud and failure than established, registered exchanges for other products. In general, crypto currency and other crypto assets exchanges are currently start-up businesses with no institutional backing, limited operating history and no publicly available financial information. Exchanges generally require cash to be deposited in advance in order to purchase crypto currency and other crypto assets, and no assurance can be given that those deposit funds can be recovered. Additionally, upon sale of crypto currency and other crypto assets, cash proceeds may not be received from the exchange for several business days. The participation in exchanges requires participants to take on credit risk by transferring crypto currency and other crypto assets from a participant’s account to a third-party's account. Crypto Miner Risk In a proof of work blockchain, the award of new crypto currency or other crypto assets for solving blocks declines and Page 26 of 48 Disclosure Brochure  transaction fees are not sufficiently high, miners may not have an adequate incentive to continue mining and may cease their mining operations. Miners ceasing operations would reduce the collective processing power on such crypto currency and crypto asset networks, as applicable, which would adversely affect the confirmation process for transactions (i.e., decreasing the speed at which blocks are added to the blockchain until the next scheduled adjustment in difficulty for block solutions) and make such networks more vulnerable to a malicious actor or botnet obtaining control in excess of fifty percent (50%) of the processing power on such networks. Any reduction in confidence in the confirmation process or processing power of such networks may have an adverse effect on the value of such networks’ tokens. There is also a possibility that blockchains using proof of stake may not sufficiently attract the needed nodes and stakes to have a blockchain run properly, with a similar outcome of blockchains degrading or failing completely. Cybersecurity Risk The computer systems, networks and devices used by us and our service providers employ a variety of protections designed to prevent damage or interruption from computer viruses, network and computer failures and cyberattacks. Despite such protections, systems, networks and devices potentially can be breached. Cyberattacks include, but are not limited to, gaining unauthorized access to digital systems for purposes of corrupting data, or causing operational disruption, as well as direct-denial-of-service (DDOS) attacks on websites. Cyber incidents may cause disruptions and impact business operations, potentially resulting in financial losses, the inability of us or our service providers to trade, violations of privacy and other laws, regulatory fines, reputational damage, reimbursement costs and additional compliance costs, as well as the inadvertent release of confidential information. Currency/Exchange Rate Risk The risk of a change in the price of one currency against another is known as currency or exchange rate risk. This risk arises from the potential for fluctuations in the exchange rates between two currencies, which can affect the value of investments denominated in foreign currencies. For investors holding international assets, changes in exchange rates can impact the returns on those investments when converted back into the investor's home currency. For instance, if an investor holds assets in a foreign currency that depreciates relative to their home currency, the value of those assets will decrease when converted back, potentially leading to a loss even if the asset's value increased in its local market. This risk is particularly significant for businesses and investors engaged in international trade or investment, as it can affect profitability, cash flow, and overall financial stability. Dependence on Key Personnel – The success of the blockchain networks and their crypto assets will also depend materially upon the active participation of core developers responsible for developing the networks. There can be no guarantee of the continuing participation of any one or more of these individuals, the loss of whose services could have a material adverse effect on the subject network and its crypto assets. In addition, although the partners and other employees of a blockchain network are expected to devote as much time as they believe is necessary to conduct the affairs of the blockchain network, generally none of them will be required to devote any particular portion of his or her working time to the affairs of the network. These core developers may to devote substantial working time to conducting the affairs of other blockchain networks they are developing. ETF Risks, including Net Asset Valuations and Tracking Error ETF performance will typically not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depositary Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. An ETF typically includes embedded expenses and related fees that reduce the fund's net asset value, and therefore directly affect the fund's performance and indirectly Page 27 of 48 Disclosure Brochure  affect a Program Account’s performance or an index benchmark comparison. Expenses of an ETF generally include investment adviser management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses can change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses can vary. Extraordinary Events Terrorism and the United States’ involvement in armed conflict may negatively affect general economic fortunes, including sales, profits, and production. An unstable geopolitical climate and continued threats of terrorism and war could have a material effect on general economic conditions, market conditions, and market liquidity (i.e., depressed securities prices and problems with trading facilities and infrastructure). Additionally, a serious pandemic or natural disaster could severely disrupt the global, national, and/or regional economies. A resulting negative impact on economic fundamentals and consumer confidence may increase the risk of default of particular companies and negatively impact our clients. Inflationary Risk The risk that future inflation will cause the purchasing power of cash flow from an investment to decline Interest Rate Risk The risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. Legislative Risk The risk of a legislative ruling resulting in adverse consequences. Liquidity Risk The possibility that an investor may not be able to buy or sell an investment as and when desired or in sufficient quantities because opportunities are limited. Market Risk The risk that the value of securities may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. Malicious Actors If a malicious actor or botnet (a network of computers controlled by coordinated software) obtains a majority of the processing power dedicated to mining on certain cryptocurrency and other crypto asset networks, it will be able to alter the blockchain on which the crypto currency and/or other crypto asset transaction relies on by constructing alternate blocks, if it is able to solve for such blocks faster than the remainder of the miners on the blockchain network can add valid blocks. In such alternate blocks, the malicious actor or botnet could control, exclude or modify the ordering of transactions, though it could not generate new crypto currency or other crypto assets or transactions using such control. Using alternate blocks, the malicious actor could double spend its own crypto currency and/or other crypto assets and prevent the confirmation of other users’ transactions for so long as it maintains control. To the extent that such malicious actor or botnet does not yield its majority control of the processing power on a blockchain network, or the crypto asset community does not reject the fraudulent blocks as malicious, reversing any changes made to the blockchain may not be possible. Mutual Fund Risks A risk exists that the investment strategies employed by the mutual funds will not meet the stated investment objectives the fund is seeking to obtain. Mutual funds may invest in equities, fixed income, derivatives, and other asset classes; the risks associated with such investments are described in the fund’s prospectus. The performance of a mutual fund may not exactly match the performance of the index or market benchmark that the fund is designed to track due to the mutual fund incurring expenses and transaction costs not incurred by any applicable index or market benchmark. Expenses can change from time to time at the sole discretion of the issuer and expenses can vary. Page 28 of 48 Disclosure Brochure  Pandemic Risk Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. Precious Metal Investing in precious metals, such as gold, silver, platinum, and palladium, is often considered a strategic move in diversifying an investment portfolio. Precious metals, particularly gold, are often viewed as a hedge against inflation. When inflation rises, the purchasing power of currency typically falls, but the value of gold tends to increase. This makes gold a preferred asset during periods of high inflation, as it helps preserve wealth. In times of economic uncertainty or geopolitical tension, investors often flock to precious metals, especially gold, as a safe haven. These metals are considered stable and less volatile than other asset classes, providing a refuge for investors during market downturns. Including precious metals in an investment portfolio can provide diversification benefits. These metals often have a low correlation with traditional assets like stocks and bonds, meaning their prices do not move in tandem with broader market trends. This can help mitigate portfolio risk and account value fluctuation. Unlike stocks or bonds, precious metals are physical commodities that investors can hold in their hands. This tangibility is appealing to some investors who prefer owning assets with intrinsic value, unaffected by the financial system's vagaries. Precious metals are traded on global exchanges, offering high liquidity. Investors can quickly buy or sell their holdings, making it easy to enter or exit positions as market conditions change. Investors can access precious metals through various means, including physical bullion (coins and bars), exchange-traded funds (ETFs), mining stocks, and mutual funds. Each type has its own risk and return characteristics. Investing in precious metals is not without risks. The risks of investing in precious metals include:  Large entities that sell large quantities of their holdings, that flood the market, increasing supply and potentially reducing prices. Increased hedging activity that could lead to a decrease in market prices. Investor Sentiment.  Changes in a country's monetary policy, economic conditions, or strategic needs.   Prices can be volatile, influenced by factors such as changes in interest rates, currency fluctuations, and geopolitical events. The official sector includes central banks and government entities that hold a substantial portion of the world's gold and other precious metals. Investing in metals such as Gold, Silver, or Palladium Bullion backed by "electronic shares" rather than physical metal involves several unique risk factors. One of these is the influence of large sales by the official sector, such as central banks and government entities, which hold a considerable portion of global gold and precious metals reserves. When these entities decide to sell large quantities, it can flood the market, increasing supply and potentially driving prices down. Additionally, a significant increase in hedging activities by producers can also impact prices. Hedging involves the sale of future production to lock in prices, and when producers engage heavily in these activities, it can lead to a surplus in the market, affecting prices negatively. Moreover, changes in the attitude of speculators and investors can dramatically impact market dynamics. If speculators suddenly change their outlook on the value or stability of precious metals, it could lead to rapid buying or selling, causing price volatility. Such shifts in sentiment can be triggered by various factors, including economic data, geopolitical events, or changes in monetary policy, all of which can affect investor confidence and market behavior Reinvestment Risk The risk that falling interest rates will lead to a decline in cash flow from an investment when its principal and interest payments are reinvested at lower rates. Social/Political The possibility of nationalization, unfavorable government action or social changes resulting in a loss of value. Page 29 of 48 Disclosure Brochure  Taxability Risk The risk that a security that was issued with tax-exempt status could potentially lose that status prior to maturity. Since municipal bonds carry a lower interest rate than fully taxable bonds, the bond holders would end up with a lower after-tax yield than originally planned. Types of Investments There are different types of investments that involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy will be profitable or equal any specific performance level(s). Past performance is not indicative of future results. The types of investments typically used by GFG Solutions include: Cash and Cash Equivalents Cash is money in the form of currency, which includes all bills, coins, and currency notes. Cash and cash equivalents refers to the line item on the balance sheet that reports the value of a company's assets that are cash or can be converted into cash immediately. Cash equivalents include bank accounts and marketable securities, which are debt securities with maturities of less than 90 days. Examples of cash equivalents include commercial paper, Treasury bills, and short-term government bonds with a maturity date of three months or less. Marketable securities and money market holdings are considered cash equivalents because they are liquid and not subject to material fluctuations in value. Corporate Debt Obligations Corporate debt obligations, also known as corporate bonds or corporate debt securities, are debt instruments issued by corporations to raise capital. These obligations represent a form of borrowing for the issuing company, where investors lend money to the company in exchange for regular interest payments and the repayment of the principal amount at maturity. Corporate debt obligations pay interest to investors, typically at fixed intervals (e.g., annually or semi-annually). The interest rate, known as the coupon rate, is determined at the time of issuance and remains fixed over the life of the debt. Corporate debt obligations have a specific maturity date, which is the date when the company is obligated to repay the principal amount to investors. Maturities can range from a few months to several decades, depending on the terms set by the company. At maturity, the company is obligated to repay the principal in full to the bondholders. Corporate debt obligations are assigned credit ratings by credit rating agencies to assess the creditworthiness and default risk of the issuing company. Cryptocurrency Cryptocurrencies refer to the actual virtual currency (decentralized digitized money) that allows individuals or entities to transfer funds online without the need for a bank or credit card company, such as Bitcoin, Ethereum, Cardano, and Litecoin. Cryptocurrencies were not designed to be investments and have not yet been deemed to be a security. They were designed to be mediums of exchange and seen as an alternative to traditional sovereign currencies. Cryptocurrency-related products refer to securities that either directly purchase cryptocurrencies or are involved in the cryptocurrency space, such as through mining cryptocurrency, investing in companies that develop and use blockchain technology, etc. The SEC, CFTC, NFA, and FINRA have issued investor alerts and advisories on the risks of cryptocurrencies and initial coin offerings (ICOs). These regulators continue to warn investors to keep in mind that actual cryptocurrency and cryptocurrency-related products continue to be speculative and extremely volatile investments. Due to the unregulated nature and lack of transparency surrounding the operations of crypto exchanges, they may experience fraud, market manipulation, security failures or operational problems, which can adversely affect the value of cryptocurrencies and, consequently, the value of the shares of cryptocurrency-related products. Certain digital assets often rely on or are built on a public or third-party blockchain, and the success of such blockchain can have a direct impact on the success of the digital assets. These digital assets are partly dependent on the effectiveness and success of such blockchains, as well as the success of other blockchain and decentralized data storage systems that are being used by the issuer of the digital assets. There is no guarantee that any of these systems or their sponsors will continue to exist or be successful. This could lead to disruptions of the operations of the issuer of the digital assets listed on the platform and could negatively affect any digital assets held by a Client. Once a transaction has been verified and recorded in a block that is added to the blockchain, an incorrect transfer or theft of digital currencies or digital assets generally will not be reversible. Page 30 of 48 Disclosure Brochure  Through computer or human error, or through theft or criminal action, Clients’ digital currencies and/or digital assets could be transferred in incorrect amounts or to unauthorized third parties. Blockchain Crypto assets are built and rely on public or third-party blockchains, and the success of such blockchains can have a direct impact on the success of the related crypto assets. These crypto assets are partly dependent on the effectiveness and success of such blockchains, as well as the success of other blockchain and decentralized data storage systems that are being used by the issuer of the crypto assets. There is no guarantee that any of these systems or their sponsors will continue to exist or be successful. This could lead to disruptions of the operations of the issuer of the crypto assets listed on the platform and could negatively affect any crypto assets held by a Client. Once a transaction has been verified and recorded in a block that is added to the blockchain, an incorrect transfer or theft of crypto currencies or crypto assets generally will not be reversible. Through computer or human error, or through theft or criminal action, Clients’ crypto currencies and/or other crypto assets could be transferred in incorrect amounts or to unauthorized third parties. Equity Investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environment. Exchange Traded Funds (ETFs) An ETF is a portfolio of securities invested to track a market index similar to an index mutual fund, but the shares are traded on an exchange like an equity. An ETF share price fluctuates intraday depending on market conditions instead of having a net asset value (NAV) that is calculated once at the end of the day. The shares may trade at a premium or discount; and as a result, investors pay more or less when purchasing shares and receive more or less than when selling shares. The supply of ETF shares is regulated through a mechanism known as creation and redemption that involves large specialized investors, known as authorized participants (APs). Authorized participants are large financial institutions with a high degree of buying power, such as market makers, banks or investment companies that provide market liquidity. When there is a shortage of shares in the market, the authorized participant creates more (creation). Conversely, the authorized participant will reduce shares in circulation (redemption) when supply falls short of demand. Multiple authorized participants help improve the liquidity of a particular ETF and stabilize the share price. To the extent that authorized participants cannot or are otherwise unwilling to engage in creation and redemption transactions, shares of an ETF tend to trade at a significant discount or premium and may face trading halts and delisting from the exchange. The performance of ETFs is subject to market risk, including the complete loss of principal. ETFs also have a trading risk based on cost inefficiency if the ETFs are actively traded and a liquidity risk if the ETFs has a large price spread and low trading volume. In addition, investors buying or selling shares in the secondary market pay brokerage commissions, which may be a significant proportional cost not incurred by mutual funds. Government Debt Obligations Government debt obligations, often called government bonds or sovereign debt, are debt instruments issued by national governments to raise funds. These obligations represent loans made by investors to the government, with the promise of regular interest payments and repayment of the principal amount at maturity. These bonds are considered among the safest investments in the financial markets since the full faith and credit of the issuing government backs them. Government debt obligations pay interest to investors, typically at fixed intervals, such as annually or semi-annually. The interest rate, known as the coupon rate, is determined at issuance and remains fixed over the bond's life. Government debt obligations have a specific maturity date, indicating when the government must repay the principal amount to bondholders. Maturities can range from short-term (less than one year) to long-term (decades). At maturity, the government repays the principal in full to the bondholders. The creditworthiness of government debt obligations is assessed based on the financial strength and stability of the issuing government. The yield on government bonds is influenced by factors such as prevailing interest rates, inflation expectations, and the creditworthiness of the issuing government. Government debt obligations are often highly liquid, meaning they can be easily bought or sold in the secondary market. Page 31 of 48 Disclosure Brochure  Money Market Funds Money markets refer to a financial market segment where short-term debt instruments with high liquidity and low risk are traded. It serves as a platform for borrowing and lending funds with maturities typically ranging from overnight to one year. Governments, financial institutions, and corporations commonly issue money market instruments to meet their short-term financing needs. Liquidity is a defining feature of money markets. Investors can easily buy or sell money market instruments in the secondary market at fair prices. Active trading, standardized contracts and the involvement of large financial institutions facilitate this liquidity. Money market instruments are generally considered low-risk investments. Entities such as governments or well-established financial institutions issue them with solid credit ratings. The low-risk nature of these instruments arises from their short maturities, which reduces the likelihood of default. Mutual Funds A pool of funds collected from many investors for the purpose of investing in securities such as stocks, bonds, money market instruments and similar assets. An open-end mutual fund is a type of mutual fund that does not have restrictions on the amount of shares the fund will issue and will buy back shares when investors wish to sell. Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs’ that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. A closed-end mutual fund is a type of mutual fund that raises a fixed amount of capital through an initial public offering (IPO). The fund is then structured, listed, and traded like a stock on a stock exchange. Clients should be aware that closed-end funds available within the program are not readily marketable. In an effort to provide investor liquidity, the funds may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, clients may be unable to liquidate all or a portion of their shares in these types of funds. Alternative strategy mutual funds primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. Treasuries Treasuries, also known as Treasury securities or government bonds, are debt instruments issued by the government of a country, primarily the United States in the case of U.S. Treasuries. They are considered among the safest investments available because they are backed by the full faith and credit of the government. Here are the key points to understand about Treasuries: Types of Treasuries U.S. Treasuries come in different forms, including Treasury bills (T-bills), Treasury notes (T-notes), and Treasury bonds (T-bonds). T-bills have short-term maturities of one year or less, T-notes have intermediate-term maturities ranging from two to ten years, and T-bonds have longer-term maturities of ten years or more. Safety and Creditworthiness U.S. Treasuries are considered to have very low credit risk since they are backed by the U.S. government. The U.S. government has the ability to raise taxes or print money to meet its debt obligations, making default highly unlikely. Fixed-Income and Interest Payments Treasuries are fixed-income securities, meaning they pay a fixed interest rate over their respective terms. T-bills are issued at a discount to their face value and mature at face value, with the difference representing the interest earned. T- notes and T-bonds pay semi-annual interest payments to bondholders until maturity when the face value is repaid. Liquidity and Marketability U.S. Treasuries are highly liquid instruments, meaning they can be easily bought and sold in the secondary market. They are actively traded on various platforms, including the U.S. Treasury's auction system and the secondary market. This liquidity makes Treasuries an attractive investment for individuals, institutions, and central banks. Page 32 of 48 Disclosure Brochure  Role in the Market U.S. Treasuries play a significant role in the global financial system. They are considered a benchmark for determining interest rates on other debt instruments. Treasury yields are often used as reference rates for corporate bonds, mortgages, and other fixed-income securities. The yields on Treasuries are influenced by factors such as economic conditions, inflation expectations, and monetary policy. Diversification and Risk Mitigation Treasuries are commonly used as a risk-free or low-risk components in investment portfolios. They are considered a haven asset that tends to perform well during periods of market volatility or economic uncertainty. Investors often allocate a portion of their portfolio to Treasuries to diversify their holdings and provide a hedge against riskier assets. Tax Considerations Interest earned on U.S. Treasuries is subject to federal income tax but exempt from state and local taxes. However, certain types of Treasury securities, such as Treasury Inflation-Protected Securities (TIPS), are subject to federal income tax on the inflation-adjusted interest accrued each year, even though the principal adjustment is taxed when received at maturity or sale. It's important to note that while Treasuries are considered low-risk investments, they are not without risk. Factors such as changes in interest rates, inflation, and economic conditions can impact the market value of Treasuries before maturity. Investors should consider their investment goals, risk tolerance, and the impact of inflation when determining their allocation to Treasuries. Additional types of investments will be considered for asset allocation and risk management purposes. Item 9 – Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would-be material to your evaluation of an advisory firm or the integrity of a firm’s management. GFG Solutions has no information to disclose. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation GFG Solutions does not have a broker/dealer affiliation. Insurance Products Compensation Certain Investment Advisor Representatives of GFG Solutions who are licensed as insurance agents receive commissions and other compensation from insurance companies and insurance intermediaries for the sale of insurance products. Commission rates differ from product to product and carrier to carrier. In addition to commissions, its representatives can also receive marketing support, reasonable meals and entertainment, and costs to attend training, conferences, and events hosted by insurance companies and third-party marketing organizations that are contracted with and receive compensation from the insurance company. Insurance commissions and other benefits are significant sources of compensation and are paid separately from advisory fees on assets in a client’s managed securities account. Commissions are generally paid up-front, at the time of sale, unlike asset-based fees which are paid periodically over the course of the relationship. This amount and form of insurance compensation creates a conflict of interest in that investment advisor representatives in their individual capacity as insurance agents are incentivized to recommend insurance products based on the compensation received rather than on a client’s needs. Investment Advisor Representatives in their individual capacity of insurance agents are not required to offer the products of a specific insurance company. Any compensation received is separate from, and does not offset regular advisory fees. GFG Solutions will not charge advisory fees on any insurance products. Clients are under no obligation to implement any recommendations, and have the option to implement such recommendations through brokers or agents of their choice. GFG Solutions addresses the conflict of interest related to insurance products sales by requiring its investment advisor representatives to act in the best interest of the client, including when acting as insurance agents. Insurance-licensed investment advisor representatives employ a process of analyzing each customer’s financial situation, needs, goals and risk profile for the purpose of making recommendations that are based on an objective evaluation of each client’s best interest rather than on the receipt of any commissions or other benefits. Page 33 of 48 Disclosure Brochure  GFG Solutions, LLC GFG Solutions, LLC operates as a distinct entity that is under common control, meaning it is part of a group of companies that share ownership or management, often to streamline operations and enhance service offerings. This entity is specifically focused on providing tailored services to business owners, aiming to address their unique financial planning needs. The services offered by GFG Solutions, LLC are comprehensive and designed to support business owners in managing various aspects of their financial health and future planning. These services include:  Risk Management: This involves identifying potential risks that could affect the business and developing strategies to mitigate or transfer these risks. Effective risk management helps protect the business from unforeseen events that could impact its operations or financial stability.  Tax Strategies: GFG Solutions, LLC offers planning related to tax efficiency, helping business owners minimize their tax liabilities while working with a client’s third-party CPA or tax professional.  Growth and Accumulation Planning: This aspect focuses on strategies to grow the business's value and the owner's wealth over time. It includes investment advice, expansion planning, and optimizing the accumulation of financial assets. Services include helping a business plan for adequate liquidity to meet its operational expenses. GFG Solutions, LLC provides planning services to help business owners manage their cash flow effectively, ensuring that they have the resources needed to sustain and grow their operations.  Legacy Planning: This involves preparing for the transfer of business ownership and wealth to future generations or other beneficiaries. Legacy planning help promote a transition that is smooth. Overall, GFG Solutions, LLC aims to provide high-level strategic planning that supports business owners in achieving their financial goals, protecting their assets, and planning for the future. Conflicts of Interest Conflicts of interests exist because securities and insurance sales create an incentive to recommend products based on the compensation earned rather than the best interests of the Client. Such potential conflicts of interest are subject to review by the Chief Compliance Officer. This chart is intended to explain the potential capacity a Financial Advisor can serve, and the type of compensation received. Capacity Compensation Investment Advisor Representatives Advisory Fee Insurance Agent Commissions Certain conflicts of interest may affect the ability of GFG, Mr. Gambin, and the Firm’s investment adviser representatives (“IARs”) to provide clients with unbiased and objective investment advice with respect to the recommendation of certain fund investments for client accounts. As a result, it is possible that other investments in which Mr. Gambin does not have a financial or other interest may be more appropriate for a client than an investment in such funds. Accordingly, a conflict of interest exists in the selection of investments for GFG clients. GFG seeks to mitigate these conflicts through several measures, including: (i) providing full and fair disclosure of all material conflicts of interest to clients in writing; (ii) adhering to fiduciary obligations that require recommendations to be made in the client’s best interest; (iii) implementing supervisory review processes designed to monitor investment recommendations and allocations for consistency with client objectives and suitability; (iv) maintaining policies and procedures to address conflicts, including periodic compliance reviews; and (v) ensuring that clients are under no obligation to invest in any recommended fund and may decline such recommendations without penalty. Despite these mitigation measures, such conflicts cannot be entirely eliminated. Additional Registrations Registered investment advisors are required to describe any relationship or arrangement that is material to its advisory business or any management persons. Registered investment advisors are also required to disclose if it recommends or select other investment advisers Page 34 of 48 Disclosure Brochure  for clients and receives compensation directly or indirectly from those advisers that creates a material conflict of interest, or if there is a business relationship that create a material conflict of interest. There is no such relationships or compensation arrangements to describe. Furthermore, neither GFG Solutions nor any of the management persons are registered or has a registration pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics GFG Solutions has implemented a Code of Ethics (the “Code”) pursuant to SEC rule 204A-1. A copy of our code of ethics will be provided to any client or prospective client upon request. This Code applies to all persons associated with GFG Solutions (“Covered Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. GFG Solutions and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of GFG Solutions’ 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 conflicts of interest. To request a copy of the Code, please contact the Advisor at (407) 627-0091. Personal Trading with Material Interest Certain covered persons are considered “access” persons. An access person is a covered person who has access to nonpublic information regarding the purchase or the sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations that are nonpublic. GFG Solutions allows Access Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Access persons must notify the Compliance Department of, and receive prior approval for, opening accounts or holding personal securities and/or holdings. Access persons are required to provide duplicate statements for review. GFG Solutions does not act as principal in any transaction, act as the general partner of a fund, or advise an investment company, have a material interest in any securities traded in Client accounts. Personal Trading in Same Securities as Clients GFG Solutions 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 that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated 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, Access Persons have a conflict of interest if trading in the same securities but their fiduciary duty to act in the best interest of its Clients mitigates this conflict. This risk is further mitigated by requiring reporting of personal securities trades by its Access Persons for review by the Chief Compliance Officer (“CCO”) or delegate. Personal Trading at the Same Time as Client While GFG Solutions 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 GFG Solutions, or any Supervised Person of GFG Solutions , transact in any security to the detriment of any Client. Item 12 – Brokerage Practices Broker/Dealer Recommendation GFG Solutions will generally not allow advisory clients to determine the broker-dealer to use. Rather, the Company will generally require that clients establish brokerage accounts with Schwab. Schwab provides the Company with Schwab's "platform" services. The platform services include, among others, brokerage, custodial, trade execution, clearance, settlement of transactions, administrative support, record keeping and related services that are intended to support intermediaries in conducting business and in serving the best interests of their clients but also benefit the GFG Solutions. Schwab charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Schwab enables the Company to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab's commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Schwab may be higher Page 35 of 48 Disclosure Brochure  or lower than those charged by other custodians and broker- dealers. Some of these transaction fees are covered by the GFG Solutions under its wrap program. As part of the arrangement, Schwab makes available to GFG Solutions, at no additional charge, certain research and brokerage services, including research services obtained by Schwab directly from independent research companies, as selected by GFG Solutions (within specified parameters). These research and brokerage services are used by GFG Solutions to manage accounts for which it has investment discretion. Services provided by Schwab include research (including mutual fund research, third-party research, and Schwab's proprietary research), brokerage, clearing, custody, and access to mutual funds and other investments that are available only to institutional investors or would require a significantly higher minimum initial investment. Research and brokerage services presently include: access to a full array of proprietary and third-party investment offerings, spanning alternatives, structured products, separately managed accounts and mutual funds; technology integration, training and support. GFG Solutions also receives additional services from Schwab. Without this arrangement, GFG Solutions might be compelled to purchase the same or similar services at its own expense. GFG Solutions is eligible for a specific schedule of fees based upon our assets under management with Schwab. A client can pay a commission that is higher than another qualified broker/dealer charges to affect the same transaction where GFG Solutions determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker/dealer's services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although GFG Solutions will seek competitive rates, to the benefit of all clients, it will not necessarily obtain the lowest possible commission rates for specific client account transactions. Although the investment research products and services obtained by GFG Solutions will generally be used to service all of its clients, a brokerage commission paid by a specific client can be used to pay for research that is not used in managing that specific client's account. Soft Dollars GFG Solutions does not receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions that would be considered soft dollar benefits. Brokerage Referrals GFG Solutions does not receive any compensation from a third-party in connection with the recommendation for establishing an account. By directing brokerage, you may be unable to achieve the most favorable execution of client transactions, this practice may cost clients more money. Directed Brokerage All Clients trades a directed to a broker/dealer determined by GFG Solutions . Clients do not have the ability to direct trades to a different broker/dealer. GFG Solutions does not have any broker/dealer affiliates or other economic relationships that create a material conflict of interest. Aggregating and Allocating Trades GFG Solutions will generally aggregate orders in a block trade for 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 is done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Best Execution As stated above, GFG Solutions will generally require that its clients establish broker accounts with Schwab. GFG Solutions, pursuant to the terms of its management agreement with clients, will generally have discretionary authority to determine which securities are to be bought and sold and the price of such securities to affect such transactions. The Company recognizes that the analysis of execution quality involves a number of qualitative and quantitative factors. The Company will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include, but are not limited, to the following:  The financial strength, reputation and stability of the broker-dealer;  The efficiency with which the transaction is affected; the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any);  The availability of the broker-dealer to stand ready to effect transactions of varying degrees of difficulty in the future; Page 36 of 48 Disclosure Brochure   The efficiency of error resolution, clearance and settlement;  Block trading and positioning capabilities;  Performance measurements;  Online access to computerized data regarding customer accounts;  Availability, comprehensiveness, and frequency of brokerage and research services;  Commission rate;  The economic benefit to the clients; and  Related matters involved in the receipt of brokerage services. GFG Solutions will utilize Schwab as its sole custodian / broker-dealer. There are some risks associated with the use of a single custodian or broker/dealer, such as the financial failure of the broker/dealer. However, brokerage firms are required to follow certain rules that are designed to minimize the chances of financial failure and, more importantly, to protect customer assets if they do fail. Various regulatory agencies enforce those rules. Another aspect of using a single broker-dealer is the inability to compare trading costs and execution, and possibly the failure to obtain the best pricing and best execution available. GFG Solutions has engaged in due diligence regarding Schwab's execution and trading costs and believes both that Schwab provides high-quality trade execution and that the Company's clients will pay competitive rates for such execution to the extent not covered by the wrap program. Although Schwab's commission rates are competitive within the securities industry, lower commissions or better execution may be able to be achieved elsewhere. GFG Solutions has considered the benefits offered to it through its relationship with Schwab in deciding to use Schwab as its broker/dealer of choice. Trade Errors GFG Solutions has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of GFG Solutions to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client is responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client is made whole and any loss resulting from the trade error is absorbed by GFG Solutions if the error is caused by GFG Solutions. If the error is caused by the broker/dealer, the broker/dealer is responsible for handling the trade error. If an investment gain results from the correcting trade, the gain remains in the client’s account unless the same error involves other client account(s) that should also receive the gains. It is not permissible for all clients to retain the gain. GFG Solutions may also confer with a client to determine if the client should forego the gain (e.g., due to tax reasons). GFG Solutions will never benefit or profit from trade errors. Cash Sweep Program Investment portfolios often include a cash allocation to maintain liquidity, manage risk, and provide funds for opportunistic investments. Cash allocations can serve as a buffer against market volatility and ensure that funds are readily available for future investment opportunities or withdrawals. Sweep programs automatically transfer uninvested cash from a brokerage account into a money market fund or other short-term investment vehicle at the custodian. This process is automated and occurs regularly, often at the end of each business day. While the cash is held in the sweep account, it earns interest. This ensures that even idle cash is generating some return, albeit typically lower than other investment options. By automating the movement of cash, sweep programs reduce the need for manual transfers, saving time and minimizing the risk of human error in managing cash balances. Sweep accounts provide quick access to cash for reinvestment or withdrawals, enhancing liquidity management within the portfolio. Minimizing manual cash management tasks reduces administrative burdens for both the investor and the advisor, allowing them to focus on strategic investment decisions. Sweep programs often offer lower interest rates compared to other short-term investments like high-yield savings accounts or CDs. This is due to the liquidity and convenience they provide. While convenient, the lower interest rates mean that investors can miss out on higher returns if cash is kept in the sweep account for extended periods. Advisor uses sweep programs strategically to manage cash flows within a portfolio, ensuring that cash is readily available for investment opportunities without sacrificing significant returns. Sweep accounts can also be used to facilitate regular transactions, such as automatic withdrawals for living expenses or periodic investments in other asset classes. While sweep programs offer convenience and liquidity, they require careful consideration as part of an overall investment strategy. Advisors and clients should weigh the benefits of liquidity and automation against the potential for higher returns through alternative cash management strategies. Page 37 of 48 Disclosure Brochure  Item 13 – Review of Accounts Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by the Chief Compliance Officer of GFG Solutions . Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. Causes for Reviews Client accounts are reviewed, by an investment advisor representative, at least annually and more frequently at a Client’s request. Accounts are reviewed as a result of major changes in economic conditions, changes in financial situation, and/or based on large deposits or withdrawals. Clients are encouraged to notify GFG Solutions of such changes. Additional reviews can be triggered by material market, economic or political events. Review Reports Clients receive written statements no less than quarterly directly from the Custodian. The Client may establish electronic access to the Custodian’s website so that they can view these reports and their account activity. Client statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports during regular meetings regarding their holdings, allocations, and performance that do not constitute official statements. Page 38 of 48 Disclosure Brochure  Item 14 – Client Referrals and Other Compensation GFG Solutions is a fee-based advisory firm, that is compensated by its Clients to provide investment advice and not from any investment product or someone other than the Client. Advisor does not receive commissions or other economic benefit or compensation from product sponsors, broker/dealers or any un-related third party. Client Referrals from Solicitors GFG Solutions does not engage paid solicitors for Client referrals. Money Managers and Product Sponsors Investment advisor representatives can, on occasion, have an opportunity to attend a training event or participate in a due diligence visit where the Money Manager or Product Sponsor will cover the associated travel expenses such as airfare, hotel and meals. Training opportunities are often held at luxury resorts where amenities such as golf, spas and entertainment are provided. Such accommodations represent a conflict of interest that can influence the evaluation of the Money Manager or Product sponsor based on factors other than the quality of services. Additional Compensation GFG Solutions can receive an economic benefit for providing advisory services from sources other than the client. Economic benefits include sales awards and gifts, an occasional meal, as well as entertainment such as a concert, show or sporting event. Such compensation is not directly related to the advice or services provided to a particular client, but it does create a conflict of interest that can influence the selection of services based on the compensation received. Industry Professionals When it is in the best interests of the client, GFG Solutions can introduce the services of other professionals for certain non- investment purposes (i.e. attorneys or accountants). Introductions represent a conflict of interest because they create a relationship where the other professional has an implied obligation to introduce potential new clients to GFG Solutions. Clients are under no obligation to engage the services of any such professional. If the client engages any such professional, and a dispute arises, any recourse will be exclusively from and against the engaged professional. Conflicts of interest are mitigated by the fiduciary duty to always act in a client’s best interest and acting accordingly. GFG Solutions will seek independent counsel to evaluate conflicts as they arise and provide sufficient disclosure and controls which may include declining to participate or proceed with an engagement. Schwab Brokerage and Custody Services GFG Solutions will recommend Schwab to clients for custody and brokerage services. There is no direct link between the Company's participation in the program and the investment advice it gives to its clients, although GFG Solutions receives economic benefits through its participation in the program that are typically not available to Schwab retail investors. Schwab makes available other products and services that benefit us, but not directly benefit our clients' accounts. Many of these products and services are used to service all or some substantial number of our client accounts, including accounts not maintained at Schwab. These benefits include the following products and services (provided without cost or at a discount):  Provide access to client account data (such as trade confirmations and account statements);  Facilitate trade execution and allocate aggregated trade orders for multiple client accounts;  Provide research, pricing and other market data;  Facilitate payment of our fees from clients' accounts; and assist with back-office functions, recordkeeping and client reporting;  Receipt of duplicate client statements and confirmations; and  The ability to have advisory fees deducted directly from our client's accounts. Other services offered to help us manage and further develop our business enterprise. These services include, but are not necessarily limited to: (1) compliance, legal and business consulting; (2) publications and conferences on practice management and business succession; (3) assistance with back-office functions, record keeping and client reporting; and (4) access to funds with no transaction Page 39 of 48 Disclosure Brochure  fees and to certain institutional money managers. Schwab makes available, arranges and/or pays third party vendors for services rendered to GFG Solutions. Schwab can discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to the Company. Schwab also provides other benefits such as educational events or occasional de minimus business entertainment for our personnel. All business entertainment will be guided by our Code of Ethics. Item 15 – Custody GFG Solutions does not accept or maintain actual custody of funds or securities. A qualified custodian is responsible for providing Clients with trade confirmations, tax forms and quarterly statements that include account balance(s). Clients are advised to carefully review the information provided by the custodian and notify their Investment Advisor Representative with any questions or if such information is not received. Item 16 – Investment Discretion GFG Solutions generally provides investment advisory services on a discretionary basis. Prior to assuming discretionary authority, the Client grants permission by executing an Advisory Agreement, granting GFG Solutions full authority to buy and/or sell the type and amount of securities. Item 17 – Voting Client Securities GFG Solutions does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. GFG Solutions can assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Clients will receive their proxies or other solicitations directly from their custodian or a transfer agent or from you, and discuss whether (and, if so, how) clients can contact you with questions about a particular solicitation. Page 40 of 48 Disclosure Brochure  Item 18 – Financial Information Neither GFG Solutions nor its management, have any adverse financial situations that would reasonably impair the ability of GFG Solutions to meet all obligations to its Clients. Neither GFG Solutions nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. GFG Solutions 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. Page 41 of 48 Disclosure Brochure  Item 1 – Cover Page Registered As: GFG Solutions | CRD No. 331977 Appendix 1 – Wrap Fee Program Brochure 150 N Orange Ave., Suite 340 | Orlando, FL 32801 Phone: (407) 627-0091 | Website: https://gfgsolutions.com/ March 30, 2026 This wrap fee program brochure provides information about the qualifications and business practices of GFG Solutions. If you have any questions about the contents of this brochure, please contact us at (407) 627-0091. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about GFG Solutions is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 42 of 48 Disclosure Brochure  Item 2 – Material Changes Material Changes Since our last annual updating amendment, there are no material changes. Annually, a complete Disclosure Brochure will be offered to Clients along with a summary of material changes, if any, within 120 days from the firm’s fiscal year-end. At any time, the current Disclosure Brochure is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching the firm name or CRD number 331977 . A copy of this Disclosure Brochure may be requested at any time, by contacting (407) 627-0091. Page 43 of 48 Disclosure Brochure  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................................................ 42 Item 2 – Material Changes.................................................................................................................................................................... 43 Item 3 – Table of Contents .................................................................................................................................................................. 44 Item 4 – Services, Fees and Compensation .......................................................................................................................................... 45 Item 5 – Account Requirements and Types of Clients .......................................................................................................................... 45 Item 6 – Portfolio Manager Selection and Evaluation .......................................................................................................................... 45 Item 7 – Client Information Provided by Portfolio Managers ............................................................................................................... 46 Item 8 – Client Contact with Portfolio Managers ................................................................................................................................. 46 Item 9 – Additional Information ........................................................................................................................................................... 46 Page 44 of 48 Disclosure Brochure  Item 4 – Services Fees and Compensation Services GFG Solutions can provide portfolio management services as a Wrap Fee Program, where the asset management fee and brokerage transaction fees (ticket charges) are combined or “wrapped” into a single fee. For such accounts, Advisor is considered the Sponsor and Portfolio Manager. This brochure is provided as an appendix to Form ADV 2A to describe fee structure of a wrap fee program. Other than the fee structure, the services offered in a wrap fee and a non-wrap fee account are identical. In either account type the total fees are negotiable and paid to Advisor. A wrap fee program will generally have a higher asset management fee to account for the additional cost of ticket charges paid by Advisor. The benefits of a wrap fee program depend, in part, upon the size of the account, the associated costs, and the frequency or type of transactions executed. A wrap fee account is generally not appropriate for an account with minimal trading or large cash positions. Program Costs The fee structure that is in the client’s best interest depends on the type of positions held, anticipated frequency of trading and fee payment preference. For example, a portfolio of primarily No Transaction Fee (NTFs) positions or an account with a low volume of trading will generally not benefit from the higher asset management fee of a wrap fee account. Whereas an account that has positions that include a ticket charge per transaction and there is an anticipated high degree of trading would likely benefit from a wrap fee program. Fees Investment advisory fees, not to exceed 1.20%, are paid monthly in advance pursuant to the terms of the investment advisory agreement. The applicable fee is 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 GFG Solutions. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. Clients will incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. In addition, all fees paid to GFG Solutions for investment advisory services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds, exchange-traded funds and alternative investment funds 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. The Client can also incur other costs assessed by the Custodian or other parties for account related activity fees, such as wire transfer fees, fees for trades executed away from the Custodian and other fees. GFG Solutions does not control nor share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged by GFG Solutions to fully understand the total fees to be paid. Compensation GFG Solutions receives investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the costs associated with the normal trading activity in the Client’s account(s). Conflict of Interest A Wrap Fee program introduces a conflict of interest because it creates an incentive to limit the number of trades placed in the Client’s account to reduce the ticket charges to the Advisor. Item 5 – Account Requirements and Types of Clients There are no other types of clients to disclose other than those listed in Item 7 of the preceding ADV 2A. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection GFG Solutions serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. Performance-Based Fees GFG Solutions does not charge performance-based fees. Page 45 of 48 Disclosure Brochure  Proxy Voting GFG Solutions 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 7 – Client Information Provided to Portfolio Managers GFG Solutions is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Item 8 – Client Contact with Portfolio Managers GFG Solutions is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at GFG Solutions . Item 9 – Additional Information Disciplinary Information There is no information to disclose. Other Financial Industry Activities and Affiliations Item 10 of the ADV 2A provides complete information about Other Financial Industry Activities and Affiliations. There is no additional information to disclose regarding a wrap fee program. Code of Ethics Item 11 of the ADV 2A provides complete information regarding the Code of Ethics. There is no additional information to disclose regarding a wrap fee program. Client Referrals and Other Compensation Item 14 of the ADV 2A provides complete information regarding the client referrals and other compensation. There is no additional information to disclose regarding a wrap fee program. Financial Information Item 18 of the ADV 2A provides complete information regarding financial information. There is no additional information to disclose regarding a wrap fee program. Page 46 of 48 Disclosure Brochure  Privacy Policy Our Commitment to You GFG Solutions (“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. GFG Solutions (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. GFG Solutions 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 Account applications and forms Other advisory agreements and legal documents Investment questionnaires and suitability documents Transactional information with us or others 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. Page 47 of 48 Disclosure Brochure  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 Servicing our Clients - We may share non-public personal information with affiliated and 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. No Not Shared Marketing Purposes - GFG Solutions 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 GFG Solutions 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. Yes Yes 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]. No Not Shared Information About Former Clients - GFG Solutions 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. Other Important State Specific Information In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations. 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 us at (407) 627-0091. Page 48 of 48 Disclosure Brochure