GREENBUSH FINANCIAL GROUP, LLC

Item 1 - Cover Page Greenbush Financial Group, LLC 159 Wolf Road, Suite 101 Albany, NY 12205 (518) 477-6686 www.greenbushfinancial.com December 2025 ____________________________________________________________________________________ This brochure provides information about the qualifications and business practices of Greenbush Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at (518) 477- 6686. 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 Greenbush Financial Group, LLC is also available on the Internet at www.adviserinfo.sec.gov. You can view information on this website by searching for Greenbush Financial Group, LLC’s name or by using its CRD number: 125500. *Registration as an investment advisor does not imply a certain level of skill or training.  Item 2 – Material Changes Since our last annual update was filed in February 2024, the following material change has been made to this disclosure brochure: • In July 2024 the firm added language clarifying how our asset management fees are calculated. Please refer to Item 5 – Fees and Compensation for more information. • In November 2024, the maximum hourly fees for financial planning were increased. The fixed fees for on-going consultation services were also increased. • In November 2024 the firm update the other business activities of the company principals. Please refer to Item 10 – Other Financial Industry Activities and Affiliations for more specific information. • The firm has increased its minimum account size requirement to $250,000, Please refer to Item 5 – Asset Management Services for more specific information. • As of 4/18/2024, the firm and our investment advisor representatives will no longer be associated with American Portfolios Financial Services, Inc. Moving forward, Greenbush Financial Group, LLC will have no broker dealer relationship and be a fully independent registered investment advisory firm registered with the SEC. • For clients utilizing Greenbush Financial Group, LLC for discretionary investment management services, Pershing, LLC has been replaced with Fidelity Investments for Custodial Services for all accounts. Please see Item 12 – Brokerage Practices for more specific information. We will continue to ensure that you receive a summary of material changes, if any, to this and subsequent disclosure brochures within 120 days after our fiscal year ends. Our fiscal year ends on December 31 so you will receive the summary of material changes, if any, no later than April 30 each year. At that time, we will also offer a copy of the most current disclosure brochure. We may also provide other ongoing disclosure information about material changes as necessary. Clients and prospective clients can always receive the most current Disclosure Brochure for Greenbush Financial Group, LLC at any time by contacting Rob Mangold at (518) 477-6686. 2 Greenbush Financial Group, LLC 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 Business ........................................................................................................................... 5 Ownership ................................................................................................................................................. 5 General Description of Primary Advisory Services ................................................................................... 5 Financial Planning Services (Plans and Investment Consulting) .......................................................... 5 Retirement Plan Investment Advisory Services .................................................................................... 5 Asset Management Services ................................................................................................................ 6 Specialization ........................................................................................................................................ 6 Limits Advice to Certain Types of Investments. .................................................................................... 6 Tailors Advice or Services to Individual Needs of Clients ......................................................................... 7 Client Assets Managed by Advisor ........................................................................................................... 7 Item 5 – Fees and Compensation ................................................................................................................. 7 Newsletters and Videos ............................................................................................................................ 7 Financial Planning Services ...................................................................................................................... 7 Investment Consulting Services ................................................................................................................ 9 Retirement Plan Investment Advisory Services ...................................................................................... 10 Asset Management Services .................................................................................................................. 14 Performance Based Fees ................................................................................................................... 16 Additional Compensation ........................................................................................................................ 17 Comparable Services .............................................................................................................................. 18 Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................... 18 Item 7 – Types of Clients ............................................................................................................................ 19 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 20 Methods of Analysis ................................................................................................................................ 20 Fundamental ....................................................................................................................................... 20 Technical ............................................................................................................................................. 20 Primary Method of Analysis or Strategy .................................................................................................. 20 Investment Strategies ............................................................................................................................. 21 Risk of Loss ............................................................................................................................................. 21 Primarily Recommend One Type of Security .......................................................................................... 22 Item 9 – Disciplinary Information ................................................................................................................. 23 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 23 Insurance Sales ...................................................................................................................................... 23 Accounting Services ................................................................................................................................ 24 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 24 Code of Ethics Summary ........................................................................................................................ 24 Participation in Client Transactions and Personal Trading ..................................................................... 25 Item 12 – Brokerage Practices .................................................................................................................... 25 Brokerage Recommendations ............................................................................................................. 25 Cash Sweep Program ............................................................................................................................. 26 Best Execution ........................................................................................................................................ 26 Soft Dollar Benefits ............................................................................................................................... 27 Handling of Trade Errors ......................................................................................................................... 27 Block Trading .......................................................................................................................................... 27 Item 13 – Review of Accounts .................................................................................................................... 28 Account Reviews ..................................................................................................................................... 28 Account Reports ...................................................................................................................................... 28 Item 14 – Client Referrals and Other Compensation .................................................................................. 29 Client Referrals ....................................................................................................................................... 29 Accounting Firm Relationship ............................................................................................................. 29 3 Greenbush Financial Group, LLC Disclosure Brochure  Other Compensation and Non-Client Economic Benefit ......................................................................... 29 Item 15 – Custody ....................................................................................................................................... 30 Item 16 – Investment Discretion ................................................................................................................. 30 Item 17 – Voting Client Securities ............................................................................................................... 31 Item 18 – Financial Information ................................................................................................................... 31 Class Action Lawsuits ................................................................................................................................. 31 Customer Privacy Policy ............................................................................................................................. 31 4 Greenbush Financial Group, LLC Disclosure Brochure  Item 4 – Advisory Business Ownership Greenbush Financial Group, LLC (“Advisor” or “we”) is an investment advisor registered with the Securities and Exchange Commission since January 2012. We were registered with the State of New York from February 29, 2009 to January 2012. Advisor is a limited liability company formed under the laws of the State of New York. David M. Wojeski, Michael R. Ruger and Robert Mangold, Jr. are the owners. General Description of Primary Advisory Services Advisor offers personalized investment advisory services including full and modular financial plans, newsletters, investment consultations, retirement plan services and asset management services. The following are brief descriptions of our primary services. A detailed description of all services is provided in Item 5, Fees and Compensation, so that clients and prospective clients (“clients” or “you”) can review the services and description of fees more thoroughly. Financial Planning Services (Plans and Investment Consulting) Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning and other areas. The role of a financial planner is to find ways to help clients understand their overall financial situation and help them set financial objectives. Advisor offers advisory services in the form of full and modular financial plans. These services do not involve the active management of client accounts. Instead, full planning services focus on a client’s overall financial situation, specifically including the areas estate planning, investment planning, insurance planning, retirement planning and education planning. Modular planning services focus on specific areas of client concern and may not take other important issues into consideration. Advisor also offers investment consulting services to clients wanting advice on a specific area or concern, such as evaluating a specific account, investment opportunity or other financial or investment-related matter. Investment consulting services can include advice on non-securities matters. These services are provided only to accounts where an associated person of Advisor is not the investment advisor representative on the account. Retirement Plan Investment Advisory Services Advisor sponsors a proprietary employer sponsored retirement plan solution called “Active(k)” and serves as a plan consultant and investment advisor to these qualified retirement plans. In this capacity, we can provide plan analysis, plan design recommendations, assistance with selection and monitoring of the plan investment menu, education meetings for plan participants, participant level advice and management of Active(k) Lifestyle Portfolios. When recommending that Client rollover his or her account from current retirement plan to an IRA, Client understands that Greenbush and its investment adviser representatives have a conflict of interest. 5 Greenbush Financial Group, LLC Disclosure Brochure  Greenbush and its representatives can earn investment advisory fees by recommending that Client rollover his or her account at the retirement plan to an IRA; however, Greenbush and its investment adviser representatives will not earn any investment advisory fees if Client does not rollover the funds in the retirement plan (unless Client retained Greenbush to provide advice about my retirement plan account). Thus, Greenbush and its investment adviser representatives have an economic incentive to recommend a rollover of my retirement plan account, which is a conflict of interest. GFG also has the ability to serve as an investment advisor to other employer retirement plan platforms outside of their Active(k) solution. Asset Management Services Advisor offers investment management services providing clients with continuous and on-going supervision over their accounts. This means that Advisor will continuously monitor a client’s account and make trades in that account when necessary. Specialization Advisor specializes in employer sponsored qualified retirement plan services. Please refer to the Retirement Plan Investment Advisory Services section of Item 5, Fees and Compensation, for additional details and discussion about these services. Limits Advice to Certain Types of Investments. Advisor generally limits its investment advice to the following types of investments: • Exchange-listed securities • Securities traded over-the-counter • Foreign issues • Warrants • Corporate debt securities (other than commercial paper) • Commercial paper • Certificates of deposit • Municipal securities • Variable life insurance • Variable annuities • Mutual fund shares • United States government securities • Options However, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for more information 6 Greenbush Financial Group, LLC Disclosure Brochure  Tailors Advice or Services to Individual Needs of Clients Advisor’s services are always provided based on the specific needs of the individual client. Clients are given the ability to impose restrictions on their accounts, including specific investment selections and sectors. However, Advisor will not enter into an investment advisor relationship with a client whose investment objectives may be considered incompatible with Advisor's investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by Advisor The amount of client assets managed by Advisor totaled $498,155,634 as of December 31, 2024, with $297,270,186 managed on a discretionary basis and $200,885,448 managed on a non-discretionary basis. Item 5 – Fees and Compensation In addition to the information provide in Item 4, Advisory Business, this section provides details regarding Advisor’s services along with descriptions of each service’s fees and compensation arrangements. Newsletters and Videos Advisor offers newsletters and videos to clients at no charge. This material can be delivered by e-mail, blog, and U.S. mail and are informational in nature. No specific investment advice or recommendations is given. Prospective clients can also request to receive this information. Financial Planning Services We offer full and modular financial planning services. Full services include, but are not limited to: • Estate planning • Investment planning • Insurance planning • Retirement planning • Education funding You can also elect to focus on a more specific area of concern. However, focusing on one or more specific areas may not take other important issues into consideration that could impact the analysis and recommendations of our investment advisor representatives (“representatives”) and your objectives. Investment advisor representatives (“IAR”) meet with you to gather information and documentation needed to perform an analysis and review. IAR’s rely on the information provided by the Client. Therefore, it is very important that the information provided by the Client be complete and accurate. Greenbush Financial Group services do not include legal or tax advice. Therefore, with the Clients 7 Greenbush Financial Group, LLC Disclosure Brochure  permission, our IAR’s may also gather information and advice from your other professional consultants (i.e., attorney, accountant, etc.). Clients are also encouraged to seek the advice of qualified attorneys and accountants. Greenbush or it’s IAR’s are not responsible for verifying the information supplied by the Client or for verifying the information and advice provided by the Clients other professional consultants. After completing a review and analysis of the information and documents received, the IAR’s may develop recommendations on investment solutions to help the Client meet their financial goals and objectives. These recommendations may be presented to Clients as a written and/or oral plan. Clients have sole responsibility for deciding whether or not to implement our recommendations and advice. If the Client decides to implement the recommendations, then the Client is responsible for taking any actions or implementing any transactions required. You are also free to select any broker/dealer to implement our recommendations. Michael Ruger and Robert Mangold are also independently licensed insurance agents. If you elect to follow the representatives’ recommendations, you could select Michael Ruger, Robert Mangold, or Brad Harkness to implement the transactions. In this case, they could receive fees in their capacity as investment advisor representatives and receive commissions in their capacity as independent insurance agents. If the client enters into an investment advisory agreement with Greenbush Financial Group, the financial planning fees are included in this service and the fees for the ongoing financial planning is included in the asset-based fee disclosure in the asset management agreement. If a client engages GFG just for financial planning and does not maintain investment accounts with GFG, the fees for financial planning services are charged at a maximum of $1,000 per hour but are negotiable depending on the complexity of your financial situation, the actual services provided by GFG and the relationship that GFG has with the Client. The IAR calculates the number of hours needed to complete the requested service, multiply that by the hourly rate, and quote a fee for the requested services. The quoted fee is given prior to any services being provided but the actual total fee may vary based on the actual amount of time that it takes to complete the financial plan. A retainer of one-half of the quoted fee is due at the time the client agreement is signed with the remainder due upon presentation of the plan to the Client and receipt of the GFG billing statement. GFG in its sole discretion has the ability to waive the fee collected at the time the client agreement is signed and collect the full fee for financial planning services once the financial service is delivered to the client. If Clients elect to implement our representatives’ advice using one of the other advisory programs described in this Brochure, we may receive on-going fees. In this event, our representatives may decide to waive or reduce the financial planning fees charged. The representatives consider the amount of time spent on the initial services requested and the anticipated amount of fees earned from the other advisory program(s) you contract for. The representatives always inform you of any reduction or waiver of financial planning fees before they provide any additional advisory services. For fee based financial planning services, our services terminate upon presentation of the requested financial service. However, either party can terminate services at any time by providing written notice to the other party. Termination is effective immediately upon receipt of the notice. If services are terminated before completion, fees are calculated on a prorated basis and you are responsible for paying fees for the time and effort expended by us prior to the effective date of termination. Fees are calculated using the 8 Greenbush Financial Group, LLC Disclosure Brochure  original hourly rate quoted and a prorated refund is issued or a prorated fee is due. We provide you with an invoice detailing the services provided and refund or fees due. Investment Consulting Services You can also request advice on specific areas of concern regarding evaluating a specific account, an investment opportunity or other financial or investment-related matters. Investment consulting services may also include some of the financial planning services previously described. In addition, the services can include advice on non-securities related matters. These consultations may be a one-time event or last multiple sessions. Investment consulting services are only provided to accounts where our representative is not the investment advisor representative of record on the account. Our representatives meet with you to assist in determining your goals and objectives. They assist you by providing direction for actions steps needed in order to accomplish the representatives’ advice and recommendations. The scope of the investment consulting project is specified in the signed client agreement. Services do not include on-going reviews, investment monitoring or implementing any transactions required as a suggested action step. You have sole responsibility for deciding whether or not to implement our recommendations, advice and suggested action steps. If you do decide to follow the suggested action steps, then you are responsible for taking any actions or implementing any transactions required. You are also free to select any broker/dealer to implement our recommendations. Michael Ruger and Robert Mangold are also independently licensed insurance agents. If you elect to follow their recommendations, you could select Michael Ruger, Robert Mangold, or Brad Harkness to implement the transactions. In this case, they will receive fees in their capacity as investment advisor representatives and commissions in their capacity as independent insurance agents. Please see Item 10, Other Financial Activities and Affiliations for additional discussion on these conflicts of interest. Fees for investment consulting services are generally charged as an hourly fee at the maximum rate of $1,000 per hour, although the hourly rate charged is negotiable depending on the complexity of your financial situation, the actual services provided by us and the relationship that we have with you. For multiple event consultations, our representatives calculate the number of hours needed to complete the requested service, multiply that by the hourly rate and quote a fee for the requested services. The quoted fee is given prior to any services being provided but the fee may vary based on the actual hours needed to complete the client engagement. For multiple event consultations, a retainer of one-half of the quoted fee is due at the time the client agreement is signed with the remainder due upon completion of the consultations and receipt of our billing statement. For one-time consultations, the fee is due upon completion of the consultations. In special circumstances, you may request that we provide on-going consultation services lasting for a period defined in the client agreement. In these cases, fees are charged on a fixed basis and generally do not exceed $50,000 per year. Fees are negotiable based on the actual services requested and the complexity of your situation. We provide you with a fee quote prior to any services being provided. On- going consultation fees are charged quarterly in advance. 9 Greenbush Financial Group, LLC Disclosure Brochure  If you elect to implement our representatives’ advice using one of the other advisory programs described in this Brochure, we will receive on-going fees. In this event, our representatives may decide to waive or reduce the investment consulting fees charged. The representatives consider the amount of time spent on the initial services requested and the anticipated amount of fees earned from the other advisory program(s) you contract for. Our representatives always inform you of any reduction or waiver of financial planning fees before they provide any additional advisory services. Services terminate upon completion of the investment consultations. However, either party can terminate services at any time by providing written notice to the other party. Termination is effective immediately upon receipt of the notice. If services are terminated before completion, fees are calculated on a prorated basis and you are responsible for paying fees for the time and effort expended by us prior to the effective date of termination. Fees are calculated using the original hourly rate quoted and a prorated refund is issued or a prorated fee is due. We provide you with an invoice detailing the services provided and refund or fees due. Retirement Plan Investment Advisory Services For a corporate sponsor of a retirement plan, Advisor’s retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services • Investment Policy Statement Preparation. Advisor helps you develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. You have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. • Non-Discretionary Investment Advice. Advisor provides you with general, non-discretionary • • • investment advice regarding assets classes and investment options, consistent with your plan’s investment policy statement. Investment Selection Services. Advisor provides you with recommendations of investment options consistent with ERISA section 404(c). Investment Due Diligence Review. Advisor will conduct quarterly due diligence reviews of the plan’s investment menu. These reports are available to the Plan Sponsor upon request. Investment Monitoring. Advisor assists in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement. Advisor makes recommendations to maintain or remove and replace investment options. • • Default Investment Alternative Advice. Advisor provides you with non-discretionary investment advice to assist you with developing qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the plan or who otherwise fail to make an investment election. You retain sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5). Individualized Participant Advice. Upon request, Advisor provides one-on-one advice to plan participants regarding their individual situations. • Due Diligence Review, Participant Educational Presentations, Participant Enrollment, Participant Advice, and Qualified Plan Development are available at the request of the plan sponsor 10 Greenbush Financial Group, LLC Disclosure Brochure  Advisor acknowledges that in performing the fiduciary consulting services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Advisor acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Advisor to be a fiduciary as a matter of law. However, in providing the fiduciary consulting services, Advisor (a) has no responsibility and does not (i) exercise any discretionary authority or discretionary control respecting management of your retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of your retirement plan, or (iii) have any discretionary authority or discretionary responsibility in administering your retirement plan or interpreting your retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of your retirement plan as defined in ERISA. Fiduciary Management Services Active(k) Managed Port. Advisor sponsors a proprietary employer sponsored retirement plan solution called “Active(k)” and serves as plan consultant and investment advisor to these qualified retirement plans. The Active(k) plan investment menu is a list of individual mutual funds recommended by us (in accordance with our fiduciary consulting services described above) and approved by the plan trustee. The Active(k) investment menu also includes the option to include three model portfolios that are managed by us with the assistance of a third-party sub-advisor. We have the discretionary authority to hire and fire a sub-advisor. The third-party sub-advisor is an unaffiliated registered investment advisor that provides investment recommendations to us about the allocations in Active(k) portfolios. The sub-advisor makes these recommendations pursuant to investment guidelines contained in the agreement between us and the sub-advisor. With respect to the model portfolios managed by us under Active(k) retirement plan solution, Advisor will be acting as an investment manager to the plan, as defined by ERISA Section 3(38), with respect to our fiduciary management services for the managed model portfolios available under Active(k), and Advisor hereby acknowledges that it is a fiduciary with respect to these fiduciary management services. However, we do not serve as 3(38) Fiduciary to the individual mutual fund menu. For plan’s that elect not to include these model portfolios within the plan’s investment menu, we do not serve as an investment manager to the plan, as defined by ERISA Section 3(38), with respect to our fiduciary management services for the managed model portfolios available under Active(k). Non-Fiduciary Services Advisor offers the following non-fiduciary retirement plan consulting services: • Participant Education. Advisor provides education services to plan participants about general investment principles and the investment alternatives available under the plan. Advisor’s assistance in participant investment education is consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations do not take into account the individual circumstances of each participant and individual recommendations are not provided unless 11 Greenbush Financial Group, LLC Disclosure Brochure  otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts. • Participant Enrollment. Advisor assists you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. • Qualified Plan Development. Advisor assists you with establishing a qualified plan by working with you and a selected third party administrator. If you have not already selected a third party administrator, we assist you with reviewing and selecting a third party administrator for the plan. • Due Diligence Review. Upon request, Advisor will provide you with periodic due diligence reviews of your plan’s fees and expenses and your plan’s service providers. • Benchmarking. Upon request, the Advisor will provide you with benchmarking services and provides analysis concerning the operations of the plan. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non- fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact services provided to you are listed and detailed in the Qualified Retirement Plan Agreement. All recommendations of investment options and portfolios are submitted to you for your ultimate approval or rejection. Therefore, it is always your responsibility to accept Advisor’s investment recommendations and then physically make changes to the plan itself In the event a client contracts with Advisor for one-on-one consulting services with plan participants, such services are consultative in nature and do not involve test implementing recommendations in individual participant accounts. It is the responsibility of each participant to implement changes in the participant’s individual accounts. We can also meet with individual participants to discuss their specific investment risk tolerance, investment time frame and investment selections. Retirement plan consulting services are not management services, and Advisor does not serve as administrator or trustee of the plan. Advisor does not act as custodian for any client account or have access to client funds or securities (with the exception of some accounts having written authorization from the client to deduct our fees). In addition, we will only implement transactions in a plan participant’s account with the written or oral consent from the participant. It remains the plan participants responsibility to review all change made to their accounts. For retirement plan consulting services, the retirement plan or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Advisor will disclose to you, to the extent required by ERISA Regulation Section 2550.408b-2(c), any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b- 2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). 12 Greenbush Financial Group, LLC Disclosure Brochure  In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or plan administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Fees for retirement plan investment advisory services can be charged as an annual percentage of total plan assets and range from 0% to 2% or a flat annual fee ranging from $2,000 - $90,000. No commissions or trails are received by ERISA accounts. For the asset-based fee structure, when determining the fee, we consider the total market value of the plan assets, the complexity of the plan (although our provided services remain the same), the number of participants and the geographical location of the plan and its participants. We also consider any special situations, relationships with the client or conflicts of interest, such as prohibitions on fees under the Employee Retirement Income Security Act of 1974 (ERISA). Fees are billed at the end of the quarter and calculated on the fair market value of the plan assets at the end of that quarter. If an account is created at any time other than the beginning of a quarter, the fee is prorated based on the number of days that services are actually provided in the quarter. For our flat fee structure, when determining the fee, we consider the total market value of the plan assets, the complexity of the plan (although our provided services remain the same), the number of participants and the geographical location of the plan and its participants. We also consider any special situations, relationships with the client or conflicts of interest, such as prohibitions on fees under the Employee Retirement Income Security Act of 1974 (ERISA). The billing period will vary based on the retirement platform that hosts each plan. Most of our retirement plans are billed at the end of the quarter. For quarterly billing cycles, our fee is expressed as either an annual asset-based fee or annual fixed dollar amount and we assess 25% of that annual fee at the end of each calendar quarter in arrears. For monthly billing cycles, our fee is expressed as either an annual asset-based fee or annual fixed dollar amount and we assess 1/12 of that annual fee at the end of each month. If an account is opened or closed at any time other than the beginning date of the billing cycle, the fee is prorated based on the number of days that services are provided during that billing cycle. The decision of whether to assess the advisory fees as an asset-based fee or flat fee is at the full discretion of the Advisor. If the model portfolios are selected by the plan sponsored to be offered as an investment option on the Active(k) platform, the sub-advisor receives a portion of the advisory fee charged by us for the services provided by the sub-advisor. While the fee that we pay each sub-advisor varies, it is usually 35% of the total fee charged by us and received from the plan/plan sponsor. We deduct expenses from the total fee received and pay the sub-advisor its net portion as described in the sub-advisor agreement. The plan 13 Greenbush Financial Group, LLC Disclosure Brochure  trustee has a copy of the sub-advisor agreement and disclosure about the sub-advisor’s compensation is included in the agreement between us and the plan trustee. The Advisor has the ability to recommend multiple participant directed retirement plan platforms to the clients which represents a conflict of interest. The Advisors net compensation will vary based on the platform selected or recommended to the client which creates a conflict of interest. The Advisor in its full discretion has the ability to offset fees charged by the retirement plan platform, IRS, regulatory bodies or retirement plan services providers on behalf of the clients. This also represents a conflict of interest because any fee offset reduces the revenue received by the Advisor. No commissions or trails are be received in ERISA accounts. The plan trustee decides whether to be billed directly for our services or to have our fees deducted from the plan assets. If the trustee elects to be billed directly, we send a billing invoice to the plan sponsor within 15 days of the end of the quarter. Fees are due upon when the sponsor receives the billing invoice. If we do not receive payment within 45 days of the billing invoice date, the plan sponsor authorizes us to automatically deduct fees from plan account assets. If the plan sponsor elects to have fees automatically deducted from the plan account, the sponsor provides written authorization to the plan custodian and/or third-party administrator for the advisory fees to be deducted from the plan account and paid directly to us. If fees are deducted from plan assets, we do not send a billing notice to the trustees. We, the plan trustee, the third party administrator and/or record keeper all receive executed copies of the fee authorization documents at the onset of the plan. At least quarterly, the plan custodian sends an account statement that includes the advisory fees deducted from the plan account. Retirement plan services automatically renew on the one year anniversary of the original client agreement being signed. Services are renewed on the same terms and conditions as contained in the original agreement. However, if there is a change in services or fees, a new client agreement is required. Either party can terminate the agreement by providing written notice to the other party. Termination is effective 30 days after receipt of the notice. If services are terminated within five business days of executing the agreement for services, the agreement is terminated without penalty. In this case, termination is effective immediately and there is no prorated fee charged for time spent during the first five business days. If services are terminated after the initial five business day period, fees are prorated based on the number of days that services are provided during the quarter. If advisory fees are billed directly, we provide a billing notice to the trustee and/or sponsor detailing the prorated charges. If advisory fees are deducted from plan assets, no billing notice is sent. Asset Management Services We offer investment supervisory services that include giving continuous investment advice and/or making investments for the client based on the individual needs, goals and objectives of a client. We offer a customized and individualized investment program providing clients management services regarding allocations among various asset classes, ongoing assistance with evaluating and selecting investments, adjusting and rebalancing portfolios. We provide these services on a discretionary basis only. This means that we make all decisions to buy, sell or hold securities, cash or other investments in the 14 Greenbush Financial Group, LLC Disclosure Brochure  managed account in our sole discretion without consulting with the client before making any transactions. Clients must provide us with written authorization to exercise this discretionary authority. See Item 16, Investment Discretion, for additional discussion on discretionary and non-discretionary authority. Clients contracting for our asset management services must establish an account at Fidelity Investments (Fidelity), a qualified custodian. We do not maintain custody of client assets. Our representatives assist clients in establishing an account at Fidelity. There is a $250,000 minimum requirement to establish and maintain an advisory account but exceptions can be granted at the discretion of the Advisor to allow advisory accounts below the $250,000 threshold. For clients that utilize GFG for asset management services, financial planning services both initial and ongoing are included in the asset-based fee structure. Fees for management services are charged as an annual percentage of assets under management and range from .1% to 1.5%. When determining the fee, we consider the aggregate dollar value of the assets managed, the complexity of the assets held in the managed account, the actual services provided, any other advisory services the client has or will be contracting for, and our relationship with the client. We disclose the exact percentage based fee to clients prior to any services being provided. Retirement Plan Participants that choose to rollover there 401(k) assets into an individual retirement account and sign an asset management agreement directly with the Advisor will be subject to the management fee referenced above which may be higher than the fee charged on the same assets while they were enrolled in the retirement plan. The fees will be based on the previous quarter’s ending value of assets under management as determined by the qualified custodian. If an account is created at any time other than the beginning of a quarter, the fee is prorated based on asset flows and the number of days that services are actually provided in the quarter. Billing is calculated utilizing a third party software provider and is calculated based upon the total account balance as of the last day of the billing period. On occasion the custodian may credit your account with dividends or interest shortly after the end of the quarter, these amounts will be included in the account totals for the next billing period. In this case, the prorated fee is billed in arrears along with the first full quarter’s fees that are billed in advance. Fees are deducted from a client’s account and the client must provide Fidelity with written authorization to have fees deducted from the account and paid directly to us. While we send a billing notice to the account custodian, we do not send a billing notice to clients. Clients should review account statements received from their account custodian and verify that appropriate advisory fees are being deducted. Asset management services automatically renew on the one year anniversary of the original client agreement being signed. Services are renewed on the same terms and conditions as contained in the original agreement. However, if there is a change in services or fees, a new client agreement is required. Either party can terminate the agreement for services by providing written notice to the other party. Termination is effective upon receipt of the notice. If services are terminated within five business days of executing the agreement for services, the agreement will be terminated without penalty and no fees will be charged for services provided in the first five business days. If services are terminated after the initial 15 Greenbush Financial Group, LLC Disclosure Brochure  five business day period, fees will be prorated based on the number of days that services were provided prior to receipt of the termination notice. If services are terminated during the first partial billing period, Advisor will bill the client for the number of days that services were provided. If services are terminated at any time after completion of the first partial billing period, fees are prorated based on the number of days that services were provided and we refund any prepaid, unearned fees. This prorated refund occurs as a credit back to the client’s account and is reflected on the account statement. Clients should be aware that management services billed as a percentage of assets managed could still lead to conflicts of interest between Advisor and clients. For example, conflicts could arise relating to financial decisions in life such as incurring or paying down debt; gifting to charities or individuals; purchasing a home, car or other non-investment assets; purchasing a lifetime immediate annuity; travel or other expenditures; investments in private equity programs (private real estate ventures, closely held businesses, etc.); and placing funds in non-managed cash reserve accounts. Our goal is that recommendations are always made with the best interests of its clients in mind, disregarding any impact the decision has on us. To help fulfill this goal, we have adopted internal policies to help manage these conflicts. For example, if the client has a mortgage or other debt, we consider this a negative allocation to fixed income and analyze the after-tax benefit of deductible mortgage debt versus an anticipated long-term return on fixed income investments. We also consider whether state income tax (if any) could impact to pay off debt rather than invest funds in a taxable account. Each client’s circumstances (i.e., liquidity issues, risk tolerances, etc.) are considered and our representatives are required to document their analyses and client’s decision in the file. Because each client’s and conflicts are unique, each situation is handled on a case-by-case basis. Performance Based Fees Under certain situations, Advisor charges performance-based fees to investors who meet the definition of “qualified client”. Under these arrangements, you will be charged a fee based on the assets under management within your account and in accordance with the fee schedule and parameters detailed below. As a result, Advisor has developed two basic fee schedules. The first fee schedule illustrated above is applied to non-qualified clients and the second fee schedule is applied to qualified clients. To be considered a qualified client, the client must have at least $1.1 million under management with our firm immediately after entering into an advisory contract or we must have reasonable belief that the client has a net worth of more than $2.2 million at the time the investment advisory agreement is executed. In addition to an annual fee based on the value of the client's assets under management, we may be compensated for our asset management services through a performance-based fee. Under this arrangement, the client will be charged a fee contingent upon the performance within the client's account(s). The performance-based fee will be tied to the capital appreciation (i.e. capital gains) within the account as evaluated at the end of each calendar quarter. In order for our firm to receive a performance-based fee, we must achieve capital appreciation within the account. The asset-based fee will be payable quarterly, in arrears. The performance-based fee over and above the asset-based fee will be payable annual, in arrears. The performance-based fee charged will be separately negotiated with each qualified client based on the complexity of client’s situation, number of 16 Greenbush Financial Group, LLC Disclosure Brochure  accounts managed, total assets under management and other factors specific to the client. The exact fee arrangements for each client will be specified in the client’s advisory services agreement with Advisor. Additional Compensation Fidelity could charge a separate fee for maintaining custody of managed client accounts. In addition, Fidelity can charge transaction or other service fees directly to the client. Advisor does not receive any portion of the fees charged by the qualified custodian. In addition, the client will incur certain charges imposed by third parties other than Advisor in connection with investments made through the client’s account, including, but not limited to, expense ratios and IAR and qualified retirement plan fees. These fees charged by third-parties include but are not limited to, the following fees assessed by Fidelity: custody fees, transaction fees, services fees, retirement plan fees, and postage and handling fees. Fidelity may also charge other fees not listed above. There may be other third parties that charge fees to the client’s account in addition to Fidelity. Advisor only recommends mutual funds that do not charge sales fees (no load funds), but clients should be aware that they may have other investments in their portfolios that could incur the fees and expenses previously discussed. Mutual funds can charge a 12(b)-1 fee, which is named after a section of the Investment Company Act of 1940. It is an annual marketing or distribution fee and considered an operational or administrative expense. The fee is included as a part of the fund’s total expense ratio and is paid from fund assets. Therefore, the fee comes indirectly from a client’s account. Every mutual fund prospectus includes a description of the funds fees and expenses. Advisor’s management fees are separate and distinct from the fees and expenses charged by the custodian, fund, or other third party. In their capacity as registered representatives, Advisor’s representatives may also be independently licensed as insurance agents and sell insurance products to any client. The representatives can earn commissions when selling insurance products in these separate capacities. This is a conflict of interest, since any commission earned could be in addition to advisory fees earned in their capacity as an investment advisor representative. As independently licensed insurance agents, Michael Ruger and Robert Mangold may enter into formal agreement with various third party insurance brokerage firms and refers insurance business to them. Although Michael Ruger and Robert Mangold are not the agents on these policies, because of these referrals he receives a share of the commissions generated by the third party insurance firm. This is a conflict because he may recommend the purchase of an insurance product resulting in a commission being paid to him in addition to advisory fees being paid to Advisor. David Wojeski is an owner of Advisor and is the president of a Wojeski & Company, CPAs, PC, a public accounting firm. If any of his accounting clients need assistance with advisory matters, he refers them to GFG. Mr. Wojeski does not provide advisory services to Advisor’s clients and does not receive advisory fees. However, this is still a conflict of interest due to his ownership interest in Advisor. While Mr. Wojeski is not directly compensated for the accounting client referrals, as an owner of Advisor he receives profits earned by the company. Advisor may also refer advisory clients needing assistance with 17 Greenbush Financial Group, LLC Disclosure Brochure  accounting matters to Mr. Wojeski and his firm. Clients are not obligated to use Mr. Wojeski or his firm for accounting services, and no referral fees are paid to Advisor if they elect to do so. Please refer to Item 14 – Client Referrals and Other Compensation for a more detailed explanation of the relationship between Advisor and Wojeski & Company, CPAs, PC. From time to time, Advisor may receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing such as advertising, publishing and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will be made. Advisor and its representatives endeavor at all times to put the interest of the clients first as a part of their fiduciary duty. However, clients should be aware that receiving additional compensation through nominal sales awards, expense reimbursements, etc. creates a conflict of interest that may impact the judgment of the representatives when making advisory recommendations. Comparable Services Advisor believes its fees for advisory services are reasonable with respect to the services provided and the fees charged by other investment advisors offering similar services. However, lower fees for comparable services may be available from other sources. Item 6 – Performance-Based Fees and Side-By-Side Management As described above in Item 5 – Fees and Compensation, Advisor charges certain clients a performance fee, which is based upon a share of capital gains or capital appreciation of the assets of such client. We also provide services and are compensated on asset-based fees, which are based on the total amount of assets owned by the client. There are conflicts of interest Advisor faces by managing performance-based accounts at the same time as managing asset based, non-performance based accounts. For example, the nature of a performance fee poses an opportunity for Advisor to earn more compensation than under a stand-alone asset-based fee. Consequently, Advisor may favor performance fee accounts over those accounts where we receive only an asset-based fee. One way Advisor may favor performance fee accounts is that we may devote more time and attention to performance fee accounts than to accounts under an asset based fee arrangement. There are other conflicts associated with performance fees that are not as common under an asset-based fee arrangement. The nature of performance fees can encourage unnecessary speculation with client assets in order to earn or increase the amount of the fee. The result of riskier investments can have a positive effect in that results could equal higher returns when compared to an asset-based fee account. On the other hand, riskier investments historically have a higher chance of losing value. Also, since in a performance fee arrangement an adviser is compensated based on capital gains or capital appreciation, 18 Greenbush Financial Group, LLC Disclosure Brochure  these arrangements could give an investment adviser an incentive to time transactions in a client's account on the basis of fee considerations rather than on what is in the best interest of the client. Performance fees can potentially cause an investment adviser to engage in transactions or strategies which will increase the amount of the performance fees, but which may not increase the overall performance of the client's account. For example, an account may lose value during a year and no performance fee will be earned. In the following year, Advisor may receive a performance fee for simply recouping losses from the previous year. Advisor controls for this conflict of interest by using the high- water mark fee calculation method described in the preceding paragraph. A performance fee may also encourage Advisor to make riskier and more speculative investments. Advisor does not represent that the amount of the performance fees or the manner of calculating the performance fees is consistent with other performance related fees charged by other investment advisers under the same or similar circumstances. The performance fees charged by Advisor may be higher than the performance fees charged by other investment advisers for the same or similar services. Advisor has established policies and procedures to address the various conflicts of interest associated with charging a performance fee: • Advisor devotes equal time to the management of performance fee accounts and asset-based fee accounts. • Only clients that are able to assume additional risk are solicited to engage in a performance fee arrangement. Advisor provides such clients full disclosure of the additional risks associated with a performance fee arrangement. • Client accounts eligible to be charged a performance-based fee must reach a pre-determined and agreed upon high-water mark before the performance based fee is charged. Performance based fee arrangements of Advisor will comply with Section 205(e) of the Investment Advisers Act of 1940. According to Section 205(e) (see Rule 205-3 thereunder), only natural individual clients meeting the SEC's definition of "qualified clients" may enter into agreements providing for performance-based compensation to Advisor. A natural person or company must meet the following conditions to be considered a qualified client: • Have at least $1,100,000 under management with Advisor at the time the client enters into an agreement with Greenbush Financial; or • Provide documentation to Advisors that Advisor will reasonably believe the client has either a net worth of $2,200,000 or is a qualified purchaser under Section 2(a)(51)(A) of the Investment Company Act. Item 7 – Types of Clients Advisor generally provides investment advice to the following types of clients: Individuals • • Trusts, corporations, estates, or charitable organizations • 401(k) plans, pension plans, and profit sharing plans 19 Greenbush Financial Group, LLC Disclosure Brochure  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Advisor uses fundamental and technical analysis when considering investment strategies and recommendations for clients. In simple terms, fundamental analysis involves analyzing the characteristics of a company to estimate its value while technical analysis studies past market data looking for price trends and movements. Fundamental Fundamental analysis is a method of evaluating a company or security by attempting to measure its intrinsic value. In other words, fundamental analysts try to determine its true value by looking at all aspects of the business, including both tangible factors (e.g., machinery, buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves examining related economic factors (e.g., overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity and price-to-equity ratios). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. Technical This method of evaluating securities analyzes statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Primary Method of Analysis or Strategy There are risks involved in fundamental and technical analysis methods. Fundamental analysis takes a long-term approach to analyzing markets, often looking at data over a number of years. The data reviewed is released over years (e.g., quarterly financial statements). Technical analysis uses a shorter timeframe—often weeks or days. The price and volume data reviewed is released on a daily basis. Therefore, fundamental analysis could mean a gain is not realized until a security’s market price rises to its “correct” value over the long run--perhaps several years. As a general statement, technical analysis is used for a trade while fundamental analysis is used for an investment. It could also be said that traders buy assets they believe they can sell to someone else at a greater price while investors buy assets they believe will increase in value. The frequency of trading 20 Greenbush Financial Group, LLC Disclosure Brochure  securities using technical analysis could have both a positive or negative impact and could also lead to increased brokerage and transaction costs, thus lowering performance. The less frequent trading practices of fundamental analysis could also have a positive or negative impact on a client’s portfolio value, but likely has reduced brokerage and transaction costs. Investment Strategies The investment strategies we use when implementing investment advice to clients include: • Long term purchases (investments held at least a year) • Short term purchases (investments sold within a year) • Trading (investments sold within 30 days) • Short sales (borrowing securities in anticipation of a price decline and returning an equal number of securities at some future time) • Option writing (including covered options, uncovered options or spreading strategies) (Note: options are contracts giving the purchaser the right to buy or sell a security, such as stocks, at a fixed price within a specific period of time) Risk of Loss Investing in securities involves a risk of loss that you should be prepared to bear, including loss of your original principal. However, you should be aware that past performance of any security is not necessarily indicative of future results. Therefore, you should not assume that future performance of any specific investment or investment strategy will be profitable. We do not provide any representation or guarantee that your goals will be achieved. Further, depending on the different types of investments, there may be varying degrees of risk: • Market Risk. Either the market as a whole, or the value of an individual company, goes down, resulting in a decrease in the value of client investments. This is referred to as systemic risk. • Equity (Stock) Market Risk. Common stocks are susceptible to fluctuations and to volatile increases/decreases in value as their issuers’ confidence in or perceptions of the market change. Investors holding common stock (or common stock equivalents) of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer. • Company Risk. There is always a certain level of company or industry specific risk when investing in stock positions. This is referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that a company may perform poorly or that its value may be reduced based on factors specific to it or its industry (e.g., employee strike, unfavorable media attention). • Options Risk. Options on securities may be subject to greater fluctuations in value than investing in the underlying securities. Purchasing and writing put or call options are highly specialized activities and involve greater than ordinary investment risk. Puts and calls are the right to sell or buy a specified amount of an underlying asset at a set price within a set time. 21 Greenbush Financial Group, LLC Disclosure Brochure  • Fixed Income Risk. Investing in bonds involves the risk that the issuer will default on the bond and be unable to make payments. In addition, individuals depending on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • ETF and Mutual Fund Risk. ETF and mutual fund investments bear additional expenses based on a pro-rata share of operating expenses, including potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities held by the ETF or mutual fund. Clients also incur brokerage costs when purchasing ETFs. • Management Risk. Your investments also vary with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our strategies do not produce the expected returns, the value of your investments will decrease. When you purchase securities, you may pay for the securities in full or borrow part of the purchase price from your account custodian or clearing firm. If you borrow part of the purchase price then you are engaging in margin transactions and there is risk involved with this. The securities held in your margin account are collateral for the custodian or clearing firm that loaned you the money. If those securities decline in value, then the value of the collateral supporting your loan also declines. As a result, the brokerage firm is required to take action in order to maintain the necessary level of equity in your account. The brokerage firm may issue a margin call and/or sell other assets in your account. It is important that you fully understand the risks involved in trading securities on margin, including: • You can lose more funds than you deposit in your margin account • The account custodian or clearing firm can force the sale of securities or other assets in your account • The account custodian or clearing firm can sell your securities or other assets without contacting you • You are not entitled to choose which securities or other assets in your margin account may be liquidated or sold to meet a margin call • The account custodian or clearing firm may move securities held in your cash account to your margin account and pledge the transferred securities • The account custodian or clearing firm can increase its “house” maintenance margin requirements at any time and are not required to provide you advance written notice • You are not entitled to an extension of time on a margin call Primarily Recommend One Type of Security We do not primarily recommend one type of security to clients. Instead, we recommend any product that may by itself or in a diversified portfolio of investments be suitable for each client relative to that client’s specific circumstances and needs. 22 Greenbush Financial Group, LLC Disclosure Brochure  Item 9 – Disciplinary Information Advisor has no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Advisor’s business or the integrity of its management. Therefore, this item is not applicable to Advisor’s brochure. Item 10 – Other Financial Industry Activities and Affiliations Advisor does not have a related person that is: • A broker/dealer, municipal securities dealer or government securities dealer or broker • An investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) • A investment adviser or financial planner • A futures commission merchant, commodity pool operator or commodity trading advisor • A banking or thrift institution • A lawyer or law firm • A pension consultant • A real estate broker or dealer • A sponsor or syndicator of limited partnerships. We are an independent registered investment registered advisor and only provide investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. However, while we do not sell products or services other than investment advice, our representatives may sell other products or provide services outside of their role as investment advisor representatives with us. Insurance Sales Some of our representatives are also independently licensed to sell insurance products through various insurance companies. When acting in this capacity, they will receive fees or commissions for selling these products. Clients are under no obligation to direct insurance transactions to insurance companies with which our representatives may be licensed. Suitable insurance and investment products may be available from other companies. Michael Ruger and Robert Mangold, two of our representatives and licensed insurance agents, may enter into formal arrangements with various third party insurance brokerage firms and refers insurance business to these firms. While Michael Ruger and Robert Mangold are not the agents of record on these policies, they can receive a share of the commissions generated by the third party insurance firms as a result of their referrals. 23 Greenbush Financial Group, LLC Disclosure Brochure  Accounting Services David Wojeski is an owner of Advisor and is also the President of Wojeski & Company, CPAs, PC, a public accounting firm. If any of his accounting clients need assistance with advisory matters, he refers them to Advisor. Mr. Wojeski does not provide advisory services to Advisor’s clients and does not receive advisory fees. This is a conflict due to Mr. Wojeski’s ownership in Advisor. While he is not directly compensated for accounting client referrals, as one of Advisor’s owners he receives profits earned by the company. Advisor may also refer advisory clients needing assistance with accounting matters to Mr. Wojeski and his firm. Clients are not obligated to use Mr. Wojeski or his firm for accounting services, and no referral fees are paid to Advisor if they elect to do so. Please refer to Item 14 – Client Referrals and Other Compensation for a more detailed explanation of the relationship between Advisor and Wojeski & Company, CPAs, PC Other Business Activity of Company Principal Michale Ruger is also partial owner of Bark and Bliss Grooming, LLC. As partial owner his duties will focus on the financial aspect of the business, He will spend less than 5% of his time on this activity. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary According to the Investment Advisers Act of 1940, an investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts. In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each of its clients. Advisor and its representatives have a fiduciary duty to all clients. Advisor has established a Code of Ethics which all associated persons must read. They must then execute an acknowledgment stating that they understand and agree to comply with Advisor’s Code of Ethics. The fiduciary duty of Advisor and its associated persons to clients is considered the core underlying principle for Advisor’s Code of Ethics and represents the expected basis for all associated persons’ dealings with clients. Advisor has the responsibility to make sure that the interests of clients are placed ahead of it or its associated persons’ own investment interests. All associated persons will conduct business in an honest, ethical and fair manner. All associated persons will comply with all federal and state securities laws at all times. Full disclosure of all material facts and conflicts of interest will be provided to clients prior to services being conducted. All associated persons have a responsibility to avoid circumstances that might negatively affect or appear to affect the associated persons’ duty of complete loyalty to their clients. This section is only intended to provide current clients and potential clients with a description of Advisor’s Code of Ethics. If current clients or potential clients wish to review Advisor’s Code of Ethics in its entirety, a copy may be requested from any of Advisor’s associated persons and a copy will be provided promptly. In addition to abiding by Advisor’s Code of Ethics, Advisor’s representatives also abide by the Code of Ethics and Responsibility of the Certified Financial Planner™ Board of Standards, Inc. The Code of Ethics and Responsibility requires CFP® designees to not only comply with all applicable laws and regulations 24 Greenbush Financial Group, LLC Disclosure Brochure  but to also act in an ethical and professional responsible manner in all professional services and activities. The principles guiding CFP® designees are: • Integrity • Objectivity • Competence (in providing services and maintaining knowledge and skills to do so) • Fairness (to clients, principals, partners and employers and disclosing any conflicts of interest in providing services) • Confidentiality (keeping all client information confidential without the specific client consent unless in response to legal process or in defense of charges of wrongdoing or civil dispute) • Professionalism • Diligence Clients can obtain a copy of the Code of Ethics and Responsibility Code by requesting a copy from one of Advisor’s representatives. Participation in Client Transactions and Personal Trading Advisor or its representatives may buy or sell securities or have an interest or position in a security for their personal account which they also recommend to clients. Advisor is and will continue to be in compliance with The Insider Trading and Securities Fraud Enforcement Act of 1988. As these situations may represent a conflict of interest, it is a policy of Advisor that no associated persons will prefer his or her own interest to that of the advisory client. No person employed by Advisor may purchase or sell any security prior to a transaction or transactions being implemented for an advisory account. Associated persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of his/her employment unless the information is also available to the investing public upon reasonable inquiry. In order to help minimize the conflict of interest, securities recommended by Advisor are widely held and publicly traded. Item 12 – Brokerage Practices Brokerage Recommendations If you elect to utilize our management services you are required to establish a brokerage account at Fidelity Investments (Fidelity). Fidelity provides GFG with access to their institutional trading and custody services, which are typically not available to retail investors. The services from Fidelity include brokerage, custody, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Fidelity also makes available to GFG other products and services that we benefit from but may not benefit your accounts. Some of these other products and services assist us in managing and administering client accounts. These include software and other technology that: • Provide access to client account data (such as trade confirmation and account statements) • Facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts) • Provide research, pricing information and other market data 25 Greenbush Financial Group, LLC Disclosure Brochure  • Facilitate payment of our fees from client accounts • Assist with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of our accounts. Fidelity also makes available other services intended to help us manage and further develop our business. These services may include: Information technology • Consulting, publications and conferences on practice management • • Business succession • Regulatory compliance • Marketing. In addition, Fidelity may make available, arrange and/or pay for these types of services rendered to GFG by independent third-parties providing these services to us. As a fiduciary, we endeavor to act in your best interest. Our requirement that you maintain your assets in accounts at Fidelity may be based in part on the benefit to us of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity. This creates a conflict of interest. You are under no obligation to act on my recommendations. You may select a broker/dealer or account custodian other than Fidelity, although in this case I cannot assist you with asset management services. Cash Sweep Program Fidelity has various Cash Sweep Programs for idle cash deposited to our client investment accounts. These various sweep programs have varying levels of interest that are credited to client accounts. GFG does not have control over which cash sweep program is assigned to each client account. Fidelity assigns the Cash Sweep program based on type of account, retirement account vs non-retirement account, and the size of the account. Clients should be aware that they may not have access to the cash sweep account paying the highest interest rate at Fidelity. Best Execution While we do not allow directed brokerage, we must still use reasonable diligence to make certain that best execution is obtained for clients when implementing any transactions. Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions surrounding the transaction execution is in the best interests of clients. When considering best execution, our representatives look at a number of factors besides prices and rates including, but not limited to: • Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with existing systems of the advisor, ease of monitoring investments) • Products and services offered (e.g., investment programs, back office services, technology, regulatory compliance assistance, research and analytic services) • Financial strength, stability and responsibility • Reputation and integrity 26 Greenbush Financial Group, LLC Disclosure Brochure  • Ability to maintain confidentiality We exercise reasonable due diligence to make certain that best execution is obtained for all clients when implementing any transaction by considering the back office services, technology and pricing of services offered. We perform periodic reviews to determine that the relationship with Fidelity is in the best interests of clients. GFG only executes trade orders through Fidelity for individual investment advisory clients. Best execution is evaluated by running reports via the Fidelity portal. Since GFG only places trade orders through a single qualified custodian, clients should be aware that the use of a single broker and custodian may not always provide clients with the benefit of receiving best execution. Soft Dollar Benefits GFG does not have a soft dollar agreement with a broker-dealer or a third-party. Handling of Trade Errors We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy 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 we absorb any loss resulting from the trade error if we caused the error. If the error is caused by the qualified custodian, the qualified custodian is responsible for covering all trade error costs. If an net investment gain results from the correcting trade, the gain is delivered to a qualified charity by Fidelity. It is not permissible for all clients to retain the gain. We never benefit or profit from trade errors. Block Trading We may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading, or block trading and may be used when we believe such action may prove advantageous to clients. If and when we aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Under this procedure, transactions are averaged as to price and are allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. If and when we determine to aggregate client orders for the purchase or sale of securities, including securities in which our associated persons may invest, we do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated persons receive any additional compensation or remuneration as a result of blocking trades. 27 Greenbush Financial Group, LLC Disclosure Brochure  Item 13 – Review of Accounts Account Reviews Fee based financial planning and investment consulting accounts terminate upon presentation of the plan or completion of the consultation. However, Advisor recommends that clients have their financial situation reviewed and updated at least yearly. If clients wish to undertake a review and update, a new client agreement is required and additional fees may be charged. Clients contracting for asset management services have their accounts reviewed at least quarterly. For retirement plan advisory accounts, reviews are conducted on a plan level at least quarterly. The individual investments making up a plan’s investment menu are monitored on a daily, weekly and/or monthly basis for both fundamental and technical merit. See Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, for additional discussion on fundamental and technical analysis considerations. Reviews are conducted by Michael Ruger, Robert Mangold, and Brad Harkness. Although the calendar is the main triggering factor, account reviews are also conducted due to: • Client request • Change in client circumstances, account holdings or investment objectives • Unusual economic conditions • Changes in geopolitical environment. Account reviews include asset allocation and security specific considerations. Absent specific client instruction, accounts are reviewed relative to asset allocation and security specific considerations, to be sure portfolio holdings are accurate, investment products are still suitable and account performance continues to work toward the client’s goals and objectives. Account Reports Financial planning and investment consulting clients do not receive any account reports other than those included as a part of the services originally contracted for. Asset management clients receive confirmation statements as trades occur in the accounts. In addition, clients receive statements from the account custodian at least quarterly. Clients contracting for retirement plan investment advisory services receive statements at least quarterly from the plan’s record keeper and/or custodian. Advisor does not provide any additional reports or statements. 28 Greenbush Financial Group, LLC Disclosure Brochure  Item 14 – Client Referrals and Other Compensation Client Referrals Advisor may enter into agreements with unaffiliated promoters (Referring Parties) to refer clients to Advisor. If a client is referred to Advisor by a promoter, the promoter provides the client with a copy of Advisor’s Disclosure Brochure as required by the Investment Advisers Act of 1940. The client also receives a copy of the promoter disclosure statement containing the information set forth in the Investment Advisers Act of 1940. If a referred client enters into an investment advisory agreement with Advisor, a referral fee is paid to the promoter that can be either a one-time flat fee or a recurring fee based on a percentage of the annual advisory fee collected by Advisor. The flat fee does not exceed $5,000 per year. The percentage fee does not exceed 50% of the advisory fees paid annually by the referred client to Advisor (net revenue less expenses). The referral relationship does not result in clients being charged any fees over and above the normal advisory fees charged for the advisory services provided. The referral agreements between Advisor and the promoters are in compliance with regulations as set out in the Rules under the Investment Advisers Act of 1940. In addition, the promoters are qualified within the applicable New York regulations. Accounting Firm Relationship Please see Item 10, Other Financial Industry Activities and Affiliations, for additional discussion about our affiliation with the accounting firm of Wojeski & Company, CPAs, PC. Clients of Wojeski & Company, CPAs, PC may be referred to us for advisory services and we may refer advisory clients to Wojeski & Company, CPAs, PC for accounting services. You are under no obligation to use our services or the services of Wojeski & Company, CPAs, PC. Because of this affiliation, both Wojeski & Company, CPAs, PC and we have an incentive to recommend each other to clients before recommending other accounting and financial firms. This creates a conflict of interest. If an advisory client decides to utilize the services of Wojeski and Company for their tax preparation needs, the Advisor initiated a program in which the firm may pay Wojeski and Company for all or a portion of the tax preparation fees for advisory clients with assets under management of over $250,000. The decision to pay the tax preparation fees on behalf of qualified clients will not be available to all clients and will be solely at the discretion of the Advisor. This payment program will not be available for clients who utilize other CPA Firms for their tax preparation services. Other Compensation and Non-Client Economic Benefit For additional discussion on other compensation received by Advisor, its owners or its representatives please refer to Additional Compensation under Item 5, Fees and Compensation and Item 10, Other Financial Industry Activities and Affiliations, and Item 12, Brokerage Practices, for discussion about the services and products Advisor may receive from Fidelity. 29 Greenbush Financial Group, LLC Disclosure Brochure  Item 15 – Custody Custody, as it applies to investment advisors, has been defined as having access or control over client funds and/or securities, but does not include the ability to execute transactions in client accounts. Custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody for purposes of the Investment Advisers Act of 1940 and must ensure proper procedures are implemented. Please note that regulators have deemed the authorization to trade in client accounts to not be custody. However, we are deemed to have custody of client funds and securities whenever we are given the authority to have fees deducted directly from client accounts. Our procedures do not result in our maintaining custody of client funds and securities. For accounts where we are deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the creation of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from us. When clients have questions about their account statements, they should contact us or the qualified custodian preparing the statement. Item 16 – Investment Discretion In addition to having trading authority on your accounts, asset management services are provided on a discretionary basis only. This means we make all decisions to buy, sell or hold securities, cash or other investments in the managed account in our sole discretion without consulting with you before implementing any transactions. You must provide us with written authorization to exercise this discretionary authority. When discretionary authority is granted, it is limited. We do not have access to your funds and/or securities with the exception of having advisory fees deducted from your account and paid to us by the account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the account custodian. You have the ability to impose reasonable restrictions on the types of investments that may be purchased in an account. You may also place reasonable limitations on the discretionary power granted to us so long as the limitations are specifically set forth or included as an attachment to the client agreement. Investment discretion also applies to the Managed Portfolios within the Active(k) solution. Advisor has discretionary authority over the Lifestyle Portfolios. 30 Greenbush Financial Group, LLC Disclosure Brochure  Item 17 – Voting Client Securities We do not vote proxies or accept proxy materials on your behalf. All proxy materials are sent directly to you from the product sponsor, custodian or transfer agent. You have the ultimate responsibility for making all proxy-voting decisions. Item 18 – Financial Information This item is not applicable to our brochure. We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for its most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. Class Action Lawsuits Clients retain the right under applicable securities laws to initiate individually a lawsuit or join a class- action lawsuit against the issuer of a security that was held, purchased or sold by or for clients. Advisor does not initiate such a legal proceeding on behalf of clients and does not provide legal advice to clients regarding potential causes of action against such a security issuer and whether the clients should join a class-action lawsuit. Advisor recommends that clients seek legal counsel prior to making a decision regarding whether to participate in such a class-action lawsuit. Moreover, Advisor's services do not include monitoring or informing clients of any potential or actual class-action lawsuits against the issuers of the securities that were held, purchased or sold by or for clients. Customer Privacy Policy Regulation S-P, Privacy of Consumer Financial Information, requires financial institutions, including Advisor, to provide notice to current clients and prospective clients about their policies and practices concerning the collection and use of customer, non-public information. This privacy policy notice is given to all prospective clients of Advisor upon entering into a contract with Advisor and annually thereafter. Privacy Disclosure Statement. A primary goal of Advisor is to protect the privacy of its clients. Advisor does not sell the personal information of clients to anyone. To conduct regular business, Advisor may collect non-public personal information from clients. This information is provided by clients to Advisor on applications and other forms provided by clients to Advisor as well as transactions with the firm, our affiliates, or others. Advisor may enter into contracts with outside third parties so that Advisor can assist its clients in servicing their accounts. In order to do this, Advisor will disclose personal information to companies that help Advisor process transactions for client accounts (for example, executing client trades at through a broker/dealer). However, Advisor does not share or disclose any non-public customer information except 31 Greenbush Financial Group, LLC Disclosure Brochure  as allowed or required by law. In addition to sharing information in order to provide financial services to clients, Advisor may be required to disclose personal information to cooperate with regulators or law enforcement authorities, to resolve customer disputes, or for risk control. Information Safeguarding. Advisor has implemented strict policies and procedures aimed at protecting the sensitive nature of client information. Advisor restricts access to client information to only those members of Advisor that must provide products and services to clients in order to service client accounts. Advisor has implemented physical, electronic, and procedural safeguards aimed at meeting Advisor’s duty to protect nonpublic client information. If you have any questions concerning Advisor’s customer privacy policy or concerns about your personal information, please feel free to contact Rob Mangold. 32 Greenbush Financial Group, LLC Disclosure Brochure