INVESTMENT CONSULTING GROUP INC

Item 1: Cover Page Brochure Supplement March 12, 2025 Investment Consulting Group, Inc. SEC File No. 801-38594 Donald R. Stanforth President Investment Adviser Representative Individual CRD No. 702426 5117 Jersey Ridge Road, Suite 1 Davenport, Iowa 52807 phone: 563-322-2322 toll free: 1-800-824-8668 email: info@investmentconsultinggroupinc.com info@icginc.co website: www.investmentconsultinggroupinc.com www.icginc.co This brochure supplement provides information about Donald R. Stanforth that supplements the Investment Consulting Group, Inc. brochure. You should have received a copy of that brochure. If you did not receive a brochure or if you have any questions about the contents of this supplement, please contact us at 563-322-2322 or info@investmentconsultinggroupinc.com. Additional information about Donald R. Stanforth is available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 Part 2B of Form ADV: Investment Consulting Group, Inc. Brochure Supplement  Item 2: Educational Background and Business Experience Donald R. Stanforth (b. 1954) is President, Chief Compliance Officer, and an investment adviser representative of Investment Consulting Group, Inc. A. Educational Background Blackhawk Jr. College, A.S. Chemistry 1974 St. Ambrose College, B.A. Business Administration 1976 B. Business Background Investment Consulting Group, Inc. 1990–Present 1979–1990 VP, Branch Office Manager, Shearson Lehman Hutton, Inc. (formerly E.F. Hutton) C. Professional Designations Certified Investment Management Analyst (CIMA) The Certified Investment Management Analyst (CIMA) designation focuses on asset allocation, ethics, due diligence, risk measurement, investment policy and performance measurement. Only individuals who are investment consultants with at least three years of professional experience are eligible to try to obtain this certification, which signifies a high level of consulting expertise. The Investment Management Consultants Association offers the CIMA courses. To receive the CIMA certification, the individual must undergo a background check, pass the qualification examination, complete the education program with a registered education provider, pass the classroom certification examination, and agree to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. In order to maintain the CIMA designation, the individual must complete at least 40 hours of continuing education every two years. Item 3: Disciplinary Information Mr. Stanforth does not have any disciplinary action to report. Public information concerning his registration as an investment advisor representative may be found by accessing the SEC's public disclosure site at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Stanforth is not involved in any other business activities. Page 2 Part 2B of Form ADV: Investment Consulting Group, Inc. Brochure Supplement  Item 5: Additional Compensation Mr. Stanforth does not receive any additional compensation outside of Investment Consulting Group, Inc. Item 6: Supervision Supervision of Mr. Stanforth is performed by himself in his capacity as Chief Compliance Officer, through reviews of internal transaction and security holdings reports, electronic and physical correspondence, and other internal reports as mandated by the firm and its regulatory authorities. Page 3 Part 2B of Form ADV: Investment Consulting Group, Inc. Brochure Supplement 

Item 1: Cover Page Brochure Supplement March 12, 2025 Investment Consulting Group, Inc. SEC File No. 801-38594 Ross C. Stanforth Vice President Investment Adviser Representative Individual CRD No. 5119305 5117 Jersey Ridge Road, Suite 1 Davenport, Iowa 52807 phone: 563-322-2322 toll free: 1-800-824-8668 email: info@investmentconsultinggroupinc.com info@icginc.co website: www.investmentconsultinggroupinc.com www.icginc.co This brochure supplement provides information about Ross C. Stanforth that supplements the Investment Consulting Group, Inc. brochure. You should have received a copy of that brochure. If you did not receive a brochure or if you have any questions about the contents of this supplement, please contact us at 563-322-2322 or info@investmentconsultinggroupinc.com. Additional information about Ross C. Stanforth is available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 Part 2B of Form ADV: Investment Consulting Group, Inc. Brochure Supplement  Item 2: Educational Background and Business Experience Ross C. Stanforth (b. 1982) is Vice President and an investment adviser representative of Investment Consulting Group, Inc. A. Educational Background Butler University, B.S. Finance 2005 B. Business Background Investment Consulting Group, Inc. 07/2009–Present Covance 02/2008–07/2009 Hill-Rom 05/2005–02/2008 C. Professional Designations - Qualifications and Related Criteria Certified Investment Management Analyst (CIMA) The Certified Investment Management Analyst (CIMA) designation focuses on asset allocation, ethics, due diligence, risk measurement, investment policy and performance measurement. Only individuals who are investment consultants with at least three years of professional experience are eligible to try to obtain this certification, which signifies a high level of consulting expertise. The Investment Management Consultants Association offers the CIMA courses. To receive the CIMA certification, the individual must undergo a background check, pass the qualification examination, complete the education program with a registered education provider, pass the classroom certification examination, and agree to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for Use of the Marks. In order to maintain the CIMA designation, the individual must complete at least 40 hours of continuing education every two years. Item 3: Disciplinary Information Mr. Stanforth does not have any disciplinary action to report. Public information concerning his registration as an investment advisor representative may be found by accessing the SEC's public disclosure site at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Stanforth is not involved in any other business activities. Page 2 Part 2B of Form ADV: Investment Consulting Group, Inc. Brochure Supplement  Item 5: Additional Compensation Mr. Stanforth does not receive any additional compensation outside of Investment Consulting Group, Inc. Item 6: Supervision Supervision of Mr. Stanforth is performed by Donald Stanforth, Chief Compliance Officer, through reviews of internal transaction and security holdings reports, electronic and physical correspondence, and other internal reports as mandated by the firm and its regulatory authorities. Donald Stanforth can be reached at 563-322-2322. Page 3 Part 2B of Form ADV: Investment Consulting Group, Inc. Brochure Supplement 

Item 1: Cover Page Item 1: Cover Page Part 2A of Form ADV Firm Brochure March 12, 2025 Investment Consulting Group, Inc. SEC File No. 801-38594 5117 Jersey Ridge Road, Suite 1 Davenport, Iowa 52807 phone: 563-322-2322 toll free: 1-800-824-8668 email: info@investmentconsultinggroupinc.com info@icginc.co website: www.investmentconsultinggroupinc.com www.icginc.co This brochure provides information about the qualifications and business practices of Investment Consulting Group, Inc. If you have any questions about the contents of this brochure, please contact us at 563-322-2322 or info@investmentconsultinggroupinc.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration with the SEC or state regulatory authority does not imply a certain level of skill or expertise. Additional information about Investment Consulting Group, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 2: Material Changes Item 2: Material Changes This Firm Brochure is our disclosure document prepared according to regulatory requirements and rules. Consistent with the rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. There are no material changes to this Brochure from the last annual update issued in March 2024. Page 2 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 3: Table of Contents 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 ......................................................................................................................................... 4 Item 5: Fees and Compensation ............................................................................................................................ 7 Item 6: Performance-Based Fees and Side-by-Side Management ......................................................... 10 Item 7: Types of Clients ........................................................................................................................................... 11 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 12 Item 9: Disciplinary Information ........................................................................................................................... 18 Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 19 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................................................... 20 Item 12: Brokerage Practices ................................................................................................................................... 22 Item 13: Review of Accounts ................................................................................................................................... 29 Item 14: Client Referrals and Other Compensation ........................................................................................ 30 Item 15: Custody .......................................................................................................................................................... 31 Item 16: Investment Discretion ............................................................................................................................... 32 Item 17: Voting Client Securities ............................................................................................................................ 33 Item 18: Financial Information ................................................................................................................................ 34 Page 3 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 4: Advisory Business Item 4: Advisory Business A. Investment Consulting Group, Inc. Investment Consulting Group, Inc. (“ICG” and/or “the firm”) is organized as an Illinois corporation. ICG was founded in 1990 and is owned by Donald R. Stanforth, the firm’s President. B. Advisory Services Offered B.1. Asset Management Services ICG is an independent asset management firm offering a variety of financial services to clients. Such services include: ▪ Assist the client in establishing investment objectives ▪ Asset allocation ▪ Investment manager searches (using primarily, but not limited to, databases purchased from independent sources) ▪ Investment manager selections ▪ Performance measurement and evaluation ▪ Cost containment including transaction expenses ▪ General investment education ICG’s investment advisory services to clients take into account a client's personal financial circumstances, investment objectives and tolerance for risk (e.g., cash-flow, tax and estate). ICG’s engagement with a client will include, as appropriate, the following: ▪ Providing assistance in reviewing the client's current investment portfolio against the client's personal and financial circumstances as disclosed to ICG in response to a questionnaire and/or in discussions with the client and reviewed in meetings with ICG. ▪ Analyzing the client's financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Implementing and/or recommending individual equity and fixed income securities, mutual funds and ETFs. ▪ Reporting to the client on a quarterly basis or at some other interval agreed upon with the client, information on contributions and withdrawals in the client's investment portfolio, and the performance of the client's portfolio measured against appropriate benchmarks (including benchmarks selected by the client). ▪ Proposing changes in the client's investment portfolio in consideration of changes in the client's personal circumstances, investment objectives and tolerance for risk, the performance record of any of the client's investments, and/or the performance of any fund retained by the client. Page 4 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 4: Advisory Business ▪ If the client’s portfolio and personal circumstances, investment objectives, and tolerance for risk make such advice appropriate, providing recommendations to hedge a client’s portfolio through the use of derivative strategies, to generate additional income through the use of covered call option writing strategies involving exchange listed or OTC options, and/or to monetize or hedge concentrated stock positions. While ICG generally provides its services on a non-discretionary basis, the firm may provide discretionary asset management services if a client prefers. For discretionary asset management services, ICG receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this brochure. ICG’s discretionary asset management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. ICG will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances ICG’s objective is to review the client’s tax, financial, and estate planning objectives and goals in connection with the client’s investment objectives, goals, tolerance for risk, and other personal and financial circumstances and make appropriate recommendations and implementation decisions. ICG may engage third-party service providers to assist with the reporting, tax, and estate planning portion of the services provided to clients. In addition, ICG may utilize third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. In addition to providing ICG with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are required to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. On a quarterly basis, ICG’s reports to clients will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. ICG will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. B.2. Qualified and Non-Qualified Retirement Plan Consulting Services Depending on the needs of the plan, ICG will provide either a third-party review of a plan’s investments and expenses on an ongoing basis, or ICG will provide a third-party review of a plan’s investments and expenses and also provide investment advice and education to the participants of the plan. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client Page 5 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 4: Advisory Business on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs ICG does not participate in wrap fee programs. (Wrap fee programs offer services for one all- inclusive fee.) E. Client Assets Under Management As of December 31, 2024, ICG managed $2,600,394,647 of non-discretionary assets. Page 6 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 5: Fees and Compensation Item 5: Fees and Compensation A. Methods of Compensation and Fee Schedule A.1. Asset-Based Fee Schedule ICG’s fees are generally charged as a percentage of the assets. Fees are negotiated and confirmed to the client in writing. Fees do not exceed the following schedule: Retail Clients 1.0% Institutional Clients 0.5% Fees may be negotiated on a case-by-case basis. In certain cases, a flat fee may be applied until client assets reach an agreed upon level which may exceed the schedule shown above. These instances are always negotiated on a case-by-case basis and confirmed to the client in writing. Asset-based fees are always subject to the investment advisory agreement between the client and ICG. Such fees are payable quarterly in arrears and are based on the market value of each account on the last day of the quarter. Other fee arrangements may be negotiated with individual clients and confirmed in writing. The fees will be prorated if the investment advisory relationship commences otherwise than at the beginning of a calendar month. The client may authorize the qualified custodian to automatically deduct the fee and all other charges payable hereunder from the assets in the account when due with such payments to be reflected on the next account statement sent to the client. If insufficient cash is available to pay such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. ICG may modify the fee at any time upon 30 days’ written notice to the client. In the event the client has an ERISA-governed plan, fee modifications must be approved in writing by the client. The client also has the option to pay fees by check. A client investment advisory agreement may be canceled by either party after one year upon 30 days’ prior written notice. Upon termination, any earned, unpaid fees will be due and payable. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. In Illinois, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the client within five (5) business days of signing the contract without incurring any advisory fees. A.2. Qualified and Non-Qualified Retirement Plan Consulting Services Fees Clients are typically charged as a percentage of the assets. Fees are negotiated and confirmed to the client in writing using the following schedule as the guideline: 1.0% Independent Review and Participant Investment Education 3rd Party Review Flat Fee based on asset level. Will not exceed 1%. Page 7 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 5: Fees and Compensation Fees may be negotiated on a case-by-case basis. In certain cases, a flat fee may be applied until client assets reach an agreed upon level which may exceed the schedule shown above. These instances are always negotiated on a case-by-case basis and confirmed to the client in writing. In instances of a flat fee, additional charges may be incurred for employee education meetings, typically at $500 per day. Additional fees may apply depending on the distance traveled and time required. A.3. Fixed Fee Arrangements Consulting services may be offered at a fixed fee, as mutually agreed upon between the client and the firm. ICG will provide the prospective client with an estimate of the costs prior to the commencement of the engagement. Estimates will be based upon a good faith estimate of the number of hours to complete the assignment multiplied by the hourly rate. Clients seeking to terminate this service must do so in writing. B. Client Payment of Fees A client may choose to deduct fees or be billed for fees. ICG requires clients to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. ICG will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. C. Additional Client Fees Charged All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by exchange-traded funds, mutual funds, separate account managers, private placement, pooled investment vehicles, broker-dealers, and custodians retained by clients. Such fees and expenses are described in each exchange-traded fund and mutual fund’s prospectus, each separate account manager’s Form ADV and Brochure and Brochure Supplement or similar disclosure statement, each private placement or pooled investment vehicle’s confidential offering memoranda, and by any broker-dealer or custodian retained by the client. Clients are advised to read these materials carefully before investing. If a mutual fund also imposes sales charges, a client may pay an initial or deferred sales charge as further described in the mutual fund’s prospectus. A client using ICG may be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. Please refer to the Brokerage Practices section (Item 12) for additional information regarding the firm’s brokerage practices. Page 8 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 5: Fees and Compensation D. Prepayment of Client Fees ICG does not require the prepayment of its fees. A client investment advisory agreement may be canceled by either party upon 30 days’ prior written notice. Upon termination, any earned, unpaid fees will be due and payable. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. In Illinois, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the client within five (5) business days of signing the contract without incurring any advisory fees. E. External Compensation for the Sale of Securities to Clients ICG advisory professionals are compensated solely through a salary and bonus structure. ICG is not paid any sales, service or administrative fees for the sale of mutual funds or any other investment products with respect to managed advisory assets. Page 9 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 6: Performance-Based Fees and Side-by-Side Management Item 6: Performance-Based Fees and Side-by-Side Management ICG does not charge performance-based fees and therefore has no economic incentive to manage clients’ portfolios in any way other than what is in the clients’ best interests. Page 10 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 7: Types of Clients Item 7: Types of Clients ICG offers its investment services to various types of clients including ▪ Individuals and High-Net-Worth Individuals ▪ Pension and Profit Sharing Plans ▪ Health and Welfare Plans ▪ Trusts, Estates, or Charitable Organizations ▪ Corporations or Business Entities other than those listed above. ▪ Qualified and Non-Qualified Retirement Plans, Trusts, and Individuals ▪ Foundations, Endowments and Union Funds ICG generally requires a minimum account size of $500,000 for retail client accounts, and $1,000,000 for institutional client accounts. On 401(k) plans, the firm generally requires a minimum account size of $500,000. The firm, in its sole discretion, may waive the required minimums. Page 11 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies ICG uses a variety of sources of data to conduct its economic, investment and market analysis, such as financial newspapers and magazines, economic and market research materials prepared by others, conference calls hosted by mutual funds, corporate rating services, annual reports, prospectuses, and company press releases. It is important to keep in mind that there is no specific approach to investing that guarantees success or positive returns; investing in securities involves risk of loss that clients should be prepared to bear. ICG and its investment adviser representatives are responsible for identifying and implementing the methods of analysis used in formulating investment recommendations to clients. The methods of analysis may include quantitative methods for optimizing client portfolios, computer-based risk/return analysis, technical analysis, and statistical and/or computer models utilizing long-term economic criteria. ▪ Optimization involves the use of mathematical algorithms to determine the appropriate mix of assets given the firm’s current capital market rate assessment and a particular client’s risk tolerance. ▪ Quantitative methods include analysis of historical data such as investment managers’ statistics, performance data, standard deviation and related risk metrics, how the security performs relative to the overall stock market index, and related data. In addition, ICG reviews research material prepared by others, as well as corporate filings, corporate rating services, and a variety of financial publications. ICG may employ outside vendors or utilize third-party software to assist in formulating investment recommendations to clients. A.1. Mutual Funds and Exchange-Traded Funds, Individual and Fixed Income Securities, Third-Party Separate Account Managers ICG may recommend no-load and load-waived mutual funds and individual securities (including fixed income instruments). ICG may also assist the client in selecting one or more appropriate manager(s) for all or a portion of the client’s portfolio. Such managers will typically manage assets for clients who commit to the manager a minimum amount of assets established by that manager—a factor that ICG will take into account when recommending managers to clients. A description of the criteria to be used in formulating an investment recommendation for mutual funds, ETFs, individual securities (including fixed-income securities), and managers is set forth below. ICG has formed relationships with third-party vendors that ▪ provide a technological platform for separate account management ▪ prepare performance reports ▪ perform or distribute research of individual securities ▪ perform billing and certain other administrative tasks Page 12 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ICG may utilize additional independent third parties to assist it in recommending and monitoring individual securities, mutual funds, and managers to clients as appropriate under the circumstances. ICG reviews certain quantitative and qualitative criteria related to mutual funds and managers and to formulate investment recommendations to its clients. Quantitative criteria may include ▪ the performance history of a mutual fund or manager evaluated against that of its peers and other benchmarks ▪ an analysis of risk-adjusted returns ▪ an analysis of the manager’s contribution to the investment return (e.g., manager’s alpha), standard deviation of returns over specific time periods, sector and style analysis ▪ the fund, sub-advisor or manager’s fee structure ▪ the relevant portfolio manager’s tenure Qualitative criteria used in selecting/recommending mutual funds or managers include the investment objectives and/or management style and philosophy of a mutual fund or manager; a mutual fund or manager’s consistency of investment style; and employee turnover and efficiency and capacity. ICG may discuss relevant quantitative and qualitative factors pertaining to its recommendations with clients prior to a client’s determination to retain a mutual fund or manager. Quantitative and qualitative criteria related to mutual funds and managers are reviewed by ICG on a quarterly basis or such other interval as appropriate under the circumstances. In addition, mutual funds or managers are reviewed to determine the extent to which their investments reflect efforts to time the market, or evidence style drift such that their portfolios no longer accurately reflect the particular asset category attributed to the mutual fund or manager by ICG (both of which are negative factors in implementing an asset allocation structure). Based on its review, ICG may make recommendations to clients regarding the retention or discharge of a mutual fund or manager. ICG may negotiate reduced account minimum balances and reduced fees with managers under various circumstances (e.g., for clients with minimum level of assets committed to the manager for specific periods of time, etc.). There can be no assurance that clients will receive any reduced account minimum balances or fees, or that all clients, even if apparently similarly situated, will receive any reduced account minimum balances or fees available to some other clients. Also, account minimum balances and fees may significantly differ between clients. Each client’s individual needs and circumstances will determine portfolio weighting, which can have an impact on fees given the funds or managers utilized. ICG will endeavor to obtain equal treatment for its clients with funds or managers, but cannot assure equal treatment. ICG will regularly review the activities of mutual funds and managers utilized for the client. Clients that engage managers should first review and understand the disclosure documents of those managers, which contain information relevant to such retention or investment, including information on the methodology used to analyze securities, investment strategies, fees and conflicts of interest. Page 13 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A.2. Material Risks of Investment Instruments ICG has a long-term focus that is tailored to the client’s personal and financial circumstances and typically invests in open-end mutual funds and exchange-traded funds for the vast majority of its clients. For certain clients, ICG may effect transactions in the following types of securities: ▪ Equity securities ▪ Warrants and rights ▪ Mutual fund securities ▪ Exchange-traded funds ▪ Fixed income securities ▪ Corporate debt securities, commercial paper, and certificates of deposit ▪ Municipal securities ▪ U.S. government securities ▪ Corporate debt obligations A.2.a. Equity Securities Investing in individual companies involves inherent risk. The major risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk and liquidity risk. A.2.b. Warrants and Rights Warrants are securities, typically issued with preferred stock or bonds that give the holder the right to purchase a given number of shares of common stock at a specified price and time. The price of the warrant usually represents a premium over the applicable market value of the common stock at the time of the warrant’s issuance. Warrants have no voting rights with respect to the common stock, receive no dividends and have no rights with respect to the assets of the issuer. Investments in warrants and rights involve certain risks, including the possible lack of a liquid market for the resale of the warrants and rights, potential price fluctuations due to adverse market conditions or other factors and failure of the price of the common stock to rise. If the warrant is not exercised within the specified time period, it becomes worthless. A.2.c. Mutual Fund Securities Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be Page 14 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. A.2.d. Exchange-Traded Funds (“ETFs”) ETFs are investment companies whose shares are bought and sold on a securities exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index Tracking StockSM (“QQQs SM”) iShares® and VIPERs®. The funds could purchase an ETF to gain exposure to a portion of the U.S. or foreign market. The funds, as a shareholder of another investment company, will bear their pro-rata portion of the other investment company’s advisory fee and other expenses, in addition to their own expenses. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the ETF. A.2.e. Fixed Income Securities Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds have liquidity and currency risk. A.2.f. Corporate Debt, Commercial Paper and Certificates of Deposit Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds also have liquidity and currency risk. Page 15 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank and the length of maturity. With respect to certificates of deposit, depending on the length of maturity there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity. A.2.g. Municipal Securities Municipal securities carry additional risks than those of corporate and bank-sponsored debt securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax free at the federal level, but may be taxable in individual states other than the state in which both the investor and municipal issuer is domiciled. A.2.h. U.S. Government Securities U.S. government securities include securities issued by the U.S. Treasury and by U.S. government agencies and instrumentalities. U.S. government securities may be supported by the full faith and credit of the United States. A.2.i. Corporate Debt Obligations Corporate debt obligations include corporate bonds, debentures, notes, commercial paper and other similar corporate debt instruments. Companies use these instruments to borrow money from investors. The issuer pays the investor a fixed or variable rate of interest and must repay the amount borrowed at maturity. Commercial paper (short-term unsecured promissory notes) is issued by companies to finance their current obligations and normally has a maturity of less than nine months. In addition, the firm may also invest in corporate debt securities registered and sold in the United States by foreign issuers (Yankee bonds) and those sold outside the U.S. by foreign or U.S. issuers (Eurobonds). B. Investment Strategy and Method of Analysis Material Risks Our investment strategy is custom-tailored to the client’s goals, investment objectives, risk tolerance, and personal and financial circumstances. B.1. Margin Leverage Although ICG, as a general business practice, does not utilize leverage, there may be instances in which exchange-traded funds, other separate account managers and, in very limited circumstances, ICG will utilize leverage. In this regard please review the following: The use of margin leverage enhances the overall risk of investment gain and loss to the client’s investment portfolio. For example, investors are able to control $2 of a security for $1. So if the price of a security rises by $1, the investor earns a 100% return on their investment. Conversely, if the security declines by $.50, then the investor loses 50% of their investment. Page 16 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss The use of margin leverage entails borrowing, which results in additional interest costs to the investor. Broker-dealers who carry customer accounts require a minimum equity requirement when clients utilize margin leverage. The minimum equity requirement is stated as a percentage of the value of the underlying collateral security with an absolute minimum dollar requirement. For example, if the price of a security declines in value to the point where the excess equity used to satisfy the minimum requirement dissipates, the broker-dealer will require the client to deposit additional collateral to the account in the form of cash or marketable securities. A deposit of securities to the account will require a larger deposit, as the security being deposited is included in the computation of the minimum equity requirement. In addition, when leverage is utilized and the client needs to withdraw cash, the client must sell a disproportionate amount of collateral securities to release enough cash to satisfy the withdrawal amount based upon similar reasoning as cited above. Regulations concerning the use of margin leverage are established by the Federal Reserve Board and vary if the client’s account is held at a broker-dealer versus a bank custodian. Broker-dealers and bank custodians may apply more stringent rules as they deem necessary. B.2. Short-Term Trading Although ICG, as a general business practice, does not utilize short-term trading, there may be instances in which short-term trading may be necessary or an appropriate strategy. In this regard, please read the following: There is an inherent risk for clients who trade frequently in that high-frequency trading creates substantial transaction costs that in the aggregate could negatively impact account performance. C. Security-Specific Material Risks There is an inherent risk for clients who have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one investment manager, one type of investment instrument (equities versus fixed income). Clients who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain, but also offer the potential for significant loss. Page 17 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 9: Disciplinary Information Item 9: Disciplinary Information A. Criminal or Civil Actions There is nothing to report on this item. B. Administrative Enforcement Proceedings There is nothing to report on this item. C. Self-Regulatory Organization Enforcement Proceedings There is nothing to report on this item. Page 18 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 10: Other Financial Industry Activities and Affiliations Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer or Representative Registration Neither ICG nor its affiliates, employees, or independent contractors are registered broker- dealers and do not have an application to register pending. B. Futures or Commodity Registration Neither ICG nor its affiliates are registered as a commodity firm, futures commission merchant, commodity pool operator or commodity trading advisor and do not have an application to register pending. C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest There is nothing to report for this item. D. Recommendation or Selection of Other Investment Advisors and Conflicts of Interest ICG does not recommend separate account managers or other investment products in which it receives any form of compensation from the separate account manager or investment product sponsor. Page 19 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Description In accordance with the Advisers Act, ICG has adopted policies and procedures designed to detect and prevent insider trading. In addition, ICG has adopted a Code of Ethics (the “Code”). Among other things, the Code includes written procedures governing the conduct of ICG's advisory and access persons. The Code also imposes certain reporting obligations on persons subject to the Code. The Code and applicable securities transactions are monitored by the chief compliance officer of ICG. ICG will send clients a copy of its Code of Ethics upon written request. ICG has policies and procedures in place to ensure that the interests of its clients are given preference over those of ICG, its affiliates and its employees. For example, there are policies in place to prevent the misappropriation of material non-public information, and such other policies and procedures reasonably designed to comply with federal and state securities laws. B. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest ICG does not engage in principal trading (i.e., the practice of selling stock to advisory clients from a firm’s inventory or buying stocks from advisory clients into a firm’s inventory). In addition, ICG does not recommend any securities to advisory clients in which it has some proprietary or ownership interest. C. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ICG, its affiliates, employees and their families, trusts, estates, charitable organizations and retirement plans established by it may purchase the same securities as are purchased for clients in accordance with its Code of Ethics policies and procedures. The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is: ▪ owned by the client, or ▪ considered for purchase or sale for the client. Such conflict generally refers to the practice of front-running (trading ahead of the client), which ICG specifically prohibits. ICG has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: ▪ require our advisory representatives and employees to act in the client’s best interest ▪ prohibit fraudulent conduct in connection with the trading of securities in a client account ▪ prohibit employees from personally benefitting by causing a client to act, or fail to act in making investment decisions Page 20 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ▪ prohibit the firm or its employees from profiting or causing others to profit on knowledge of completed or contemplated client transactions ▪ allocate investment opportunities in a fair and equitable manner ▪ provide for the review of transactions to discover and correct any trades that result in an advisory representative or employee benefitting at the expense of a client. Advisory representatives and employees must follow ICG’s procedures when purchasing or selling the same securities purchased or sold for the client. D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest ICG, its affiliates, employees and their families, trusts, estates, charitable organizations, and retirement plans established by it may effect securities transactions for their own accounts that differ from those recommended or effected for other ICG clients. ICG will make a reasonable attempt to trade securities in client accounts at or prior to trading the securities in its affiliate, corporate, employee or employee-related accounts. Trades executed the same day will likely be subject to an average pricing calculation (please refer to Item 12.B.3 Order Aggregation). It is the policy of ICG to place the clients’ interests above those of ICG and its employees. Page 21 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 12: Brokerage Practices Item 12: Brokerage Practices A. Factors Used to Select Broker-Dealers for Client Transactions A.1. Custodian Recommendations ICG may recommend that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab” or “custodian”), a FINRA registered broker- dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although ICG may recommend that clients establish accounts at the custodian, it is the client’s decision to custody assets with the custodian. ICG is independently owned and operated and not affiliated with custodian. For ICG client accounts maintained in its custody, the custodian generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through the custodian or that settle into custodian accounts. ICG considers the financial strength, reputation, operational efficiency, cost, execution capability, level of customer service, and related factors in recommending broker-dealers or custodians to advisory clients. In certain instances and subject to approval by ICG, ICG will recommend to clients certain other broker-dealers and/or custodians based on the needs of the individual client, and taking into consideration the nature of the services required, the experience of the broker-dealer or custodian, the cost and quality of the services, and the reputation of the broker-dealer or custodian. The final determination to engage a broker-dealer or custodian recommended by ICG will be made by and in the sole discretion of the client. The client recognizes that broker- dealers and/or custodians have different cost and fee structures and trade execution capabilities. As a result, there may be disparities with respect to the cost of services and/or the transaction prices for securities transactions executed on behalf of the client. Clients are responsible for assessing the commissions and other costs charged by broker-dealers and/or custodians. A.1.a. How We Select Brokers/Custodians to Recommend ICG seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, the following: ▪ combination of transaction execution services along with asset custody services (generally without a separate fee for custody) ▪ capability to execute, clear, and settle trades (buy and sell securities for client accounts) ▪ capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) ▪ breadth of investment products made available (stocks, bonds, mutual funds, exchange- traded funds (ETFs), etc.) Page 22 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 12: Brokerage Practices ▪ availability of investment research and tools that assist us in making investment decisions ▪ quality of services ▪ competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them ▪ reputation, financial strength, and stability of the provider ▪ their prior service to us and our other clients ▪ availability of other products and services that benefit us, as discussed below A.1.b. Client’s Custody and Brokerage Costs For client accounts that the firm maintains, the custodian generally does not charge clients separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the custodian’s accounts. The custodian’s commission rates applicable to the firm’s client accounts were negotiated based on the firm’s commitment to maintain a certain minimum amount of client assets at the custodian. This commitment benefits the client because the overall commission rates paid are lower than they would be if the firm had not made the commitment. In addition to commissions, the custodian charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that the firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into the client’s custodian account. These fees are in addition to the commissions or other compensation the client pays the executing broker- dealer. Because of this, in order to minimize the client’s trading costs, the firm has the custodian execute most trades for the account. A.1.c. Soft Dollar Arrangements ICG does not utilize soft dollar arrangements. ICG does not direct brokerage transactions to executing brokers for research and brokerage services. A.1.d. Institutional Trading and Custody Services The custodian provides ICG with access to its institutional trading and custody services, which are typically not available to the custodian’s retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain minimum amount of the advisor’s clients’ assets are maintained in accounts at a particular custodian. The custodian’s brokerage services include the execution of securities transactions, 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. A.1.e. Other Products and Services Custodian also makes available to ICG other products and services that benefit ICG but may not directly benefit its clients’ accounts. Many of these products and services may be used to Page 23 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 12: Brokerage Practices service all or some substantial number of ICG's accounts, including accounts not maintained at custodian. The custodian may also make available to ICG software and other technology that ▪ provide access to client account data (such as trade confirmations and account statements) ▪ facilitate trade execution and allocate aggregated trade orders for multiple client accounts ▪ provide research, pricing and other market data ▪ facilitate payment of ICG’s fees from its clients’ accounts ▪ assist with back-office functions, recordkeeping and client reporting The custodian may also offer other services intended to help ICG manage and further develop its business enterprise. These services may include ▪ compliance, legal and business consulting ▪ publications and conferences on practice management and business succession ▪ access to employee benefits providers, human capital consultants and insurance providers The custodian may also provide other benefits such as educational events or occasional business entertainment of ICG personnel. In evaluating whether to recommend that clients custody their assets at the custodian, ICG may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers, and not solely the nature, cost or quality of custody and brokerage services provided by the custodian, which may create a potential conflict of interest. A.1.f. Independent Third Parties The custodian may make available, arrange, and/or pay third-party vendors for the types of services rendered to ICG. The custodian may discount or waive fees it would otherwise charge for some of these services or all or a part of the fees of a third party providing these services to ICG. A.1.g. Additional Compensation Received from Custodians ICG may participate in institutional customer programs sponsored by broker-dealers or custodians. ICG may recommend these broker-dealers or custodians to clients for custody and brokerage services. There is no direct link between ICG’s participation in such programs and the investment advice it gives to its clients, although ICG receives economic benefits through its participation in the programs that are typically not available to retail investors. These benefits may include the following products and services (provided without cost or at a discount): ▪ Receipt of duplicate client statements and confirmations ▪ Research-related products and tools ▪ Consulting services ▪ Access to a trading desk serving ICG participants Page 24 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 12: Brokerage Practices ▪ Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts) ▪ The ability to have advisory fees deducted directly from client accounts ▪ Access to an electronic communications network for client order entry and account information ▪ Access to mutual funds with no transaction fees and to certain institutional money managers ▪ Discounts on compliance, marketing, research, technology, and practice management products or services provided to ICG by third-party vendors The custodian may also pay for business consulting and professional services received by ICG’s related persons, and may pay or reimburse expenses (including client transition expenses, travel, lodging, meals and entertainment expenses for ICG’s personnel to attend conferences). Some of the products and services made available by such custodian through its institutional customer programs may benefit ICG but may not benefit its client accounts. These products or services may assist ICG in managing and administering client accounts, including accounts not maintained at the custodian as applicable. Other services made available through the programs are intended to help ICG manage and further develop its business enterprise. The benefits received by ICG or its personnel through participation in these programs do not depend on the amount of brokerage transactions directed to the broker-dealer. ICG also participates in similar institutional advisor programs offered by other independent broker-dealers or trust companies, and its continued participation may require ICG to maintain a predetermined level of assets at such firms. In connection with its participation in such programs, ICG will typically receive benefits similar to those listed above, including research, payments for business consulting and professional services received by ICG’s related persons, and reimbursement of expenses (including travel, lodging, meals and entertainment expenses for ICG’s personnel to attend conferences sponsored by the broker-dealer or trust company). As part of its fiduciary duties to clients, ICG endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by ICG or its related persons in and of itself creates a potential conflict of interest and may indirectly influence ICG’s recommendation of broker-dealers for custody and brokerage services. A.1.h. The Firm’s Interest in Custodian’s Services The availability of these services from the custodian benefits the firm because the firm does not have to produce or purchase them. The firm does not have to pay for the custodian’s services so long as a certain minimum of client assets is kept in accounts at the custodian. This minimum of client assets may give the firm an incentive to recommend that clients maintain their accounts with the custodian based on the firm’s interest in receiving the custodian’s services that benefit the firm’s business rather than based on the client’s interest in receiving the best value in custody services and the most favorable execution of client transactions. This is a potential conflict of interest. The firm believes, however, that the selection of the custodian as custodian and broker is in the best interest of clients. It is primarily supported by the scope, Page 25 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 12: Brokerage Practices quality, and price of the custodian’s services and not the custodian’s services that benefit only the firm. A.2. Brokerage for Client Referrals ICG does not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. A.3. Directed Brokerage A.3.a. ICG Recommendations For convenience, ICG may recommend Schwab as custodian for clients’ funds and securities and to execute securities transactions on its clients’ behalf. A.3.b. Client-Directed Brokerage Occasionally, clients may direct ICG to use a particular broker-dealer to execute portfolio transactions for their account or request that certain types of securities not be purchased for their account. Clients who designate the use of a particular broker-dealer should be aware that they will lose any possible advantage ICG derives from aggregating transactions. Such client trades are typically effected after the trades of clients who have not directed the use of a particular broker-dealer. ICG loses the ability to aggregate trades with other ICG advisory clients, potentially subjecting the client to inferior trade execution prices as well as higher commissions. B. Aggregating Securities Transactions for Client Accounts B.1. Best Execution ICG, pursuant to the terms of its investment advisory agreement with clients, has discretionary authority to determine which securities are to be bought and sold, and the amount of such securities. ICG recognizes that the analysis of execution quality involves a number of factors, both qualitative and quantitative. ICG will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include but are not limited to the following: ▪ The financial strength, reputation and stability of the broker ▪ The efficiency with which the transaction is effected ▪ The ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any) ▪ The availability of the broker to stand ready to effect transactions of varying degrees of difficulty in the future ▪ The efficiency of error resolution, clearance and settlement ▪ Block trading and positioning capabilities ▪ Performance measurement Page 26 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 12: Brokerage Practices ▪ Online access to computerized data regarding customer accounts ▪ Availability, comprehensiveness, and frequency of brokerage and research services ▪ Commission rates ▪ The economic benefit to the client ▪ Related matters involved in the receipt of brokerage services Consistent with its fiduciary responsibilities, ICG seeks to ensure that clients receive best execution with respect to clients’ transactions by blocking client trades to reduce commissions and transaction costs. To the best of ICG’s knowledge, these custodians provide high-quality execution, and ICG’s clients do not pay higher transaction costs in return for such execution. Commission rates and securities transaction fees charged to effect such transactions are established by the client’s independent custodian and/or broker-dealer. Based upon its own knowledge of the securities industry, ICG believes that such commission rates are competitive within the securities industry. Lower commissions or better execution may be able to be achieved elsewhere. B.2. Security Allocation Since ICG may be managing accounts with similar investment objectives, ICG may aggregate orders for securities for such accounts. In such event, allocation of the securities so purchased or sold, as well as expenses incurred in the transaction, is made by ICG in the manner it considers to be the most equitable and consistent with its fiduciary obligations to such accounts. ICG’s allocation procedures seek to allocate investment opportunities among clients in the fairest possible way, taking into account the clients’ best interests. ICG will follow procedures to ensure that allocations do not involve a practice of favoring or discriminating against any client or group of clients. Account performance is never a factor in trade allocations. ICG’s advice to certain clients and entities and the action of ICG for those and other clients are frequently premised not only on the merits of a particular investment, but also on the suitability of that investment for the particular client in light of his or her applicable investment objective, guidelines and circumstances. Thus, any action of ICG with respect to a particular investment may, for a particular client, differ or be opposed to the recommendation, advice, or actions of ICG to or on behalf of other clients. B.3. Order Aggregation Orders for the same security entered on behalf of more than one client will generally be aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of all participating clients. Subsequent orders for the same security entered during the same trading day may be aggregated with any previously unfilled orders. Subsequent orders may also be aggregated with filled orders if the market price for the security has not materially changed and the aggregation does not cause any unintended duration exposure. All clients participating in each aggregated order will receive the average price and, subject to minimum ticket charges and possible step outs, pay a pro rata portion of commissions. Page 27 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 12: Brokerage Practices To minimize performance dispersion, “strategy” trades should be aggregated and average priced. However, when a trade is to be executed for an individual account and the trade is not in the best interests of other accounts, then the trade will only be performed for that account. This is true even if ICG believes that a larger size block trade would lead to best overall price for the security being transacted. B.4. Allocation of Trades All allocations will be made prior to the close of business on the trade date. In the event an order is “partially filled,” the allocation will be made in the best interests of all the clients in the order, taking into account all relevant factors including, but not limited to, the size of each client’s allocation, clients’ liquidity needs and previous allocations. In most cases, accounts will get a pro forma allocation based on the initial allocation. This policy also applies if an order is “over-filled.” ICG acts in accordance with its duty to seek best price and execution and will not continue any arrangements if ICG determines that such arrangements are no longer in the best interest of its clients. B.5 Trade Errors From time to time, ICG may make an error in submitting a trade order on the client’s behalf. When this occurs, ICG may place a correcting trade with the broker-dealer. If an investment gain results from the correcting trade, the gain will remain in client’s account unless the same error involved other client account(s) that should have received the gain, it is not permissible for client to retain the gain, or ICG confers with client and client decides to forego the gain (e.g., due to tax reasons). If the gain does not remain in client’s account and Schwab is the custodian, Schwab will donate the amount of any gain $100 and over to charity. If a loss occurs greater than $100, ICG will pay for the loss. Schwab will maintain the loss or gain (if such gain is not retained in client’s account) if it is under $100 to minimize and offset its administrative time and expense. Generally, if related trade errors result in both gains and losses in client’s account, they may be “netted.” Page 28 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 13: Review of Accounts Item 13: Review of Accounts A. Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Client accounts are reviewed a minimum of four times per year, usually after the calendar quarter, unless more frequency is required by the client or advisor. Levels of review include the following performance analyses: rates of return, gross and net of fees, standard deviation, Alpha, Beta, R-Squared, cost analysis, and any other statistical computation considered necessary by the client of advisor. In certain cases, due to state statute, a review of an overall asset allocation may also be completed more frequently than four times per year. Investment Advisors (Money Managers) will typically be requested to visit the client personally on an annual basis to review the portfolio. Additional factors that would trigger a review would regard any changes in the Investment Advisor/Money Manager's Firm that would be construed as being pertinent to the investment objectives of the client or information that is needed to adhere to those investment objectives and/or “Prudent Man Rule,” monitor each manager performance (returns), people (personnel), price (fees), philosophy, and process. In addition, triggering factors would be any changes in the client's investment objectives. The reviewer will be Donald R. Stanforth, Certified Investment Management Analyst, or Ross C. Stanforth, whose function will be to provide consulting advice, to develop written investment objectives, conduct Investment Manager/Money Manager searches, oversee the Investment Advisor/Money Manager interview, select Investment Advisor/Money Managers, and to provide an ongoing consulting process in the review of the client's objectives by providing reports which compare the performance of the portfolio to the objectives. Client reports are written, but provided electronically, unless a hardcopy/written report is requested by the client. B. Review of Client Accounts on Non-Periodic Basis ICG may perform ad hoc reviews on an as-needed basis if there have been material changes in the client’s investment objectives or risk tolerance, or a material change in how ICG formulates investment advice. C. Content of Client-Provided Reports and Frequency ICG reports to the client on a quarterly basis or at some other interval agreed upon with the client, information on contributions and withdrawals in the client's investment portfolio, and the performance of the client's portfolio measured against appropriate benchmarks (including benchmarks selected by the client). The client’s independent custodian provides account statements directly to the client no less frequently than quarterly. The custodian’s statement is the official record of the client’s securities account and supersedes any statements or reports created on behalf of the client by ICG. Page 29 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 14: Client Referrals and Other Compensation Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ICG receives an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above in Item 12: Brokerage Practices. The availability of Schwab’s products and services to us is not based on our giving particular investment advice, such as buying particular securities for our clients. B. Advisory Firm Payments for Client Referrals ICG does not pay for client referrals. Page 30 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 15: Custody Item 15: Custody Under government regulations, ICG is deemed to have custody of a client’s assets if the client authorizes us to instruct their custodian to deduct our advisory fees directly from the client’s account. The custodian maintains actual custody of clients’ assets. Clients will receive at least quarterly account statements directly from their custodian containing a description of all activity, cash balances and portfolio holdings in the client’s account. Clients are urged to compare billing statements provided by ICG to the custodian statement for accuracy. Any discrepancies should be brought to the firm’s attention. The custodian’s statement is the official record of the account. Page 31 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 16: Investment Discretion Item 16: Investment Discretion While ICG generally provides its services on a non-discretionary basis, the firm may provide discretionary asset management services if a client prefers. For discretionary asset management services, clients will grant a limited power of attorney to ICG with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, ICG will exercise full discretion as to the nature and type of securities to be purchased and sold, and the amount of securities for such transactions. Investment limitations may be designated by the client as outlined in the investment advisory agreement. Page 32 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 17: Voting Client Securities Item 17: Voting Client Securities ICG does not take discretion with respect to voting proxies on behalf of its clients. ICG will endeavor to make recommendations to clients on voting proxies regarding shareholder vote, consent, election or similar actions solicited by, or with respect to, issuers of securities beneficially held as part of ICG supervised and/or managed assets. In no event will ICG take discretion with respect to voting proxies on behalf of its clients. Except as required by applicable law, ICG will not be obligated to render advice or take any action on behalf of clients with respect to assets presently or formerly held in their accounts that become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. ICG has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. ICG also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, ICG has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where ICG receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials to the client. Electronic mail is acceptable where appropriate and where the client has authorized contact in this manner. Page 33 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure  Item 18: Financial Information Item 18: Financial Information A. Balance Sheet ICG does not require the prepayment of fees of $1200 or more, six months or more in advance, and as such is not required to file a balance sheet. B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ICG does not have any financial issues that would impair its ability to provide services to clients. C. Bankruptcy Petitions During the Past Ten Years There is nothing to report on this item. Page 34 Part 2A of Form ADV: Investment Consulting Group, Inc. Brochure