Jfg Family Office

1144 Fifteenth Street, Suite 3950 Denver, CO 80202 720-475-1195 (P) www.jfgfamilyoffice.com March 30, 2026 Form ADV Part 2A Brochure This brochure provides information about the qualifications and business practices of Johnson Financial Group, LLC, DBA JFG Family Office. If you have any questions about the contents of this brochure, please contact us at 720-475-1195. 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 Johnson Financial Group, LLC also is available on the SEC's website at www.adviserinfo.sec.gov. 1  Item 2 Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the filing of our last annual updating amendment, dated March 27, 2025, we have made the following material changes to this brochure: • Item 4 - Advisory Business - We expanded our advisory services to include detail on our philanthropic capital services and OCIO solutions. We also updated disclosures regarding private investments and pooled investment vehicles offered to certain eligible investors. For additional details, see Item 4. • Item 5 - Fees and Compensation - We revised and expanded fee disclosures to clarify how advisory fees are calculated, billed, and prorated, including the treatment of private investments and third-party money managers. We also enhanced disclosures regarding additional fees and expenses clients may incur and clarified that certain existing clients may pay fees under historical fee schedules that differ from those currently offered. Disclosures were also added to describe the use of margin in client accounts. For additional details, see Item 5. • Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss: We updated this section to include additional disclosures regarding the Firm's limited use of artificial intelligence tools in support of internal research and operational functions. We also included a description of risks associated with investments in Semi-Liquid and Interval Funds. For additional details, see Item 8. • Item 10 – Other Financial Industry Activities and Affiliations and Item 14 - Client Referrals and Other Compensation: We updated disclosures regarding potential conflicts arising from service by certain investment professionals on nonprofit boards. In addition, we removed disclosures relating to certain referral and solicitor compensation arrangements that are no longer offered by the Firm. We also removed references to our affiliate, JFG Wealth Management, LLC. As of December 31, 2025, this affiliate merged into JFG Family Office. For additional details, see Item 10 and Item 14. 2  Item 3 Table Of Contents Item 1 Cover Page Page 1 Item 2 Material Changes Page 2 Item 3 Table Of Contents Page 3 Item 4 Advisory Business Page 4 Item 5 Fees and Compensation Page 7 Item 6 Performance-Based Fees and Side-By-Side Management Page 9 Item 7 Types of Clients Page 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Page 9 Item 9 Disciplinary Information Page 11 Item 10 Other Financial Industry Activities and Affiliations Page 12 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Page 12 Item 12 Brokerage Practices Page 13 Item 13 Review of Accounts Page 15 Item 14 Client Referrals and Other Compensation Page 15 Item 15 Custody Page 15 Item 16 Investment Discretion Page 16 Item 17 Voting Client Securities Page 16 Item 18 Financial Information Page 17 3  Item 4 Advisory Business Johnson Financial Group, LLC, DBA JFG Family Office ("JFG", "we" or "us"), offers investment management, financial planning and family office services to individual, private foundation, business and institutional clients. We have been in business since 2002. JFG is principally owned by B&W Holdings LLC. Brandon C. Johnson and Wendy M. Johnson are the owners of B&W Holdings LLC. Investment Management JFG constructs customized portfolios for investment management clients based on their financial objectives and constraints. We begin by collecting information from the client, which is used to create an Investment Policy Statement (the "IPS"). This document details the client's past investment related experience, current financial situation (including goals and risk tolerance), probable future financial needs (including constraints such as liquidity needs, time horizons, tax issues, legal and regulatory considerations, and unique circumstances). From this information, JFG develops an investment strategy to address these designated criteria, and manages the client's assets on a discretionary or non-discretionary basis. When acting with discretion, JFG considers any reasonable restrictions the client may have imposed on the account. We continuously monitor the client's portfolio and may rebalance the portfolio due to certain events, such as changes in the client's financial situation or market-driven events. Financial Planning As part of our investment management service, we offer financial planning services at no additional charge. Financial planning typically involves providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. Our planning services range from comprehensive financial planning, through which the client receives a written report of the client's overall financial situation and a recommended investment plan to more modular consultative services which focus on one or more targeted financial goals. JFG tailors advisory services to the individual needs of clients by gathering all relevant asset and liability information to create an investment strategy and financial plan that address the clients' complete financial picture. The financial plans address the very specific circumstances that affect a client's financial goals including family information, required spending needs, financial strength and wealth targets. Clients may impose restrictions on investing in certain securities and types of securities. Selection of Other Advisers JFG may recommend that you use the services of a third party money manager or private fund manager ("TPMM"), to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, JFG may recommend that you engage a specific TPMM or investment program. Factors that JFG takes into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. JFG will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. The TPMM(s) will actively manage your portfolio and in some cases assume discretionary investment authority over your account. With the exception of private fund managers, JFG will assume discretionary authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where JFG deem such action appropriate. Private fund managers are recommended on a non-discretionary basis and clients will receive a private placement memorandum and other offering documents prior to investing. 4  Family Office Services We provide a high touch service model for families and entities with more than $30 million in assets under management and complex financial and planning needs. These services are included as a part of our investment management service and support multi-entity structures, advanced reporting, significant money movement, and estate and governance considerations. We help coordinate long term planning across generations and provide guidance during business transitions, liquidity events, and other major milestones. Our team delivers responsive execution with a focus on accuracy, discretion, and continuity. We also coordinate closely with a client's broader advisory team, including CPAs, attorneys, investment managers, insurance professionals, tax advisors, and operating company leadership, to promote alignment across all areas of the client's financial life. Trust & Entity Accounting & Bill Pay Trust and Entity Accounting and Bill Pay services are available to clients who meet certain minimum asset thresholds, as determined by the Firm. Accounting services are offered to non-operating entities and non-individuals and include monthly bank reconciliations and entity financial statement preparation on a quarterly basis. Our team does not prepare tax information or provide tax or legal advice. The Accounting team works directly with the client and if needed, their tax CPA, or other accounting professionals to ensure that information is complete and accurate. Bill pay and trust and entity accounting are scoped separately and may carry a separate fee. Philanthropic Capital Services JFG offers a wide range of philanthropic services designed to assist clients in defining, structuring, and implementing their charitable giving strategies. These services may include helping families articulate the purpose of their giving, develop grantmaking frameworks, evaluate charitable opportunities, and establish governance structures to support multi-generational involvement. These services are provided pursuant to a separate engagement agreement. Human Capital As part of our investment management service, we provide advice and tools to help families focus on the human capital side of wealth, not just the financial capital. For clients that are interested in doing more in-depth work in this area, we offer extensive expertise and coaching under a separate engagement on a wide range of topics such as Family Dynamics, Communication, Mission, Vision, Values, Philanthropy, History and Legacy, and Succession Planning. OCIO Solutions JFG OCIO Solutions integrates institutional investment discipline with tailored service, designed specifically for organizations requiring focused attention and access. Key features include bespoke portfolio construction, private market expertise, and collaborative governance ensuring alignment with your long-term goals. Pooled Investment Vehicles 5  JFG offers employees and their family members access to the JFG Fund LLC (the "Fund"), a private pooled investment vehicle that invests in private equity, private credit, and private real assets focused on generating long term capital appreciation. The Fund is not open to the general public and is not offered to clients of JFG. Our advisory services are separate and distinct from the compensation paid to our affiliate for their services. The Fund is offered to certain sophisticated investors and knowledgeable employees, who meet certain requirements under applicable state and/or federal securities laws. Investors to whom the Fund is offered will receive a private placement memorandum and other offering documents. Types of Investments We provide advice on various types of investments. Our services are not limited to a specific type of investment or product. As a part of our Investment Management service, JFG may recommend an allocation to one or more unaffiliated private investments. When we recommend a private investment, the client will receive a private placement memorandum and other offering documents which include a complete description of the fees, investment objectives, risks and other relevant information associated with the investment. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures and risks. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Assets Under Management As of December 31, 2025, we have regulatory assets under management of $4,529,119,285 of which $2,461,558,118 was managed on a discretionary basis, and $2,067,561,167 was managed on a non- discretionary basis. 6  Item 5 Fees and Compensation Investment Management JFG's fee is based on a percentage of assets under management management and billed quarterly in advance. Investment advisory fees are based on the market value of assets held in accounts under management as of the last day of the prior quarter. JFG is not compensated based on the activity level of an account. The management fee will be automatically debited from the account held at the primary custodian at the beginning of each quarter, as authorized in writing by the client. JFG's minimum annual fee is $100,000. Under certain circumstances, we may accept new investment management relationships below this minimum. Fees are generally non-negotiable, although we reserve the right at our sole discretion to negotiate the fees lower. Agreed-upon fees will be stated in the written agreement signed by the client. Fees are calculated as detailed in the fee table below and are paid in advance. When services commence other than at the beginning of a quarter, billing generally begins when client assets are received and under management. Fees for the initial period are prorated based on the number of days remaining in the calendar quarter. If services are terminated before the end of the quarter, the fee will be prorated for that quarter (i.e. if services are terminated on the 18th day of the quarter, the fee charged will be 18 days/the number of days in the quarter * quarterly fee). Clients are charged as households and thus receive the applicable price breaks taking into account all of the assets in the household accounts that JFG manages. The annual tiered fee schedule is as follows: Total Fair Market Value Annual Percentage Fee First $30,000,000 0.75% Amounts over $30,000,000 0.40% JFG generally pro-rates fees to reflect significant contributions or withdrawals of account assets during a billing period. The Firm applies a materiality threshold in determining whether to prorate such transactions, and smaller contributions or withdrawals may not result in a fee adjustment. JFG charges ongoing investment management fees (as detailed in the JFG Investment Advisory Agreement) on the total value of all assets invested in our Investment Management service including the value of your private investments which are calculated based on the most recent available value at the beginning of each quarter. JFG does not receive any additional compensation for recommending private investments. When using private funds and separately managed accounts, clients may pay two management fees, one to the private fund and one to JFG. Fees charged by private investments are separate and apart from our advisory fees. You should refer to the offering documents for a full description of the applicable fees, including performance based fees, management fees, and expenses charged by the respective private fund. Existing clients of the company may pay fees according to historical fee schedules that may differ from the fee schedules described herein. Please refer to Item 12 for additional information about brokerage fees and practices. Neither JFG nor its supervised persons accept compensation for the sale of securities or other investment products. Trust & Entity Accounting & Bill Pay 7  Accounting and Bill Pay services are available to clients who meet certain minimum asset thresholds, as determined by the Firm. Such fees are generally billed quarterly in advance. The amount of the fee is determined based on various factors, including the scope of services to be provided, the complexity of the client's circumstances, and the anticipated level of time and resources required. The scope of services and applicable fees are agreed upon in advance of the engagement and documented in a separate written agreement to ensure clarity regarding the services to be provided and the associated fees. Philanthropic Capital Services Philanthropic services and resources are offered as part of JFG's broader family office services. These services are generally provided at no additional charge to clients who meet certain minimum asset thresholds, as determined by the Firm. Clients who do not meet the applicable asset thresholds may be eligible to receive such services for an additional fee. In addition, clients requiring more comprehensive or specialized philanthropic services may engage JFG for additional services subject to a separate fee arrangement. All philanthropic services are provided pursuant to a separate written agreement that outlines the scope of services and applicable fees. Human Capital Human Capital service and tools are available through your adviser at no additional fee. For a more personalized approach, clients can enter into a separate engagement letter for an additional fee. The fee depends on the services the client chooses and is generally payable 50% at the onset of the engagement and 50% at the conclusion. OCIO Solutions Our fees for OCIO services are set forth in our investment advisory agreement with the institutional client. Our fees are generally based on a percentage of the institutional client's assets under management and subject to our standard investment management fee schedule. Fees are negotiable and can vary between institutional clients based on a number of factors such as scope and complexity of services to be provided. Selection of Other Advisers Advisory fees charged by TPMMs are separate and apart from JFG's advisory fees. Assets managed by TPMMs will be included in calculating our advisory fee, which is based on the fee schedule set forth in the Investment Management section in this brochure. Advisory fees that you pay to the TPMM are established and payable in accordance with the brochure and/or offering document provided by each TPMM to whom you are referred. These fees may or may not be negotiable. You should review the recommended TPMM's brochure and/or offering documents and take into consideration the TPMM's fees along with our fees to determine the total amount of fees associated with this program. You may be required to sign an agreement directly with the recommended TPMM(s). You may terminate your advisory relationship with the TPMM according to the terms of your agreement with the TPMM. You should review each TPMM's brochure and/or offering documents for specific information on how you may terminate your advisory relationship with the TPMM and how you may receive a refund, if applicable. You should contact the TPMM directly for questions regarding your advisory agreement with the TPMM. Pooled Investment Vehicles 8  JFG offers employees and their family members access to the JFG Fund LLC (the "Fund"), a private pooled investment vehicle that invests in private equity, private credit, and private real assets focused on generating long term capital appreciation. The Fund is not open to the general public and is not offered to clients of JFG. The fees charged by JFG Fund are separate and apart from our advisory fees. You should refer to the offering documents for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in the Fund. See Item 10 below (Other Financial Industry Activities and Affiliations) for more information. Other Fees The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. Other types of fees that clients may incur include brokerage and transaction fees when purchasing or selling securities.These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. when purchasing or selling securities. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. JFG may trade certain client accounts on margin, subject to a separate margin agreement with the custodian. Margin is generally used to address short-term cash flow needs (e.g., to meet client requests when insufficient cash is available), rather than to purchase additional securities, and accounts are rebalanced as appropriate thereafter. Advisory fees are based on the total market value of the account, including assets purchased with margin. This creates a conflict of interest, as the use of margin increases account value and, therefore, advisory fees; however, JFG mitigates this conflict by limiting margin use to cash management purposes. The use of margin will result in interest charges in addition to other applicable fees and expenses. Item 6 Performance-Based Fees and Side-By-Side Management JFG does not charge performance-based fees. Item 7 Types of Clients JFG provides investment advice to individuals, trusts, charitable organizations, pooled investment vehicles and small businesses. JFG's minimum annual fee is $100,000. Under certain circumstances, we may accept new investment management relationships below this minimum. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Portfolio construction begins by selecting a universe of investments that are appropriate for each client's circumstances. Portfolios are then built by including securities that exhibit the desired asset class, risk, return, and tax characteristics as described in the Investment Policy Statement. In order to analyze investment strategies and specific securities, JFG uses a variety of quantitative and research- based approaches. These approaches include an analysis of performance, return distributions, standard deviation, risk exposures (through multi-factor regression models), and tax efficiency, in addition to other modern portfolio theory (MPT) methods. 9  We generally employ a total return approach to portfolio management and incorporate the client's unique situation, risk tolerance, and needs for income and liquidity. Portfolios will potentially include domestic and foreign equities, fixed income securities, CD's and options, mutual funds, separately managed accounts, ETFs, alternative investments and private placements, depending on client consent and comfort level. Investment strategies are primarily focused on building globally diversified portfolios that are highly tax and cost efficient. This is done principally through the use of mutual funds, ETFs, and separately managed accounts. Investing in securities involves risk of loss and clients should be prepared to bear the loss of their investments. It should also be noted that at the outset of a relationship with a new client, JFG may provide investment advice on any holdings in a client's investment portfolio. Decisions regarding whether to continue to hold an existing asset are based on the Investment Policy Statement, tax implications, trading costs, and the client's specific requests. The risk of loss varies depending on what type of investment strategy is employed. Clients who have indicated that they have the ability and willingness to bear more risk in their portfolios have riskier investment strategies. These portfolios have higher expected risk and returns. These portfolios will have greater amounts of stocks and others riskier assets versus fixed-income. Clients who have indicated that they have less ability and willingness to assume risk will have more fixed-income and less stocks and other riskier assets in their portfolios. Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield similar performance. Semi-Liquid and Interval Fund Investment Risk The Firm may recommend certain investment vehicles that provide limited or periodic liquidity rather than daily liquidity. These investments may include interval funds, tender offer funds, non-traded vehicles, or similar investment structures. These types of investments often invest in less liquid underlying assets such as private credit, real estate, structured credit, or other alternative strategies. Investors generally must submit redemption requests during designated repurchase 10  windows established by the fund. The liquidity terms, fees, investment strategy, and risks associated with any such investment are described in the applicable prospectus or offering materials, which clients should review carefully before investing. Redemptions may be subject to fund-level limits or "gates." Funds commonly limit the amount of shares that may be repurchased during a repurchase period, and if redemption requests exceed the amount the fund has made available, redemption requests may be prorated, deferred to a future period, or suspended in accordance with the fund's governing documents. As a result, investors may not be able to access their full investment when desired and should be prepared to hold these investments for an extended period of time. Private Investments: Investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. The range of risks are dependent on the nature of the fund and are disclosed in the offering documents. Margin Transactions: Margin Transactions are securities transactions in which an investor borrows money using securities as collateral on the loan. If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned to them. Artificial Intelligence: JFG uses a closed, enterprise-based artificial intelligence ("AI") system to support certain internal research, operational, administrative, or analytical functions. While the Firm believes such tools can enhance efficiency and productivity, the use of AI involves inherent risks. These risks may include inaccuracies, incomplete information, embedded bias, or misleading outputs ("hallucinations") generated by the system. AI-generated content may rely on data that is outdated, inaccurate, or not fully transparent. There are also risks related to cybersecurity, data privacy, confidentiality, and regulatory compliance. Although the Firm has implemented policies and supervisory procedures designed to mitigate these risks, no system is entirely free from error or vulnerability. The Firm does not rely on AI for autonomous investment decisions, and all AI-generated outputs used in connection with advisory services are subject to human review. Nonetheless, the use of AI tools could result in operational, compliance, or reputational risks that may adversely affect clients. Item 9 Disciplinary Information Neither JFG nor its employees have been involved in any disciplinary or investment related issues or events in the past ten years that would be considered material to a prospective client's evaluation of our advisory business or the integrity of our management. 11  Item 10 Other Financial Industry Activities and Affiliations JFG serves as the Manager of the JFG Fund LLC (the "Fund"), a private pooled investment vehicle. The Fund is offered to knowledgeable employees and their family members who must be sophisticated investors that meet certain requirements under applicable state and/or federal securities laws. Investors to whom the Fund is offered will receive a private placement memorandum and other offering documents. The fees charged by the Fund are separate and apart from our advisory fees. You should refer to the offering documents for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in the Fund. JFG identifies private investments via a broad array of sources. In some cases, the source of a private investment is a client of JFG. We undertake a thorough due diligence process on all investments, including those that may be introduced to JFG and/or owned by a client. This creates a conflict of interest as we have an incentive to recommend private investments that financially benefit clients over those that do not. While this conflict exists, we believe that our policies and procedures mitigate such conflict. JFG does not receive any direct or indirect compensation for recommending a client owned private investment. Moreover, when making investment recommendations to clients, JFG makes individualized recommendations based on what it believes to be in the best interest of the client on whose behalf it is making the recommendation viewed on an overall basis. JFG is the majority owner of WECtec, LLC, a technology company that created a private capital allocation solution called Trace8. JFG's ownership of WECtec, LLC creates a conflict of interest in that one of JFG's advisory clients has a minority ownership interest in WECtec, LLC. No JFG client is required to invest in opportunities that Trace8 determines would be an appropriate investment and any decision to do so is at the client's sole discretion. JFG and WECtec share offices and resources. Although JFG compensates WECtec for its services, no portion of this cost is passed on to clients. Certain investment professionals of the Firm serve on the boards or investment committees of nonprofit organizations, including private foundations. These roles are generally uncompensated, and the Firm does not provide advisory services to such organizations. However, because these organizations may evaluate or invest in similar asset classes or investment vehicles as the Firm's clients, potential conflicts of interest may arise. The Firm has adopted policies designed to address potential conflicts and protect confidential information. We may recommend that you use a third party money manager ("TPMM") based on your needs and suitability. We will not receive separate compensation, directly or indirectly, from the TPMM for recommending that you use their services. Moreover, we do not have any other business relationships with the recommended TPMM(s). Refer to Item 4 - Advisory Business for additional disclosures on this topic. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading All persons performing advisory functions on behalf of JFG and those who have access to client transactions or recommendations, as well as all directors, officers, and partners are considered "access persons" and must adhere to JFG's Code of Ethics. A copy of JFG's Code of Ethics will be provided to any client or prospective client on request. The Code of Ethics requires all access persons to report their personal securities holdings within ten days of becoming an access person and annually thereafter. This information must be current as of a date not more than 45 days prior to the date the individual becomes an access person or, for an 12  annual report, the date the report is submitted. Access persons also must report their personal trading activities, if any, quarterly to the CCO within 30 days of the close of the quarter. IPO or private placement participation requires pre-approval for the access person by the compliance team. The Code of Ethics requires that violations of the Code of Ethics be reported to the CCO and it is stressed that JFG's culture encourages internal reporting of violations. JFG will protect supervised persons who report violations from retaliation. All access persons are required to provide written acknowledgement of receipt of the Code of Ethics. JFG maintains an ongoing education program regarding the Code of Ethics for its access persons. Gifts valued at more than $500, must be promptly reported to the CCO. Participation on a board of a public company requires pre-approval from the compliance team. Material non-public information is not to be traded upon by access persons or any associated person. All records of violations of the Code of Ethics and actions taken in response will be maintained by JFG. Written acknowledgment of the receipt of the Code of Ethics will be maintained by JFG as will a record of the names of access persons, personal securities reports by access persons and any records of decisions approving access persons' participation in IPOs or private placements. Certain clients own Class B shares of the JFG. Issuance of these shares resulted from specific client inquiries as to whether the clients could have ownership in JFG. JFG does not recommend such ownership interests to its clients, nor does it assess an advisory fee on these assets. Nonetheless, client ownership of the firm creates a conflict of interest as JFG benefits from outside investment in the firm. Client ownership of the firm has the potential to lead to preferential treatment of these client accounts. JFG mitigates this potential conflict in a number of ways, including block trading of client transactions, as well as utilization of allocation procedures regarding private capital investment opportunities. JFG does not recommend to clients, nor does it buy or sell for client accounts, securities in which JFG or a related person has a material financial interest. From time to time, JFG may recommend that clients buy or sell the same securities, including private placements and private equity, that JFG or a related person may also buy or sell. Some of these investments may be placed at, or about the same time as, the placement of client securities transactions. This presents a conflict of interest, as JFG and its related persons may benefit from client transactions by placing their own interests ahead of those of the JFG's clients. We mitigate this conflict by adhering to policies and procedures that state that trading for JFG's own accounts will never take precedence over transactions in clients' accounts. When possible, block trades will be used to make sure every account receives the same execution price. Item 12 Brokerage Practices Where JFG has been granted discretionary authority by the client, this discretionary authority is limited to determining the security, and the amount of the security, to be bought or sold for the client's account. We have neither the authority to determine which broker or dealer will be used, nor the authority to determine the amount of commission fees paid. In providing investment management services, JFG generally recommends that clients hold their accounts at Schwab Institutional, a division of Charles Schwab & Co., Inc. ("Schwab"), or Fidelity Wealth Central ("Fidelity"), both FINRA-registered broker-dealers, members SIPC, to maintain custody of client assets and to effect trades for their accounts, as JFG has established relationships with these brokerage firms through which we receive products and services, in addition to execution, which may benefit the client directly or indirectly. These products and services are described in detail below. The cost of brokerage services at Schwab and Fidelity is also discussed with the client along with 13  alternative brokerage services of interest to the client, if any. Clients are informed that research obtained from JFG's brokerage relationships may be used to manage their account as well as other accounts under JFG's management. We require that you, the client, direct us to execute transactions through a broker-dealer that you select. Not all advisers require their clients to direct brokerage. If you direct us to place transactions through a brokerage firm other than those we recommend to you, you should understand that we may not be able to achieve best execution and that this practice may cost you more money, as you may pay higher commissions than we could obtain from the firms we recommend, we may not be able to aggregate orders to reduce transaction costs, and you may receive less favorable pricing. JFG has a fiduciary duty to seek best price and execution when effecting trades. In recommending Schwab and Fidelity, JFG's primary consideration is in securing the most favorable price and efficient execution. The reasonableness of commission or other transaction costs is also a major factor in our recommendations and is considered together with other relevant factors, including, but not limited to: the brokerage firm's financial stability and reputation; responsiveness; commission rates; research and other services offered by the broker (as described above); ease of use of trade confirmations, the size and type of the transaction, whether or not any factors warrant a disruption to the current services the client receives, back office support and the expertise to answer client questions and timeliness of such contact. JFG evaluates the execution performance of its brokers no less than annually. As described above, JFG receives products and services in addition to execution services from Schwab and Fidelity. Additional services received include a website including a client portal for online access to a client's account, research accessibility, account status information and quality customer service, as well as access to mutual funds and other investments that are otherwise generally only available to institutional investors or would require a significantly higher minimum initial investment. Products received include performance measurements of client accounts, S&P research reports and other screening tools that assist in the investment management process. Schwab and Fidelity also make available other services intended to help us manage and further develop our business enterprise. These services may include compliance, legal and business consulting, publications and conferences on practice management and business succession, information technology, regulatory compliance and marketing and access to employee benefit providers, human capital consultants and insurance providers. In addition, Schwab and Fidelity may make available, arrange and/or pay for these types of services rendered to us by independent third parties. Schwab and Fidelity may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to us. Schwab and Fidelity may also provide other benefits such as educational events or occasional business entertainment of JFG personnel. While as a fiduciary, we endeavor to act in our clients' best interests; clients should understand that the ability to receive these additional benefits from Schwab and Fidelity creates a conflict of interest, as our recommendations of these brokerage firms is influenced by the availability of some of the foregoing products and services. As stated above, in recommending Schwab and Fidelity, JFG's primary consideration is in securing the most favorable price and efficient execution of client transactions. JFG has not entered into any formal soft dollar agreements; however, as stated above, JFG does receive research, evaluated pricing, various publications, and other benefits when we place client transactions through Schwab and Fidelity. 14  When possible, JFG aggregates client orders to ensure no client transaction is favored over another, as all transactions in an aggregated order are executed at the same price. JFG has adopted written policies and procedures with regard to its order aggregation process to ensure fair distribution among participating client accounts. Item 13 Review of Accounts As part of our investment management services, we monitor client portfolios on an ongoing basis and conduct formal reviews at least quarterly or as otherwise desired by the client. The reviews include examining asset allocation as compared to the client's Investment Policy Statement (IPS), examining past transactions & current recommendations, as well as the economic outlook going forward. The Portfolio Manager reviews all accounts in accordance with instructions from the client. Triggering factors that could lead to a review other than those described above include major geopolitical and/or market-related events or a change in the client's risk tolerance or financial situation. The individuals conducting reviews may vary from time to time, but in all circumstances and at all times, the individual conducting the review will be an investment adviser representative of JFG. All accounts are held in the clients' names at brokerage houses selected by the client. Thus, the clients have access to their accounts at their convenience in addition to receiving monthly and/or quarterly reports from the brokerage firm. JFG also provides written quarterly reports showing performance of the account and the amount of the fee paid to JFG, the net asset value of the account upon which the fee was based, along with the fees charged & the method in which the fee was calculated. Item 14 Client Referrals and Other Compensation JFG does not receive any economic benefit from non-clients for providing investment advice and advisory services to clients. JFG compensates employees for client referrals that result in new client relationships. Employees who refer clients to us must comply with the requirements of the jurisdictions where they operate. The compensation is a percentage of the advisory fee you pay us for as long as you are our client, or such time that the employee's employment with JFG ends. You will not be charged additional fees based on this compensation arrangement. Incentive based compensation is contingent upon you entering into an advisory agreement with us. Therefore, the individual has a financial incentive to recommend us to you for advisory services. This creates a conflict of interest; however, you are not obligated to retain us for advisory services. Comparable services and/or lower fees may be available through other firms. Item 15 Custody Clients receive monthly statements from the custodian and clients should review these statements carefully. Clients receive quarterly statements from JFG and clients should compare these statements against the statements they receive from the custodian. JFG is deemed to have custody of client assets because it deducts advisory fees from client accounts, offers bill-pay services to clients, and may effect transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, as long as the client has provided us with written authorization to do so. Such 15  written authorization is known as a Standing Letter of Authorization. Due to JFG's ability to access client funds and securities, JFG is examined no less than annually on a surprise basis by a third-party accountant to ensure the protection of client funds. As discussed in Item 4, JFG serves as the investment adviser to JFG Fund LLC (the "Fund," whether one or more), a private pooled investment vehicle offered only to employees and their family members. In our capacity as investment adviser to the Fund, we will have access to the Fund's funds and securities, and therefore have custody over such funds and securities. We provide each investor in the Fund with audited annual financial statements. If you are a Fund investor and have questions regarding the financial statements or if you did not receive a copy, contact us directly at the telephone number on the cover page of this brochure. Brandon Johnson serves as trustee for a limited number of clients' trusts. His capacity as trustee gives our firm custody over the advisory accounts for which he serves as trustee. These accounts will be held with a bank, broker-dealer, or other qualified custodian. Brandon's relationship with the beneficiaries of these trusts pre-existed the establishment of the trusts as clients of JFG. JFG is examined no less than annually on a surprise basis by a third-party accountant to ensure the protection of client funds. Item 16 Investment Discretion For transactions placed in client accounts over which the client has granted JFG discretion, JFG maintains the discretionary authority to determine the securities to be bought and sold, and the amount of securities to be bought and sold for said client's account, without obtaining prior consent or approval from the client. However, these purchases or sales are subject to specified investment objectives, guidelines, or limitations previously set forth in the IPS. Discretionary authority will only be exercised upon written authorization by the client as evidenced by the client's execution of an agreement containing all applicable limitations to such authority. Item 17 Voting Client Securities As a general policy, JFG will not vote proxies on behalf of client accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitations to vote proxies. In limited circumstances, JFG may vote proxies for certain accounts where the client typically does not have authority to vote proxies and JFG has been delegated proxy voting authority as part of the advisory engagement. These circumstances may include accounts associated with donor-advised funds ("DAFs") or accounts where Schwab Trust Services serves as trustee and JFG has been engaged as the investment adviser. When JFG votes proxies in these limited circumstances, the firm seeks to vote proxies in a manner it believes to be consistent with the best interests of the client and the investment objectives of the account however JFGmay abstain fromvoting a proxy for immaterial positions. Proxy voting decisions may take into consideration factors such as corporate governance practices, shareholder rights, and matters that may affect the long-term value of the investment. Clients may obtain information about how their proxies were voted, if applicable, by contacting JFG. 16  Item 18 Financial Information JFG does not require or solicit prepayment of fees six months or more in advance and thus a balance sheet is not included in this ADV Part 2A. We do not have any financial conditions that are reasonably likely to impair our ability to meet contractual commitments to clients. 17