MAINSAIL FINANCIAL GROUP

11245 SE 6th Street Suite 140 Bellevue, WA 98004 Telephone: 425-502-7693 https://www.mainsailfg.com/ Jan 30, 2026 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Mainsail Financial Group, LLC dba Mainsail Financial Group. If you have any questions about the contents of this brochure, please contact us at (425) 502-7693 or adam@mainsailfg.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. Additional information about Mainsail Financial Group also is available on the SEC's website at www.advisorinfo.sec.gov. The SEC's website also provides information about any persons affiliated with Mainsail Financial Group who are registered, or are required to be registered, as Investment Advisor Representatives of Mainsail Financial Group. Mainsail Financial Group is an SEC registered investment advisor. Registration as an investment advisor does not imply a certain level of skill or training. 1  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisors to amend their brochure when information becomes materially inaccurate. If there are any material changes to an advisor's disclosure brochure, the advisor is required to notify you and provide you with a description of the material changes. Since our annual amendment filing dated March 1, 2025, we have made the following material changes to our Form ADV: • More detailed explanation of fee calculation. • Addition of Fidelity as a custodian You may request a copy of our current brochure at any time, without charge, by calling or emailing us using the contact information on the cover page of this brochure. 2  Item 3 Table of Contents Item 1 Cover Page Page 1 Item 2 Summary of Material Changes Page 2 Item 3 Table of Contents Page 3 Item 4 Advisory Business Page 4 Item 5 Fees and Compensation Page 8 Item 6 Performance-Based Fees and Side-By-Side Management Page 13 Item 7 Types of Clients Page 13 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Page 14 Item 9 Disciplinary Information Page 16 Item 10 Other Financial Industry Activities and Affiliations Page 16 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Page 16 Item 12 Brokerage Practices Page 17 Item 13 Review of Accounts Page 18 Item 14 Client Referrals and Other Compensation Page 18 Item 15 Custody Page 19 Item 16 Investment Discretion Page 19 Item 17 Voting Client Securities Page 20 Item 18 Financial Information Page 20 3  Item 4 Advisory Business About Us Mainsail Financial Group is a registered investment advisor, offering financial planning and asset management services to clients. Mainsail Financial Group has been in business since 2019 and applied for registration as an investment advisor in 2022. Its principal owners are Adam Laibson and Brandon Steele. This Brochure is designed to provide detailed information relating to each item noted in the table of contents. Certain disclosures are repeated in one or more items, and/or other items are referred to in an effort to be as comprehensive as possible on the subject matters discussed. Within this Brochure, certain terms in either upper- or lowercase are used as follows: • "Mainsail", "We," "us," "the firm" and "our" refer to Mainsail Financial Group. • "Advisor" refers to persons who provide investment advisory services on behalf of Mainsail Financial Group. • "You," "yours," and "client" refer to clients of Mainsail Financial Group and its advisors. Description of Services Available Mainsail offers a suite of investment advisory services and programs to its advisors for use with their clients. Our investment advisory services and programs are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. Through these various advisory programs and services, clients have access to a wide range of securities products, including, but not limited to, common and preferred stocks; municipal, corporate, and government fixed income securities; mutual funds; exchange-traded products ("ETPs"); options and derivatives; unit investment trusts ("UITs"); and variable and fixed-indexed insurance products, as well as other products and services, including a variety of asset allocation services, financial planning, and consulting services. Our advisors may also offer advice related to direct participation programs, private placements, and other alternative investments, such as alternative energy programs, research, and development programs, leasing programs, real estate programs, and pooled commodities futures programs. We offer the following programs: 1. Portfolio Management Services Mainsail provides portfolio management services that are tailored to meet our clients' needs and investment objectives. We will gather information about your financial situation and objectives, and assist you in determining your investment goals, objectives, risk tolerance and income needs (collectively "investment parameters). Through our discussion to determine your investment parameters, we will provide you with recommendations and/or allocate your investments in models constructed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Typically models consist of no-load mutual funds and/or exchange-traded products ("ETPs") to achieve the clients investment goals. In some situations, Mainsail may utilize individual stocks, bonds, and alternative investments to meet the needs of its clients. If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary 4  authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities transactions in your account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in an investment portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. We also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. 2. Individual Financial Planning Services Mainsail's advisors provide financial planning services on a wide range of topics, including, but not limited to, comprehensive financial planning, budgeting and cash flow analysis, advice on major purchases, education planning, retirement income/longevity planning, portfolio analysis, estate planning analysis, investment analysis, business succession planning, and fringe benefit analysis. Our individual financial planning services begin with a formal consultation with the client to determine the client's assets, liabilities, investment objectives, present and future foreseeable financial obligations, income, and risk tolerance. Using this information, we will create a financial plan consistent with the client's needs. When the plan is completed, our advisors will meet with you to present the plan and answer any question you may have. You may also engage us for an annual update of your financial plan. The fees for both the initial plan and subsequent annual updates (if desired) are listed in Item 5 of this brochure. These Individual Financial Planning services may be included in the AUM fees in certain cases where total household AUM is over $750,000 and clients have engaged with us for the Portfolio Management Services listed in Item 1. 3. Retirement Plan Consulting Mainsail may provide a fee-for-service consulting program whereby advisors offer one time or ongoing advisory services to qualified retirement plans. Clients may engage our firm for Retirement Plan Consulting services on a negotiated flat, fixed, or asset-based fee basis. The maximum annual consulting fee, when stated as a percentage of assets, is 1.00% and is negotiable. Fees may be paid at the time of service, in advance of service, or after service has been rendered. Through the Retirement Plan Consulting Program, Mainsail can assist plan sponsors with their fiduciary duties and provide individualized advice based upon the needs of the plan and/or plan participants regarding investment management matters, such as: Investment policy statement support Investment selection and monitoring Overall portfolio composition Participant advice programs 5  4. Pontera Order Management System We may also provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to manage asset allocation and opportunistic rebalancing strategies on behalf of the client, to maintain financial planning objectives. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody. We regularly review, on a quarterly basis, the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. The Order Management System allows us to manage client accounts on a discretionary basis without having to obtain and maintain a client’s login credentials. Clients using the Order Management System will receive a link allowing them to connect their account(s) to the platform. Once a client account is connected to the Order Management System, We will monitor and rebalance or reallocate investments in that account in the same way as we do for other (non-held away) accounts, though using different tools. When clients engage us in this capacity, they are responsible to keep the Pontera platform link active, so that we will be able to access and manage the respective account without delay. If our firm determines that an Order Management System link has become inactive, we will use our best efforts to notify the client to resolve the issue. However, clients will remain subject to the portfolio fees described in Item 5 even when we are not capable of executing trades because of an inactive link. IRA Rollover Considerations As part of our financial planning and advisory services, we may provide you with recommendations and advice concerning your employer retirement plan or other qualified retirement account. When appropriate, we may recommend that you withdraw the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA") to be managed by our firm. If you elect to roll the assets to an IRA under our management, we will charge you an asset-based fee as described in Item 5. This practice presents a conflict of interest because our Advisory Representative has an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have your IRA assets managed under our program. You have the right to decide whether to complete the rollover and the right to consult with other financial professionals. Some employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: • Leave the funds in your employer's (former employer's) plan. • Roll over the funds to a new employer's retirement plan. • Cash out and take a taxable distribution from the plan. • Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Before making a change, we encourage you to speak with your financial advisor at Mainsail, CPA and/or tax attorney. Before rolling over your retirement funds to an IRA for us to manage, carefully consider the following. NOTE: This list is not exhaustive. 6  • Determine whether the investment options in your employer's retirement plan address your needs or whether other types of investments are needed. • Employer retirement plans generally have a more limited investment menu than IRAs. • Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. • Your current plan may have lower fees than our fee and/or the Third-Party Manager's fee • combined. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. • You should understand the various products and services available through an IRA provider • and their costs. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. If your plan offers management services, the fee associated with the service may be more or less than our fee. • The Third-Party Manager's or our management strategy may have higher risk than the options provided to you in your plan. • Your current plan may offer financial advice, guidance, management and/or portfolio options at no additional cost. If you keep your assets titled in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. • Your 401(k) may offer more liability protection than a rollover IRA; each state varies. Generally, Federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies; however, there can be exceptions. Consult an attorney if you are concerned about protecting your retirement plan assets from creditors. • You may be able to take out a loan on your 401(k), but not from an IRA. • • IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or a home purchase. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. • Your plan may allow you to hire us or another firm as the manager and keep the assets titled in the plan name. It is important that you understand your options, their features, and their differences, and decide whether a rollover is best for you. If you have questions, contact us at our main number listed on the cover page of this brochure. Individualized Services and Client-Imposed Restrictions The investment advisory services provided by Mainsail depend largely on the personal information the client provides to the advisors of Mainsail. In order for our advisors to provide appropriate investment advice to, or, in the case of discretionary accounts, make tailored investment decisions for, the client, it is very important that clients provide accurate and complete responses to their advisor's questions about their financial condition, needs, goals, and objectives and notify the advisor of any reasonable restrictions they wish to apply to the securities or types of securities to be bought, sold, or held in their managed account. It is also important that clients promptly inform their advisor of any changes in their financial condition, investment objectives, personal circumstances, or reasonable investment restrictions pertaining to the management of their account, if any, that may affect their overall investment goals and strategies or the investment advice provided or investment decisions made by their advisor. 7  In general, the client's advisor is responsible for delivering investment advisory services to clients, and clients generally deal with matters relating to their accounts by contacting their advisor directly. Of course, clients may contact Mainsail Financial Group directly with questions about the advisory services offered by our firm. Assets Under Management As of December 31, 2025, we provide continuous management services for $ 377,980,246 in client assets on a discretionary basis and $ 25,940,126 in client assets on a non-discretionary basis. Program Choices and Conflicts of Interest Clients should be aware that the compensation to Mainsail Financial Group will differ according to the specific advisory program chosen. This compensation to us may be more than the amounts we would otherwise receive if you participated in another program or paid for investment advice, brokerage, and/or other relevant services separately. As a result of the differences in fee schedules and other sources of compensation that exist among the various advisory programs and services offered by our firm and your advisor, Mainsail and your advisor have a financial incentive to recommend a particular program or service over other programs or services. Lower fees for comparable services may be available from other sources. Mainsail and your advisor have a financial incentive to recommend advisory programs or services that provide us higher compensation over other comparable programs or services available elsewhere that may cost you less. It is important to understand all the associated costs and benefits of each option so you can decide which types of accounts and services may be best suited for your unique financial goals, investment objective, and time horizon. We encourage you to review its Form CRS and to discuss your options with your advisor. Item 5 Fees and Compensation How You're Charged and How We're Compensated Clients who elect to receive portfolio management services through one or more of Mainsail Financial Group's asset management programs will generally pay Mainsail for those services with an annual asset management fee based on a percentage of assets under management, including cash and money market positions. The maximum account management fee that can be charged in any of our firm's managed account program is listed in the fee schedule below. Clients are urged to carefully review and discuss the contents of this Brochure with their advisor, including descriptions of the various programs and services offered, the fees and charges clients will pay, how Mainsail is compensated, and the conflicts of interest that exist between the client and Mainsail in respect to each program or service offered, to determine the most appropriate programs or services for your specific needs. The annual account management fee is payable monthly in advance and is computed on a per day rate multiplied by the number of days in the month based on the AUM on the last business day of the previous calendar month. In limited circumstances, estimated month or quarter end values of alternative investments provided by the product issuer may be used when calculating billable AUM. Please refer to the respective program description in this Brochure or to the respective client agreement for specific information about the maximum fee allowed, the varying fee schedules of each program, and the methods of fee billing for the program(s) you select. Mainsail may waive a particular fee, whether on an ongoing or a one-time basis, in its sole discretion. In the event a client terminates an advisory agreement with Mainsail, any unearned fees resulting from 8  payments made by clients in advance will be refunded to the client. Likewise, in the event Mainsail bills clients in arrears for services that have already been rendered, Mainsail will prorate such fees up to the termination date (with written request of client) of the advisory agreement. Our standard fee schedule for portfolio management is as follows: Portfolio Management Services Our fee for portfolio management services is based on a percentage of the assets in your account and is set forth in the following annual fee schedules: Flat Fee Schedule - For Household Values under $500,000: A flat fee schedule looks at the account value and compares it to a set fee schedule. Annual Fee Schedule Assets Under Management $0 - $249,999 $250,000 - $499,999 Annual Fee 1.50% 1.25% For example, assume that the account value at the end of the billing period is $300,000. In this hypothetical example, and assuming an advanced monthly billing cycle (31 days in this example) is applied, the account for the upcoming month would be assessed as follows: The $300,000 account value falls within the fee schedule value range of $250,001 to $499,999, which corresponds with a fee rate of 1.25%. The math: $300,000 x 1.25% = $3,750 / 365 days = $10.27 per day x 31 days in the following month = $318.37 advance monthly account fee. Blended/Tiered Fee Schedule – For Household Accounts $500,000 and above: A blended or tiered schedule identifies specific portions of the account value to be charged at different fee rates. The total value of the account is compared against the schedule and, based on the account size, the different fee rates are blended to determine the total account fee for that period. Annual Fee Schedule Assets Under Management $0 $1,000,000 $1,000,000 - $2,000,000 $2,000,000 - $4,000,000 $4,000,000 - $7,000,000 $7,000,000 - + Annual Fee 1.1% .90% .70% .65% .55% For example, let’s assume the account value at the end of the billing period is $3,000,000 and assume an advanced monthly billing cycle is applied (for a 30 day month). The math: 9  First Second Third $1,000,000 x 1.1% = $11,000; $11,000 / 365 = $30.14; $30.14 x 30=$904.20 $1,000,000 x .9% = $9,000; $9,000 / 365 = $24.65; $24.65 x 30=$739.50 $1,000,000 x .7% = $7,000; $7,000 / 365 = $19.17; $19.17 x 30=$575.10 Each of the different fee rate amounts is added together to determine the total monthly fee. $904.20+$739.50+$575.10 = $2,218.80 advance monthly account fee and a blended annual fee rate of .88% If the portfolio management agreement is executed at any time other than the first day of a calendar month, our fees will apply on a pro rata basis for the first month, which means that the advisory fee is payable in proportion to the number of days in the month for which you are a client. Our annual portfolio management fee is billed and payable, monthly in advance, based on the aggregate household balance at the end of the prior month. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. You may terminate the portfolio management agreement at any time upon written or email notice. You will no longer be billed from the day of the month in which written notice is submitted. Termination requests are required to be submitted by email or regular mail. In the event that no notice is given, we will consider the day of termination to be the last day we have discretion over the accounts (the day accounts are de-linked, for example) Financial Planning Services Mainsail's consultative Individual Financial Planning Services and Retirement Plan Consulting program provide the following fee payment options: Individual Financial Planning Services: The Individual Financial Planning Services Program provides clients with the option of paying an annual or flat fee. Fees for financial plans generally range from $2,000 - $10,000. The fee a client will pay is negotiable between the client and Mainsail, and may either be paid at the time of service or in advance of service. Annual fees may be paid in monthly, quarterly, semiannual, or annual installments as agreed between the client and the firm. Clients may engage the firm for updates to a previously created financial plan at an additional cost negotiated between the two parties. At no point will we collect fees in excess of $1200 within 6 months prior to engagement of planning services. Retirement Plan Consulting: The Retirement Plan Consulting Program provides clients with the option of paying an annual management fee for ongoing services based on a percentage of assets under advisement or a flat fee. The fee amount a client will pay is negotiable between the client and the advisor. Fees may be paid directly from qualified plan assets or may be direct billed, as agreed between the client and the advisor. This program is administered by Fidelity’s Tax Exempt Market (TEM) trading platform (via Wealthscape). Your advisor has discretion to trade on these accounts in a 10  manner that is reflective of the client’s overall risk tolerance and risk profile. Fees can be directly billed from these accounts in accordance with the fee schedule listed on Mainsail Financial Group’s Discretionary Fee Agreement but not to exceed 1.0%. Managed Account Fee Collection Process Managed account fees are typically automatically charged to the client's account pursuant to instructions provided to the account custodian by Mainsail Financial Group. Managed account clients will generally pay fees monthly in advance. Consulting clients will pay fees at time of service, in advance of service, or in arrears, as well as in monthly, quarterly, semiannual, or annual installments, as agreed to between the client and Mainsail. Additional deposits of funds and/or securities greater than $10,000 during a particular calendar month are subject to billing on a pro rata basis. Clients who withdraw funds from a managed account during a billing period are not generally entitled to a pro rata refund unless they are terminating their managed account program client agreement. Mainsail Financial Group allows for the aggregation of assets among a client's "related" managed accounts for purposes of determining the value of AUM and the applicable advisory fee to be paid by a client. Mainsail Financial Group reserves the right to determine whether client accounts are "related" for purposes of aggregating a client's accounts together for a reduction in the percentage fee amount. Other Fees and Costs Clients may incur charges in connection with certain investments, transactions, and services in your account. The actual fees and charges that clients will incur are dependent upon the type of account and the nature and quantity of the transactions that occur, the services that are provided, or the positions that are held in the account. Additional fees and charges that clients may typically pay include, but are not limited to: • Mutual fund or money market 12b-1 fees, sub-transfer agent fees, and distributor fees • Mutual fund transaction and redemption fees • Certain deferred sales charges on mutual funds purchased or transferred into the account • Other charges that may be required by law • One time brokerage account fees and charges Information describing the brokerage fees and charges that are applicable to a Mainsail Financial Group managed account (custodied with Schwab or Fidelity) is available upon request. In most cases, mutual fund companies offer multiple share classes of the same mutual fund. Some share classes of a fund charge higher internal expenses, whereas other share classes of a fund charge lower internal expenses. Institutional and advisory share classes typically have lower expense ratios and are less costly for a client to hold than Class A shares or other share classes that are eligible for purchase in an advisory account. Mutual funds that offer institutional share classes, advisory share classes, and other share classes with lower expense ratios are available to investors who meet specific eligibility requirements that are described in the mutual fund's prospectus or its statement of additional information. These eligibility requirements include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts that the fund considers qualified fee-based programs. The lowest-cost mutual fund share class for a fund may not be offered through our clearing firm or made available by Mainsail Financial Group for purchase within our managed 11  accounts. Clients should never assume that they will be invested in the share class with the lowest possible expense ratio or cost but when mutual funds are deemed appropriate for a client, Mainsail will seek out the lowest cost mutual fund share available to them. Mainsail Financial Group urges clients to discuss with their advisor whether lower-cost share classes are available in their program account. Clients should also ask their advisor why the funds or other investments that will be purchased or held in their managed account are appropriate for them in consideration of their expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, trading frequency, the amount of the advisory fee charged, whether the client will pay transaction charges for fund purchases and sales, whether clients will pay higher internal fund expenses in lieu of transaction charges that could adversely affect long-term performance, and relevant tax considerations. Your advisor may recommend, select, or continue to hold a fund share class that charges you higher internal expenses than other available share classes for the same fund. Prorated Rebate of Fees Paid in Advance In the event a client terminates an advisory agreement with Mainsail Financial Group, any unearned fees resulting from advanced payments will be refunded to the client. Likewise, in the event Mainsail bills clients in arrears for services that have already been rendered, Mainsail will prorate such fees up to the termination date of the advisory agreement. Termination requests are required to be submitted by email or regular mail. In the event that no notice is given, we will consider the day of termination to be the last day we have discretion over the accounts (the day accounts are de-linked, for example). Other Forms of Compensation As mentioned above, an ongoing asset management fee, billed monthly in advance, is the most common method of payment for the client and compensation to Mainsail Financial Group. Please refer to the respective program description in this Brochure and to the client agreement for specific information about the maximum fee allowed, the varying fee schedules of each program, and the methods of fee billing for the program(s) you select. When Mainsail Financial Group provides individual financial planning services for a client, the client pays for services rendered on a one-time basis or may pay a monthly or annual fee for ongoing services depending on the engagement(s) entered into by the client. For Retirement Plan Consulting, the fee may be a flat, fixed, or asset-based fee for providing one-time, or ongoing, advisory services to a plan. For individual financial planning services, the fee is typically a fixed fee. For both types of services, payment may be made either at the time of the service, in advance, or in arrears. Clients should make checks payable to Mainsail Financial Group only in relation to Qualified Plan Consulting or Individual Financial Planning services. Checks should never be made payable to the advisor or any other entity under the control of the advisor in relation to any asset management programs offered by Mainsail. Clients who are asked or instructed by their advisor to make checks payable to the advisor or any entity under control of the advisor should contact Adam Laibson, CCO directly for verification. Clients should be aware that, when assets are invested in shares of mutual funds, clients will pay investment advisory fees to Mainsail Financial Group for advisory services in connection with the investments. In addition to the payments received by Mainsail Financial Group and the advisor, clients will also typically pay management fees and other fees charged by the investment company, alternative investment, or other product sponsor. Clients may be able to invest directly in the investment company, alternative investment, or insurance product without incurring the investment advisory fees charged by Mainsail Financial Group. If a client's assets are invested in a fee- based 12  annuity, the client will pay both the direct management fee to Mainsail Financial Group for the advisory services provided by Mainsail Financial Group in connection with that investment and, indirectly, the management and other fees charged by the underlying annuity investment options, as well as the charges assessed by the insurance company for the product. Clients should also be aware of the tax implications of investing, as well as of the existence of deferred sales charges or redemption fees charged by some product sponsors for positions the client subsequently sells in Mainsail Financial Group managed accounts. For California Residents: Subsection (j) of Rule 260.238 of the California Code of Regulations requires that all investment advisors disclose to their advisory clients that lower fees for comparable services may be available from other sources. Special Disclosures for ERISA Plans: In this Brochure, Mainsail Financial Group has disclosed conflicts of interest, such as receiving additional compensation from third parties (e.g., 12b-1 fees, sub transfer agent fees, and revenue sharing) for providing marketing, recordkeeping, or other services in connection with certain investments. Mainsail Financial Group, however, has adopted policies and procedures that are designed to ensure compliance with the prohibited transaction rules under the Employee Retirement Income Security Act of 1974 ("ERISA"), as amended. For example, Mainsail Financial Group has taken several steps to address the conflict of interest associated with Mainsail Financial Group's or Mainsail Financial Group's advisors' receipt of compensation for services provided to ERISA plans. First, Mainsail negotiates the compensation with ERISA plan sponsors or participants ("ERISA clients") and the compensation is either an annual fee for ongoing services based on a percentage of assets under advisement or a flat fee. Second, to the extent that any Mainsail advisor receives additional compensation from a third party, the advisor must report it to Mainsail Financial Group to enable the additional compensation to be offset against the fees that the ERISA clients would otherwise pay for the advisor's services. Third, Mainsail Financial Group has established a policy not to influence any advice or management of assets at any time or for any reason based on any compensation that Mainsail Financial Group or the advisor might receive from third parties. In no event will Mainsail Financial Group allow its advisors to provide advice or manage assets for ERISA clients if they have conflicts of interest that Mainsail Financial Group believes are prohibited by ERISA. As a covered service provider to ERISA plans, Mainsail Financial Group will comply with the U.S. Department of Labor regulations on fee disclosures, effective July 16, 2011 (or such other date as provided by the Department). Thus, Mainsail Financial Group and its advisors will disclose (i) direct compensation received from ERISA clients; (ii) indirect compensation (e.g., 12b-1 fees) received from third parties; and (iii) transaction-based compensation (e.g., commissions) or other similar compensation shared with related parties servicing the ERISA plan. These fee disclosures will be made reasonably in advance of entering into, renewing, or extending the advisory service agreement with the ERISA client. Item 6 Performance-Based Fees and Side-By-Side Management Mainsail Financial Group does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 Types of Clients Mainsail Financial Group generally provides advisory services to the following types of clients: 13  Individuals (other than high net worth individuals) • • High net worth individuals • Pension and profit-sharing plans • Trusts, estates, and charitable organizations • Corporations or other businesses not listed above Mainsail Financial Group's managed account programs generally require clients to meet certain account minimums. In some cases, account balances may be combined at the household level to satisfy the account minimum. The following is a description of the account minimums in the various managed accounts available through Mainsail Financial Group: Mainsail Financial Group typically has a minimum investable asset requirement of $500,000. This minimum is negotiable and may be waived. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that investors should be sure they understand and should be prepared to bear. Mainsail Financial Group primarily serves retail investors. Clients of the firm are generally invested in one or more model portfolios developed by Mainsail's investment committee, taking into account the client's individual goals, risk tolerance and other factors. There are several sources of information that Mainsail may use as part of the investment analysis process when developing the firm's model portfolios. These sources include, but are not limited to: • Financial publications • Research materials prepared by others • Corporate rating services • SEC filings (annual reports, prospectus, 10-K, etc.) • Company press releases As a firm, Mainsail does not favor any specific method of analysis over another and, therefore, would not be considered to have one approach deemed to be a "significant strategy." There are, however, a few common approaches that may be used by Mainsail and its advisors, individually or collectively, in the course of providing advice to clients. Please note that there is no investment strategy that will guarantee a profit or prevent loss. Following are some common strategies employed Mainsail Financial Group in the management of client accounts: • Dollar Cost Averaging ("DCA"): The technique of buying a fixed dollar amount of a particular investment on a regular schedule, regardless of the share price. More shares are purchased when prices are low, and fewer shares are bought when prices are high. DCA is believed to lessen the risk of investing a large amount in a single investment at higher price. DCA strategies are not effective and do not prevent against loss in declining markets. • Asset Allocation: An investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes— equities (stocks), fixed income (bonds), and cash/cash equivalents—each of which has different risk and reward profiles/behaviors. Asset classes are often further divided into domestic and foreign investments, and equities are often divided into small, intermediate, and 14  large capitalization. The general theory behind asset allocation is that each asset class will perform differently from the others in different market conditions. By diversifying a portfolio of investments among a wide range of asset classes, advisors seek to reduce the overall volatility and risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. Asset allocation does not guarantee a profit or protect against loss. • Technical Analysis (aka "Charting"): A method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that performance of the stock, rather than performance of the company itself, has more to do with the company's future stock price. It is important to understand that past performance does not guarantee future results. • Fundamental Analysis: A method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is the opposite of technical analysis. • Quantitative Analysis: An analysis technique that seeks to understand behavior by using complex mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. • Qualitative Analysis: Securities analysis that uses subjective judgment based on nonquantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. This type of analysis technique is different from quantitative analysis, which focuses on numbers. The two techniques, however, are often used together. • Cycle Analysis: A method of statistical analysis of specific events occurring at a sufficient number of regular intervals that they can be forecasted into the future. Risks of Loss Regardless of what investment strategy or analysis is undertaken, investing in securities involves risk of loss that clients must be prepared to bear; in fact, some investment strategies could result in total loss of your investment. Some risks may be avoided or mitigated, while others are completely unavoidable. Some of the common risks you should consider prior to investing include, but are not limited to: • Market risks: The prices of, and the income generated by, the common stocks, bonds, and other securities you own may decline in response to certain events taking place around the world, including those directly involving the issuers; conditions affecting the general economy; overall market changes; local, regional, or global political, social, or economic instability; governmental or governmental agency responses to economic conditions; and currency, interest rate, and commodity price fluctuations. 15  • Interest rate risks: The prices of, and the income generated by, most debt and equity securities may be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities generally will decline when interest rates rise and will increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, "call," or refinance a security before its stated maturity date, which may result in having to reinvest the proceeds in lower-yielding securities. • Credit risks: Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. • Geopolitical risks: Investments in securities issued by entities based outside the United States may be subject to the risks described above to a greater extent. Investments may also be affected by currency controls; different accounting, auditing, financial reporting, disclosure, and regulatory and legal standards and practices; expropriation (occurs when governments take away a private business from its owners); changes in tax policy; greater market volatility; different securities market structures; higher transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends. These risks may be heightened in connection with investments in developing countries. Investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Any of the common risks described above could adversely affect the value of your portfolio and account performance, and you can lose money. Even though these risks exist, Mainsail will still earn the fees and other compensation described in this Brochure. Clients should carefully consider the risks of investing and the potential that they may lose principal while Mainsail continue to earn fees and other forms of compensation. Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any other governmental agency, entity, or person, unless otherwise noted and explicitly disclosed as such, and as such may lose value. Item 9 Disciplinary Information Neither Mainsail nor any of its management persons have any disciplinary items applicable to this section. Item 10 Other Financial Industry Activities and Affiliations None Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Pursuant to Rule 204A-1 under the Investment Advisors Act of 1940, as amended, Mainsail Financial Group has adopted a Code of Ethics that governs a number of conflicts of interest we have when providing our advisory services to you. Our Code of Ethics is designed to ensure that we meet our fiduciary obligations to you and to foster a culture of compliance throughout our firm. 16  Our Code of Ethics is comprehensive and is designed to help us detect and prevent violations of securities laws and to help ensure that we always keep your interests first. We distribute our Code of Ethics to each supervised person at Mainsail at the time of his or her initial affiliation with our firm; we make sure it remains available to each supervised person for as long as he or she remains associated with our firm; and we ensure that updates to our Code of Ethics are communicated to each supervised person as changes are made. Our Code of Ethics sets forth certain standards of conduct and addresses conflicts of interest between our firm, our employees, our agents, our advisors, and our advisory clients. Clients and prospective clients of Mainsail Financial Group may request a copy of our Code of Ethics at any time. Mainsail Financial Group and its advisors may purchase or sell for their own accounts securities or other investment products that are also recommended to clients, which may create a conflict of interest. The firm's policy prohibits "trading ahead" of clients' transactions. When advisors are purchasing or selling securities for their own accounts, priority will be given to client transactions. Mainsail has implemented a review process that is designed to identify and correct situations in which firm or advisor transactions are placed ahead of client transactions. Item 12 Brokerage Practices Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on Mainsail Financial Group’s duty to seek “best execution,” which is the obligation to seek to execute securities transactions for a client on terms that are the most favorable to the client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent, and Mainsail Financial Group may also consider the market expertise and research access provided by the payment of commissions, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers to aid in the research efforts of Mainsail Financial Group. Mainsail Financial Group will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. Mainsail Financial Group recommends Charles Schwab & Co., Inc. and Fidelity Brokerage Services LLC. Research and Other Soft Dollar Benefits Mainsail Financial Group has access to research, products, or other services from its broker/dealer in connection with client securities transactions (“soft dollar benefits”) consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended, and may consider these benefits in recommending brokers. There can be no assurance that any particular client will benefit from any particular soft dollar research or other benefits. Mainsail Financial Group benefits by not having to produce or pay for the research, products or services, and Mainsail Financial Group will have an incentive to recommend a broker dealer based on receiving research or services. Clients should be aware that Mainsail Financial Group’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 17  Brokerage for Client Referrals Mainsail Financial Group receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use Mainsail Financial Group will require clients to use either Charles Schwab & Co, Inc. or Fidelity Brokerage Services, LLC to execute transactions. Block Trading Policy Mainsail Financial Group may aggregate ("bunch") transactions in the same security on behalf of more than one client to strive for best execution and to possibly reduce the price per share. However, aggregated or bunched orders will not reduce the transaction costs to participating clients. Typically, the process of aggregating client orders is done to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Mainsail conducts aggregated transactions in a manner designed to ensure that no participating client is favored over another client. Participating clients will obtain the average share price per share for the security executed that day. To the extent the aggregated order is not filled in its entirety and when possible, securities purchased or sold in an aggregated transaction will be allocated pro-rata to the participating client accounts in proportion to the size of the orders placed for each account. The amount of securities may be increased or decreased to avoid holding odd-lot or a small number of shares for particular clients. It should be noted, Mainsail does not receive any additional compensation or remuneration as a result of aggregation. Advisory clients purchase open end mutual funds at net asset value. Soft Dollars Mainsail Financial Group does not use commissions to pay for research and brokerage services (i.e., soft dollar transactions). Research, along with other products and services other than trade execution, are available to Mainsail Financial Group on a cash basis from various vendors. Item 13 Review of Accounts All client accounts are reviewed by an Investment Advisor Representative (IAR) of the firm no less than quarterly, or more often when changes in client circumstances or market conditions warrant. The firm's model portfolios are regularly reviewed by the firm's investment committee. All clients will be offered the opportunity to meet with their advisor no less than annually to discuss any changes to their financial situation which may impact the management of the client's account(s). Clients will be provided statements at least quarterly directly from account custodian where your assets are maintained. Additionally, you will receive confirmations of all transactions directly from account custodian. All non-retirement accounts and retirement accounts for those clients taking distributions will receive an annual tax reporting statement. Item 14 Client Referrals and Other Compensation Schwab Advisor Network In this optional program, the Company may receive client referrals from Charles Schwab & Co., Inc. ("Schwab") through its participation in Schwab Advisor Network® ("the Service"). The Service is 18  designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with our Company. Schwab does not supervise our Company and has no responsibility for the management of our clients' portfolios or other advice or services. We pay Schwab fees to receive client referrals through the Service. Our participation in the Service raises potential conflicts of interest as described below. If enrolled in the program, Mainsail may pay Schwab a Participation Fee on all referred clients' accounts that are maintained in custody at Schwab and a separate one-time Transfer Fee on all accounts that are transferred to another custodian. The Transfer Fee creates a conflict of interest that encourages us to recommend that client accounts be held in custody at Schwab. The Participation Fee paid by us is a percentage of the value of the assets in the client's account. We pay Schwab the Participation Fee for as long as the referred client's account remains in custody at Schwab. The Participation Fee is paid by our Company and not by the client. We have agreed not to charge clients referred through the Service fees or costs greater than the fees or costs we charge clients with similar portfolios who were not referred through the Service. The Participation and Transfer Fees are based on assets in our client's accounts who were referred by Schwab and those referred clients' family members living in the same household. Thus, we will have an incentive to recommend that client accounts and household members of clients referred through the Service maintain custody of their accounts at Schwab. Refer to the Brokerage Practices section above for disclosures on research and other benefits we may receive resulting from our relationship with your account custodian. As of Dec 31, 2025 Mainsail Financial Group is not participating in this program. Item 15 Custody Your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. Clients should carefully review the statements they receive from their account custodians and should promptly report material discrepancies to Mainsail at (425) 679-6875. Item 16 Investment Discretion Mainsail Financial Group renders investment advice to its managed account clients on a discretionary basis, pursuant to written authorization granted by the client to Mainsail Financial Group and your advisor. This authorization grants to Mainsail Financial Group and your advisor the discretion to buy, sell, exchange, convert, or otherwise trade in securities and/or insurance products, and to execute orders for such securities and/or insurance products as Mainsail Financial Group or your advisor may select. Your advisor may, without obtaining your consent, determine which products to purchase or sell for your managed account, as well as when to purchase or sell such products, and the prices to be paid. Neither Mainsail Financial Group nor your advisor, however, is granted authority to take possession of your assets or direct the delivery of your assets to anywhere other than your address of record. You may terminate this discretionary authorization at any time by providing written notice to us. 19  If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Clients may impose reasonable restrictions on their managed account, including, but not limited to, the type, nature, or specific names of securities to be bought, sold, or held in their managed account, as well as the type, nature, or specific names of securities that may not be bought, sold, or held in their managed account. Clients grant Mainsail Financial Group and their advisor discretionary trading authority over their managed accounts as part of the account opening process. As a matter of firm policy, neither Mainsail Financial Group nor its advisors have or will accept the authority to file class action claims on behalf of clients. This policy reflects Mainsail Financial Group's recognition that it does not have the requisite expertise to advise clients with regard to participating in class actions. Mainsail Financial Group and its advisors have no obligation to determine if securities held by the client are subject to a pending or resolved class action settlement or verdict. Mainsail Financial Group and its advisors also have 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, Mainsail Financial Group and its advisors have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. The decision to participate in a class action or to sign a release of claims when submitting a proof of claim may involve the exercise of legal judgment, which is beyond the scope of services provided to clients by Mainsail Financial Group or your advisor. In all cases, clients retain the responsibility for evaluating whether it is prudent to join a class action or to opt out. Item 17 Voting Client Securities As a matter of firm policy, and in accordance with this Brochure and our advisory client agreements, neither Mainsail Financial Group nor our advisors have or will accept the authority to vote proxies on behalf of advisory clients in any situation where Mainsail Financial Group or the advisor acts as investment advisor to the client. Mainsail Financial Group or our advisors may, but are not obligated to, provide advice to clients regarding the clients' voting of proxies. In all cases, clients must either retain the responsibility for receiving and voting proxies for any and all securities maintained in their managed accounts, or they must appoint a third-party investment advisor or other person who is not associated with Mainsail Financial Group to vote proxies for their managed accounts. In the event the advisor chooses to provide advice to clients designed to assist the client in making a decision as to how to vote their proxies, the advisor has a fiduciary duty to disclose to the client any material conflicts of interest the advisor may have with respect to such advice. In all cases, Mainsail Financial Group or the advisor will send, or will cause to be sent, all such proxy and legal proceedings information and documents it receives to the client, so that the client may take whatever action the client deems advisable under the circumstances. Item 18 Financial Information Mainsail Financial Group neither has a financial commitment that would impair its ability to meet its contractual and fiduciary commitments to clients, nor has Mainsail Financial Group been the subject of a bankruptcy proceeding. 20