MIDWEST FINANCIAL GROUP LLC

Item 1 – Cover Page Form ADV Part 2A Brochure Midwest Financial Group, LLC Main Office: 7400 W 130th Street, Suite 100, Overland Park, KS 66213 (913) 696-0041 Topeka Office: 7630 SW 21st Street, Topeka, KS 66615 (785) 290-0007 www.midwestfinancialkc.com February 28, 2026 This Brochure provides information about the qualifications and business practices of Midwest Financial Group, LLC (MFG). If you have any questions about the contents of this Brochure, please contact us at (913) 696-0041. 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. MFG is a registered investment adviser. Registration as an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information from which you can determine whether to hire or retain an adviser. i       Item 2 – Material Changes This Brochure dated February 28, 2026, represents the annual amendment to the Brochure for Midwest Financial Group, LLC. Since the filing of the firm’s annual update Brochure on February 06, 2025, we have made various updates to the Brochure but no material changes were made. Pursuant to SEC Rules, we will deliver to you a summary of any material changes to this and subsequent Brochures within 120 days of the close of our fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. All such information will be provided to you free of charge. Currently, our Brochure may be requested by contacting us at (913) 696-0041. Additional information about MFG is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with MFG who are registered as investment adviser representatives of the firm. ii       Item 3 - Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 – Material Changes ............................................................................................................................ ii Item 3 - Table of Contents ........................................................................................................................... iii Item 4 – Advisory Business .......................................................................................................................... 1 Item 5 – Fees and Compensation .................................................................................................................. 3 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 5 Item 7 – Types of Clients .............................................................................................................................. 5 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 5 Item 9 – Disciplinary Information ................................................................................................................ 6 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 6 Item 11 – Code of Ethics .............................................................................................................................. 6 Item 12 – Brokerage Practices ...................................................................................................................... 7 Item 13 – Review of Accounts ...................................................................................................................... 9 Item 14 – Client Referrals and Other Compensation .................................................................................. 10 Item 15 – Custody ....................................................................................................................................... 10 Item 16 – Investment Discretion ................................................................................................................. 10 Item 17 – Voting Client Securities .............................................................................................................. 11 Item 18 – Financial Information ................................................................................................................. 11 Brochure Supplement(s) iii       Item 4 – Advisory Business Midwest Financial Group, LLC (CRD # 175288) (MFG) is registered as an investment adviser with the Securities Exchange Commission. MFG is based in Kansas and is organized as a limited liability company under the laws of the State of Kansas. The firm was formed in 2015, has been registered as a registered investment adviser since 2015, and currently has 5 employees. MFG’s principal office and place of business is located at 7400 W 130th Street, Suite 100, Overland Park, KS 66213. Regular business hours are Monday through Friday 8:00 am to 5:00 pm. The firm can be contacted by phone at (913) 696-0041 and by fax at (913) 696-0042. MFG has an office located at 7630 SW 21st Street, Topeka, KS 66615. The firm can be contacted at this location at (785) 290-0007 or by fax at (785) 235-0046. The firm is owned equally by Leigha A. Shepard, Cole S. Reichle, Steven D. Reichle, and Richard K Ryan. Ms. Shepard currently serves as MFG’s Chief Compliance Officer. MFG consists of multiple investment advisory representatives operating under one legal entity, MFG. Four of the representatives with ownership interest in MFG, Ms. Leigha Shepard, Mr. Cole Reichle, Mr. Steven Reichle, and Mr. Richard Ryan, conduct MFG business under the business name “Midwest Financial Partners”, which is similar in name to “Midwest Financial Partners, Inc”, a separate legal entity used by them for accounting and tax purposes. One representative, Ms. Mitzi Swaffar, conducts MFG business under the business name “MS Financial Resources,” with is similar in name to “MS Financial Resources, Inc.”, a separate legal entity she uses for accounting and tax purposes. MFG provides ongoing discretionary and non-discretionary portfolio management services to individuals, families and businesses. When providing portfolio management services, the firm not only makes recommendations related to investments, but also implements these recommendations and provides ongoing monitoring and reporting. Clients may elect to give the firm discretion to make all decisions (discretionary management), or may prefer to approve all decisions before implementation (non discretionary management). MFG also provides investment advisory services to individuals, families and businesses where the firm makes ongoing investment recommendations but the client is responsible for determining whether or not to implement recommendations, and if they decide to do so, are responsible for actual implementation. Additionally, the firm provides project oriented and ongoing financial planning services to individuals and families where the firm offers advice or other strategic assistance in areas such as education funding, retirement planning, estate planning, risk management, employee benefits planning, tax planning, etc. When engaged to provide financial planning assistance, clients are 1       responsible for determining whether or not to implement a recommendation, and if they decide to do so, are responsible for implementation. The details of an engagement vary on a case by case basis depending on the complexity of the client’s financial situation. Generally, however, an engagement involves identification of goals and objectives, collection and analysis of data, formulation of a strategy, and preparation of a written plan. MFG also provides retirement plan services to businesses which may include plan level services such as discretionary management services, non-discretionary management services, and investment advisory services related to different types of retirement plans. When providing management services, the firm is responsible for implementing recommendations. When the firm is providing advisory services, the client is responsible for implementation of recommendations. Regardless of the services provided, each is tailored to the individual needs of a particular client (whether an individual, a family, or a business) through an assessment conducted prior to an engagement. Clients may impose restrictions related to the level of discretion granted, the types of investments used, etc. Terms of an actual engagement, including description of service, limitations and restrictions, fees, etc., are all detailed before any engagement begins in a written client agreement. Because MFG is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered 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. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients however are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. In addition to these services, the firm also provides fee-based investment management services under a “Wrap Fee Program” whereby participants in the program receive portfolio management, custodial, reporting, and clearing services for one all inclusive fee (see our “Form ADV Part 2A Appendix 1- Investment Management Wrap Fee Program Brochure”). As of 12/31/2025, MFG managed approximately $566,081,879 in assets, $559,354,347 of which was managed on a discretionary basis and $6,727,531 of which was managed on a non- discretionary basis. 2       Item 5 – Fees and Compensation Investment Management Services Fees charged for discretionary and non discretionary investment management services are negotiated prior to the engagement at a rate not to exceed 1.5%. Fees are generally calculated and charged quarterly in advance based on the average daily balance of assets under management during the preceding quarter. Fees for partial quarters are prorated based on the number of days assets are under management. Fees are generally deducted directly from client accounts, but clients may elect to alternatively pay fees by check. Services may be terminated at any time by either party with 30 days written notice to the other party, and fees will be prorated accordingly. Any payments made in advance will be prorated and refunded to the client. All management fees paid to MFG are separate and unrelated to any fees or expenses assessed by mutual funds or exchange traded funds, or to any trade commission charged by an account custodian, although trade commissions may at times be paid by MFG at the firm’s discretion. Information pertaining to fund-generated fees and expenses can be found in mutual fund and exchange traded fund prospectuses. Investment Advisory Services Fees charged for advisory services may be charged in advance or in arrears depending on the service provided. Fees are negotiated in advance, and generally range from .50% to 1.50% depending on the level of complexity of the engagement. Fee rates are based on actual services provided rather than being based on the level of assets managed as detailed above for investment management services. In some cases, fees may be deducted directly from client accounts, but clients generally are billed directly on a quarterly basis. Services may be terminated at any time by either party with 30 days written notice to the other party, and fees will be prorated accordingly. Any payments made in advance will be prorated and refunded to the client. All advisory fees paid to MFG are separate and unrelated to any fees or expenses assessed by any broker, custodian, or other outside party. 3       Financial Planning Services Fees charged for financial planning services are quoted in advance and charged at a fixed amount. Quoted fixed fees will be based on the complexity and level of service provided on a case by case basis. As mentioned above, services may include planning in areas such as education funding, retirement planning, estate planning, risk management, employee benefits planning, tax planning, etc. Since each of these areas can vary in complexity depending on the complexity of the client’s financial situation, cost will vary as well. Fees are negotiable depending on the circumstances of the engagement, location, etc. Fees are generally billed directly to the client in arrears, although a portion of which may be billed in advance. Services may be terminated at any time by either party with 30 days written notice to the other party, and fees will be prorated based on the degree to which services have been completed. Any payments made in advance will be prorated and refunded to the client. All financial planning fees paid to MFG are separate and unrelated to any fees or expenses assessed by any broker, custodian, or other outside party. Retirement Plan Services Fees charged for retirement plan services may be charged in advance or in arrears depending on the service provided. Fees may be fixed or asset based (not to exceed 1.50% annually), and are negotiable depending on the complexity of the service. Fee levels (whether fixed or asset based) are primarily based on actual services to be provided. Fees may be deducted directly from client accounts on a quarterly basis, or clients may elect to alternatively pay fees by check or wire transfer. There is a minimum annual fee of $1,000 per plan. Services may be terminated at any time by either party with 30 days written notice to the other party, and fees will be prorated accordingly. Any payments made in advance will be prorated and refunded to the client. All retirement plan fees paid to MFG are separate and unrelated to any fees or expenses assessed by any broker, custodian, or other outside party. 4       Item 6 – Performance-Based Fees and Side-By-Side Management MFG does not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client), and consequently does not simultaneously manage performance based and non performance based accounts. Item 7 – Types of Clients MFG provides services to individuals, businesses and retirement plans. For its services, MFG does not require a minimum dollar value in assets for establishing or maintaining a client’s account, but the firm reserves the right to decline engagements for various reasons including account size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss MFG’s general investment strategy, consistent with the tenets of modern portfolio theory, is to attempt to reduce risk and volatility by building globally diversified portfolios. To implement this strategy, MFG primarily uses fundamental security methods of analysis, as well as market trend and economic cycle analysis. While mutual funds and exchange traded funds are the primary investment vehicles used in or recommended for client accounts, we may also use or recommend various other investment vehicles in the implementation of our strategies, including long-term purchases (securities held at least a year), short-term purchases (securities sold within a year), trading (securities sold within 30 days), margin and options. Investing in securities involves risk of loss that clients should be prepared to bear. Such risks include market risk, interest rate risk, currency risk, and political risk, and loss of capital, among others. Additionally, certain trading strategies can affect investment performance through increased brokerage and other transactions. Each client’s propensity for risk however is thoroughly evaluated, documented, and considered throughout the portfolio implementation process. Although MFG intends to manage risk though the careful selection of investments, no investment strategy can assure a profit or avoid a loss. 5       Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to the evaluation of the firm or the integrity of its management. MFG is currently not subject to, nor has ever been subject to, any legal or disciplinary events of a material nature. Item 10 – Other Financial Industry Activities and Affiliations MFG may also offer clients advice or recommendations related to insurance products. Some associated persons of MFG are licensed insurance agents and represent various insurance companies. Any insurance product placed through associated persons would generate standard and customary insurance commissions and other compensation, a portion of which may be received by associated persons of MFG. While MFG will endeavor at all times to put the interest of clients first as part of its fiduciary duty, clients should be aware that the receipt of additional compensation creates a conflict of interest, and may affect the judgment of individuals who make recommendations. However, our clients are under no obligation to purchase products recommended by our associated persons or to purchase products through our associated persons. We believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. Item 11 – Code of Ethics Code of Ethics MFG has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. The MFG Code of Ethics describes the firm's fiduciary duties and responsibilities to clients, and details practices for reviewing the personal securities transactions of supervised persons with access to client information. The Code also requires compliance with applicable securities laws, addresses insider trading, and details possible disciplinary measures for violations. MFG will provide a complete copy of its Code of Ethics to any client upon request to the Chief Compliance Officer. 6       Trading Conflicts of Interest Individuals associated with MFG are permitted to buy or sell securities for their personal accounts identical to or different than those recommended to clients. However, no person employed by MFG is allowed to favor his or her own interest over that of a client or make personal investment decisions based on the investment decisions of advisory clients. In order to address conflicts of interest, MFG requires that associated persons with access to advisory recommendations provide annual securities holdings reports and quarterly transaction reports to the firm's Chief Compliance Officer. MFG also requires prior approval from the Chief Compliance Officer for investing in any IPOs or private placements (limited offerings). Item 12 – Brokerage Practices The Custodian and Brokers We Use We do not maintain possession of client assets. Instead, we require all client assets be maintained in an account at a non affiliated “qualified custodian,” generally a broker-dealer or bank. We are not affiliated with any particular custodian but instead all custodians are independently owned and operated. The custodian will hold your assets in a brokerage account and will be able to buy and sell securities on your behalf. While we may recommend that you use a particular custodian/broker, you will ultimately decide whether to do so and will open your account with the custodian/broker by entering into an account agreement directly with one of them. We cannot actually open accounts for you, but we can assist you in opening an account at whatever custodian/broker you decide to use. How We Select Custodians and Brokers When recommending a custodian or broker for our clients, we consider many different factors including quality of service, types of services offered, overall capability, execution quality, competitiveness of transaction costs, availability of investment research, reputation of the firm, and financial resources, among other things. In determining the reasonableness of a broker’s compensation, we consider the overall cost to you relative to the benefits you receive, both directly and indirectly, from the broker. 7       Your Brokerage and Custody Costs Our clients receive various services directly from our custodians. For our clients’ accounts that they maintain, the custodian generally does not charge separately for custody services but instead is compensated by charging commissions or other fees on trades that it executes or trades that are executed by other brokers to and from the custodial accounts. Fees applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a certain level of assets at the custodian. We feel this commitment benefits you because we expect the overall rates you pay will be lower than they might be otherwise. Since custodians often charge clients a fee for each trade that we have executed by a different broker-dealer, we have the custodians execute most trades for your account in order to minimize your trading costs. We have determined that having the custodians execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means seeking the most favorable terms for a transaction based on all relevant factors, including those listed above. Products and Services Available to Us from Brokers/Custodians The custodians provides us and our clients with access to its institutional brokerage services like trading, custody, reporting, and related services, many of which are not typically available to retail customers. The custodians also make available various support services, some of which may help us manage or administer our clients’ accounts, while others may help us manage and grow our business. Other institutional brokerage services which benefit you directly include access to a broad range of investment products, execution of securities transactions, and asset custody. The investment products available through the custodians include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. The custodians may also make available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both the custodians’ own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at the custodians. In addition to investment research, the custodians may also make available software and other technology that provide access to client account data, facilitates trade execution for multiple client accounts, provides pricing and other market data, facilitates payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. 8       The custodians may also offer other services intended to help us manage and further develop our business. These services include educational conferences and events, consulting on technology, compliance, legal, and business needs, publications and conferences on practice management and business succession, and access to employee benefits providers, human capital consultants, and insurance providers. The availability of these services from the custodians benefits us because we do not have to produce or purchase them. Of course, this may give us an incentive to recommend that you maintain your account with a particular custodian based on our interests rather than yours, which is a conflict of interest. We believe, however, that our recommendation of a custodian is in the best interests of our clients, and is primarily supported by the scope, quality, and price of the custodian’s services and not the custodian’s services that benefit only us. Aggregation of Transactions MFG may, from time to time, aggregate client orders into blocks in order to facilitate more efficient account management and execution. When aggregating orders, an average price is given to all participants in the block, or other measures are taken, in order to treat all accounts fairly. Item 13 – Review of Accounts Review of Accounts Accounts are generally reviewed on a weekly, monthly, quarterly, or semi-annual basis, depending on the type of account. Reviews may be general in nature, addressing investment objectives, risk tolerances or asset allocations, or they may be more detailed, depending on circumstances. The level of detail of the review is generally triggered by factors such as market, political, or economic conditions, or the client's individual financial situation. Clients should notify the firm of any material personal financial changes. Regular Reports Provided to Clients In addition to the monthly statements and confirmations of transaction that clients receive from the custodian, MFG may provide other reports directly to the client from time to time depending on the type of engagement. Investment management clients for example may receive periodic performance related reports. Financial planning clients may receive a planning analysis but do not receive regular reports from MFG. 9       MFG urges clients to carefully review custodial statements and compare them to the reports which we may provide. Item 14 – Client Referrals and Other Compensation MFG does not compensate any outside parties for client referrals, nor do we receive any compensation or non cash economic benefit for client referrals. MFG does however receive economic benefits from our custodian in the form of the support products and services that are made available to us and to other independent investment advisors. These products and services, how they benefit us, and the related conflicts of interest are described in Item 12 above. The firm may also on limited occasions receive travel expense reimbursements for industry meetings related to market analysis, investment strategies, and practice management and various cost reimbursements from platform providers for client investment related seminars. The availability to us of these economic benefits is not based on us giving particular investment advice, such as buying or recommending particular securities for our clients. Furthermore, our representatives are required to make all investment decisions and recommendations based solely on the interests of the applicable client. Item 15 – Custody As noted in Item 12, MFG recommends that clients’ assets be held by a qualified custodian. Although we do not hold assets, we may have limited control in some instances to trade on your behalf, to deduct our advisory fees from your account with your authorization, or to request disbursements to you (although various types of written authorizations are required depending on the type of disbursements). You will receive account statement directly from your custodian at least quarterly, which will be sent to the email or postal mailing address you provide. MFG urges clients to carefully review custodial statements and compare them to any account reports that we might provide. Item 16 – Investment Discretion MFG will accept discretionary authority to manage securities accounts on behalf of clients, although we will also accept non discretionary accounts. 10       When granted authority to manage accounts, MFG customarily has the authority to determine which securities and the amounts that are bought or sold. Any discretionary authority accepted by MFG however is subject to the client’s risk profile and investment objectives, and may be limited by any other limitations provided by the client in writing. MFG will not exercise any discretionary authority until it has been given authority to do so in writing. Such authority is granted in the written agreement between MFG and the client, and in the written agreement with the third party custodian. Item 17 – Voting Client Securities MFG does not vote proxies on behalf of clients. Item 18 – Financial Information Registered investment advisers are required in some cases to provide certain financial information and or disclosures about their financial condition. For example, if the firm requires prepayment of fees for six months in advance, has custody of client funds, or has a condition that is reasonably likely to impair its ability to meet it contractual commitments to its clients, it must provide financial information and make disclosures. MFG has no financial or operating conditions which trigger such additional reporting requirements. 11      

Item 1 – Cover Page Form ADV Part 2A Appendix 1 - Investment Management Wrap Fee Program Brochure Midwest Financial Group, LLC Main Office: 7400 W 130th Street, Suite 100 Overland Park, KS 66213 (913) 696-0041 Topeka Office: 7630 SW 21st Street, Topeka, KS 66615 (785) 290-0007 www.midwestfinancialkc.com February 28, 2026 This Investment Management Wrap Fee Program Brochure provides information about the qualifications and business practices of Midwest Financial Group, LLC (MFG). If you have any questions about the contents of this Brochure, please contact us at (913) 696-0041. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. MFG is a registered investment adviser. Registration as an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information from which you can determine whether to hire or retain an adviser. Additional information about MFG is also available via the SEC’s web site www.adviserinfo.sec.gov. i  Item 2 – Material Changes This Brochure, dated February 28, 2026, represents the annual amendment to the Wrap Fee Program Brochure for Midwest Financial Group, LLC. Since the filing of the firm’s annual Wrap Brochure on March 06, 2025 we have made various updates, but no material changes were made. Pursuant to SEC Rules, we will deliver to you a summary of any material changes to this and subsequent Brochures within 120 days of the close of our fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. All such information will be provided to you free of charge. Currently, our Brochures may be requested by contacting us at (913) 696-0041. Additional information about MFG is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with MFG who are registered as investment adviser representatives of the firm. ii  Item 3 - Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 – Material Changes ............................................................................................................................ ii Item 3 - Table of Contents ........................................................................................................................... iii Item 4 – Services, Fees and Compensation ................................................................................................... 1 Item 5 – Account Requirements and Types of Clients ................................................................................. 2 Item 6 – Portfolio Manager Selection and Evaluation .................................................................................. 2 Item 7 – Client Information Provided to Portfolio Managers ....................................................................... 4 Item 8 – Client Contact with Portfolio Managers ......................................................................................... 4 Item 9 – Additional Information ................................................................................................................... 5 Brochure Supplement(s) iii  Item 4 – Services, Fees and Compensation Investment Management Services Investment management services are provided through this Wrap Fee Program where participants will receive portfolio management, custodial, reporting, and clearing services for one all inclusive fee. When providing investment management services, the firm not only makes recommendations related to investments, but also implements these recommendations and provides ongoing monitoring and reporting. MFG will assist the client in assessing their current financial situation, financial goals and attitudes towards risk, and will then recommend an appropriate asset allocation. Once an asset allocation is approved by a client, the individual portfolios will be managed by the advisory representative on a discretionary or non-discretionary basis. Clients may elect to give the firm discretion to make all decisions (discretionary management), or may prefer to approve all decisions before implementation (non-discretionary management). Portfolios will be invested in a variety of investment classes, including stocks, bonds, mutual funds, and exchange traded funds, among others. The advisory representative will recommend changes to a client's portfolio based on market, economic, or political circumstances, and the individual characteristics of the securities in the portfolio. Annual wrap program fees range up to 1.5% and are negotiated based on the complexity of the engagement prior to the start of the engagement. Fees are generally calculated and charged quarterly in advance based on the average daily balance of assets under management during the preceding quarter. Fees for partial quarters are prorated based on the number of days assets are under management. Fees are typically deducted directly from the client’s account. Wrap programs may be terminated by either party at any time with 30 days written notice to the other party. Upon termination, any unearned prepaid fees will be refunded. Wrap program fees include investment management and brokerage charges, but are separate from charges that may be imposed by third parties, such as custodial fees, expense or other charges imposed directly by mutual funds or exchange traded funds, margin costs, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund transfer fees, and other fees and taxes on brokerage accounts and securities transactions. MFG does not hold client assets. Instead, we require all client assets be maintained in an account at a non-affiliated “qualified custodian,” generally a broker-dealer or bank. The 1  custodian will hold your assets in a brokerage account and will be able to buy and sell securities on your behalf. For our clients’ accounts that the custodian maintains, the custodian generally does not charge separately for custody services but instead is compensated by charging commissions or other fees on trades that it executes or trades that are executed by other brokers to and from client accounts. Fees applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a certain level of assets at the custodian. We feel this commitment benefits you because we expect the overall rates you pay will be lower than they might be otherwise. Services purchased through this program may cost clients less than purchasing similar services from the firm on a stand-alone basis, in that brokerage costs (if any) are paid on behalf of the client through the Wrap Program. However, since MFG absorbs certain transaction costs in Wrap Program accounts, we may have a financial incentive not to place trade orders in those accounts, so clients should be aware that this conflict of interest exists. Clients are encouraged to compare the costs they may incur in this Wrap Program vs. a typical investment management account, as the anticipated level of trading activity will impact the costs associated with each type of arrangement. Item 5 – Account Requirements and Types of Clients MFG provides advisory services to individuals, businesses and retirement plans. The firm has not set a minimum investment amount to open a Wrap Program account; however we reserve the right to decline certain accounts if we feel a relationship would not be beneficial or economical for the client. Item 6 – Portfolio Manager Selection and Evaluation MFG functions not only as the Wrap Program sponsor but also as the portfolio manager. No outside portfolio managers are used. Since MFG functions as the Wrap Program’s sole portfolio manager, a conflict of interest exists because MFG pays certain client trading costs from its fee. This may give us an incentive to make recommendations that cost us less, or to recommend fewer trades, regardless of the benefit to our client. However, we feel that the cost of trading is not material enough to influence our 2  investment recommendations, and we feel that the harm to our clients and our reputation far outweighs any potential cost savings. It is our policy to always act in the best interests of our clients. Advisory Business In addition to providing investment management services under this Wrap Program, MFG also provides investment management and advisory services on a stand-alone basis (See Form ADV Part 2A Brochure). We also provide advice on strategies for education funding, retirement planning, estate planning, risk management, employee benefits planning and tax planning, as well as general financial planning and consultation services. Whether services are provided through this Wrap Program or on a stand-alone basis, MFG accepts discretionary and non-discretionary authority, and services are tailored to the individual needs of clients. Clients can also impose restrictions on investing in certain securities or types of securities. Because MFG is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered 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. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients however are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. Performance Based Fees and Side by Side Management MFG does not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) and consequently does not simultaneously manage performance based and not performance based accounts. Methods of Analysis, Investment Strategies, and Risk of Loss MFG’s general investment strategy, consistent with the tenets of modern portfolio theory, is to attempt to reduce risk and volatility by building globally diversified portfolios. To implement this strategy, MFG primarily uses fundamental security methods of analysis, as well as market 3  trend and economic cycle analysis. While mutual funds and exchange traded funds are the primary investment vehicles used in or recommended for client accounts, we may also use or recommend various other investment vehicles in the implementation of our strategies, including long-term purchases (securities held at least a year), short-term purchases (securities sold within a year), trading (securities sold with 30 days), margin and options. Investing in securities involves risk of loss that clients should be prepared to bear. Such risks include market risk, interest rate risk, currency risk, and political risk, and loss of capital, among others. Additionally, certain trading strategies can affect investment performance through increased brokerage and other transactions. Each client’s propensity for risk however is thoroughly evaluated, documented, and considered throughout the portfolio implementation process. Although MFG intends to manage risk though the careful selection of investments, no investment strategy can assure a profit or avoid a loss. Voting Client Securities MFG does not vote proxies on behalf of clients. Item 7 – Client Information Provided to Portfolio Managers As the Wrap Program’s sole portfolio manager, MFG does not communicate client information to outside portfolio managers. Item 8 – Client Contact with Portfolio Managers MFG does not use outside portfolio managers, and consequently has no restrictions related to client contact with outside managers. 4  Item 9 – Additional Information Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to the evaluation of the firm or the integrity of its management. MFG is currently not subject to, nor has ever been subject to, any legal or disciplinary events of a material nature. Other Financial Industry Activities and Affiliations MFG may also offer clients advice or recommendations related to insurance products. Some associated persons of MFG are licensed insurance agents and represent various insurance companies. Any insurance product placed through associated persons will generate standard and customary insurance commissions and other compensation, a portion of which may be received by associated persons of MFG. While MFG will endeavor at all times to put the interest of clients first as part of its fiduciary duty, clients should be aware that the receipt of additional compensation creates a conflict of interest and may affect the judgment of individuals who make recommendations. However, our clients are under no obligation to purchase products recommended by our associated persons or to purchase products through our associated persons. We believe that our recommendations are in the best interests of our clients, and are consistent with our clients’ needs. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MFG has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. The MFG Code of Ethics describes the firm's fiduciary duties and responsibilities to clients, and details practices for reviewing the personal securities transactions of supervised persons with access to client information. The Code also requires compliance with applicable securities laws, addresses insider trading, and details possible disciplinary measures for violations. MFG will provide a complete copy of its Code of Ethics to any client upon request to the Chief Compliance Officer. MFG also requires prior approval from the Chief Compliance Officer for investing in any IPOs or private placements (limited offerings). Review of Accounts Accounts are generally reviewed on a weekly, monthly, quarterly, or semi-annual basis, depending on the type of account. Reviews may be general in nature, addressing investment objectives, risk tolerances or asset allocations, or they may be more detailed, depending on 5  circumstances. The level of detail of the review is generally triggered by factors such as market, political, or economic conditions, or the client's individual financial situation. Clients should notify the firm of any material personal financial changes. In addition to the monthly statements and confirmations of transaction that clients receive from the custodian, MFG may provide other reports directly to the client from time to time depending on the type of engagement. Investment management clients for example may receive periodic performance related reports. Financial planning clients may receive a planning analysis but do not receive regular reports from MFG. MFG urges clients to carefully review custodial statements and compare them to the reports which we may provide. Client Referrals and Other Compensation MFG does not compensate any outside parties for client referrals, nor do we receive any compensation or non-cash economic benefit for client referrals. MFG does however receive economic benefits from our custodian in the form of the support products and services that are made available to us and to other independent investment advisors. These products and services, how they benefit us, and the related conflicts of interest are described in Item 12 of Form ADV Part 2A Brochure. The firm may also on limited occasions receive travel expense reimbursements for industry meetings related to market analysis, investment strategies, and practice management and various cost reimbursement from platform providers for client investment related seminars. The availability to us of these economic benefits is not based on us giving particular investment advice, such as buying or recommending particular securities for our clients. Furthermore, our representatives are required to make all investment decisions and recommendations based solely on the interests of the applicable client. Financial Information Registered investment advisers are required in some cases to provide certain financial information and or disclosures about their financial condition. For example, if the firm requires prepayment of fees for six months in advance or has custody of client funds it is required to disclose any condition that is reasonably likely to impair its ability to meets it contractual commitments to its clients. MFG has no financial or operating conditions which trigger such additional reporting requirements. 6