Overview

Assets Under Management: $552 million
Headquarters: SANTA BARBARA, CA
High-Net-Worth Clients: 148
Average Client Assets: $3.2 million

Frequently Asked Questions

OMEGA FINANCIAL GROUP, LLC charges 1.50% on the first $0 million, 1.25% on the next $1 million, 1.00% on the next $2 million, 0.90% on the next $5 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #164147), OMEGA FINANCIAL GROUP, LLC is subject to fiduciary duty under federal law.

OMEGA FINANCIAL GROUP, LLC is headquartered in SANTA BARBARA, CA.

OMEGA FINANCIAL GROUP, LLC serves 148 high-net-worth clients according to their SEC filing dated February 19, 2026. View client details ↓

According to their SEC Form ADV, OMEGA FINANCIAL GROUP, LLC offers financial planning, portfolio management for individuals, portfolio management for institutional clients, and educational seminars and workshops. View all service details ↓

OMEGA FINANCIAL GROUP, LLC manages $552 million in client assets according to their SEC filing dated February 19, 2026.

According to their SEC Form ADV, OMEGA FINANCIAL GROUP, LLC serves high-net-worth individuals and institutional clients. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Educational Seminars

Fee Structure

Primary Fee Schedule (OFG - FORM ADV PART 2A - FIRM BROCHURE)

MinMaxMarginal Fee Rate
$0 $500,000 1.50%
$500,001 $1,000,000 1.25%
$1,000,001 $2,000,000 1.00%
$2,000,001 $5,000,000 0.90%
$5,000,001 $10,000,000 0.75%
$10,000,001 $15,000,000 0.65%
$15,000,001 and above 0.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,750 1.38%
$5 million $50,750 1.02%
$10 million $88,250 0.88%
$50 million $295,750 0.59%
$100 million $545,750 0.55%

Clients

Number of High-Net-Worth Clients: 148
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 86.15%
Average Client Assets: $3.2 million
Total Client Accounts: 974
Discretionary Accounts: 969
Non-Discretionary Accounts: 5
Minimum Account Size: $1,000,000
Note on Minimum Client Size: $1,000,000

Regulatory Filings

CRD Number: 164147
Filing ID: 2053311
Last Filing Date: 2026-02-19 22:25:42

Form ADV Documents

Additional Brochure: OFG - FORM ADV PART 2A - FIRM BROCHURE (2026-02-19)

View Document Text
ITEM 1. COVER PAGE FOR PART 2A OF FORM ADV: FIRM BROCHURE FEBRUARY 2026 OMEGA FINANCIAL GROUP, LLC 812 ANACAPA STREET SANTA BARBARA, CA 93101 P: (805) 617-4363 FIRM CONTACT: BRYAN REINHARD, CHIEF COMPLIANCE OFFICER FIRM WEBSITE ADDRESS: WWW.OMEGAFINGROUP.COM This brochure provides information about the qualifications and business practices of Omega Financial Group, LLC. If you have any questions about the contents of this brochure, please contact Bryan Reinhard, Chief Compliance Officer, at (805) 617-4363 or by email at bryan.reinhard@omegafingroup.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 Omega Financial Group, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD#: 164147. Please note that the use of the term “registered investment adviser” and description of Omega Financial Group, LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees. ITEM 2. MATERIAL CHANGES TO OUR PART 2A OF FORM ADV: FIRM BROCHURE Omega Financial Group, LLC is required to advise you of any material changes to our Firm Brochure (“Brochure”) from our last annual update, identify those changes on the cover page of our Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Brochure. We must state clearly that we are discussing only material changes since the last annual update of our Brochure, and we must provide the date of the last annual update of our Brochure. Please note that we do not have to provide this information to a client or prospective client who has not received a previous version of our brochure. Previous Annual Amendment Filing Date: 02/10/2025 Since our last annual amendment filing, we do not have any material changes to report. 2 ITEM 3. TABLE OF CONTENTS Section: Page(s): Item 1. Cover Page ................................................................................................................................................................... 1 Item 2. Material Changes ...................................................................................................................................................... 2 Item 3. Table Of Contents .................................................................................................................................................... 3 Item 4. Advisory Business ................................................................................................................................................... 4 Item 5. Fees And Compensation ....................................................................................................................................... 6 Item 6. Performance-Based Fees And Side-By-Side Management ..................................................................... 8 Item 7. Types Of Clients ....................................................................................................................................................... 8 Item 8. Methods Of Analysis, Investment Strategies And Risk Of Loss ............................................................ 9 Item 9. Disciplinary Information .................................................................................................................................... 11 Item 10. Other Financial Industry Activities And Affiliations ............................................................................ 11 Item 11. Code Of Ethics ...................................................................................................................................................... 11 Item 12. Brokerage Practices ........................................................................................................................................... 12 Item 13. Review Of Accounts ........................................................................................................................................... 16 Item 14. Client Referrals And Other Compensation ............................................................................................... 16 Item 15. Custody ................................................................................................................................................................... 17 Item 16. Investment Discretion ...................................................................................................................................... 18 Item 17. Voting Client Securities .................................................................................................................................... 19 Item 18. Financial Information ....................................................................................................................................... 19 3 ITEM 4. ADVISORY BUSINESS Omega Financial Group, LLC is dedicated to providing clients with a wide array of investment advisory services. We specialize in comprehensive portfolio management offered through our Wrap Fee Program, non-wrap Asset Management, Financial Planning and Consulting, and Retirement Plan Consulting services. Our firm is a limited liability company formed in the State of California in 2009. We have been a Registered Investment Adviser since going independent in 2012. Our firm is owned as follows: Dylan B. Minor – Eighty-percent owner Bryan W. Reinhard – Twenty-percent owner Description of the Types of Advisory Services We Offer Asset Management: We emphasize continuous and regular account supervision. As part of our Asset Management service, we provide financial planning/financial consulting to clients alongside asset management. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We generally create a portfolio consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Financial Planning and Consulting: We provide a variety of Financial Planning and Consulting services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-advisory related services. For written financial planning engagements, we provide our clients with a written summary of their financial 4 situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. Retirement Plan Consulting: Our firm provides Retirement Plan Consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment options, plan structure and participant education. Retirement Plan Consulting services typically include: • • Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. • • Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk. Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. When providing Retirement Plan Consulting services, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Newsletter: We offer our clients complimentary articles that include information regarding updates on the markets, planning, retirement and other relevant topics relating to the financial industry. Tailoring of Advisory Services We offer individualized investment advice to all clients. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio, however, 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. 5 Participation in Wrap Fee Programs We do not currently offer a Wrap Fee Program to new clients. We only offer our Wrap Fee Program to legacy clients who are already in the Wrap Fee Program. In addition to our Brochure, legacy clients in the Wrap Fee Program will receive Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) of our Brochure. Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different fashion than non-wrap fee accounts. As further described in our Wrap Fee Program Brochure, we receive a portion of the wrap fee for our services. Regulatory Assets Under Management We managed $549,914,757 on a discretionary basis and $2,498,897 on a non-discretionary basis for a total of $552,413,654 as of December 31st, 2025. ITEM 5. FEES AND COMPENSATION Description of How We Are Compensated for Our Advisory Services Provided to You Asset Management: Assets Under Management First $500,000 Next $500,000 $1,000,000 - $2,000,000 $2,000,000 - $5,000,000 $5,000,000 - $10,000,000 $10,000,000 - $15,000,000 $15,000,000 – $9,999,999,999 Annual Fee % 1.50% 1.25% 1.00% 0.90% 0.75% 0.65% 0.50% Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Legacy clients may be subject to an advisory fee of 1.00% of assets under management for our Asset Management service. Legacy accounts over $2,000,000 may be subject to a lower fee percentage based on the complexity of the services offered. Our firm requires a minimum account balance of $1,000,000 for our Asset Management service. This minimum account balance requirement is negotiable and may be waived for individuals who are active accumulators. Asset Management fees will be payable monthly in advance upon deposit of any funds or securities in the account. The first payment will be prorated to cover the period from the date the account is opened through the end of the first calendar month. Thereafter, the fee will be based on the account value on the last business day of the preceding calendar month and will be due the following business day. The client may make additions to the account at any time. Additional assets received into the account after it is opened will be included in the fee calculation for the following month. The client may withdraw account assets upon notice to the Adviser, subject to the usual and customary securities settlement procedures. No fee adjustments will be made for partial withdrawals or for account appreciation or depreciation within a billing period. Unless indicated otherwise in writing, our firm bills on cash. 6 Upon the client’s authorization, a qualified custodian will deduct advisory fees from the client’s account and pay directly to our firm the management fee for each calendar year month. The custodian will send clients a monthly statement showing all amounts paid from the account, including all management fees paid by the custodian to our firm. Financial Planning and Consulting: We charge on an hourly or flat fee basis for Financial Planning and Consulting services. The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. Our hourly fees range from $150 to $950 for financial advisors. Flat fees generally range from $1,500 to $20,000. We require a retainer of at least $1,000 of the ultimate Financial Planning or Consulting fee with the remainder of the fee directly billed to you and due to us within thirty (30) days of your financial plan being delivered or consultation rendered to you. All Financial Plans will be delivered to clients in less than 6 months. If the Planner estimates that a Financial Plan will exceed 6 months to complete, the retainer will not surpass $1,200. Retirement Plan Consulting: Our Retirement Plan Consulting services are billed on an hourly basis, flat fee basis, or based on the percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Our hourly fees range from $150 to $950. Our flat fees range from $1,500 to $20,000. Fees based on a percentage of managed Plan assets will not exceed 1.00%. The fee-paying arrangements for Retirement Plan Consulting service will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. Clients will be invoiced directly for the fees. Newsletter: Our articles are available through our firm’s website at no charge. Other Types of Fees or Expenses Non-Wrap Clients will incur transaction fees for trades executed by their chosen custodian. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds. Fidelity Brokerage Services (“Fidelity”) does not charge transaction fees for U.S. listed equities and exchange traded funds to clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Clients who custody assets with Fidelity that do not meet either criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds. Legacy wrap fee clients will receive our Wrap Fee Program Brochure and will not incur transaction costs for trades. More information about this is disclosed in our separate Wrap Fee Program Brochure. Clients may also pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire 7 transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Terminations and Refunds Either party may terminate the Asset Management Agreement signed with our firm at any time by providing written notice to the other party. Upon notice of termination, our firm will process a pro-rata refund of any unearned portion of the advisory fees charged in advance. Financial Planning & Consulting clients may terminate their agreement at any time before the delivery of a financial plan by providing written notice. For the purpose of calculating refunds, all work performed by us up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will receive a pro-rata refund of any unearned fees based on the time and effort expended by our firm. Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written notice to the other party. Full refunds will only be made in cases where cancellation occurs within 5 business days of signing an agreement. After 5 business days from initial signing, either party must provide the other party 30 days written notice to terminate billing. Billing will terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work completed by our firm on behalf of the client. Clients will incur charges for bona fide advisory services rendered up to the point of termination (determined as 30 days from receipt of said written notice) and such fees will be due and payable. Commissionable Securities Sales We do not sell securities for a commission. ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance fees to our clients. ITEM 7. TYPES OF CLIENTS & ACCOUNT REQUIREMENTS We have the following types of clients: • Individuals and High Net Worth Individuals • Trusts, Estates or Charitable Organizations • Corporations, Limited Liability Companies and/or Other Business Types Our firm requires a minimum account balance of $1,000,000 for our Asset Management service. This minimum account balance requirement is negotiable and may be waived for individuals who are active accumulators. 8 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis: We use the following methods of analysis in formulating our investment advice and/or managing client assets: Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Investment Strategies We Use: We use our proprietary STATES OF THE WΩRLD WEALTH MANAGEMENT® and ΩPTIMIZED WEALTH INTEGRATION® investment strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations. Our strategies are based on possible known outcomes rather than attempting to predict particular outcomes of financial markets. To do this, we allocate a client’s holdings across different assets that have returns tied explicitly to different states (i.e. possible outcomes) of the financial world. For example, we have a strategy designed to survive precipitous market drops (i.e., PRΩTECTED VALUE®), another to earn modest returns during flat market periods (i.e., TΩTAL RETURN®), and another to thrive during strong market return periods (i.e., DIFFUSSIΩN™). Our wealth management services are thus in sharp contrast to the conventional approach of simply assuming some return across assets and holding a static asset allocation of various traditional investments (e.g., 60% S&P500 and 40% intermediate US bonds). PRΩTECTED VALUE® - This strategy is designed to protect a portfolio during steep declines in the stock market. We use call options and short term debt instruments to create a loss floor on a portfolio, typically targeted, depending on the client, in the 0‐15% range. On the upside, we target a capture of 40‐60% of the positive return. The name of the strategy is derived from the 9 mathematical concept of absolute value‐‐‐converting negative values into positive ones while still maintaining the sign of positive values. TΩTAL RETURN® - This strategy is designed to garner modest returns in those environments where stocks have roughly a zero return. This is accomplished through a proprietary covered put and covered call writing strategy on the S&P500 stock market index. The ratio of puts and calls changes dynamically, depending on market sentiment. Thus, returns and losses are muted but income is enhanced such that in those zero return environments, clients still potentially earn modest returns, which are targeted at 4‐6% per annum—hence, the strategy name. DIFFUSSIΩN™ - This strategy creates an investment that tends to fall in line with the stock market when it falls in value, but tends to increase at a greater rate when the stock market increases in value. In particular, the strategy is a unique blend of short‐term investments and smaller capitalization equity investments. This creates a “barbell” of risk that yields a similar overall risk to the stock market but with improved upside. Thus, the positive returns become more diffuse, as the name of the strategy suggests. Additional Proprietary Methods Further, we combine advances in academia with financial practice to better form strategic financial and investment advice for clients. This takes the form of using certain methods (e.g., customized monte carlo simulations and econometric analysis) and unique data (e.g., proprietary and academic research sources) from top tier universities. This approach enables Omega to tie all of the financial pieces of the puzzle together when greater complexity is involved. Risk of Loss: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask us any questions you may have. ESG Investing - ESG Investing maintains a focus on Environmental, Social, and Governance issues. ESG investing may be referred to in many different ways, such as sustainable investing, socially responsible investing, and impact investing. ESG practices can include, but are not limited to, strategies that select companies based on their stated commitment to one or more ESG factors; for example, companies with policies aimed at minimizing their negative impact on the environment, social issues, or companies that focus on governance principles and transparency. ESG practices may also entail screening out companies in certain sectors or that, in the view of the investor, demonstrate poor management of ESG risks and opportunities or are involved in issues that are contrary to the investor's own principles. Variability and imprecision of industry ESG definitions and terms can create confusion among investors if investment advisers and funds have not clearly and consistently articulated how they define ESG criteria and how they use ESG-related terms, especially when offering products or services to retail investors. Additionally, actual portfolio management practices of investment advisers and funds may not be consistent with their disclosed ESG investing processes or investment goals. 10 Description of Material, Significant, or Unusual Risks We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to asset management, as applicable. ITEM 9. DISCIPLINARY INFORMATION There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A representative of our firm is an insurance agent/broker. He may offer insurance products and receive normal and customary fees as a result of insurance sales. A conflict of interest may arise as these insurance sales may create an incentive to recommend products based on the compensation that he may earn. Dylan Minor, Bryan Reinhard, and Robert Schultz are managing members of Argos Global Advisors, LLC (CRD# 287672), a related registered investment adviser that manages the Argos Total Return Fund, LP. Accredited investors of Omega Financial Group, LLC may be solicited to participate in the Argos Total Return Fund, LP. An investment in the private fund involves a high degree of risk and should only be considered by sophisticated investors able to assume the risks of loss (including the risk of loss of such investor’s entire investment) and illiquidity inherent with these types of investments. This offering does not waive our firm’s fiduciary duty to its clients or infringe upon any clients right to remedy under state or federal laws. ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is 11 considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities within 48 hours of buying or selling for our clients. If related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. ITEM 12. BROKERAGE PRACTICES Our firm has an arrangement with Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”) and National Financial Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity"). Schwab and Fidelity offer independent investment advisers non-soft dollar services, which include custody of securities, trade execution, clearance and settlement of transactions. We may receive some non-soft dollar benefits from Schwab and Fidelity through our participation in their programs. Schwab and Fidelity also make certain research and brokerage services available at no additional cost to our firm. These services include certain research and brokerage services, including research services obtained directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided to our firm may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Schwab and Fidelity to our firm in the performance of our investment decision-making responsibilities. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. We may have an incentive to continue to use or expand the use of Schwab’s or Fidelity’s services. Our firm examined this potential conflict of interest when we chose to enter into these relationships and we have determined that the relationships are in the best interest of our firm’s clients and satisfies our client obligations, including our duty to seek best execution. 12 Schwab and Fidelity charge brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for debt securities transactions). Schwab and Fidelity enable us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab and Fidelity commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by Schwab and Fidelity may be higher or lower than those charged by other custodians and broker- dealers. Custody & Brokerage Costs Schwab and Fidelity generally do not charge a separate fee for custody services, but are compensated by charging commissions or other fees to clients on trades that are executed or that settle into the Schwab or Fidelity account. For some accounts, Schwab and Fidelity may charge your account a percentage of the dollar amount of assets in the account in lieu of commissions. Commission rates and/or asset-based fees applicable to client accounts charged by Schwab or Fidelity were negotiated based on our firm’s commitment to maintain a minimum threshold of assets statement equity in accounts at Schwab or Fidelity. This commitment benefits clients because the overall commission rates and/or asset-based fees paid are lower than they would be if our firm had not made the commitment. In addition to commissions or asset-based fees Schwab and Fidelity charge a flat dollar amount as a “prime broker” or “trade away” fee for each trade that our firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a Schwab or Fidelity account. These fees are in addition to the commissions or other compensation paid to the executing broker-dealer. Because of this, in order to minimize client trading costs, our firm has Schwab or Fidelity execute most trades for the accounts. Products & Services Available from Schwab Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like ours. They provide our firm and clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help manage or administer our client accounts while others help manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (our firm does not have to request them) and at no charge as long as out firm keeps a total of at least $10 million of client assets in accounts at Schwab. If our firm has less than $10 million in client assets at Schwab, our firm may be charged quarterly service fees. Here is a more detailed description of Schwab’s support services: Services that Benefit Clients Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which our firm might not otherwise have access to or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). 13 Services that May Not Directly Benefit Clients Schwab also makes available other products and services that benefit our firm but may not directly benefit clients or their accounts. These products and services assist in managing and administering our client accounts. They include investment research, both Schwab’s and that of third parties. This research may be used to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; facilitates payment of our fees from our clients’ accounts; and • • provides pricing and other market data; • • assists with back-office functions, recordkeeping, and client reporting. Schwab Advisor Services may also reimburse Transfer of Account Exit Fees for client accounts transferred to Schwab from September 2016 to January 2017. Services that Generally Benefit Only Our Firm Schwab also offers other services intended to help manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • educational conferences and events; • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, Schwab will arrange for third- party vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other benefits, such as occasional business entertainment for our personnel. Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance the client experience, help clients reach their goals and put client interests before that of our firm or associated persons. Our Interest in Schwab’s Services The availability of these services from Schwab benefits our firm because our firm does not have to produce or purchase them. Our firm does not have to pay for Schwab’s services so long as a total of at least $10 million of client assets in accounts are kept at Schwab. However, to the extent our firm recommends you use Schwab for such services, it is because we believe that it is in your best interest to do so based on the quality and pricing of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services provided by Schwab. Our firm does not believe that maintaining at least $10 million in assets at Schwab in order to avoid paying Schwab quarterly service fees presents a material conflict of interest. 14 Client Brokerage Commissions Although the non-soft dollar investment research products and services that may be obtained by our firm will generally be used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. Brokerage for Client Referrals Our firm does not use client brokerage to compensate or otherwise reward brokers for client referrals. Directed Brokerage Neither we nor any of our firm’s related persons have discretionary authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Permissibility of Client-Directed Brokerage We allow clients to direct brokerage. However, we may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. Aggregation of Purchase or Sale We perform investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when we believe that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. 15 ITEM 13. REVIEW OF ACCOUNTS We review accounts on at least a quarterly basis for our Asset Management clients. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. Financial planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the service. Our firm also provides ongoing services where clients are met with upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not receive written or verbal updated reports regarding their plans unless they choose to engage our firm for ongoing services. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Verbal reports to clients take place on at least an annual basis when we contact clients for our Asset Management service. Financial planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post-financial plan meeting or update to their initial written financial plan. In addition, written reports will periodically be made available, depending on the complexity of the client situation. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION Our firm does not receive any compensation from National Financial Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity"). Our firm may recommend that clients establish brokerage accounts with Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”), registered broker-dealers, Members SIPC, to maintain custody of Clients’ assets and to effect trades for their accounts. Our firm is independently owned and operated and not affiliated with Schwab. Our firm may also recommend that Clients establish accounts with firms other than Schwab. Our firm places trades for its Clients' accounts subject to its duty to seek best execution and its other fiduciary duties. Our firm may use broker-dealers other than Schwab to execute trades for client accounts maintained at Schwab, but this practice may result in additional costs to clients so that we are more likely to place trades through Schwab rather than other broker-dealers. Schwab's execution quality may be different than other broker-dealers. For our client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction- 16 related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Some of the products, services and other benefits provided by Schwab benefit us and may not benefit our firm's client accounts. Our recommendation/requirement that a client place assets in Schwab's custody may be based in part on benefits Schwab provides to us, and not solely on the nature, cost or quality of custody and execution services provided by Schwab. Schwab also makes available to our firm other products and services that benefit us but may not benefit clients’ accounts. These benefits may include national and regional educational events organized and/or sponsored by Schwab Institutional. Other potential benefits may include occasional business entertainment of personnel of our firm by Schwab Institutional personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of our fees from its clients’ accounts, and assist with back- office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of our firm’s accounts, including accounts not maintained at Schwab Institutional. Schwab Institutional also makes available to us other services intended to help our firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to our firm by independent third parties. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to us. While, as a fiduciary, our firm endeavors to act in its clients’ best interests, our recommendation/requirement that clients maintain their assets in accounts at Schwab may be based in part on the benefit to our firm of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Referral Fees: In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). ITEM 15. CUSTODY Affiliated Fund Managers: Our firm is deemed to have custody of client cash and securities invested in the Argos Total Return Fund, LP (the “Fund”) because representatives of our firm are managing members of Argos Global Advisors, LLC. In compliance with SEC Rule 206(4)-2(b)(4)(i), Argos Global Advisors, LLC sends a financial statement, audited by a registered Public Company Accounting Oversight Board 17 (“PCAOB”) accountant, to each Fund investor within 120 days of the Fund’s fiscal year end. By ensuing these steps are followed, our firm’s annual surprise examination requirement is satisfied. Deduction of Advisory Fees: All of our clients receive at least quarterly account statements directly from their custodians. Upon opening an account with a qualified custodian on a client's behalf, we promptly notify the client in writing of the qualified custodian's contact information. If we decide to also send account statements to clients, such notice and account statements include a legend that recommends that the client compare the account statements received from the qualified custodian with those received from our firm. Third Party Money Movement: The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodians: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. We encourage our clients to raise any questions with us about the custody, safety, or security of their assets. The custodians we do business with will send you independent account statements listing your account balance(s), transaction history, and any fee debits or other fees taken out of your account. ITEM 16. INVESTMENT DISCRETION Clients have the option of providing our firm with investment discretion on their behalf, pursuant to a signed client agreement. By granting investment discretion, we are authorized to execute securities transactions, which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Limitations may be imposed by the 18 client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. ITEM 17. VOTING CLIENT SECURITIES We do not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. ITEM 18. FINANCIAL INFORMATION We are not required to provide financial information to our clients because: • We do not require the prepayment of more than $1,200 in fees when services cannot be • rendered within 6 (six) months. In compliance with SEC Rule 206(4)-2(b)(4)(i), Argos Global Advisors, LLC sends a financial statement, audited by a registered PCAOB accountant, to each Fund investor within 120 days of the Fund’s fiscal year end. • We do not have a financial condition or commitment that impairs its ability to meet contractual and fiduciary obligations to clients. • We have never been the subject of a bankruptcy proceeding. 19

Primary Brochure: OFG - FORM ADV PART 2A APPENDIX 1 - WRAP FEE BROCHURE (2026-02-19)

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ITEM 1. COVER PAGE FOR PART 2A APPENDIX 1 OF FORM ADV: WRAP FEE PROGRAM BROCHURE FEBRUARY 2026 Omega Financial Group’s Wrap Fee Program Sponsored By: 812 ANACAPA STREET SANTA BARBARA, CA 93101 FIRM CONTACT: BRYAN REINHARD, CHIEF COMPLIANCE OFFICER FIRM WEBSITE ADDRESS: WWW.OMEGAFINGROUP.COM This Wrap Fee Program brochure provides information about the qualifications and business practices of Omega Financial Group, LLC. If you have any questions about the contents of this brochure, please contact Bryan Reinhard, Chief Compliance Officer, at (805) 617-4363 or by email at bryan.reinhard@omegafingroup.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 Omega Financial Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD#: 164147. Please note use of the term “registered investment adviser” and description of Omega Financial Group, LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates which advise you for more information on the qualifications of our firm and its employees. ITEM 2. MATERIAL CHANGES TO FORM ADV PART 2A APPENDIX 1: WRAP FEE PROGRAM BROCHURE Omega Financial Group, LLC is required to advise you of any material changes to our Wrap Fee Program Brochure (“Wrap Brochure”) from our last annual update, identify those changes on the cover page of our Wrap Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Wrap Brochure. We must state clearly that we are discussing only material changes since the last annual update of our Wrap Brochure, and we must provide the date of the last annual update of our Wrap Brochure. Please note we do not have to provide this information to a client or prospective client who has not received a previous version of our Wrap Brochure. Previous Annual Amendment Filing Date: 02/10/2025 Since our last annual amendment filing, we do not have any material changes to report. 2 ITEM 3. TABLE OF CONTENTS Topic: Page(s): Item 1. Cover Page for Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure ........................ 1 Item 2. Material Changes to Part 2A Appendix 1 (Wrap Fee Program Brochure) of our Form ADV:.. 2 Item 3. Table of Contents..................................................................................................................................................... 3 Item 4. Services, Fees and Compensation..................................................................................................................... 4 Item 5. Account Requirements and Types of Clients ............................................................................................... 5 Item 6. Portfolio Manager Selection and Evaluation ............................................................................................... 6 Item 7. Client Information Provided to Portfolio Manager(s) ............................................................................. 8 Item 8. Client Contact with Portfolio Manager(s) ..................................................................................................... 9 Item 9. Additional Information ......................................................................................................................................... 9 3 ITEM 4. SERVICES, FEES AND COMPENSATION Omega Financial Group’s Wrap Fee Program is an investment advisory program sponsored by Omega Financial Group LLC, an independent registered investment adviser with the Securities and Exchange Commission. A wrap fee program allows our clients to pay a specified fee for investment advisory services and the execution of transactions. The advisory services may include portfolio management and/or advice concerning selection of other advisers, and the fee is not based directly upon transactions in your account. Your fee is bundled with our costs for executing transactions in your account(s). This may result in a higher advisory fee to you. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. By participating in a wrap fee program, you may end up paying more or less than you would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to you by the executing broker. We recommend that clients custody their accounts with Charles Schwab & Co., Inc. (“Schwab”) or Fidelity Brokerage Services (“Fidelity”). Schwab does not charge transaction fees for U.S. listed equities and exchange traded funds. Fidelity does not charge transaction fees for U.S. listed equities and exchange traded funds to clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Since we pay the transaction fees charged by the chosen custodian to clients participating in our wrap fee program, we are incentivized to recommend U.S. listed equities and exchange traded funds over other types of securities in order to reduce our costs. To mitigate this conflict, our firm will recommend the type of security that we believe to be in the client’s best interest. Wrap Fee Program Our Wrap Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Fee Schedule We charge an advisory fee of 1.50% of assets under management for our Wrap Comprehensive Portfolio Management service. Accounts over $2,000,000 may be subject to a lower fee percentage based on the complexity of the services offered. Our firm requires a minimum account balance of 4 $1,000,000 for our Wrap Comprehensive Portfolio Management service. This minimum account balance requirement is negotiable and may be waived for individuals who are active accumulators. Our firm’s fees are billed on a pro-rata annualized basis monthly in advance based on the value of your account on the last day of the previous month. The client may make additions to the account at any time. Additional assets received into the account after it is opened will be included in the fee calculation for the following month. The client may withdraw account assets upon notice to the Adviser, subject to the usual and customary securities settlement procedures. No fee adjustments will be made for partial withdrawals or for account appreciation or depreciation within a billing period. Unless indicated otherwise in writing, our firm bills on cash. Upon the client’s authorization, a qualified custodian will deduct advisory fees from the client’s account and pay directly to our firm the management fee for each calendar year month. The custodian will send clients a monthly statement showing all amounts paid from the account, including all management fees paid by the custodian to our firm. Other Types of Fees & Expenses You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap-fee you are charged by our firm. Our investment advisory representatives receive a portion of the advisory fee that you pay us, either directly as a percentage of your overall fee or as their salary from our firm. In cases where our investment advisory representatives are paid a percentage of your overall advisory fee, this may create an incentive to recommend that you participate in a wrap fee program rather than a non-wrap fee program (where you would pay for trade execution costs) or brokerage account where commissions are charged. This is because, in some cases, we may stand to earn more compensation from advisory fees paid to us through a wrap fee program arrangement if your account is not actively traded. Terminations and Refunds Either party may terminate the advisory agreement signed with our firm at any time. Upon notice of termination, our firm will process a pro-rata refund of any unearned portion of the advisory fees charged in advance. ITEM 5. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Types of clients we typically manage wrap fee accounts on behalf of, include: • Individuals and High Net Worth Individuals • Trusts, Estates or Charitable Organizations • Corporations, Limited Liability Companies and/or Other Business Types 5 Our firm requires a minimum account balance of $1,000,000 for our Wrap Comprehensive Portfolio Management service. This minimum account balance requirement is negotiable and may be waived for individuals who are active accumulators. ITEM 6. PORTFOLIO MANAGER SELECTION AND EVALUATION Our firm and its related persons act as portfolio managers for this wrap fee program. This may create a conflict of interest in that other investment advisory firms may charge the same or lower fees than our firm for similar services. Our investment advisor representatives (“IARs”) are subject to individual licensing requirements as imposed by state securities boards. Our firm is required to confirm or update each IAR’s Form U4 on an annual basis. IAR supervision is conducted by our Chief Compliance Officer or management personnel. Advisory Business See Item 4 of this Wrap Fee Program Brochure for a full description of our Wrap Comprehensive Portfolio Management service. Additionally, we offer individualized investment advice to our clients. We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing their account. In rare instances, we may allow restrictions. Participation in Wrap Fee Programs We do not currently offer a Wrap Fee Program to new clients. We only offer our Wrap Fee Program to legacy clients who are already in the Wrap Fee Program. Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different fashion than non-wrap fee accounts. Performance-Based Fees and Side-by-Side Management We do not charge performance fees to our clients. Methods of Analysis, Investment Strategies and Risk of Loss We use the following methods of analysis in formulating our investment advice and/or managing client assets: Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. 6 Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Investment Strategies We Use: We use our proprietary STATES OF THE WΩRLD WEALTH MANAGEMENT® and ΩPTIMIZED WEALTH INTEGRATION® investment strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations. Our strategies are based on possible known outcomes rather than attempting to predict particular outcomes of financial markets. To do this, we allocate a client’s holdings across different assets that have returns tied explicitly to different states (i.e. possible outcomes) of the financial world. For example, we have a strategy designed to survive precipitous market drops (i.e., PRΩTECTED VALUE®), another to earn modest returns during flat market periods (i.e., TΩTAL RETURN®), and another to thrive during strong market return periods (i.e., DIFFUSSIΩN™). Our wealth management services are thus in sharp contrast to the conventional approach of simply assuming some return across assets and holding a static asset allocation of various traditional investments (e.g., 60% S&P500 and 40% intermediate US bonds). PRΩTECTED VALUE® - This strategy is designed to protect a portfolio during steep declines in the stock market. We use call options and short term debt instruments to create a loss floor on a portfolio, typically targeted, depending on the client, in the 0‐15% range. On the upside, we target a capture of 40‐60% of the positive return. The name of the strategy is derived from the mathematical concept of absolute value‐‐‐converting negative values into positive ones while still maintaining the sign of positive values. TΩTAL RETURN® - This strategy is designed to garner modest returns in those environments where stocks have roughly a zero return. This is accomplished through a proprietary covered put and covered call writing strategy on the S&P500 stock market index. The ratio of puts and calls changes dynamically, depending on market sentiment. Thus, returns and losses are muted but income is enhanced such that in those zero return environments, clients still potentially earn modest returns, which are targeted at 4‐6% per annum—hence, the strategy name. DIFFUSSIΩN™ - This strategy creates an investment that tends to fall in line with the stock market when it falls in value, but tends to increase at a greater rate when the stock market increases in value. In particular, the strategy is a unique blend of short‐term investments and smaller capitalization equity investments. This creates a “barbell” of risk that yields a similar overall risk to the stock market but with improved upside. Thus, the positive returns become more diffuse, as the name of the strategy suggests. 7 Additional Proprietary Methods Further, we combine advances in academia with financial practice to better form strategic financial and investment advice for clients. This takes the form of using certain methods (e.g., customized monte carlo simulations and econometric analysis) and unique data (e.g., natural language processing derived data and proprietary academic data) from top tier academics. This approach enables Omega to tie all of the financial pieces of the puzzle together when greater complexity is involved. Risk of Loss: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask us any questions you may have. ESG Investing - ESG Investing maintains a focus on Environmental, Social, and Governance issues. ESG investing may be referred to in many different ways, such as sustainable investing, socially responsible investing, and impact investing. ESG practices can include, but are not limited to, strategies that select companies based on their stated commitment to one or more ESG factors; for example, companies with policies aimed at minimizing their negative impact on the environment, social issues, or companies that focus on governance principles and transparency. ESG practices may also entail screening out companies in certain sectors or that, in the view of the investor, demonstrate poor management of ESG risks and opportunities or are involved in issues that are contrary to the investor's own principles. Variability and imprecision of industry ESG definitions and terms can create confusion among investors if investment advisers and funds have not clearly and consistently articulated how they define ESG criteria and how they use ESG-related terms, especially when offering products or services to retail investors. Additionally, actual portfolio management practices of investment advisers and funds may not be consistent with their disclosed ESG investing processes or investment goals. Voting Client Securities We do not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. ITEM 7. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGER(S) All accounts are managed by our in-house licensed IARs. The IAR selected to manage the client’s account(s) or portfolio(s) will be privy to the client’s investment goals and objectives, risk tolerance, restrictions placed on the management of the account(s) or portfolio(s) and relevant client notes taken by our firm. Please see our firm’s Privacy Policy for more information on how our firm utilizes client information. 8 ITEM 8. CLIENT CONTACT WITH PORTFOLIO MANAGER(S) Clients are always free to directly contact their portfolio manager(s) with any questions or concerns about their portfolios or other matters. ITEM 9. ADDITIONAL INFORMATION Disciplinary Information We have determined that our firm and management have no disciplinary information to disclose. Financial Industry Activities & Affiliations A representative of our firm is an insurance agent/broker. He may offer insurance products and receive normal and customary fees as a result of insurance sales. A conflict of interest may arise as these insurance sales may create an incentive to recommend products based on the compensation that he may earn. Dylan Minor, Bryan Reinhard, and Robert Schultz are managing members of Argos Global Advisors, LLC (CRD# 287672), a related registered investment adviser that manages the Argos Total Return Fund, LP. Accredited investors of Omega Financial Group, LLC may be solicited to participate in the Argos Total Return Fund, LP. An investment in the private fund involves a high degree of risk and should only be considered by sophisticated investors able to assume the risks of loss (including the risk of loss of such investor’s entire investment) and illiquidity inherent with these types of investments. This offering does not waive our firm’s fiduciary duty to its clients or infringe upon any clients right to remedy under state or federal laws. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts1. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. 9 and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Review of Accounts We review accounts on at least a quarterly basis for our Wrap Comprehensive Portfolio Management clients. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we contact clients. Client Referrals and Other Compensation Our firm does not receive any compensation from National Financial Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity"). Our firm may recommend that clients establish brokerage accounts with Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”), registered broker-dealers, Members SIPC, to maintain custody of Clients’ assets and to effect trades for their accounts. Our firm is independently owned and operated and not affiliated with Schwab. Our firm may also recommend that Clients establish accounts with firms other than Schwab. Our firm places trades for its Clients' accounts subject to its duty to seek best execution and its other fiduciary duties. Our firm may use broker-dealers other than Schwab to execute trades for client accounts maintained at Schwab, but this practice may result in additional costs to clients so that we are more likely to place trades through Schwab rather than other broker-dealers. Schwab's execution quality may be different than other broker-dealers. For our client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction- related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Some of the products, services and other benefits provided by Schwab benefit us and may not benefit our firm's client accounts. Our recommendation/requirement that a client place assets in 10 Schwab's custody may be based in part on benefits Schwab provides to us, and not solely on the nature, cost or quality of custody and execution services provided by Schwab. Schwab also makes available to our firm other products and services that benefit us but may not benefit clients’ accounts. These benefits may include national, regional or specific to our firm, educational events organized and/or sponsored by Schwab Institutional. Other potential benefits may include occasional business entertainment of personnel of our firm by Schwab Institutional personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of our fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of our firm’s accounts, including accounts not maintained at Schwab Institutional. Schwab Institutional also makes available to us other services intended to help our firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to our firm by independent third parties. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to us. While, as a fiduciary, Our firm endeavors to act in its clients’ best interests, our recommendation/requirement that clients maintain their assets in accounts at Schwab may be based in part on the benefit to our firm of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Referral Fees In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Financial Information We are not required to provide financial information to our clients because: • We do not require the prepayment of more than $1,200 in fees when services cannot be • rendered within 6 (six) months. In compliance with SEC Rule 206(4)-2(b)(4)(i), the Argos Total Return Fund, LP sends a financial statement, audited by a registered PCAOB accountant, to each Fund investor within 120 days of the Fund’s fiscal year end. • We do not have a financial condition or commitment that impairs its ability to meet contractual and fiduciary obligations to clients. • We have never been the subject of a bankruptcy proceeding. 11