Overview

Assets Under Management: $1.0 billion
Headquarters: TARRYTOWN, NY
High-Net-Worth Clients: 258
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection, Educational Seminars

Fee Structure

Primary Fee Schedule (FORM ADV PART 2A AND 2A APP 1 - WRAP BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 1.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $50,000 1.00%
$10 million $100,000 1.00%
$50 million $500,000 1.00%
$100 million $1,000,000 1.00%

Clients

Number of High-Net-Worth Clients: 258
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 58.67
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 3,852
Discretionary Accounts: 3,844
Non-Discretionary Accounts: 8

Regulatory Filings

CRD Number: 306097
Filing ID: 1979716
Last Filing Date: 2025-04-15 12:31:00
Website: https://onyxbridge.com

Form ADV Documents

Additional Brochure: FORM ADV PART 2A AND 2A APP 1 - WRAP BROCHURE (2025-09-16)

View Document Text
Item 1: Cover Page Part 2A of Form ADV: Firm Brochure September 16, 2025 Onyx Bridge Wealth Group, LLC 120 White Plains Road, Suite 115 Tarrytown, NY, 10591 Firm Contact: Cindy Schlanger Chief Compliance Officer This brochure provides information about the qualifications and business practices of Onyx Bridge Wealth Group, LLC. If clients have any questions about the contents of this brochure, please contact us at (914)909-6699. 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 our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #306097. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees. Item 2: Material Changes Onyx Bridge Wealth Group, LLC is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. As of September 2025, our firm has added disclosure in Item 4 (Advisory Business) and Item 10 (Other Financial Industry Activities & Affiliations) regarding two affiliated entities under common control: Onyx Bridge Tax Group LLC and Onyx Bridge Retirement Group LLC. These entities operate as separate businesses providing tax preparation/consulting services and retirement plan administration services, respectively. While our firm shares certain physical premises with these affiliates, all operations and client relationships are maintained independently. Clients of Onyx Bridge Wealth Group, LLC are under no obligation to engage either entity for services, and any such engagement would be pursuant to a separate agreement. In addition, we have updated Item 10 of our Form ADV Part 2A Brochure to disclose that certain of our investment adviser representatives are also registered representatives of Emerson Equity LLC, a broker-dealer. We continue to have representatives affiliated with Purshe Kaplan Sterling Investments (“PKS”). ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 2 Onyx Bridge Wealth Group, LLC Item 3: Table of Contents Contents Item 1: Cover Page ........................................................................................................................................ 1 Item 2: Material Changes ............................................................................................................................... 1 Item 3: Table of Contents .............................................................................................................................. 3 Item 4: Advisory Business ............................................................................................................................. 4 Item 5: Fees & Compensation ....................................................................................................................... 7 Item 6: Performance-Based Fees & Side-By-Side Management................................................................. 10 Item 7: Types of Clients & Account Requirements ..................................................................................... 11 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .......................................................... 11 Item 9: Disciplinary Information ................................................................................................................. 24 Item 10: Other Financial Industry Activities & Affiliations........................................................................ 24 Item 11: Code of Ethics, Participation or Interest in ................................................................................... 25 Item 12: Brokerage Practices ....................................................................................................................... 26 Item 13: Review of Accounts ...................................................................................................................... 29 Item 14: Client Referrals & Other Compensation ....................................................................................... 29 Item 15: Custody.......................................................................................................................................... 30 Item 16: Investment Discretion ................................................................................................................... 31 Item 17: Voting Client Securities ................................................................................................................ 31 Item 18: Financial Information .................................................................................................................... 32 Item 1: Cover Page ...................................................................................................................................... 33 Item 2: Material Changes ............................................................................................................................. 33 Item 3: Table of Contents ............................................................................................................................ 35 Item 4: Services, Fees & Compensation ...................................................................................................... 36 Item 5: Account Requirements & Types of Clients ..................................................................................... 41 Item 6: Portfolio Manager Selection & Evaluation ..................................................................................... 41 Item 7: Client Information Provided to Portfolio Manager(s) ..................................................................... 42 Item 8: Client Contact with Portfolio Manager(s) ....................................................................................... 43 Item 9: Additional Information .................................................................................................................... 43 ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 3 Onyx Bridge Wealth Group, LLC Item 4: Advisory Business Onyx Bridge Wealth Group, LLC is a limited liability company formed under the laws of the State of Delaware in 2019 and has been in business as an investment adviser since that time. Our firm is wholly owned by Jared Cohen. Our firm is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. The purpose of this Brochure is to disclose the conflicts of interest associated with the investment transactions, compensation and any other matters related to investment decisions made by our firm or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing our client. Our firm has established a service-oriented advisory practice with open lines of communication for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Types of Advisory Services Offered Asset Management Services (Wrap fee program) Our firm offers discretionary and non-discretionary asset management services to our clients. Discretionary asset management service means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions would be made based upon your stated investment objectives. Non-discretionary asset management service means that we must obtain your approval prior to making any transactions in your account. You choose as to whether to grant our firm discretionary authority or non-discretionary authority in your investment management agreement with our firm. In offering asset management services to its clients, our firm offers portfolio models for use with clients. Our firm creates and manages its own portfolio models for use with clients, except for portfolio models sourced through Schwab’s Managed Account Services™. In creating its own portfolio models, we rely on research we obtain from third-party research consultants. Currently, we receive our research from consultant Helios Quantitative Research LLC of Granite Bay, CA (“Helios”). Capital Integration Systems LLC and iCapital Network, Inc. Clients may also request that we consider certain investments offered on the Capital Integration Systems LLC (“CAIS”) and iCapital Network, Inc. (“iCapital”) Alternative Investments Portals as potential investments for the client’s Account. Please see Item 8 below for more information about CAIS and iCapital, and risks associated with alternative investments. Please see the firm’s Form ADV Part 2A, Appendix 1: Wrap Fee Program Brochure for more information with respect to our wrap fee program. Financial Planning & Consulting: Our firm provides a variety of standalone financial planning and consulting services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 4 Onyx Bridge Wealth Group, LLC Financial planning services will typically 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 Investment Planning, Retirement Planning, Estate Planning, End of Life 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, or Business and Personal Financial Planning. Some of these services could be offered through third-party vendors engaged by our firm. 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. Implementation of the recommendations will be at the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for financial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. Assuming that all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our firm. 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 may 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. • Participant Education – Our firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, 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. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Onyx Bridge Wealth Group, LLC In some cases, we may use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary Donor Advised Funds: We may assist clients in establishing and managing Donor-Advised Funds (DAFs) as part of their charitable giving strategy. Our services may include advising clients on the selection of a DAF provider, recommending suitable investments for the fund, and coordinating charitable donations made from the DAF. Corporate Trustees: As part of our fiduciary services, we assist clients in establishing trusts and may recommend using Charles Schwab & Co., Inc. as a corporate trustee for clients who do not have an individual to act in this capacity. Schwab serves as the corporate trustee and is responsible for the management and administration of the trust assets in accordance with the terms of the trust agreement. Tailoring of Advisory Services Each Asset Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Regulatory Assets Under Management As of December 31, 2024, our firm manages approximately $994,089,023 in client assets on a discretionary basis and $6,812,294 in client assets on a non-discretionary basis. Affiliated Business Our firm is under common control with two affiliated entities: Onyx Bridge Tax Group LLC and Onyx Bridge Retirement Group LLC. These entities are operated as separate businesses and provide tax and retirement plan administration services, respectively. While we share certain physical office space, each business maintains separate operations, personnel, and financial records. Clients of our advisory firm are under no obligation to engage either affiliated entity for services, and any such engagement would be pursuant to a separate agreement. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 Onyx Bridge Wealth Group, LLC Item 5: Fees & Compensation Compensation for Our Advisory Services Asset Management Fees: Please see our Wrap Fee Program Brochure for information regarding our fees and compensation for Wrap Asset Management services. Financial Planning & Consulting: Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. The maximum hourly fee to be charged for our financial planning and consulting services will not exceed $500; and flat fees to be charged for such services will not exceed $10,000. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months. Retirement Plan Consulting: Our Retirement Plan Consulting services are billed on the percentage of plan assets under management or, in select cases, based on a flat fee as described below, in either case as agreed with the client. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Fees based on a percentage of managed Plan assets will not exceed 1.00%. Our fee for Retirement Plan Consulting services is negotiable, depending on individual client circumstances. For example, instead of the above 1.00%-based fee for Retirement Plan Consulting services, we and the client may agree to have an annual flat fee for such services; provided, that, in order to have a flat fee arrangement with us, client must have one or more accounts with us with assets under management equal to $2,500,000 or greater (“AUM threshold”). If the AUM threshold is met at the time of contracting, Client may be charged a flat fee of up to $100,000. As the fee for our Retirement Plan Consulting services is annual, it is charged to client each year, regardless of whether a percentage-based fee or a flat fee is chosen. The fee arrangement for our Retirement Plan Consulting services will be determined on a case-by-case basis and will be detailed in the signed agreement for such services between us and the client. We may modify the fee for our Retirement Plan Consulting services at any time upon 30 days prior written notice to client. Donor Advised Funds: In connection with our advisory services for Donor-Advised Funds, we may charge an asset-based fee for managing the investments held within the DAF. Additionally, clients may be subject to fees imposed by the DAF sponsor, which are not collected by us. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 Onyx Bridge Wealth Group, LLC Corporate Trustees: If Schwab serves as a corporate trustee, clients may be subject to fees charged by Schwab for its trustee services. These fees are separate from the fees charged by our firm for advisory services. Other Types of Fees & Expenses Clients may also pay holdings charges imposed by the chosen custodian for certain investments, 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, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Wrap clients will not incur transaction costs for trades by their chosen custodian. More information about this can be found in our separate Wrap Fee Program Brochure. IRA Rollover Considerations: As a normal extension of financial advice, we provide education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended to these assets. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interests and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person servicing your account may charge more or less for the same service than another Associated Person of our firm. Further, our annual investment management fee may be higher than that charged by other investment advisors offering similar services/programs. Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating the firm’s advisory ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 8 Onyx Bridge Wealth Group, LLC fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. Billing on Margin: Unless otherwise agreed in writing, the gross amount of assets in the client’s account, including margin balances, are included as part of assets under management for purposes of calculating the firm’s advisory fee. Clients should note that this practice will increase total assets under management used to calculate advisory fees which will in turn increase the amount of fees collected by our firm. This practice creates a conflict of interest in that our firm has an incentive to use margin in order to increase the amount of billable assets. At all times, the firm and its Associated Persons strive to uphold their fiduciary duty of fair dealing with clients. Clients are free to restrict the use of margin by our firm. However, clients should note that any restriction on the use of margin may negatively impact an account’s performance in a rising market. limited to Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific performance level(s). Termination & Refunds Either party may terminate the advisory agreement signed with our firm for our Asset Management services by providing the written notice as provided in such agreement. Upon notice of termination pro-rata advisory fees for services rendered to the point of termination will be charged. If advisory fees cannot be deducted, our firm will send an invoice for due advisory fees to the client. Either party may terminate the financial planning & consulting agreement signed with our firm for our Financial Planning & Consulting services by providing the written notice as provided in such agreement. For purposes 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 unearned fees based on the time and effort expended by our firm. Either party may terminate the retirement plan consulting agreement signed with our firm for our Retirement Plan Consulting services by providing the written notice as provided in such agreement. 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 ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 9 Onyx Bridge Wealth Group, LLC 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 Some representatives of our firm are registered representatives of Purshe Kaplan Sterling Investments (“PKS”), a broker-dealer, member FINRA/SIPC. As such they are able to accept compensation for the sale of securities or other investment products, including distribution or service (“trail”) fees. Please see the Form ADV Part 2B Brochure Supplement for your designated representative to see if he or she is a registered representative of PKS. Clients should be aware that the practice of accepting commissions for the sale of securities presents a conflict of interest and gives our firm and/or our representatives an incentive to recommend investment products based on the compensation received. Our firm generally addresses commissionable sales conflicts that arise when explaining to clients these sales create an incentive to recommend based on the compensation to be earned and/or when recommending commissionable mutual funds, explaining that “no-load” funds are also available. Our firm does not prohibit clients from purchasing recommended investment products through other unaffiliated brokers or agents. Certain Associated Persons of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to our clients. Insurance commissions earned by these persons are separate from and in addition to our advisory fees. The sale of insurance instruments and other commissionable products offered by Associated Persons are intended to complement our advisory services. However, this practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. We address this conflict of interest by recommending insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances and only after a full presentation of the recommended insurance product to our client. In addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also reviews the client’s application and disclosures prior to the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory services are informed that they are under no obligation to purchase insurance services. Clients who do choose to purchase insurance services are under no obligation to use our licensed Associated Persons and may use the insurance brokerage firm and agent of their choice. Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up-front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns mentioned on any program presented are subject to change without notice. Insurance products are subject to fees and additional expenses. Item 6: Performance-Based Fees & Side-By-Side Management ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 10 Onyx Bridge Wealth Group, LLC Our firm does not charge performance-based fees. Item 7: Types of Clients & Account Requirements Our firm has the following types of clients: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Pension and Profit-Sharing Plans; • Corporations, Limited Liability Companies and/or Other Business Types Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging us. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis We do not implement our own methods of analysis, but, rather, will rely on research we obtain from third party research consultants. At this time, we receive research from Helios. Clients should refer to our third-party research consultant’s brochures for more information about these firms’ methods of analysis. Helios may use one or more of the following methods of analysis when providing research to us: Charting: In this type of technical analysis, our firm reviews 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. Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical forces drive price movements in the financial markets. Risks include that cycles may invert or disappear and there is no expectation that this type of analysis will pinpoint turning points, instead be used in conjunction with other methods of analysis Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on numbers that can be found on reports such as balance sheets. The two techniques, however, will often be used together in order to examine a company's operations and evaluate its potential as an investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to the social and experiential realm rather than the mathematical one. This approach depends on the kind of intelligence that machines (currently) lack, since things like positive associations with a brand, management trustworthiness, customer satisfaction, competitive advantage and cultural shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative analysis is that subjective judgment may prove incorrect. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 11 Onyx Bridge Wealth Group, LLC Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The process usually consists of searching vast databases for patterns, such as correlations among liquid assets or price-movement patterns (trend following or mean reversion). The resulting strategies may involve high-frequency trading. The results of the analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. Sector Analysis: Sector analysis involves identification and analysis of various industries or economic sectors that are likely to exhibit superior performance. Academic studies indicate that the health of a stock's sector is as important as the performance of the individual stock itself. In other words, even the best stock located in a weak sector will often perform poorly because that sector is out of favor. Each industry has differences in terms of its customer base, market share among firms, industry growth, competition, regulation and business cycles. Learning how the industry operates provides a deeper understanding of a company's financial health. One method of analyzing a company's growth potential is examining whether the amount of customers in the overall market is expected to grow. In some markets, there is zero or negative growth, a factor demanding careful consideration. Additionally, market analysts recommend that investors should monitor sectors that are nearing the bottom of performance rankings for possible signs of an impending turnaround. Technical Analysis: A security analysis methodology for forecasting the direction of prices through the study of past market data, primarily price and volume. A fundamental principle of technical analysis is that a market's price reflects all relevant information, so their analysis looks at the history of a security's trading pattern rather than external drivers such as economic, fundamental and news events. Therefore, price action tends to repeat itself due to investors collectively tending toward patterned behavior – hence technical analysis focuses on identifiable trends and conditions. Technical analysts also widely use market indicators of many sorts, some of which are mathematical transformations of price, often including up and down volume, advance/decline data and other inputs. These indicators are used to help assess whether an asset is trending, and if it is, the probability of its direction and of continuation. Technicians also look for relationships between price/volume indices and market indicators. Technical analysis employs models and trading rules based on price and volume transformations, such as the relative strength index, moving averages, regressions, inter-market and intra-market price correlations, business cycles, stock market cycles or, classically, through recognition of chart patterns. Technical analysis is widely used among traders and financial professionals and is very often used by active day traders, market makers and pit traders. The risk associated with this type of analysis is that analysts use subjective judgment to decide which pattern(s) a particular instrument reflects at a given time and what the interpretation of that pattern should be. Investment Strategies We Use The following investment strategies are used 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: Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus reward by adjusting the percentage of each asset in an investment portfolio according to the investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle that different assets perform differently in different market and economic conditions. A fundamental justification for asset allocation is the notion that different asset classes offer returns that are not ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 12 Onyx Bridge Wealth Group, LLC perfectly correlated, hence diversification reduces the overall risk in terms of the variability of returns for a given level of expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation and variance) that existed over some past period. Expectations for return are often derived in the same way. An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return. There are many types of assets that may or may not be included in an asset allocation strategy. The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally: investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long- term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these three provides a starting point. Usually included are hybrid instruments such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.; Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps; insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products, etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and futures; foreign currency; venture capital; private equity; and/or distressed securities. There are several types of asset allocation strategies based on investment goals, risk tolerance, time frames and diversification. The most common forms of asset allocation are: strategic, dynamic, tactical, and core-satellite. • Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset mix that seeks to provide the optimal balance between expected risk and return for a long- term investment horizon. Generally speaking, strategic asset allocation strategies are agnostic to economic environments, i.e., they do not change their allocation postures relative to changing market or economic conditions. • Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Like strategic allocation strategies, dynamic strategies largely retain exposure to their original asset classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust their postures over time relative to changes in the economic environment. • Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a more active approach that tries to position a portfolio into those assets, sectors, or individual stocks that show the most potential for perceived gains. While an original asset mix is formulated much like strategic and dynamic portfolio, tactical strategies are often traded more actively and are free to move entirely in and out of their core asset classes • Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core' strategic element making up the most significant portion of the portfolio, while applying a dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical allocation strategies mentioned above. Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end fund or unit investment trust) whose primary objective is to achieve the same return as a particular market index. The vast majority of ETFs are designed to track an index, so their performance is close to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference between the returns of a fund and the returns of the index, can arise due to differences in ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 13 Onyx Bridge Wealth Group, LLC composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs trade like stocks, you can place orders just like with individual stocks - such as limit orders, good- until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought and sold at the market prices on the exchanges, which resemble the underlying NAV but are independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which generally can only be bought in the country in which they are registered. One of the main features of ETFs are their low annual fees, especially when compared to traditional mutual funds. The passive nature of index investing, reduced marketing, and distribution and accounting expenses all contribute to the lower fees. Margin Transactions: Our firm may purchase stocks, mutual funds, and/or other securities for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash, and allows us to purchase stock without selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate for every client. The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; and (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call. Options: An option is a financial derivative that represents a contract sold by one party (the option writer) to another party (the option holder, or option buyer). The contract offers the buyer the right, but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the strike price) during a certain period of time or on a specific date (exercise date). Options are extremely versatile securities. Traders use options to speculate, which is a relatively risky practice, while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option buyers and writers have conflicting views regarding the outlook on the performance of a: • Call Option: Call options give the option to buy at certain price, so the buyer would want the stock to go up. Conversely, the option writer needs to provide the underlying shares in the event that the stock's market price exceeds the strike due to the contractual obligation. An option writer who sells a call option believes that the underlying stock's price will drop relative to the option's strike price during the life of the option, as that is how he will reap maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock for a lower price and then sell it for a profit. However, if the underlying stock does not close above the strike price on the expiration date, the option buyer would lose the premium paid for the call option. • Put Option: Put options give the option to sell at a certain price, so the buyer would want the stock to go down. The opposite is true for put option writers. For example, a put option buyer is bearish on the underlying stock and believes its market price will fall below the specified strike price on or before a specified date. On the other hand, an option writer who sells a put option believes the underlying stock's price will increase about a specified price on or before ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 14 Onyx Bridge Wealth Group, LLC the expiration date. If the underlying stock's price closes above the specified strike price on the expiration date, the put option writer's maximum profit is achieved. Conversely, a put option holder would only benefit from a fall in the underlying stock's price below the strike price. If the underlying stock's price falls below the strike price, the put option writer is obligated to purchase shares of the underlying stock at the strike price. The potential risks associated with these transactions are that (1) all options expire. The closer the option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move very quickly. Depending on factors such as time until expiration and the relationship of the stock price to the option’s strike price, small movements in a stock can translate into big movements in the underlying options. Structured Products: Structured products are designed to facilitate highly customized risk-return objectives. While structured products come in many different forms, they typically consist of a debt security that is structured to make interest and principal payments based upon various assets, rates or formulas. Many structured products include an embedded derivative component. Structured products may be structured in the form of a security, in which case these products may receive benefits provided under federal securities law, or they may be cast as derivatives, in which case they are offered in the over-the-counter market and are subject to no regulation. Investing in structured products includes significant risks, including valuation, lack of liquidity, price, credit and market risks. The relative lack of liquidity due to the highly customized nature of the investment. Moreover, the full extent of returns from the complex performance features is often not realized until maturity. As such, structured products tend to be more of a buy-and-hold investment decision rather than a means of getting in and out of a position with speed and efficiency. Another risk with structured products is the credit quality of the issuer. Although the cash flows are derived from other sources, the products themselves are legally considered to be the issuing financial institution's liabilities. The vast majority of structured products are from high-investment-grade issuers only. Also, there is a lack of pricing transparency. There is no uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of alternative structured product offerings than it is, for instance, to compare the net expense ratios of different mutual funds or commissions among broker-dealers. Third-Party Money Manager Analysis: The analysis of the experience, investment philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and reviewed. A risk of investing with a third-party manager who has been successful in the past is that they may not be able to replicate that success in the future. In addition, as our firm does not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as our firm does not control the manager’s daily business and compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Donor Advised Funds: ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 15 Onyx Bridge Wealth Group, LLC As part of our advisory services, we may recommend specific investment strategies for assets held within Donor-Advised Funds. The investment options available within a DAF are generally limited to the choices offered by the sponsoring organization, and we will consider these options when providing advice. Capital Integration Systems LLC Investments (“CAIS”) CAIS sources and selects various private funds for its platform through a due diligence process conducted by Mercer Investment Consulting (“Mercer”). Products that are appropriate and desirable for the platform are subject to internal committee reviews by CAIS and a fully independent review by Mercer. Product onboarding occurs only following the successful completion of these processes. iCapital Network, Inc. (“iCapital”) We have contracted with iCapital and their affiliates to provide our Associated Persons with access to the iCapital Network alternative investment platform, software, and services. iCapital and/or its affiliates conduct due diligence (investment and operational) on private equity and hedge fund offerings available on their platform. Privately Offered Securities valuations can lag a month or more and are provided by the issuer’s third-party administrator, iCapital or CAIS to the custodian. The fee calculation uses this data to calculate the fee. In addition to reviewing the risk disclosure contained herein, clients participating in alternative investments available to them through the iCapital and CAIS portals should closely read the relevant prospectus or private placement memorandum prior to investing. Such documents are intended to include all material risks of such investments, and are hereby incorporated herein by reference. Risk of Loss General Investment Risk: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, and that their assets are appropriately diversified in investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance. Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may lose 100% of your money. All investments carry some form of risk and the loss of capital is generally a risk for any investment instrument. Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate account assets in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors, certain accounts may, or may be advised to, hold concentrated positions in specific securities. Therefore, at times, an account may, or may be advised to, hold a relatively small number of securities positions, each representing a relatively large portion of assets in the account. As a result, the account will be subject to greater volatility than a more sector diversified portfolio. Investments in issuers within an industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio will affect the overall value of the portfolio and will cause greater losses than it would in a portfolio that holds more diversified investments. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 16 Onyx Bridge Wealth Group, LLC Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or unfavorable performance if a borrower does not repay the borrowed funds as expected or required. Investment holdings that involve forms of indebtedness (i.e., borrowed funds) are subject to credit risk. Cryptocurrency Risk: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual currency,” “digital currency,” or “digital assets,” is designed to act as a medium of exchange. Cryptocurrency is an emerging asset class. There are thousands of cryptocurrencies, the most well- known of which is bitcoin. Certain of the firm’s clients may have exposure to bitcoin or another cryptocurrency, directly or indirectly through an investment such as an ETF or other investment vehicles. Cryptocurrency operates without central authority or banks and is not backed by any government. Cryptocurrencies may experience very high volatility and related investment vehicles may be affected by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients may also trade at a significant premium or discount to NAV. Cryptocurrency is also not legal tender. Federal, state or foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing. The market price of many cryptocurrencies, including bitcoin, has been subject to extreme fluctuations. If cryptocurrency markets continue to be subject to sharp fluctuations, investors may experience losses if the value of the client’s investments decline. Similar to fiat currencies (i.e., a currency that is backed by a central bank or a national, supra-national or quasi-national organization), cryptocurrencies are susceptible to theft, loss and destruction. Cryptocurrency exchanges and other trading venues on which cryptocurrencies trade are relatively new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure than established, regulated exchanges for securities, derivatives and other currencies. The SEC has issued a public report stating U.S. federal securities laws require treating some digital assets as securities. Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers or malware. Due to relatively recent launches, most cryptocurrencies have a limited trading history, making it difficult for investors to evaluate investments. Generally, cryptocurrency transactions are irreversible such that an improper transfer can only be undone by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the original sender. Digital assets are highly dependent on their developers and there is no guarantee that development will continue or that developers will not abandon a project with little or no notice. Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including cryptocurrencies, and their source code. Any threatened action that reduces confidence in a network’s long-term ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies. Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are uncertain and an investment in cryptocurrency may produce income that is not treated as qualifying income for purposes of the income test applicable to regulated investment companies. Certain cryptocurrency investments may be treated as a grantor trust for U.S. federal income tax purposes, and an investment by the firm’s clients in such a vehicle will generally be treated as a direct investment in cryptocurrency for tax purposes and “flow-through” to the underlying investors. Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed to protect networks, systems, computers, programs, and data from cyber- ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 17 Onyx Bridge Wealth Group, LLC attacks and hacking by other computer users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however, unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading. Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In addition, clients could be exposed to additional losses as a result of unauthorized use of their personal information. While our firm has established a business continuity plan and systems designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Similar types of cyber security risks are also present for issuers of securities, investment companies and other investment advisers in which we invest, which could result in material adverse consequences for such entities and may cause a client's investment in such entities to lose value. Economic Risk: The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain environmental, social and governance (ESG) investment criteria it may avoid purchasing certain securities for ESG reasons when it is otherwise economically advantageous to purchase those securities or may sell certain securities for ESG reasons when it is otherwise economically advantageous to hold those securities. In general, the application of the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers, industries, sectors and geographic areas, which may affect the financial performance of the portfolio, positively or negatively, depending on whether these issuers, industries, sectors or geographic areas are in or out of favor. An adviser can vary materially from other advisers with respect to its methodology for constructing ESG portfolios or screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be objective in principle but not verified or reliable. ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Financial Risk: Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 18 Onyx Bridge Wealth Group, LLC financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds from your investment will not be worth what they are today. Throughout time, the prices of resources and end-user products generally increase and thus, the same general goods and products today will likely be more expensive in the future. The longer an investment is held, the greater the chance that the proceeds from that investment will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get you less than what it can today. Inverse Funds: Inverse mutual funds and ETFs, which are sometimes referred to as "short" funds, seek to provide the opposite of the single-day performance of the index or benchmark they track. Inverse funds are often marketed as a way to profit from, or hedge exposure to, downward moving markets. Some inverse funds also use leverage, such that they seek to achieve a return that is a multiple of the opposite performance of the underlying index or benchmark (i.e., -200%, -300%). In addition to leverage, these funds may also use derivative instruments to accomplish their objectives. As such, inverse funds are highly volatile and provide the potential for significant losses. Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited market in which they trade. Thus, you may experience the risk that your investment or assets within your investment may not be able to be liquidated quickly, thus, extending the period of time by which you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e., not being able to quickly get out of an investment before the price drops significantly) a particular investment and therefore, can have a negative impact on investment returns. Manager Risk: There is always the possibility that poor security selection will cause your investments to underperform relative to benchmarks or other funds with a similar investment objective. Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g., earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. Market Timing Risk: Market timing can include high risk of loss since it looks at an aggregate market versus a specific security. Timing risk explains the potential for missing out on beneficial movements in price due to an error in timing. This could cause harm to the value of an investor's portfolio because of purchasing too high or selling too low. Options Risk: Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Additionally, options have an expiration date, which makes them “decay” in value over the amount of time they are held and can expire worthless. Purchasing ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 19 Onyx Bridge Wealth Group, LLC and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. Past Performance: Charting and technical analysis are often used interchangeably. Technical analysis generally attempts to forecast an investment’s future potential by analyzing its past performance and other related statistics. In particular, technical analysis often times involves an evaluation of historical pricing and volume of a particular security for the purpose of forecasting where future price and volume figures may go. As with any investment analysis method, technical analysis runs the risk of not knowing the future and thus, investors should realize that even the most diligent and thorough technical analysis cannot predict or guarantee the future performance of any particular investment instrument or issuer thereof. Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety of factors including the global response of regulators and governments to address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and macroeconomic factors will negatively impact investment returns. Preferred Securities Risk: Preferred Securities have similar characteristics to bonds in that preferred securities are designed to make fixed payments based on a percentage of their par value and are senior to common stock. Like bonds, the market value of preferred securities is sensitive to changes in interest rates as well as changes in issuer credit quality. Preferred securities, however, are junior to bonds with regard to the distribution of corporate earnings and liquidation in the event of bankruptcy. Preferred securities that are in the form of preferred stock also differ from bonds in that dividends on preferred stock must be declared by the issuer’s board of directors, whereas interest payments on bonds generally do not require action by the issuer’s board of directors, and bondholders generally have protections that preferred stockholders do not have, such as indentures that are designed to guarantee payments – subject to the credit quality of the issuer – with terms and conditions for the benefit of bondholders. In contrast preferred stocks generally pay dividends, not interest payments, which can be deferred or stopped in the event of credit stress without triggering bankruptcy or default. Another difference is that preferred dividends are paid from the issue’s after- tax profits, while bond interest is paid before taxes. Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to manage all or a portion of your assets, we will advise you on how to allocate your assets among various classes of securities or third-party investment managers, programs, or managed model portfolios. As such, we will primarily rely on investment model portfolios and strategies developed by the third-party investment advisers and their portfolio managers. If there is a significant deviation in characteristics or performance from the stated strategy and/or benchmark, we may recommend changing models or replacing a third-party investment adviser. The primary risks associated with investing with a third party is that while a particular third party may have demonstrated a certain level of success in the past; it may not be able to replicate that success in future markets. In addition, as we do not control the underlying investments in third party model portfolios, there is also a risk that a third party may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. To mitigate this risk, we seek third parties with proven track records that have demonstrated a consistent level of performance and success over time. A third party’s past performance is not a guarantee of future results and certain market and economic risks exist that may adversely affect an account’s performance that could result in capital ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 20 Onyx Bridge Wealth Group, LLC losses in your account. Please refer to the third-party investment adviser’s advisory agreements, Form ADV Brochure, and associated disclosure documents for details on their specific investment strategies, methods of analysis, and associated risks. Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and ETFs generally seek to deliver multiples of the daily performance of the index or benchmark that they track. Inverse mutual funds and ETFs generally seek to deliver the opposite of the daily performance of the index or benchmark that they track. Inverse funds often are marketed as a way for investors to profit from, or at least hedge their exposure to, downward-moving markets. Some Inverse funds are both inverse and leveraged, meaning that they seek a return that is a multiple of the inverse performance of the underlying index. To accomplish their objectives, leveraged and inverse funds use a range of investment strategies, including swaps, futures contracts, and other derivative instruments. Leveraged, inverse, and leveraged inverse funds are more volatile and riskier than traditional funds due to their exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will recommend leveraged and/or inversed funds, which may amplify gains and losses. Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases, monthly) basis, and reset their leverage daily. A "single day" is measured from the time the leveraged fund calculates its net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The return of the leveraged fund for periods longer than a single day will be the result of each day's returns compounded over the period. Due to the effect of this mathematical compounding, their performance over longer periods of time can differ significantly from the performance (or inverse performance) of their underlying index or benchmark during the same period of time. For periods longer than a single day, the leveraged fund will lose money when the level of the Index is flat, and the leveraged fund may lose money even if the level of the Index rises. Longer holding periods, higher index volatility, and greater leverage all exacerbate the impact of compounding on an investor's returns. During periods of higher Index volatility, the volatility of the Index may affect the leveraged fund's return as much as or more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged inverse funds for longer periods of time increases their risk due to the effects of compounding and the inherent difficulty in market timing. Leveraged funds are riskier than similarly benchmarked funds that do not use leverage. Non-traditional funds are highly volatile and not suitable for all investors. They provide the potential for significant losses. Risks Associated with Investing in Buffer ETFs: Buffer ETFs are also known as defined-outcome ETFs since the ETF is designed to offer downside protection for a specified period of time. These ETFs are modeled after options-based structured notes, but are generally cheaper, and offer more liquidity. Buffer ETFs are designed to safeguard against market downturns by employing complex options strategies. Buffer ETFs typically charge higher management fees that are considerably more than the index funds whose performance they attempt to track. Additionally, because buffer funds own options, they do not receive dividends from their equity holdings. Both factors result in the underperformance of the Buffer ETF compared to the index they attempt to track. Clients should carefully read the prospectus for a buffer ETF to fully understand the cost structures, risks, and features of these complex products. Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under all market conditions and each investor should evaluate his/her ability to maintain any investment he/she is considering in light of his/her own investment time horizon. Investments are subject to risk, including possible loss of principal. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 21 Onyx Bridge Wealth Group, LLC Structured Notes: Below are some specific risks related to the structured notes recommended by our firm: • Complexity: Structured notes are complex financial instruments. Clients should understand the reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may include leverage multiplied by the performance of the reference asset or index, protection from losses should the reference asset or index produce negative returns, and/or fees. Structured notes may have complicated payoff structures that can make it difficult for clients to accurately assess their value, risk and potential for growth through the term of the structured note. Determining the performance of each note can be complex and this calculation can vary significantly from note to note depending on the structure. Notes can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a structured note to fully understand how the payoff on a note will be calculated and discuss these issues with our firm. • • Market risk. Some structured notes provide for the repayment of principal at maturity, which is often referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing financial institution. Many structured notes do not offer this feature. For structured notes that do not offer principal protection, the performance of the linked asset or index may cause clients to lose some, or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the structured note may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, and/or market volatility. Issuance price and note value: The price of a structured note at issuance will likely be higher than the fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated value of the structured note on the cover page of the offering prospectus, allowing investors to gauge the difference between the issuer’s estimated value of the note and the issuance price. The estimated value of the notes is likely lower than the issuance price of the note to investors because issuers include the costs for selling, structuring, and/or hedging the exposure on the note in the initial price of their notes. After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value given their complexity. • Liquidity: The ability to trade or sell structured notes in a secondary market is often very limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on securities exchanges. As a result, the only potential buyer for a structured note may be the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date or risk selling the note at a discount to its value at the time of sale. • Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated to make payments on the notes as promised. These promises, including any principal protection, are only as good as the financial health of the structured note issuer. If the structured note issuer defaults on these obligations, investors may lose some, or all, of the principal amount they invested in the structured notes as well as any other payments that may be due on the structured notes. Alternatives Risk: Non-traded REITs, business development companies, limited partnerships, and direct alternatives are subject to various risks such as devaluation based on adverse market conditions and may not be suitable for all investors. A prospectus that discloses all risks, fees, and ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 22 Onyx Bridge Wealth Group, LLC expenses may be obtained from your investment adviser representative. Read the prospectus carefully before investing. This disclosure is not a solicitation or offering which can only be made in conjunction with a copy of the prospectus. Investors considering an investment strategy utilizing alternative investments should understand that alternative investments are generally considered speculative in nature; and, such investments involve a high degree of risk, particularly if concentrating investments in one or few alternative investments. Risks Associated with Investing in Private Funds: Private investment funds are not registered with the Securities and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little public information available about their investments and performance. Moreover, as sales of shares of private investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to sell its shares of a private investment company at an advantageous price and time, and investments in a private investment company routinely include a “lock up” period, during which investors are not permitted to withdraw their funds from such private investment company. Since shares of private investment companies are not publicly traded, from time to time it may be difficult to establish a fair value for the client’s investment in these companies. In addition, private investment companies may employ leverage, including the use of borrowed funds. While such strategy may increase the opportunity to achieve higher returns on the amounts invested, it also increases the risk of loss. Illiquid securities: Illiquid securities involve the risk that investments may not be readily sold at the desired time or price. Securities that are illiquid, that are not publicly traded, and/or for which no market is currently available may be difficult to purchase or sell, which may impact the price or timing of a transaction. An inability to sell securities can adversely affect an account's value or prevent an account from taking advantage of other investment opportunities. Lack of liquidity may cause the value of investments to decline and illiquid investments may also be difficult to value. A client may not be able to liquidate investment in the event of an emergency or any other reason. Certain investment strategies used by our firm may invest in illiquid asset vehicles, such as private equity and real estate. Investment in an illiquid asset vehicle poses similar risks as direct investments in illiquid securities. In addition, investment in an illiquid asset vehicle will be subject to the terms and conditions of the illiquid asset vehicle’s investment policy and governing documents that often include provisions that may involve investor lock-in periods, mandatory capital calls, redemption restrictions, infrequent valuation of assets, etc. In addition, investments in illiquid securities or vehicle may normally involve investment in non-marketable securities where there is limited transparency. If obligated to sell an illiquid security prior to an expected maturity date, particularly with an infrastructure investment, they may not be able to realize fair value. Investments in illiquid securities or vehicles may include restrictions on withdrawal rights and shares may not be freely transferable. Description of Material, Significant or Unusual Risks Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm tries to achieve the highest return on client 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 our Wrap Asset Management service, as applicable. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 23 Onyx Bridge Wealth Group, LLC 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 your evaluation of us or the integrity of our management. There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Affiliations Our firm has an affiliation with Charles Schwab & Co., Inc., and in certain scenarios we may recommend Schwab to serve as a corporate trustee for client trusts. Schwab provides both custodial and trust services and this relationship creates a potential conflict of interest, which we disclose fully to clients. Certain of our Investment Adviser Representatives (“IARs”) are also registered representatives of Purshe Kaplan Sterling Investments (“PKS”), a broker-dealer and member of FINRA/SIPC. In addition, some of our IARs are also registered representatives of Emerson Equity LLC (“Emerson”), a broker-dealer and member of FINRA/SIPC. In their capacities as registered representatives of PKS or Emerson, these individuals may recommend or effect securities transactions for which they receive normal and customary commissions or other compensation. This arrangement creates a conflict of interest because it gives our IARs an incentive to recommend investment products based on the compensation received, rather than solely on the client’s needs. To mitigate these conflicts, we disclose the relationship to clients and emphasize that our IARs have a fiduciary duty to act in the client’s best interest. Clients are under no obligation to purchase securities or investment products through PKS or Emerson and may choose any broker-dealer of their preference. Our firm is under common control with Onyx Bridge Tax Group LLC and Onyx Bridge Retirement Group LLC. • Onyx Bridge Tax Group LLC provides tax preparation, accounting, and related consulting services. • Onyx Bridge Retirement Group LLC provides third-party administration (“TPA”) and retirement plan services. These entities are separate from our investment advisory business. No client information, revenue, or operations are commingled unless we have signed client permission. A potential conflict of interest exists to the extent that our investment adviser representatives may recommend the services of these affiliates. To mitigate this conflict, we disclose the relationship and inform clients that they are free to select any accounting firm or third-party service provider of their choice. Activities ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 24 Onyx Bridge Wealth Group, LLC As part of our client acquisition strategy, we may engage in cold calling as a tool for prospecting potential clients. This activity is solely intended to identify and reach individuals who may benefit from our investment advisory services. Our Investment Adviser Representatives (IARs) use cold calling as an outreach method, and there are no associated sales incentives or commissions linked to these calls. We may source potential client leads through third-party lead generation services. However, there are no conflicts of interest or financial incentives related to these services, and we are committed to ensuring that all prospecting efforts comply with applicable regulations and maintain the highest standards of professionalism. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 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. Our fiduciary duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our firm requires all representatives 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 with our firm, and at least annually thereafter, all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives 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. 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. Our firm recognizes that the personal investment transactions of our representatives demand the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of some securities. In order to prevent conflicts of interest, our firm has established procedures for transactions effected by our representatives for their personal accounts1. In order to monitor compliance with our personal trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting system for all of our representatives. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. 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 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. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 25 Onyx Bridge Wealth Group, LLC client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Likewise, related persons of our firm 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 prior to buying or selling for our clients in the same day unless included in a block trade. If related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. Item 12: Brokerage Practices Selecting a Brokerage Firm While our firm does not maintain physical custody of client assets, we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts (see Item 15 Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to recommend a custodian who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. The factors considered, among others, are these: • Timeliness of execution • Timeliness and accuracy of trade confirmations • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record-keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities • Financial condition • Business reputation • Quality of services With this in consideration, we recommend the services of Charles Schwab & Co., Inc. (Schwab) through their Institutional Platform. Schwab is an independent and unaffiliated registered broker-dealer and member of FINRA and SIPC. The primary factor in suggesting a broker-dealer or custodian is that the services of the recommended firm are provided in a cost-effective manner. While the quality of execution at the best price is an important determinant, best execution does not necessarily mean the lowest price and it is not the sole consideration. The trading process of any broker-dealer suggested by our firm must be efficient, seamless, and straight-forward. Overall custodial support services, trade correction services, and statement preparation are some of the other factors determined when suggesting a broker-dealer. Research and Other Soft Dollar Benefits received from Schwab ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 26 Onyx Bridge Wealth Group, LLC Our firm has an institutional custodial relationship with Schwab Advisor Services (formerly called Schwab Institutional). Schwab Advisor Services serves independent investment advisory firms like ours. We are independently owned and operated and not affiliated with Schwab. Schwab will hold your assets in a brokerage account and will buy and sell securities in your account(s) upon our instructions. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and you will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you. Your Custody and Brokerage Costs Schwab generally does not charge you separately for custody services, but it is compensated by charging commissions or other fees on trades that it executes or that settle into your Schwab account. In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. Research and Other Soft Dollar Benefits Although not considered “soft dollar” compensation, our firm may receive some economic benefits from Schwab Advisor Services in the form of 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 us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we do not have to request them) and at no charge to us. Below is a detailed description of Schwab’s support services: Services that Benefit You: 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 we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You: Schwab also makes 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 Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and • • provide pricing and other market data; • • assist with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • educational conferences and events; • technology, compliance, legal, and business consulting; ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 27 Onyx Bridge Wealth Group, LLC • 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, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. Transition Assistance Benefits Schwab has provided our firm and its related persons assistance with the transition of their associated business to their platform. The proceeds made available as Transition Assistance are intended for a variety of purposes, including but not limited to: offsetting account transfer fees (“ACAT”) that our clients might have otherwise incurred, legal services related to the formation of the advisory firm, technology set-up fees, marketing and mailing costs, stationery, and licensure transfer fees. Our firm attempts to mitigate these conflicts of interest by evaluating and recommending that Clients use Schwab’s services based on the benefits that such services provide, rather than the Transition Assistance made available to our firm. We consider our custodial broker-dealers’ suite of services when recommending that Clients maintain accounts with them. Clients should, however, be aware of this conflict of interest and take it into consideration when deciding whether to custody their assets in an advisory account at Schwab. Client Transactions in Return for Soft Dollars Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals We do not receive client referrals from broker-dealers and custodians with which we have an institutional advisory arrangement. In addition, we do not receive other benefits from a broker- dealer in exchange for client referrals. Directed Brokerage Neither our firm nor any of our firm’s representatives have discretionary authority in determining the brokers-dealers and/or custodians 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. Our firm routinely requests that clients direct us to execute through a specified broker-dealer. Our firm recommends the use of Schwab. Each client will be required to establish their account(s) with Schwab if not already done. Please note that not all advisers have this requirement. 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 ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 28 Onyx Bridge Wealth Group, LLC empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, our firm 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. Client-Directed Brokerage Our firm does not allow client-directed brokerage outside our recommendations. Aggregation of Purchase or Sale Our firm provides 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 our firm believes 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, our firm attempts 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. Item 13: Review of Accounts Our management personnel or financial advisors review accounts on at least an annual basis for our Wrap Asset Management. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm 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. Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when our Wrap Asset Management clients are contacted. Item 14: Client Referrals & Other Compensation Schwab Our firm has brokerage and clearing arrangements with Schwab and receives additional benefits from them in the form of electronic delivery of client information, electronic trading platforms, institutional trading support, proprietary and/or third-party research, continuing education, practice management advice, and other services provided by custodians for the benefit of ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 29 Onyx Bridge Wealth Group, LLC investment advisory clients. Please refer to item 12 above for more information about the receipt of additional benefits from broker-dealers/account custodians. Product Sponsor Funded Events Various product wholesalers provide financial assistance to allow us to sponsor client appreciation events, educational seminars, or attend such seminars hosted by the product sponsor. This money is not directly tied to our use of their products, nor it is contingent upon any future business to be directed to their products, nonetheless it creates a conflict of interest that may incentivize us to utilize their products. Our firm will adhere to our fiduciary duty to act in our client’s best interest when selecting what products to use in client accounts. Referral Fees Our firm pays referral fees (non-commission based) to independent solicitors (non-registered representatives) for the referral of their clients to our firm in accordance with Rule 206 (4)-3 of the Investment Advisers Act of 1940. Such referral fee represents a share of our investment advisory fee charged to our clients. This arrangement will not result in higher costs to the referred client. In this regard, our firm maintains Solicitors Agreements in compliance with Rule 206 (4)-3 of the Investment Advisers Act of 1940 and applicable state and federal laws. All clients referred by Solicitors to our firm will be given full written disclosure describing the terms and fee arrangements between our firm and Solicitor(s). In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is paying solicitation fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. Item 15: Custody While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further described in the Third Party Money Movement discussion, below. All our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Third Party Money Movement: On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 30 Onyx Bridge Wealth Group, LLC 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 custodian: • 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. Item 16: Investment Discretion Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Should clients grant our firm non-discretionary authority, our firm would be required to obtain the client’s permission prior to effecting securities transactions. Limitations may be imposed by the 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 Our firm does 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, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 31 Onyx Bridge Wealth Group, LLC Item 18: Financial Information Our firm is not required to provide financial information in this Brochure because: • Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months. • Our firm does not take custody of client funds or securities. • Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. • Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 32 Onyx Bridge Wealth Group, LLC Item 1: Cover Page Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure April 15, 2025 Wrap Program Sponsored by: Onyx Bridge Wealth Group, LLC 120 White Plains Rd #115 Tarrytown, NY 10591 Firm Contact: Cindy Schlanger Chief Compliance Officer This brochure provides information about the qualifications and business practices of Onyx Bridge Wealth Group, LLC. If clients have any questions about the contents of this brochure, please contact us at (914) 909-6699. 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 our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #306097. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees. Item 2: Material Changes ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 33 Onyx Bridge Wealth Group, LLC Onyx Bridge Wealth Group, LLC is required to make clients aware of information that has changed since the last annual update to the Wrap Brochure (“Wrap Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. On March 31, 2025, we submitted our annual updating amendment filing for fiscal year 2024. We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately $994,089,023, and non-discretionary assets under management of approximately $6,812,294. Additionally, we have updated several sections of our Brochure to provide information about added services as detailed in Item 4 and the associated conflicts of interest including fees in Item 5. Please refer to the Form ADV Part 2A for a complete list of our material changes. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 34 Onyx Bridge Wealth Group, LLC Item 3: Table of Contents A table of contents is found on page 3 of this Form ADV Part 2 Brochure. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 35 Onyx Bridge Wealth Group, LLC Item 4: Services, Fees & Compensation Onyx Bridge Wealth Group, LLC is a limited liability company formed under the laws of the State of Delaware in 2019 and has been in business as an investment adviser since that time. Our firm manages assets for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Our Wrap Advisory Services Wrap Fee Program: Our firm sponsors and offers a wrap fee program (“Wrap Fee Program”) whereby the firm manages client accounts for an annual fee that includes certain discretionary or non-discretionary portfolio management services, custodial services and trade execution services. Discretionary asset management service means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions would be made based upon your stated investment objectives. Non-discretionary asset management service means that we must obtain your approval prior to making any transactions in your account. You choose as to whether to grant our firm discretionary authority or non-discretionary authority in your investment management agreement with our firm. Under our Wrap Fee Program, we implement asset allocation and advisory services and create portfolio models in conjunction with research we receive from third-party research consultants. Certain portfolio models may be sourced through Schwab’s Managed Account Services™, and other sub-advisers. At this time, we also receive research from consultant Helios Quantitative Research LLC of Granite Bay, CA (“Helios”). In such cases, we are responsible for the creation of the portfolio models and the client’s asset allocation strategy, security selection, account supervision, and implementation of transactions. Capital Integration Systems LLC and iCapital Network, Inc. Clients may also request that we consider certain investments offered on the Capital Integration Systems LLC (“CAIS”) and iCapital Network, Inc. (“iCapital”) Alternative Investments Portals as potential investments for the client’s Account. Please see Item 8 of our Form ADV Part 2A above for more information about CAIS, iCapital and risks associated with alternative investments. A portfolio is created, and accounts are managed, to diversify a client’s investments and may include various types of securities such as equity securities, exchange traded funds (“ETFs”), mutual funds, U.S. government securities, corporate debt securities, commercial paper, municipal securities, certificates of deposit, and covered options in its portfolio management programs. Other types of investments may also be recommended where such investments are appropriate based on the client’s stated goals and objectives. The client’s individual investment strategy under our Wrap Fee Program is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 36 Onyx Bridge Wealth Group, LLC continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives In some cases, our firm will utilize the sub-advisory services of a third-party investment advisory firm or individual advisor to aid in the implementation of an investment portfolio designed by our firm. Before selecting a firm or individual, our firm will ensure that the chosen party is properly licensed or registered where required. We will provide initial due diligence on third party money managers and ongoing reviews of the portion of client accounts that they manage. In order to assist in the selection of a third-party money manager, our firm will gather client information pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will periodically review third party money manager reports provided to the client at least annually. Our firm will contact clients from time to time in order to review their financial situation and objectives; communicate information to third party money managers as warranted; and, assist the client in understanding and evaluating the services provided by the third-party money manager. Clients will be expected to notify our firm of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial standing. Investments and allocations are determined and based upon the client’s investment objectives, risk tolerance, time horizon, financial horizon, financial information, and other various suitability factors. Further restrictions and guidelines imposed by clients may affect the composition and performance of a client’s portfolio. For these reasons, performance of the portfolio may not be identical with the average client of our firm. On an ongoing basis, our firm reviews the client’s financial circumstances and investment objectives and makes the necessary adjustments to the client’s portfolio to achieve the desired results. In addition to providing us with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are required to provide the firm with prompt notice of any changes in their personal financial circumstances, investment objectives, goals, and tolerance for risk. We will contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives, and tolerance for risk. However, we construct your investment portfolio, we will monitor your portfolio’s performance on a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions, your financial circumstances, or both. In addition to the advisory services, the wrap fee program includes certain brokerage services of Schwab. We are independently owned and operated and not affiliated with Schwab. Schwab will act solely as broker-dealer and not as an investment advisor to you. They will have no discretion over your account and will act solely on instructions they receive from us or you. Schwab has no responsibility for our services and undertakes no duty to you to monitor our firm’s management of your account or other services we provide to you. Schwab will hold your assets in a brokerage account and buy and sell securities and execute other transactions when we or you instruct them to. We do not open the account for you. Wrap Fee Program Fee For our Wrap Fee Program services, we charge an annual asset management fee of up to 2.00% of the market value of the assets being managed. As mentioned above in this Item 4, the client receives ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 37 Onyx Bridge Wealth Group, LLC asset management services that include discretionary portfolio management services, advisory services, custodial services, and trade execution services for this annual fee. Asset management fees are negotiable depending on factors such as the amount of assets under management, range of investments, and complexity of the client’s financial circumstances, among others. For example, instead of the above percentage-based fee for wrap asset management services, we and client may agree to have a flat fee arrangement for such services; provided, that, in order to have a flat fee arrangement with us, client must have one or more accounts with us with assets under management equal to $2,500,000 or greater (“AUM threshold”). If the AUM threshold is met at the time of contracting, Client may be charged a flat fee of up to $100,000. We may modify the asset management fee for our services under our Wrap Fee Program at any time upon 30 days prior written notice to client. Asset management fees are billed monthly or quarterly, in advance or in arrears, based on the average daily balance of the account for the billing period. The exact fee to be paid by the client, and the timing of its payment, will be clearly stated in the asset management agreement signed by the client and the firm. The custodian holding the client’s account will deduct the asset management fees directly and automatically from the account provided the client has given written authorization and will forward our portion of the fee to our firm. A client may choose to pay an annual flat fee for wrap asset management services directly to us or to have such a flat fee deducted from the account at the custodian. If insufficient cash is available to pay such asset management fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. The qualified custodian will send an account statement at least quarterly. This statement will detail all account activity. The custodian will usually deduct from a designated account to facilitate billing. Privately Offered Securities valuations can lag a month or more and are provided by the issuer’s third-party administrator, iCapital or CAIS to the custodian. The fee calculation uses this data to calculate the fee. At the inception of asset management services, the first pay period’s fees will be calculated on a pro- rata basis. The investment advisor representative (an “IAR”) recommending our wrap asset management services to a client will share in the asset management fee charged by us. Fees are generally negotiable and will be deducted from client account(s). Adjustments will be made for deposits and withdrawals during the billing period. Our firm does not offer direct invoicing. As part of this process, Clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Advisory fees for assets managed through CAIS will be directly deducted separately by CAIS. Fee Based Variable Annuity Products ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 38 Onyx Bridge Wealth Group, LLC We have entered into an agreement with various vendors to provide fee-based variable annuity products to our clients. Our firm and Associated Persons do not receive a commission on these products. For these products, we will be paid an asset-based management fee according to our advisory fee schedule (detailed above) and/or the client’s written agreement with the product sponsor. Advisory fees are withdrawn directly from the client’s account(s) with the client’s written authorization. With regard to variable annuity products, individual accounts will be maintained at the insurance company that issued the variable annuity product. For fee-based variable annuity accounts, our quarterly asset management fee is based on the value of the account as of the close of business on the last day of each calendar quarter and is billed in arrears. Additional Fees In some cases, sub advisers and third-party money managers will charge a separate fee for sub advisory services that is in addition to our wrap fee advisory fee. The combined annual fee charged to clients whose wrap fee portfolios incorporate third party money managers and/or sub advisors will not exceed the maximum fee published in our Wrap Fee Program Brochure. Our firm will debit its fees as laid out in the executed advisory agreement between the client and our firm. Third-party money managers establish and maintain their own billing procedures over which we have no control. In general, they will directly bill you and you will receive a copy of the appropriate disclosure documents that explain these procedures. In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen custodian for certain investments, 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, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark- downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Important Information About Fees The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 39 Onyx Bridge Wealth Group, LLC for advisory fees, brokerage, and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. For example, our wrap fee arrangement creates incentives for us to trade less frequently or select investments that that reduce our costs, and in some cases increase expenses that are borne by the client. Our recommended custodian Schwab generally does not charge transaction fees for online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these types of securities, we can do so without paying commissions to Schwab. Since we pay the transaction fees charged by the custodian to clients participating in our Wrap Fee Program, this presents a conflict of interest because we are incentivized to recommend no transaction fee equities and exchange traded funds over other types of securities in order to reduce our costs. In determining whether to establish a Wrap Fee Program account, you are advised that the overall cost of the Wrap Fee Program may be higher than you might otherwise incur by purchasing separately the types of securities available in the Wrap Fee Program. In order to compare the cost of the Wrap Fee Program with unbundled services, you should consider the turnover rate in our investment strategies, trading activity in the account, and standard advisory fees and brokerage commissions that would be charged at Schwab, or other broker-dealers and investment advisers. The advisory fee may cost you more compared to assets held in a traditional brokerage account. In a brokerage account, a client is charged a commission for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If you plan to follow a buy-and-hold strategy for the account or you do not wish to purchase ongoing investment advice or management services, you should consider opening a brokerage account rather than a Wrap Fee Program account. The investment products available to be purchased in the wrap fee program can be purchased by you outside of a wrap fee program account, through broker-dealers or other investment firms not affiliated with our firm. Fees and Costs Not Included in Wrap Fee Our wrap fee does not include the fees and costs listed below. The fees and costs may apply to transactions in your account. The fees and costs not included in the wrap fee that you will pay include: • Commissions and other fees charged by broker-dealers other than Schwab for transactions in your account if our firm uses Prime Brokerage, Step-In, or Trade Away Services. • Fees charged by mutual fund companies, closed-end funds, electronically traded funds, and other collective investment vehicles, including, but not limited to, sales loads and/or charges and short-term redemption fees. • Markups and markdowns, bid-ask spreads, and selling concessions in connection with transactions Schwab executes as principal. Principal transactions contrast with transactions in which Schwab acts as your agent in effecting trades. Markups and markdowns and bid-ask spreads are not separate fees but are reflected in the net price at which a trade order is executed. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 40 Onyx Bridge Wealth Group, LLC • Costs imposed by third parties, such as transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, and any other fees required by law. Schwab may also charge for additional services such as wire transfer fees and fees for alternative investments. Termination and Refunds: Either party may terminate the advisory agreement signed with our firm for Wrap Asset Management services by providing the written notice provided under the asset management agreement you sign with us for our Wrap Asset Management services. Upon notice of termination, our firm will process a pro-rata refund of the unearned portion of the advisory fees (if any) charged in advance. Item 5: Account Requirements & Types of Clients Our firm has the following types of clients: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Pension and Profit Sharing Plans; • Corporations, Limited Liability Companies and/or Other Business Types Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging us. Item 6: Portfolio Manager Selection & Evaluation Selection of Portfolio Managers: Our firm’s investment adviser representatives (“IARs”) act as portfolio manager(s) for our Wrap Fee Program. A conflict arises in that other investment advisory firms may charge the same or lower fees than our firm for similar services. Our 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. In some cases, our firm will utilize the sub-advisory services of a third-party investment advisory firm or individual advisor to aid in the implementation of an investment portfolio designed by our firm. Before selecting a firm or individual, our firm will ensure that the chosen party is properly licensed or registered where required. We will provide initial due diligence on third party money managers and ongoing reviews of the portion of client accounts that they manage. In order to assist in the selection of a third-party money manager, our firm will gather client information pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will periodically review third party money manager reports provided to the client at least annually. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 41 Onyx Bridge Wealth Group, LLC In some cases, third-party money managers will charge a separate fee for sub advisory services that is in addition to our wrap fee advisory fee. The combined annual fee charged to clients whose wrap fee portfolios incorporate third party money managers and/or sub advisors will not exceed the maximum fee published in our Wrap Fee Program Brochure. Advisory Business: Information about our Wrap Fee Program services can be found in Item 4 of this brochure. Our firm offers individualized investment advice to our clients under the Wrap Fee Program. Each client under the Wrap Fee Program has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs: All accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. Performance-Based Fees & Side-By-Side Management: Our firm does not charge performance-based fees. Investment Strategies Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about our firm’s investment strategies. Methods of Analysis Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about the methods of analysis used by our firm. Risk of Loss Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about risks associated with investments in securities. Voting Client Securities: Our firm does 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, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client 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) ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 42 Onyx Bridge Wealth Group, LLC All accounts are managed by our 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. Our firm will provide the following types of information about our clients to sub advisers and/or third-party investment managers: • Client name and contact information • Client income • Employment and residential information • Social security number • Personal information • Cash balance • Security balances • Transaction detail history • Investment objectives, goals and risk tolerance Most sub advisers and/or third-party investment managers also collect separate suitability information from clients. 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 There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Financial Industry Activities & Affiliations Please refer to Item 10 of our Form ADV Part 2A Brochure above for information about our other financial industry activities and/or affiliations. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Please refer to Item 11 of our Form ADV Part 2A Brochure above for information about our Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 43 Onyx Bridge Wealth Group, LLC Review of Accounts Please refer to Item 13 of our Form ADV Part 2A Brochure above for information about Account Reviews, Statements, and Reports. Brokerage Practices and Trade Aggregation Please refer to Item 12 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about our brokerage practices and trade aggregation. Client Referrals & Other Compensation Please refer to Item 14 of our Form ADV Part 2A Brochure above for information about Client Referrals & Other Compensation. Financial Information Please refer to Item 18 of our Form ADV Part 2A Brochure above for Financial Information about our firm. ADV Part 2A – Firm Brochure & ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 44 Onyx Bridge Wealth Group, LLC